Combined JA Bridge-Rev1 19AUG2026_Final_Redacted.pdf

DEPARTMENT OF THE NAVY

NAVAL FACILITIES ENGINEERING AND EXPEDITIONARY WARFARE CENTER

1000 23RD AVENUE

PORT HUENEME CA 93043-4301

IN REPLY REFER TO:

JA-26-0026

CON731

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity.

The requiring activity is Naval Facilities Engineering and Expeditionary Warfare Center

(NAVFAC EXWC), Port Hueneme, CA. The contracting activity is NAVFAC EXWC

Contracting Department.

2. Description of Action Being Approved.

This Justification and Approval (J&A) authorizes a sole-source, 12-month bridge extension of previously competed task order N39430-22-F-9978, under General Services Administration

(GSA) Multiple Award Schedule (MAS) Contract GS-35F-0431Y, with the incumbent contractor, Bahfed Corp (Bahfed).

The extension period is effective from September 30, 2026, through September 29, 2027, with an estimated value of $3,800,000. This non-competitive bridge action is required to maintain uninterrupted operations and maintenance (O&M) of the legacy electronic Construction

Management System (eCMS) while executing database migration support to ensure a compliant transition of historical Navy construction data from the incumbent’s proprietary CMiC platform to the follow-on contractor’s (Procon Consulting LLC) Kahua-based environment.

In accordance with Navy Marine Corps Acquisition Regulation Supplement (NMCARS)

5206.104-1(S-90) (implementing the Revolutionary FAR Overhaul (RFO) J&A procedures), an approved copy of the Request for Bridge Contract (NMCARS Annex 5) is provided alongside this J&A.

3. Description of Supplies/Services.

The required services encompass the highly specialized technical, operational, database, and security administration support necessary to sustain the legacy CMiC eCMS application, while simultaneously executing the technical migration of historical project data to the follow-on

Kahua system. Continuous operation of this application is vital to the NAVFAC enterprise mission, as it enables quality control workflows between thousands of external construction contractors, Contracting Officer’s Representatives (CORs), Construction Quality Management

(CQM) personnel, and Project Managers.

While the follow-on eCMS 2.0 contract (N39430-25-C-0010) was successfully competed and awarded to Procon Consulting LLC (Procon) in August 2025, two major, unforeseen external factors stalled the planned transition schedule:

1. A 43-day partial federal government shutdown at the start of Fiscal Year 2026 (FY26).

2. Complex, multi-agency coordination required to obtain the Defense Information Systems

Agency (DISA) Provisional Authorization (PA) for the new Kahua Cloud Service

Provider (CSP) environment.

These disruptions created an execution gap that halted database migration tasks requiring proprietary database schema coordination between Bahfed and Procon. A one-year sole-source extension of Bahfed's services is required to bridge this execution gap, maintain the secure cloud hosting environment, deploy security hotfixes, and finalize the structured data transfer to the new competitive platform.

The estimated value of this 12-month extension is $3,500,000, based on the Independent

Government Cost Estimate (IGCE). The requirement will be funded using Operations &

Maintenance, Navy (O&M,N) appropriations.

4. Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. 3204(a)(1), as implemented previously at the time of award by FAR 8.405-6(a)(1)(i)(B): “Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized”.

5. Rationale Justifying Use of Cited Statutory Authority.

As the underlying contract continues through an active period of performance, this sole-source bridge extension continues to use the same justification as that underlying contract found in FAR

8.405-6(a)(1)(i)(B). The statutory authority permitting other than full and open competition is applicable to this procurement because Bahfed is the incumbent contractor and the only source capable of providing the required secured services without interruption. Furthermore, Bahfed is the exclusive authorized reseller and operator of the legacy eCMS environment and possesses the unique technical expertise, authorized system access, and vendor-backed licensing support required to maintain CMiC products, licenses, and associated database support. This includes the exclusive capability to deliver and deploy critical CMiC updates and hotfixes to address system vulnerabilities during this transition period within the necessary timeframe.

Any gap in coverage during this transition would result in the immediate deactivation and removal of NAVFAC data from the cloud database on September 30, 2026. This deactivation would severely disrupt the Planning, Design, and Construction Directorate, paralyzing construction scheduling and management activities across the entire NAVFAC enterprise.

Transitioning to a new vendor would cause a minimum schedule delay of six (6) months for the new contractor to establish necessary secured network accesses and comprehend the legacy architecture, based on NAVFAC’s historical timelines for onboarding privileged-access system administrators under Department of Defense (DoD) and Navy cybersecurity policies. A delay of this length is unacceptable and prohibitive.

Additionally, the Government would incur duplicative set-up and transition-in costs estimated at

$1,225,000 for ramp-up labor costs, proprietary software licensing fee, and technical support costs, representing approximately 35% of the estimated $3.5M contract value to allow a new vendor to "learn" the system without receiving actionable sustainment or migration support. The transition-in costs are unrecoverable, offer zero operational benefit, and would completely negate any theoretical savings achieved through short-term competition. Furthermore, it is not in the government’s best interest to contract to incur further, unnecessary costs given that:

1. There is a new iteration of eCMS being set up (eCMS 2.0) that utilizes the Kahua platform and incurring unnecessary additional expenses to train a new vendor to “learn” a system that the government is transitioning out of is not cost-effective.

2. The eCMS 2.0 prime contractor, Procon, is already positioned to collaborate with Bahfed on various data migration-related taskings within the scope of the eCMS 2.0 contract.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

The government conducted market research in accordance with FAR 6.103-1 and evaluated if other sources could meet the eCMS program requirements without causing unacceptable schedule delays and unrecoverable cost duplication. It was determined Bahfed is the only source capable of maintaining the highly specialized legacy CMIC database environment during the transitional period because they possess site-specific, non-replicable technical data, and historical knowledge as the current contractor. Soliciting alternative sources for a short-term extension is impracticable and not in the Government's best interest, as any other vendor would lack the proprietary system and security access necessary to maintain services and execute migration without incurring unacceptable delays and duplicative costs.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer will utilize price analysis methodologies outlined in FAR 15.404-

1(b), Proposal Analysis, to ensure the final agreed-to price is fair and reasonable. Specifically, the Contracting Officer will compare the proposed bridge prices to the historical prices paid by the Government for identical services under current task order N39430-22-F-9978.

8. Actions to Remove Barriers to Future Competition.

The government has taken proactive steps to foster long-term competition and eliminate future barriers. While this short-term extension must be awarded on a sole-source basis because Bahfed is the exclusive authorized reseller of the legacy CMiC software, the follow-on contract was already competed and awarded to Procon under the Small Business Innovation Research (SBIR) program for the eCMS 2.0 modernization effort. This strategic transition to the new Kahua-based platform under contract N3943025C0010 will eliminate the agency's reliance on proprietary legacy software and ensure competitive opportunities for future requirements. The follow-on contract was successfully awarded and full transition is scheduled to be completed by September

29, 2027, removing barriers to competition.

APPROVING

Upon the basis of the above justification, I hereby approve, as the the proposed procurement described herein using other than full and open competition, pursuant to the authority of 10 U.S.C. 3204(a)(1), only one responsible source and no other supplies or services will satisfy agency requirements.