NAD-AF W91DY26CA075 JA.pdf

Control Number:

Justification and Approval For Official Use Only

For Other Than Full and Open Competition USACE Engineering and Support Center

JUSTIFICATION AND APPROVAL (J&A)

FOR OTHER THAN FULL AND OPEN COMPETITION

PREVENTIVE MAINTENANCE, CORRECTIVE MAINTENANCE,

AND EMERGENCY REPAIR SERVICES

NORTH ATLANTIC DIVISION–AIR FORCE

(NAD-AF) FUELS PROGRAM

U.S. Army Corps of Engineers, Huntsville Engineering and Support Center

Bridge Contract Solicitation/Notice No. W912DY26QA327

Justification and Approval For Official Use Only For Other Than Full and Open Competition USACE Engineering and Support Center

RFO FAR Part 6 Justification and Approval for Other than Full and Open Competition

1. Requiring Activity: Defense Logistics Agency – Energy (DLA-E), 8725 John J.

Kingman Road, Fort Belvoir, Virginia 22060.

2. Contracting Activity: U.S. Army Corps of Engineers (USACE), Huntsville Engineering and Support Center (CEHNC), 300 Secured Gateway SW, Redstone Arsenal, Alabama 35898.

3. Description of Action: Approval is requested to negotiate and award a short term, sole source bridge contract to for continued preventive maintenance, corrective maintenance, emergency repair response, maintenance records management, and service order support for the Fuel Program.

The proposed bridge contract will be awarded on a firm-fixed-price basis. It will provide a maximum potential period of performance of 336 calendar days, consisting of a 66-day base period and three 90-day option periods. The anticipated performance is 29 September 2026, immediately following the expiration of current task order on 28 September 2026.

The estimated total value of the bridge contract, including all option periods, is

The bridge contract will prevent a gap in liquid fuel maintenance services while the protest litigation remains active and while the Government completes any actions required by the litigation outcome, if necessary. The Government will exercise option periods only when necessary to prevent a service gap. If contract W912DY-26-C-A031 remains available for performance, the Government will transition to that contract when authorized and when the successor contractor can complete an orderly phase in. If the litigation requires corrective action or another acquisition approach, the Government will use the bridge only for the minimum period necessary to maintain uninterrupted PMCM support.

4. Description of Services: The requirement is for non-personal preventive maintenance and corrective maintenance services for Defense Logistics Agency– Energy to ensure military petroleum facilities and fuels systems remain operational, mission capable, and fully compliant with all governing criteria, codes, and environmental regulations. The contractor shall provide all labor, supervision, management, quality control, transportation, materials, supplies, vehicles, tools, equipment, facilities, and incidental services required to perform the work across forty five military installations and operational sites within the area of responsibility.

The Fuels Program supports petroleum systems used to receive, store, transfer, distribute, issue aviation fuel, motor fuel, lubricants, and diesel fuel. These systems support aircraft fueling, fleet fueling, fuel storage, fuel transfer, fuel distribution, emergency response, and related installation missions.

The asset inventory includes more than that support the fuel mission at major installations, including locations.

Preventive maintenance includes scheduled inspections, testing, servicing, calibration, cleaning, lubrication, reporting, and maintenance record updates. These actions help identify equipment problems before they affect fuel system availability or create safety and environmental risks.

Corrective maintenance includes minor repairs, service order work, urgent repairs, and emergency responses. Corrective maintenance may involve pumps, motors, valves, seals, gauges, sensors, control panels, filters, coalescers, piping components, electrical equipment, and other system elements that affect petroleum system operation.

The contractor must maintain site specific maintenance records. These records include equipment information, maintenance history, preventive maintenance reports, service order status, deficiencies, corrective actions, inspection results, and supporting documentation.

The contractor must use Resident Management System Contractor Mode, also known as RMS CM, for contract administration, schedules, submittals, correspondence, quality control records, reports, and other required functions. The contractor must also use a computerized maintenance management system, also known as CMMS, for service order tracking, equipment history, maintenance reports, and repair records.

The contractor must provide qualified personnel with training, certifications, experience, installation access, and safety qualifications to work on military petroleum systems. The contractor must maintain supplier relationships, material sources, specialized equipment, vehicles, and technical resources needed to support scheduled maintenance and emergency repairs.

The bridge contract is necessary to maintain uninterrupted PMCM support while Court of Federal Claims litigation remains active, and the follow-on contractor is unable to begin performance.

b. Bid Protest History and Effect on Follow On Performance

On 16 July 2026, ., an unsuccessful offeror, filed a protest with the Government Accountability Office (GAO) challenging the award of contract

On 06 August 2026, filed a separate protest with the U.S. Court of Federal Claims (COFC). Because the same procurement was then before a court with jurisdiction over the matter, GAO dismissed the protest on 17 August 2026 under 4 C.F.R. § 21.11(b).

On 18 August 2026, filed a separate protest with COFC. Both protests are still currently pending before the court.

Because the follow on contractor cannot begin transition activities until the Notice to Proceed is issued, it will be unable to achieve operational capability before the current task order expires.

Without a bridge contract, the Government will have no contractor available after 28 September 2026 to receive service orders, coordinate with installation representatives, access petroleum facilities, inspect and repair equipment, document completed work, maintain maintenance records, or respond promptly to emergency requirements.

c. Unacceptable Delay

The Government’s determination is based on the distinction between a contractor’s technical capability to perform petroleum system maintenance and its ability to satisfy the Government’s immediate bridge requirement within the time available.

The Government recognizes that other firms may be capable of competing for and performing the long term PMCM requirement. However, the bridge requirement is not a long term contract. The bridge requires a contractor that can assume full responsibility for the current requirement on 29 September 2026 without a transition gap.

A non-incumbent contractor would require a substantial transition period before it could assume full performance. That transition would include identifying, hiring, assigning, and retaining qualified project managers, maintenance managers, site managers, technicians, safety personnel, quality control personnel, schedulers, and administrative personnel.

A non-incumbent contractor would also need to complete installation access requirements. Personnel may require background vetting, installation access, defense credentialing, local badging, and flightline driving authorization. These requirements are controlled by individual installations and cannot be completed solely by contractor action.

A non-incumbent contractor would need to establish its equipment and materials capability. This would include assigning or acquiring service vehicles, transporting tools and test equipment, establishing storage and staging arrangements, obtaining material sources, confirming supplier relationships, and ensuring access to replacement parts.

A non-incumbent contractor would also need to establish management and information systems. These systems include RMS CM accounts, CMMS processes, work order tracking, maintenance reporting procedures, Government maintenance-record access, and processes for transferring asset history and deficiency information into the contractor’s operating system.

The contractor would need to prepare and receive approval for required plans and submittals. These documents include the transition plan, Accident Prevention Plan, Activity Hazard Analyses, quality control documents, schedules, personnel information, records management procedures, and other required submittals.

The contractor would also need to become familiar with each supported site’s petroleum infrastructure, maintenance history, open service orders, recurring maintenance requirements, emergency response procedures, site access rules, and installation specific restrictions.

The Government estimates that a non-incumbent contractor would require 60 to 90 days to complete these transition and mobilization actions and reach full operational capability.

currently performs the PMCM requirement under task order . has an existing workforce, established management structure, installation access, maintenance records, operational processes, supplier relationships, tools, vehicles, equipment, and site knowledge needed to continue the full requirement without a separate transition period.

The difference is not simply technical competence. It is immediate capability within the available period. A contractor other than would have to complete substantial staffing, access, equipment, safety, records, systems, and mobilization actions before assuming full performance.

Award to another source would create an unacceptable delay in fulfilling the Government’s requirements. The Government cannot accept a break in preventive maintenance, corrective maintenance, emergency repair response, service order management, maintenance records, or fuel system support.

d. Substantial Duplication of Cost

Awarding the bridge contract to a non-incumbent contractor would also create costs that the Government would not recover through competition.

A new contractor would incur costs for personnel recruitment, hiring, onboarding, background checks, installation access, credentialing, site verification, equipment movement, system access, CMMS implementation, maintenance record review, safety plan preparation, and quality control setup.

These costs would be incurred only to support a short bridge period. When the follow on contract begins, the Government would then incur another transition effort for the competitively awarded successor contractor.

has already completed the required staffing, installation access, equipment staging, systems setup, maintenance record management, supplier coordination, and safety document preparation under the current task order.

Retaining avoids duplicate transition and mobilization costs associated with replacing the incumbent for a limited bridge period and then transitioning again to the permanent follow on contractor.

The Government’s primary basis for this justification is unacceptable delay. The duplication of cost consideration provides additional support for retaining the incumbent during the limited bridge period.

e. Alternatives:

The Government considered the following alternatives and rejected them for the reasons stated below.

Suspension of PMCM Services. The Government considered suspending PMCM services until the Court of Federal Claims resolves the protest litigation. The Government rejected this alternative because the fuel systems require ongoing inspections, preventive maintenance, corrective maintenance, emergency repairs, maintenance record support, and safety oversight. Suspending services would increase the risk of equipment failures, fuel leaks, fire hazards, incomplete maintenance records, and environmental noncompliance. These conditions could adversely affect installation fuel operations and mission support.

Use of Government Personnel. The Government considered using military or civilian Government personnel to perform the requirement. The requiring activity rejected this alternative because the supported installations do not have sufficient certified liquid fuels maintenance technicians, calibrated test equipment, specialized vehicles, installation access, or capacity to perform the full PMCM requirement across the area of responsibility.

Competitive Short Term Procurement. The Government considered conducting competitive short term procurement. The Government rejected this alternative because the time remaining before expiration of the current task order cannot accommodate a new competition, evaluation, award, and contractor transition. Even if the Government made an expedited award, a nonincumbent contractor would need to complete required staffing, mobilization, installation access, safety, equipment, systems, and maintenance record actions before assuming full performance. The technical office estimates that these actions would require 60 to 90 days to achieve full operational capability.

After evaluating these alternatives, the Government determined that a sole source bridge contract to is necessary to maintain uninterrupted PMCM and emergency response coverage while the protest litigation is pending. has the existing workforce, installation access, equipment, maintenance records, operating processes, supplier relationships, and site knowledge needed to continue performance on the required start date without a transition gap. Based on the available timeframe and the need for uninterrupted services, no other alternative can reasonably meet the Government’s requirements.

f. Impact if not approved:

Disapproval of this justification would create an immediate lapse in preventive maintenance, corrective maintenance, inspection support, service order management, maintenance record support, and emergency repair coverage for fuel systems.

The requirement supports petroleum storage, distribution, dispensing, containment, power, and control systems. These systems directly support fuel receipt, storage, transfer, aircraft fueling, fleet fueling, and installation mission requirements.

Without contractor support, the Government will not have assured capability to inspect, maintain, repair, test, document, or operate these systems.

A lapse in service may require the Government to

Preventive maintenance actions may be delayed or missed. These actions include inspections, filter and calibration, leak detection checks, alarm testing, equipment condition assessments, records updates, and corrective action tracking.

If the Government does not have a contractor available to receive and respond to service orders, it may need to limit, defer, or suspend certain fueling operations until qualified support is available.

A maintenance lapse would also affect the Government’s ability to maintain accurate records of equipment conditions, complete maintenance, deficiencies, service orders, and corrective actions. Incomplete maintenance records reduce the Government’s ability to track equipment history, identify recurring failures, plan repairs, conduct quality assurance, and demonstrate that required maintenance actions occurred.

Disapproval would therefore expose the Government to unacceptable operational delay, mission risk, and unnecessary transition costs.

Controlled Unclassified Information

7. Efforts to Obtain Competition

The Government made efforts to obtain competition for the underlying long-term PMCM requirement.

CEHNC conducted a full and open competition for the long term follow on requirement and awarded contract . The current sole source action is a temporary bridge action resulting from post award protest litigation and the resulting delay in follow on performance.

Once the need for a bridge action became apparent, CEHNC conducted additional market research focused on the immediate interim requirement.

CEHNC published Sources Sought Notice W912DY26QA327 on 11 September 2026.

The notice requested capability statements from firms able to immediately perform

PMCM services under a 66-day base period and three 90-day option periods.

The Sources Sought notice required interested firms to demonstrate experience maintaining military petroleum systems; the ability to mobilize qualified personnel, materials, tools, and equipment immediately upon award; and the ability to support the requirement without a transition period.

The Sources Sought notice stated that responses were due no later than 1600 Central Standard Time on 15 September 2026. , the current incumbent, submitted the sole capability statement received in response to the market research notice. No other company submitted a capability statement.

8. Action To Increase Competition

The Government remains committed to competition. CEHNC completed a full and open competition for the long term PMCM requirement and awarded follow on contract .

This temporary bridge action is necessary because active protest litigation prevents an immediate transition from the current task order. It does not replace the competed follow on requirement contract .

The Contracting Officer, with input from Office of Counsel, will review the need for each option period based on the status and outcome of the Court of Federal Claims litigation, the availability of a legally effective follow on contract, the required acquisition actions, and the need to avoid a lapse in PMCM services.

If contract remains available for performance, the Government will issue the Notice to Proceed when authorized and transition to the follow on contract after the successor contractor completes an approved phase in. If the litigation results in corrective action, a revised award decision, or another lawful acquisition outcome, the Government will use bridge options only as necessary to maintain uninterrupted services until the Government completes the required procurement actions.

9. Market Research

Market research for the long term PMCM requirement confirmed that a competition exists for the full duration requirement. CEHNC conducted a full and open competition for the follow on requirement and awarded contract

The existence of a competitive market for the long term requirement does not establish that another contractor can assume full performance of the immediate bridge requirement before expiration of the current task order. The bridge requirement requires a contractor that can continue full PMCM performance on 29 September 2026 without a transition gap.

When CEHNC identified a potential need for a bridge action, it conducted market research focused specifically on the immediate interim requirement. Sources Sought Notice W912DY26QA327 requested that interested sources demonstrate their ability to assume full PMCM performance without interruption of services. The notice required firms to address staffing, mobilization, installation access, technical capability, equipment, logistics, fuel system maintenance experience, RMS CM, and CMMS requirements.

submitted the only capability statement in response to the Sources Sought notice. stated that it can continue full performance without a separate transition period based on its current PMCM performance, regional technical workforce, supplier network, equipment, maintenance processes, and experience supporting petroleum storage, distribution, fleet fueling, and aircraft hydrant systems.

also stated that it maintains an existing operating footprint, localized technical staff, and an established fuel equipment supplier and parts logistics network within the area of responsibility. further stated that it will self perform 75 percent of the requirement as the prime contractor.

Based on market research, is the only source that has demonstrated the ability to continue full PMCM performance on 29 September 2026 without a transition period. The market research does not establish that another contractor can assume full performance by that date without an unacceptable interruption of services.

Market research confirms no other source possesses the physical footprint, security credentials, and trained workforce to assume operations across installations on 29 September 2026 without a multi month mobilization hiatus and therefore, a gap in service.

10. Interested Sources:

Sources Sought Notice W912DY26QA327 closed on 15 September 2026.

submitted the only timely capability statement in response to the notice.

In its capability statement, stated that it had the existing operating footprint, qualified personnel, certifications, equipment, and capacity necessary to begin full performance on 29 September 2026 without a separate transition period. No other firm submitted a capability statement or otherwise demonstrated an ability to assume full PMCM performance across the supported installations by the required start date.

The Government posted a Synopsis of Intent to Award a Sole Source Contract, which closed on 28 September 2026. No capability statements, proposals, quotations, or other expressions of interest were received in response to the synopsis.

Based on the Sources Sought notice, the absence of responses to the Synopsis of Intent to Award a Sole Source Contract, and the operational status of the PMCM requirement, the Contracting Officer determined that was the identified source capable of meeting the Government’s immediate bridge requirement without unacceptable delay.

This determination was limited to the bridge requirement. It did not mean that other firms were incapable of performing the long term PMCM requirement. Rather, it reflected the requirement for a contractor to assume full responsibility for preventive maintenance, corrective maintenance, emergency repair response, maintenance records, RMS CM, CMMS, installation access, qualified staffing, equipment staging, and site specific fuel system support on the required start date.

This bridge action was intended to provide continuity of PMCM services only until the competitively awarded follow on contract could begin full performance. The Government did not anticipate requiring an additional sole source bridge action for this requirement.

11. Other Facts:

a. Acquisition History

CEHNC previously acquired fuels maintenance services through competitive General Services Administration Multiple Award Schedule task orders.

The current task order, , was competitively awarded to and will expire on 28 September 2026.

To ensure continuity of services beyond the current task order, CEHNC initiated a competitive follow on procurement. The Government issued Solicitation W912DY- 26-R-A005 on 18 March 2026 and received proposals on 13 April 2026. Following source selection, the Government awarded follow on contract in July 2026.

Post award protest litigation delayed the start of performance under the follow on contract. As a result, the bridge requirement is necessary to prevent a gap in services when the current task order expires. The need for the bridge results from court required delay in follow on performance, not from a failure to plan for expiration of the current task order.

b. Basis for Interim Sole Source Action

This J&A addresses the immediate bridge requirement and the contractor’s ability to assume full performance by the required start date. It does not assess the capability of other firms to perform the long term PMCM requirement.

currently performs the PMCM requirement and has the workforce, installation access, equipment, maintenance records, operating processes, supplier relationships, and site knowledge needed to continue required services on 29 September 2026 without a transition gap.

A new contractor would require time to establish qualified staffing, installation access, credentials, systems access, equipment setup, safety documentation, and maintenance record access, before assuming full performance. Those actions cannot be completed within the remaining period before expiration of the current task order.

A delay in assuming full performance would create an unacceptable interruption in critical fuels maintenance and emergency response capability. The sole source bridge action is limited to the period necessary to maintain uninterrupted services until the Government completes any actions required by the protest outcome and a successor contractor can begin performance without creating a maintenance or emergency response gap.