OCPO SF009 - Limited Source Justification SAM_Redacted.pdf

Department of Commerce First Responder Network Authority

LIMITED SOURCES JUSTIFICATION

FAR subpart 8.4

(Mandatory LSJ/Brand Name for Acquisitions > SAT)

This acquisition is being conducted under the authority of the Multiple-Award Schedule (MAS) Program pursuant to 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting Activity [FAR 8.405-6(c)(2)(i)]

2. Description of Supplies or Services [FAR 8.405-6(c)(2)(iii)]

6. REQUESTING OFFICE CERTIFICATION

I certify that this recommendation contains the information required by FAR 8.405-6(c) and its contents are accurate.

Signature and Date

7. PROCUREMENT OFFICE CERTIFICATION

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer (Name) Signature and Date

3. Requisition No. 5. Name of Proposed Source(s) g options)

This contract is currently being used by four mission units (OED, NMO, PSA, and I2) and provides the following services:

Engagement & Investment – Planning and execution of stakeholder engagements to educate on FirstNet and understand public safety’s current use of and needs for the FirstNet network, products, and services to drive improvement of the network. Contract services include program and project management; development of stakeholder engagement plans, materials, surveys, and post-engagement summaries; and analysis of data sets to summarize engagement findings. Support also includes specialized Geographic Information System (GIS) expertise that’s critical to developing the models and tools used to identify, assess and validate coverage needs that inform over $2 billion in coverage investments. Technical writing and analysis are also leveraged to support overall reinvestment activities.

Oversight– Conduct validation and verification efforts of the NPSBN. Contract services include programmatic, technical, and b it l i f th Fi tN t t k l ti ith di h d t i l d l t P id

AA-NTI-SE-O-25-02145 Lafayette Group, Inc.

First Responder Network Authority

Identify the authority being used to justify restricting consideration to a limited number of vendors [FAR 8.405-6].

Provide sufficient facts and rationale associated with the respective authority. Refer to block number 12 for additional justification details.

8. FAR 8.405-6(a)(1)(i)(A) – An urgent and compelling need exists, and following the procedures would result in unacceptable delays.

9. FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of responding due to the unique or specialized nature of the work.

10. FAR 8.405-6(a)(1)(i)(C) – The new work is a logical follow-on to an original FSS order or BPA, and the original order or BPA was placed in accordance with applicable FSS ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

11. FAR 8.405-6(b) – An item peculiar to one manufacturer is required.

The original task order (1333P220F00000043) was competed amongst small business federal supply schedule holders pursuant to FAR Part 8.4, and awarded to Lafayette Group, Inc. (LGI), with a 1-year base period plus four, 1-year option periods. Task order 1333P220F00000043 requires LGI to provide services in areas of Engagement & Investment, Oversight, and Outreach, as described in Section 2 above. This contract supports FNA’s ability to take actions necessary to ensure the building, deployment, and operation of the nationwide public safety broadband network (NPSBN), engage with public safety entities, and reinvest in the NPSBN. The work that will be completed by exercising the FAR 52.217-8 will be a continuation of the work being done under task order 1333P220F00000043 which includes assisting with public safety and stakeholder engagement, investment analysis, telecommunications analysis, and outreach support for the NPSBN contract.

Pricing for these FAR 52.217-8 services will also be based on current Option Period IV hourly rates. FirstNet did an informal price analysis prior to exercising FAR 52.217-8. It was determined that current Option Period IV labor rates that will be used for the FAR 52.217-8 extension are cheaper and more advantageous to the government in comparison to labor rates currently being offered in

12. JUSTIFICATION (Attach additional pages if needed)

(a) Nature and/or description of the action being approved [FAR 8.405-6(c)(2)(ii)]. [Prepared by Mission Unit]

(b) Determination by the Contracting Officer that the order represents the best value consistent with FAR 8.404(d) [FAR 8.405-6(c)(2)(v)]. [Prepared by Contracting Officer]

(c) Description of the market research conducted among schedule holders, and the results of the research, or a statement why market research was not conducted [FAR 8.405-6(c)(2)(vi)]. [Initiated by the Mission Unit and finalized in collaboration with the Contracting Officer]

The LGI contract is in Option Period 4 and will expire on 09/21/25. This contract is currently being used by four mission units (OED, NMO, PSA, and I2) A recompete of these services is currently underway and an extension of existing operations (up to) six months is required to accommodate the competition and transition. The Contracting Officer wil be exercising FAR 52.217-8, Option to Extend Services. The period of performance for the FAR 52.217-8 six month extension would be 09/22/2025-03/31/2026.

In accordance with FAR clause 52.217-8, continued services will be at the prices specified in the current task order. The current task order was competed among small business offerors in accordance with FAR Part 8.4, Federal Supply Schedule via the GSA Federal Supply Schedules. In addition, GSA has already determined the prices of supplies and fixed-price services, and rates for services offered at hourly rates, under schedule contracts to be fair and reasonable. Pricing for these services will also be based on current Option Period IV hourly rates. FirstNet did an informal price analysis prior to exercising FAR 52.217-8. It was determined that current Option Period IV labor rates that will be used for the FAR 52.217-8 extension are cheaper and more advantageous to the government in comparison to labor rates currently being offered in the market.

This modification to exercise the option to extend pursuant to FAR clause 52.217-8 is a logical follow-on to the original task order and is in the interest of economy and efficiency. Issuing a new, competitive solicitation at this time, would not be more advantageous to the government both contractually and administratively as current option period IV prices will be used for this FAR 52.217-8 extension. For economy and efficiency, using the incumbent for continued performance of the required functions prior to the recompete is in the best interest of the government; FirstNet has recently conducted market research for the recompete of this requirement prior to exercising FAR 52.217-8 and determined that current Option Period IV labor rates that will be used for the FAR 52.217-8 extension are cheaper and more advantageous to the government in comparison to labor rates currently being offered in the market. The work that LGI will continue to perform under this modification is the same work as performed in the original task order and represents a logical follow-on to that original task order. This modification will allow the Government to realize the cost savings and other benefits associated with continued performance by the incumbent and furthermore, will avoid substantial duplication of previously incurred costs that would otherwise be incurred by a competitive solicitation for a short-term bridge award while the full recompete of this requirement is pending. Transitioning this work away from LGI to onboard another vendor under a short-term bridge award would incur transition costs and also comes with significant risk of potential disruption of services given the short time period remaining on the original task order award. For these reasons, The Government determines that exercising the option to extend pursuant to FAR clause 52.217-8 is a logical follow-on to the original task order and expects continued economies and efficiencies by continued performance with LGI.

12. JUSTIFICATION CONTINUED (Attach additional pages if needed)

(d) Statement of the actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration before any subsequent acquisition for supplies and services is made [FAR 8.405-6(c)(2)(viii)]. [Initiated by the Mission Unit and finalized in collaboration with the Contracting Officer]

(e) Any other facts supporting the justification [FAR 8.405-6(c)(2)(vii)]. [Prepared by the Mission Unit and Contracting Officer]

FirstNet has commenced the process to issue a solicitation for the follow-on to this task order, which will allow for competition. The competitive solicitation will be released in the near future and awarded prior to the expiration of the task order.

FirstNet has already started the process of a competitive follow-on to this task order, and release of the solicitation is imminent. The plan for the follow-on task order is to release a competitive solicitation utilizing Federal Supply Schedule contracts and set-aside for small businesses.

REVIEW AND APPROVALS [FAR 8.405-6(d), FAM 1333-8.4] O ve r

$7

,0

13. Competition Advocate (Name & Title)

APPROVED

DISAPPROVED

Signature and Date O ve r

$1 m ill io n 14. Head of the Procuring Activity (Name & Title) Signature and Date

APPROVED

DISAPPROVED