R4014_Substantial Bundling DF_REDACTED.pdf

United States Department of Agriculture Determination and Findings (D&F)

Authority to Substantially Bundle Contract Requirements Solicitation Number:12363N25R4014

Rev. 4/9/26

This D&F is prepared in accordance with Federal Acquisition Regulation (FAR) 7.107-1 (b)(3) to support a substantially bundled requirement

FINDINGS

1. Mission Area and Contracting Activity.

Requesting Activity Agency: NRE Forest Service, Nez Perce-Clearwater National Forests, Salmon River Ranger District

Contracting Activity: USDA-NRE-Forest Service-Land Management and Stewardship Contracting

2. Acquisition Information:

Solicitation/Contract/Order Number 12363N25R4014 Period of Performance Date of award through 9/15/2036 Estimated Total Amount

3. Description of the Requirement: This D&F documents the U.S. Forest Service, Nez Perce- Clearwater National Forest’s decision to request authority to utilize substantially bundled contract actions .

. The authorizes commercial treatment on over 17,000 acres primarily through intermediate harvest. The purpose of the is to thin overstocked stands to reduce the risk of catastrophic wildfire as well as improve stand health. The is within the Wildland Urban Interface and has numerous private inholdings with seasonal and permanent residents. This requirement supports increased pace and scale of active forest management

f. The directly supports Executive Order 14225, the Immediate Expansion of American Timber Production which was posted to the Federal Register on March 1, 2025, Memorandum 1078- 006 and follows the direction put forth in producing timber volume, reducing hazardous fuels, providing wood fiber to struggling industries and supporting local economies on the Salmon River Ranger District of the Nez Perce/Clearwater National Forest.

This project will be reducing hazardous fuels in Wildland Urban Interface (WUI) areas and supporting wood products infrastructure in central Idaho.

This bundled requirement combines the following services into one integrated acquisition:

• Harvest unit layout and GPS‑based identification of harvest units and temporary roads (mapping)

• Timber cruising to Forest Service standards and timber removal operations

• Multi‑season road surveying, road maintenance, reconstruction, and decommissioning

Authority to Substantially Bundle Contract Requirements Solicitation Number:12363N25R4014

Rev. 4/9/26

• Hazardous fuels and slash treatments

• Related forest-restoration activities

These services are highly interdependent and consolidating them ensures coordinated implementation, reduces duplication of mobilization and administrative burden, and supports ability to achieve pace-and-scale objectives. The bundled requirement directly facilitates wildfire-risk reduction, stand-health improvement, and economic support to local wood-products infrastructure consistent with Executive Order 14225 and agency leadership directives.

4. Acquisition Strategy

a. Market Research Summary: A Request for Information (RFI) was posted to SAM.gov for the G-Z LTIRSC on August 6, 2025, to gauge industry interest in the project and to solicit feedback that could be utilized to inform requirements and contract terms. The RFI included a questionnaire and instructions to RSVP for an industry meeting that was held on September 10, 2025. Six representatives from small businesses and four from

, a large business attended the meeting in person, and eight attended online, all representing small businesses. A second site visit was held on October 30, 2025, where industry was shown the project and draft documents were shared for feedback on potential requirements. This meeting was attended by two representatives from , one small business who would be completing road work for

, and representatives from seven other small businesses. Six responses to the questionnaire were received from small businesses and one response was received from

. Several responses to the RFI questionnaire from small businesses contained statements that they were interested in participating in the project but that the total scope exceeded their capabilities, or that they would be interested in completing portions of the project such as road or fuels reduction work as a subcontractor as they did not have the expertise to complete preparatory or timber harvest scopes. Additional market research was performed through the Small Business Administration (SBA) Dynamic Small Business Search tool to evaluate small business capacity. Market research indicates that while several small businesses possess capabilities in individual task areas, such as fuels reduction, road work, or timber operations none demonstrated the ability to perform the full integrated scope required for a long term, landscape scale

IRSC.

b. Alternative Contracting Approaches: During project development, several alternative contracting strategies were evaluated to determine whether bundling or substantial bundling could be reduced or avoided. Each option was assessed for feasibility, efficiency, cost‑effectiveness, technical risk, and ability to support the integrated, landscape‑scale nature of the G‑Z LTIRSC.

A task order structure was initially considered; however, a critical component of the project is the ability to leverage surplus stumpage value from one contract area to offset service work costs in another. Under a task order contract, stumpage cannot be applied across separate orders, making it impossible to implement the offset methodology that is essential to balancing the project’s harvest and service requirements. Because many service tasks depend on offsets from adjacent areas, a task order structure would create financial and operational barriers and was therefore rejected.

A second alternative considered was to break the project into several smaller standalone contracts aligned to functional areas such as timber operations, fuels reduction, road work, or reforestation. This approach was rejected because the project requires sequential, coordinated, and interdependent execution of harvest layout, road improvements, fuels treatment, and restoration work . Awarding separate smaller contracts would fragment accountability, increase mobilization costs, introduce schedule conflicts, and significantly increase the Government’s administrative burden. This would undermine efficiency and impede the pace and scale necessary for successful landscape level implementation.

Options that limited bundling to only certain services, such as fuels reduction only, road work only, or timber work only were evaluated. These approaches were rejected because separating service categories eliminates operational integration and prevents the contractor from coordinating activities such as layout, road work, and slash treatment in the sequence required. These fragmented approaches would create delays, duplicate mobilizations, inconsistent performance standards, and higher project costs.

Options for partially set-aside components or reserving portions of the requirement for small businesses were reviewed. Market research showed that while small businesses have capability in individual task areas, staffing, bonding, equipment, or management capacity to perform the full integrated IRSC scope as a prime contractor would be a challenge and likely restrict competition. Breaking off components for small business prime performance would create the same coordination and sequencing challenges noted above. Small business participation is instead most feasible and impactful through subcontracting and teaming arrangements, which will be required under this bundled acquisition.

Awarding the project in multiple phases, planning, harvest, fuels reduction and reforestation was considered. This approach was rejected because the project requires continuous multi-season execution, with road work, timber removal, and fuels treatments occurring in a tightly coordinated sequence. Phase-based contracting introduces schedule gaps, rework, and loss of continuity, and prevents adaptive management across the full project life cycle.

All alternative strategies were found to introduce significant inefficiencies, coordination risks, or impacts that would undermine the ability to achieve the integrated landscape scale outcomes required for the project. Because the project’s success relies on tight interdependencies, stumpage offsets, and long-term continuity of operations, a substantially bundled contract is the only approach capable of meeting mission requirements effectively.

c. Coordination: The determination has been coordinated with the Office of Small Disadvantaged Business Utilization Office (OSBDU).

The G-Z LTIRSC integrates layout, cruising, road maintenance, timber removal, site rehabilitation, and rapid-response salvage into a single, interdependent sequence of tasks that cannot be divided without reducing efficiency and increasing operational risk.

Each activity drives the next: boundary layout and GPS data inform cruising; cruise results determine appraisal, system selection, and road package requirements; road maintenance and reconstruction must align with harvest system mobilization; and harvesting operations directly affect rehabilitation, weed treatment, and access needs.

Separating these interconnected tasks into multiple contracts would require duplicate mobilizations, create conflicting schedules, increase the potential for misaligned data, and heighten the risk of delays or resource damage particularly given the terrain, access limitations, and seasonal constraints

Although one recently expired MATOC IDIQ and two BPAs contain some of the service elements included in the IRSC, none of these existing vehicles include the stewardship authorities or integrated scope required for this project. Stewardship is the primary purpose of the IRSC, and the partial scopes within those parent vehicles are not sufficient to meet the comprehensive, interdependent requirements of this effort.

Parent Vehicle Contract No. Vendor Land Management Integrated Resources

(LMIR) BPA

Region 1/Region 4 Forest Engineering and Road Maintenance (FERM) BPA

Timber Sales Preparation Services IDIQ

Timber Sales Preparation Services IDIQ

d. Impact on Small Business: While many small local businesses have strong expertise in specific task areas, such as fuels reduction, timber harvesting, timber hauling, and road maintenance, market research shows they are generally best positioned to participate as subcontractors. These capabilities reflect a long-standing pattern in the timber industry, where mills and large contractors routinely subcontract road reconstruction, timber removal, and haul activities to small businesses. As a result, small firms remain a critical component of the local industry base and are expected to play a significant role under this contract.

However, bundling the requirement into a single long-term integrated contract impacts small business opportunities at the prime level. Market research, including RFI responses, site visits, and SBA Dynamic Small Business Search analysis, found only one small business, or combination of small businesses that possessed the capability needed to perform the full, interdependent 10-year scope of work as a prime contractor. The integrated nature of the project requires concurrent management of harvest layout, road engineering, fuels reduction, timber removal, and restoration work

. These technical and operational demands exceed typical small business capacity and create structural barriers to small business prime participation

To mitigate these impacts and maximize small business participation, will require a small business subcontracting plan with ambitious small business goals to maximize subcontracting opportunities. This plan will ensure meaningful subcontracting opportunities across multiple service areas, It is standard practice within the timber industry for mills holding timber sales to rely on subcontractors for road reconstruction, timber harvest and haul activities, further demonstrating that small businesses will have a significant role in performance. While small businesses cannot reasonably compete as prime contractors for the full integrated requirement, the bundling approach is expected to maintain or increase opportunities for small businesses to participate through subcontracting arrangements

Overall, deliberate steps to mitigate potential harm by ensuring small businesses retain substantial participation opportunities under the subcontracting model. Through required subcontracting plans, ambitious small business goals, and alignment with existing industry practices, the agency will support local economic participation while still meeting the mission-critical need for a long-term, integrated, landscape scale stewardship contract.

5. Benefits of Substantial Bundling

a. Cost Savings or Price Reductions:

The Independent Government Estimate of approx. $ is based on an integrated approach with one prime contractor leading and managing the work and includes a % adjustment for risk and inflation over time. When estimated using recent small‑business quotes for similar requirements, the projected cost increases to approximately $ , a difference of more than $ . This represents an increase of roughly 32 percent and demonstrates the substantial cost inefficiencies associated with awarding to an out of area small‑business.

. These firms generally incur higher mobilization and demobilization expenses due to the need to travel long distances and transport specialized equipment to multiple dispersed sites. Extended lodging and per‑diem requirements further elevate labor costs, as crews must remain on site for longer periods compared to local providers. Moreover, unfamiliarity with local environmental and market conditions can reduce efficiency and require additional time to gain familiarity or build new business relationships. Collectively, these factors result in significantly higher total costs for out‑of‑area small businesses compared to local large businesses capable of performing work more efficiently and with fewer mobilizations.

As a result, the bundled G‑Z LTIRSC approach yields cost avoidances far exceeding the 10 percent threshold identified in FAR 7.107‑2(c)(1), clearly supporting bundling as the most cost‑effective solution.

b. Quality Improvements that will save time or enhance performance or efficiency:

Executing a single large, long-term contract is significantly more efficient than developing, awarding, and managing numerous smaller, short-term contracts covering the same geographic area. Consolidating the work under one contract enhances quality by giving the Government a single point of accountability and greater flexibility in how performance is overseen and managed. This structure allows the Government to sequence tasks correctly, ensure that requirements are completed at the appropriate time, and maintain consistent quality in accordance with the quality assurance plan.

A unified contract also improves overall schedule optimization. With one contractor coordinating and performing all integrated tasks, the Government eliminates interference gaps that typically occur when multiple contractors must coordinate access, mobilization, handoff of data, or completion of dependent fieldwork. Reducing these coordination points decreases the likelihood of rework, data inconsistencies, field-level errors, and operational delays. Fewer mobilizations, fewer schedule conflicts, and fewer cross-contract dependencies directly contribute to more predictable execution and higher-quality outcomes.

Additionally, managing one long-term contract saves substantial staff time in procurement, contract administration, and project oversight throughout the contract’s life cycle. A multi-year structure provides a stable and predictable cost environment, reducing vulnerability to annual budget fluctuations and ensuring that landscape-scale treatments can be executed without interruption across fiscal years.

c. Reduction in acquisition lead time: A single prime contractor is responsible for integrating and coordinating all work across a large and complex landscape, eliminating the need to award and administer multiple separate contracts that would otherwise introduce significant acquisition lead times and phase-to-phase scheduling delays.

Consolidating the requirement into one contract removes sequential award dependencies that can hold up mobilization, restrict access, and create gaps between critical field activities. Instead of waiting for multiple procurements to be completed, the Government can immediately sequence work by exercising contract options, enabling rapid deployment of resources and smoother continuity between tasks.

This unified contract structure streamlines operations and shortens lead times, materially reducing the Government’s day-to-day management burden. It prevents the bottlenecks and coordination conflicts that arise when several contractors operate in overlapping areas with different schedules and mobilization timelines. By avoiding fragmented awards, the Government ensures that work can proceed at the pace and scale necessary to meet active forest management objectives, something that would be extremely difficult, if not impossible, to achieve through multiple smaller and disjointed contracts.

d. Terms and Conditions: Standardized terms, conditions, and performance metrics applied consistently across the entire lifecycle of the contract will significantly reduce learning curves for both the COR, the CO and the Prime. Instead of repeatedly interpreting new clauses, adjusting oversight processes, or re training staff for multiple smaller awards, the acquisition team can rely on a stable, uniform framework that governs performance, reporting, inspection methods, and compliance expectations.

The use of consistent terms also reduces administrative errors, strengthens documentation quality, and supports more predictable and enforceable contract oversight. This stability is particularly valuable in a long-term stewardship contract where revised wage determinations, and economic price adjustment provisions must be administered correctly. Applying these updates within a single, integrated contract rather than across numerous independent procurements reduces the probability of inconsistent implementation, missed updates, or misalignment between contract actions.

Consistent application of economic price adjustment mechanisms protects both the Government and the contractor from cost volatility over multiple performance periods, ensuring clearer budget planning and smoother execution. By managing wage determinations and price adjustments under one consolidated vehicle, the contracting office can maintain compliance with regulatory requirements while minimizing administrative workload and reducing the risk of conflicting or duplicative modifications. These standardized structures create an efficient oversight environment for the requiring activity, the contracting office, and the contractor resulting in fewer administrative errors, improved documentation practices, and more consistent enforcement of contract requirements over the full performance timeline.

e. Other Benefits:

i. Comprehensive, Landscape-Scale Restoration: This contract is designed to treat an entire watershed, not just isolated stands of trees. This allows the government to address systemic issues like wildfire risk, insect and disease outbreaks, and water quality on a scale that is ecologically meaningful.

ii. Better Long-Term Outcomes: A contractor who is responsible for an area for a decade or more has a vested interest in the long-term success of their work. High-quality work in year one leads to better and easier conditions in year five, creating a positive feedback loop that benefits public lands and improves forest health.

iii. Adaptive Management: Long-term contracts allow for adaptive management, where the lessons learned in the early years of the contract can be used to adjust and improve the work plans for later years, ensuring the best available methods are being applied.

iv. Local Economic Stability: A large, long-term contract provides a stable and predictable source of work for a prime contractor and, by extension, their network of local subcontractors. This supports jobs and provides economic stability to rural, forest-dependent communities.

v. Strengthened Government-Industry Partnerships: These contracts move the relationship from a purely transactional one to a long-term partnership. This can lead to better communication, more collaborative problem-solving, and a shared commitment to achieving the land management goals.

f. The total benefits quantified in dollar amounts are: $ This is 32 percent of the total estimated contract value, including all options.

6. Substantial Bundling Justification

a. Describe specific benefits anticipated from substantial bundling: Substantial bundling is a strategic contracting approach that consolidates numerous small, fragmented projects into a single, long term, integrated contract, generating significant operational and administrative benefits. This approach dramatically reduces the Government’s procurement and contract administration burden while unlocking considerable economies of scale in field operations, economies clearly reflected in the comparative IGCE pricing, which showed lower per unit costs and reduced overhead when requirements were combined into a single, integrated acquisition rather than procured individually.

Bundling also transfers the complex responsibility of coordinating multiple interdependent tasks to a single prime contractor, ensuring consistent quality, unified sequencing, and more efficient oversight across a large landscape. None of the alternative contracting methods identified in Section 4(b) including multiple smaller contracts or sequential IDIQs can deliver these landscape scale efficiencies because they fragment accountability, disrupt operational sequencing, and increase mobilization costs and schedule delays.

This efficiency is not merely administrative; it is the mechanism that enables cohesive, large scale active forest management treatments that cannot be achieved through piecemeal contracting approaches. It directly aligns with the land management objectives established under Section 604 of the Healthy Forest Restoration Act of 2003, Stewardship End Result Contracting Projects (16 U.S.C. 6591c), which emphasize integrated, outcome driven forest management.

Furthermore, the stability and long term certainty provided by a bundled contract encourages private investment in specialized equipment and the development of a skilled local workforce, strengthening economic resilience in rural communities. Ultimately, substantial bundling shifts the Government’s role from tactically managing numerous small contracts to strategically overseeing a unified, long term effort resulting in greater cost effectiveness, improved quality, and more impactful mission outcomes.

b. Identify the specific impediments to small business prime participation:

Many small businesses in the region face inherent capability and capacity limitations that prevent them from performing the full scope of the G‑Z LTIRSC. The requirement integrates professional forestry services, commercial timber harvest operations, road maintenance and reconstruction, and post‑harvest restoration activities across a large and complex landscape

. Successful performance requires coordinated execution of multiple specialized disciplines, each of which demands qualified staff such as project managers, superintendents, safety managers, and quality control managers operating concurrently across geographically dispersed work sites. This level of simultaneous technical and field management support exceeds the staffing depth and managerial bandwidth typically available within small businesses in the local market.

Additionally, the bonding requirements create a structural barrier to small business participation. Road construction and reconstruction work over the 10‑year contract is estimated at $ , which would require a significant aggregate bonding capacity and sustained financial strength. Most local small businesses do not possess bonding levels sufficient to support this magnitude of cumulative work, nor the ability to carry the financial risk for infrastructure obligations across multiple years.

Taken together, these capability, resource, and bonding constraints make it unreasonable to expect small businesses in the region to perform the full, integrated scope of the

G‑Z LTIRSC. The multidiscipline, geographically‑broad, and long‑duration nature of the requirement inherently favors firms with larger organizational capacity, diversified crews, broader financial backing, and the ability to manage multiple complex workstreams concurrently.

c. Detail actions designed to maximize small business participation as prime contractors, including provisions that encourage small business teaming: The solicitation does not include any prohibitions on small business joint ventures, mentor protégé arrangements, or teaming agreements, allowing small firms to combine complementary capabilities and compete effectively for the integrated scope of work. The solicitation also provides flexibility in how prime contractors may organize their work and identify subcontracting partners, creating opportunities for small businesses to participate both as prime contractors and as key subcontractors. By allowing these collaborative structures and avoiding restrictive provisions that would limit teaming, the acquisition promotes increased small business involvement across all functional areas of the project.

d. Detail actions designed to maximize small business participation as subcontractors

(including suppliers) at any tier under the contract: The Government will require a small business subcontracting plan with proposals for all other than small business respondents.

The subcontracting plan must be compliant with all requirements of 52.219-9, and the Government reserves the right to negotiate a suitable plan that aligns with Agency small business goals.

e. Explain why anticipated benefits justify substantial bundling:

The efficiencies gained through substantial bundling are essential to the agency’s ability to successfully execute the G‑Z LTIRSC. The integrated 10‑year approach enables to coordinate complex, interdependent project elements including timber harvest, road work, fuels reduction, and restoration in a manner that cannot be replicated through multiple smaller procurements. This structure significantly reduces duplication of mobilization, administration, and contract management, while establishing continuity of operations necessary for multi‑season implementation.

Bundling also provides cost stability and long‑term predictability that protect mission‑critical forest health and fuels‑reduction objectives from annual budget fluctuations. A single contract eliminates the delays, scope misalignments, and efficiency losses inherent in managing numerous standalone contracts across the same geography.

These non‑monetary but operationally indispensable benefits directly support national priorities for increased timber production, hazardous fuels reduction, and landscape‑scale forest restoration, and cannot be achieved through alternative contracting methods. For these reasons, substantial bundling is critical to mission success.

7. Substantial Financial Benefit Determination

☒ The estimated value of the contract is $94 million or less and the anticipated financial benefits are equivalent to 10% or more of the total contract value, including options.

☐ The estimated value of the contract, including all options, exceeds $94 million, and the anticipated financial benefits are the greater of either 5% of the estimated contract value or $9.4 million.

☐ The financial benefits do not meet the thresholds in FAR 7.107-2 (c)(3). However, they are critical to the agency’s mission success.

Substantial bundling is critical to mission success because the G‑Z LTIRSC requires tightly integrated harvest layout, timber operations, road reconstruction, fuels treatment, and forest restoration requirements across a 50,000‑acre landscape. These interdependent tasks cannot be effectively executed through multiple smaller contracts without losing efficiency, continuity, and the ability to complete multi‑season treatments at the required pace and scale.

The bundled structure ensures uninterrupted execution of hazardous‑fuel reduction and timber‑production objectives that directly support national priorities, including Executive Order 14225 and agency leadership direction. It reduces administrative burden, eliminates delays caused by repeated acquisition cycles, and provides long‑term stability necessary for work in the Wildland Urban Interface.

Without bundling, the Forest Service would be unable to achieve coordinated, landscape‑scale outcomes essential for wildfire‑risk reduction, forest‑health improvement, and economic support to rural communities making this approach operationally necessary for mission success.

8. The draft notification to the public required in FAR 7.107-3 (b) is attached for review and approval. The Contracting Officer will post the approved notification to the Government Point of Entry no less than seven (7) after approval of this D&F. All other required notifications in FAR 7.107-3 will be issued within the required timelines and no solicitation will be issued until the approved timeframe after required notifications.

DETERMINATION

Based on the above facts, I determine that in accordance with FAR 7.107-1 (b)(3) is critical to the agency's mission success and is necessary and justified for this requirement.

Submitted by:

Reviewed by:

1. The required review has been completed. Resulting comments, if any, have been satisfactorily addressed. The package may be forwarded to the Branch Chief/Procurement Analyst for further review.

2. The required review has been completed. Resulting comments, if any, have been satisfactorily addressed. The package may be forwarded to the Chief of the Contracting Office (COCO) for further review.

3. The required review has been completed. Resulting comments, if any, have been satisfactorily addressed. The package may be forwarded to the Head of the Contracting Activity (HCA) for further review.

4. The required review has been completed. Resulting comments, if any, have been satisfactorily addressed. The package may be forwarded to the Senior Procurement Executive (SPE) for further review and approval.

Approved by: