Redacted_-_Limited_Sources_Justification.pdf

U.S. General Services Administration

LIMITED SOURCES JUSTIFICATION FOR FEDERAL SUPPLY SCHEDULE PROGRAM

Upon the basis of the following justification, prepared in accordance with Federal Acquisition Regulation (FAR) 8.405-S(c), I as the Competition Advocate, hereby approve the use of sources .limited to fewer t}Jan those required in FAR 8.495-1, FAR 8.405-2, and FAR 8.405-3 pursuant to authority of 41 U.S.C. 3302 as Implemented by 8.405-6(a)(1 )(i){B) "Only one source is cap?tble of providing the supplies or services required at the level of quality required because the supplies or services are Lihiqueor highly specialized.fl

1. Identification of the agency and contracting activity, and specific Identification of the document

This justification by the General $ervices Administration, Public Buildings Service, Region 8, Acquisition Division •· (GSA), is for·~ task order award using other than full and open competition as documented in this Limited ..

Sources Justification. . .

2. The Nature and/or description of the action being approved.

The lirni!ecf ~ourc:es fl<;tion be.Ing approved Is for an award by q$.4. to Quality Control lnternaponaJ, LLC (QGI), .• which is ~ sril~ll ~uslr\~ss, for a full facilities maintenance services contract covering eight federalfacilities· i,p . / Montar:ia'(Fed~rafi3uU<:lir:igs) on a limited source basis on October 31, 2018, in accordance with FAR ~.40p~ 6(a)(1)(i)(E3)(only one ~9ur~ IN~S capal;>le of providing services required) as discussed In more detaii in section > 4 belbw. The seivices'),Jie described in more detail in section 3 below

This pftj9Lii~m~nt o/as~qli~iJ~~ y~ing the Federal Supply Schedule (FSS) specific:~lly schedule 03FAC, Faciliti~ ...

Mairit~11aric~ and Mt:liJagerrierit; 'Category 811 002 Complete Facilities Maintenance for the required servi~$ •..

avaUat>l~.bri QCl's $~~i$.qtjequle. Contract GS'.'.21F-0047V. GSA issued a firm fixed price (FFP) limited sourci3s •..

task ofd~ftoQCI ag~frist'its'GSA Sctiedule <::ontract GS-21F-0047V for these services. The NAICS code fcir this'procyrElrrie~ti.s Ml?i<5;' J=~cHities Support Services and a.Cl is a small business.uri~er this NAICS code

3. A d~~Cl'ipticfra of fije ¢~ppl!es. or services required to meet the agency's needs (including the total .

estimated value)

Full FaciliUes Maintenaric~ s~rvices for the following Federal Buildings located throughout Montana:

B~t!in U.S. Coµr,house (CH) 2601 - 2"d Aveni:fe North Billings, MT 591i:H

. l3.9z:Elrnan Ft39El,l'~I ~µilding/U.S. Post Office (FB/PO)

· 1 o East Babcock street Boie'man; MT. ssiif . Mansfield Federal Bliilding/U.S. Courthouse (FB/CH) 400 North Mairj . .

BuJte, MT 59701

Missoula Federal Bullding/U.S. Post Office (FB/PO) ?00 East Broadway Missoula, MT 59802

R~ymond U.S.Land Port of Entry (LPOE) Highway 16 North @ Canadian Border Raymond, Montana 59256

I

Roosville U.S. Land Port of Entry (LPOE} 8395 Highway 93 North Roosville located near Eureka, Montana 59917

Sweetgrass U.S. Land Port of Entry (LPOE) Interstate 15 @ Canadian Border Sweetgrass, Montana 59484

Havre Border Patrol Sector Headquarters (BPSHQ) 2605 - 5th Avenue SE Havre, Montana !59501

The limited sources task order is for a two month base period and includes eight (8) one month optional periods which may be exercised if additional time is needed by GSA to review its requirements, to allow adequate time to properly procure the facilities maintenance services for the Federal Buildings on a longer term basis, and to allow for another contractor, if applicable, to properly transition into the performance of the work on a longer term basis.

The requirement is to provide facilities maintenance services to these Federal Buildings dispersed throughout the state. The value of these services Is approximately $2 miHion {if all options are exercised} or approximately $200,000 monthly. Facili~es maintenance services performed under this limited sources task order are categorized under the folloi.ving functional areas; operations and maintenance, custodial, pest control, snow removal and grounds maintenance for nine federal facilities. Specifically, services include HVAC systerns maintenance and repairs, plumbing maintenance and repairs, electrical maintenance and repairs, mechanical maintenance and ref)airs, Waste removal arJd general cleaning maintenance, eradication of insects and othE:?r destructive pests, snow a.nd icl:! removal, and grounds maintenance. The limited sources task ord.er covers routine facilities mai11teria11¢e services, which is defined as covering standard upkeep of the buiiding arid equipment, including> such efforts as preventative maintenance and inspections on electrical generation and distribution. equipment, waste water treatment plant, water treatment and distribution, removal of waste, removal of snow and ice, removai of interior and exterior pests and rodents, and exterior grounds maintenance. The services needed are for all labor, supervision, supplies, materials, tools, equipment, spare parts, inventory control, trarisportation and other items necessary to perform tht:!se facilities maintenance services.

4. The authority and supporting rationale and, if applicable, a demonstration of the proposed contractor's unique qlialiflcatfons to provide the required supply or service.

The statutory authority permitting limited sources is 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 as discussed below.

This limited sources award to QCI is essential because of the unique and specialized nature of the facilities maintenance services required under the circumstances described below in this section 4. QCI is uniquely qualified to provide the required services because QCI is the only known source that can fulfill the requirements as described generally above in section 2 within the required timeframes. The requirements as described generally above in section 2 are needed immediately to maintain the safety, security and working conditions of the building systems and tenants using the Federal Buildings as well as the safety and security of visitors to the Federal Buildings during the time it takes to allow for the proper re-solicitation of the requirements. They are essential to ensure the prevention of damage to Federal property, injury to workers and visitors at the Federal Buildings, and disruption to Government operations at the Federal Buildings. Additionally, ther.e are fire, life, and safety risks to the Federal Buildings and its users because the facility maintenance services are responsible for, among other things, ensuring the fire systems are properly and fully functional.

These facility maintenance services are necessary to support use by multiple federal agencies as well as the general public, which needs services from, for example, a post office, various federal court judges, the Land Ports of Entry, etc. Without these facility maintenance services, the Federal Buildings cannot safely be accessed, occupied, or used because of the risk of catastrophic events such as fires, explosions, flooding, unsafe access (ice or snow), invasive pests, etc. that could result from the lack of proper facilities maintenance services at the Federal Buildings. ·

Even a . brief suspension of the. faci(ities maintenance services could trigger severe mission consequences at any moment not only for the GSA, but the federal agencies using the Fedefal Buildings. Also, a lack of any of these services for utility and infr:astructure .systems (electrical, Water, heat, ~nd sewer) provided to the Federal Buildings can cause them to fall into disrepair. Without these facilities maintenahqe servic::es, the basic facility and facjlity operating systems would be degraded and the buildings i.vould no' longer be able to be used for their designated tu11ctional ,purpose. Such degradation would cause damage to the Federal Buildings and would restrict the ability of GSA and all agencies using the Federal Buildings to meet their mission.

Any new CQntractor pr~viding facilities maintenance services at the FEM:feral ,f;3uilcfings must be provided at least··· 30 days of transition startup services prior to the contract start date to assist transitioning between contractors (the incumbent contractor and the new contractor). This transition period ensures that the new contractor<is familiar with each of the Federal facilities and is able to adeq·uately'proyic:I~ ·proper facilities maintenance services and avoid any catastroptlic events. The incumbent contract;which contained no authority to extend the period of performtmce, e~pired on October 31, 2018. Given the time constraint~ des¢ribed above, no contract9r was capable of providing such transition startup services for all of the Federal Buildings and only for QCI is such transition startup services not needed or not problematic.

Only QC! is capable of providing the quality of services at the level of quality reqlllred as described in this justification arid QCl's position as the incumbent contractor, for seven of:the.eigh!Fed1:1rc1IB1,1ildings, give QCI the unique capability to .perform tl'les.e facility maintenance services.. iQCI is)amiliar.wtfh the GSA personnel in Montana ilnd the· seriilce$d1eeded to perform the work in the Federal'BLiildirigs>·For the incumbent contract, QCI satisfactorily performed these services for all of the Federal Buildings under its contract. QCI maintained the staff to perform ttje facility maintenance services and was rnobiU#ed Jo p~i"fC>ll11 these services without disrupt!on.c1t thenine Fei:l~ral ;Buildings where it was already perfoiming1p,~$~:sefyices, and well positioned to perform such services at the sweetgrass, Chief Mountain, and Piegan LP.p!;sWhen.reeded.

Any altemc:1te contractor would have been unable to commence contract performi'lnce on November 1, 2018, as needed ajicl would have required at least 30 days for hiring, training and)rarisition, ijspeclally as many of the Federal Buildings are in locations that are remote. The costs and difficuity for arioffier contractor . to hir~ personnel and arrange subcontractors for such a short period ot time :would ·be :cumbersome.. An alternate · contic!ctor would fac~ ~xtr~ordirufry anc;I viijually unachievable obsta~tes in\ramping'.up 'teams. ~nd ~iring·. k¢.y .

personnel arjd SUbGontractors to perform Jhe services by Novemb~r'j ;\2Q18. ·· 1t c:1Jjmit~9 so.urces task ord~r · were not to be awarded to QCI, there is a very high risk that not only would .GSA be able to meet its mission; but •··.

the agendas using the Federal Buildings might fail in their missions as well.

5. A d,t!rmlnatlon by the ordering activity contracting officer that the order represents the best value consist,enfwith 8.404(d).

For the reasons above, QC I is the only source on the GSA Schedule with the seryices capa.~le of meeting this limited sources action requirement, arid issuing this order to QCI represents tl')e bestvalui:fconsistent with FAR 8.404(d) because it results in the'lowest overall risk to timely performa11~ pf seryi¢es ahpJhe lpwest overall cost alternative (considering price, administrative costs, etc.) to meet GSA's needs identified above under this limited sources action.

Approximately $2 million (if all options are exercised), or on average $200,000 monthly, is the cost of the limited sources task order. To ensure that this cost of an average $200,000 per month to the Government would be fair and reasonable, I reviewed · · · · The limited sources pricing is

· Therefore, the cost of the limited sources task order is considered fair and reasonable.

Considering the ability of QCI to meet the needs of the GSA at a fair and reasonable price, awarding an order to QCI in accordance with this justification represents the best value to the Government.

6. A description of the market research conducted among schedule holders and the results or statement of the reason market research was not conducted.

A limited source task order was awarded to QCI on a limited source basis because QCI is the only source available to provide services as described above and because, as the incumbent contractor, QCI was mobilized and employed the required staff to perform the facilities maintenance services beginning on November 1, 2018.

For this reason, market research was not conducted.

It was not possible for GSA to solicit any potential competitors for the procurement of these facilities maintenance services, evaluate offers and make contract award, familiarize the new contractor with the equipment, systems and facilities of the applicable Federal Buildings and then wait for that new contractor to obtain the necessary security clearances, to properly staff the applicable Federal Buildings with qualified workers, to obtain the tools and equipment necessary for this kind of work, and to timely perform.

7. Any other facts supporting the justification.

None.

8. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supply or services is made.

The GSA is currently conducting two new procurements for the facilities maintenance services. GSA awarded a limited sources task order for a two month base period with eight one-month options to ensure there would not be a lapse in the performance of facilities maintenance services while the GSA conducts these two procurements.

The subsequent acquisition (at the end of the limited source task order) for these facility maintenance services will be in compliance with the competitive requirements that are legally required.

CERTIFICATION

Contracting Officer:

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

RHONDA WIDICK

Rhonda Widick Contracting Officer

Legal Sufficiency:

_, Digitally signed by RHONDA WIDICK ' Date:2018.11.0715:36:32-06'00' 11/07/2018

Date

REVIEWS AND APPROVALS

l· ~ -•o ,-,. tion, and it is legally sufficie~nt-. .

Robert W. Schlattman Deputy Regional Counsel

Competition Advocate:

_ It 7 2oJg Dae

I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Since this justification does not exceed $13.5 million, my signature below serves as approval of the limited

Tanisha Hamson Competition Advocate

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