LSJ_DW-SFTIES_fe_synopsized_1.pdf

LIMITED SOURCES JUSTIFICATION

FAR Subpart 8.405-6(a)(1)(i)(A)

Upon the basis of the following limited sources justification, I, as Contracting Officer, hereby recommend limiting competition for the proposed contractual action pursuant to the authority of Federal Acquisition Regulation (FAR) 8.405-6 Limiting sources.

l. Agency and Contracting Activity:

Contracting Office:

United States Environmental Protection Agency (EPA) Office of Acquisition Solutions (OAS) Information Technology Acquisition Division (ITAD) 109 T.W Alexander Drive Mail Code: AA005 Research Triangle Park, NC 27711

Project Office:

Office of Water (OW) Office of Ground Water and Drinking Water (OGWDW) Drinking Water Infrastructure Development Division (DWIDD) WJC Building East Washington, DC 20460

2. Nature and/or Description of Action(s) Being Approved:

This action to be effected by modification to an existing task order.

The US Environmental Protection Agency’s (EPA), Office of Water, Office of Ground Water and Drinking Water (OGWDW), Drinking Water Infrastructure Development Division (DWIDD)1 along with EPA’s ten Regional offices are responsible for program development, modernization, and enhancement (DME) operations as well as operation and maintenance (O&M) of all information technology (IT) systems that support the implementation of the EPA’s Public Water Supply Supervision (PWSS) program pursuant to the Safe Drinking Water Act (SDWA). Many PWSS program functions are delegated to, or managed by, EPA HQ, Regional and State Offices, as well as Territorial and Tribal Primacy Agencies. Thus, supporting a large and diverse stakeholder and end user base. The IT system suite consists of several stand-alone systems, applications, and components that, together, provide capabilities to manage data generated by the EPA's Public Water PWSS program2.

The subject task order, 47ATCA20D0006 / 68HERD21F0106 (68HERD21F0106), was competed as a small business set-aside under General Services Administration (GSA) Multiple Award Schedule (MAS) Information Technology (IT) Professional Services, Category 54151S (MAS – IT Professional Services 54151S), North American Industry Classification System (NAICS) code 541512 – Computer Systems Design Services, $30.0. The task order, consisting of a Base and four (4) one-year option periods plus an option to extend 6 months under FAR 52.217-8 Option to Extend Services was awarded to Systalex Corporation (Systalex), 1 Research Court, Ste 450, Rockville, MD 20850, on April 12, 2021, under

1 Formerly known as EPA’s Office of Water (OW), Office of Ground Water and Drinking Water (OGWDW), Drinking Water Protection Division (DWPD).

2 State and territorial drinking water programs (except for Wyoming) are responsible for ensuring the approximately 150,000 public water systems across the U.S. protect public health and comply with the Agency’s National Primary Drinking Water Regulations

(NPDWR).

Systalex’s GSA MAS contract number 47QTCA20D0006. 68HERD21F0106 is a time and materials type task order with firm fixed-price elements with a total cost ceiling of $61,499,210.57.

68HERD21F0106 provides the following support services for the OW’s DWIDD IT Systems: program and project management; new software applications design, development, and deployment; software application operations and maintenance; program implementation; and monthly progress reports. A subtask within the task order Performance Work Statement (PWS) is the planning, design, and implementation of a centrally hosted Drinking Water State-Federal-Tribal Information Exchange System (DW-SFTIES)3 to which the EPA’s OW is responsible for supporting and managing throughout its intended lifecycle4.

There are two pricing schedules associated with the task order: task order Attachment 4 – Pricing Schedule

– Pricing Detail and T&M Labor Rates (PWS) (Attachment 4) and task order Attachment 5 Pricing Schedule – Pricing Detail and T&M Labor Rates (SDWIS Modernization) (Attachment 5). Attachment 4 and Attachment 5 Contract Line Item Numbers (CLINs) are as follows:

Attachment 4

CLIN x001 DWPD Information Technology (IT) Systems Support Services (T&M) (Severable) Performance Work Statement (PWS) Tasks (Task 1 - Program and Project Management; Task 2 New Software Application Design, Development, and Deployment; Task 3 - Software Application Operations and Maintenance; Task 4 - Program Implementation) CLIN x002 Other Level Materials (OLM) (Severable) SubCLIN x002AA: Travel (Not to Exceed) SubCLIN x002AB: Materials (Not to Exceed) CLIN x003 Monthly Progress Report (Firm Fixed Price (Non-Severable) PWS Task 5: Monthly Progress Report (Firm Fixed-Price)

Attachment 5

CLIN x004 Safe Drinking Water Information System (SDWIS) Modernization (T&M) (Severable) Reference to - DWPD Performance Work Statement (PWS) Task 2 New Software Application Design, Development, and Deployment and PWS Appendix B - Current IT Systems and Software Applications 23. Expected Systems and Applications CLIN x005 Other Level Materials (OLM) – SDWIS Modernization (Severable) SubCLIN x005AA: Travel (Not to Exceed) SubCLIN x005AB: Materials (Not to Exceed)

3 Formerly known as OW’s Safe Drinking Water Information System (SDWIS)

4 https://e-enterprisefortheenvironment.net/our-projects/dw-sfties/#:~:text=for%20the%20Environment- ,Drinking%20Water%20State%2DFederal%2DTribal%20Information%20Exchange%20System%20(DW,formerly%20known% 20as%20SDWIS%20Modernization).

https://e-enterprisefortheenvironment.net/our-projects/dw-sfties/#:%7E:text=for%20the%20Environment-,Drinking%20Water%20State%2DFederal%2DTribal%20Information%20Exchange%20System%20(DW,formerly%20known%20as%20SDWIS%20Modernization) https://e-enterprisefortheenvironment.net/our-projects/dw-sfties/#:%7E:text=for%20the%20Environment-,Drinking%20Water%20State%2DFederal%2DTribal%20Information%20Exchange%20System%20(DW,formerly%20known%20as%20SDWIS%20Modernization) https://e-enterprisefortheenvironment.net/our-projects/dw-sfties/#:%7E:text=for%20the%20Environment-,Drinking%20Water%20State%2DFederal%2DTribal%20Information%20Exchange%20System%20(DW,formerly%20known%20as%20SDWIS%20Modernization)

The Periods of Performance are as follows:

Base Period 04/12/2021 - 04/11/2022 Option Period 1 04/12/2022 - 04/11/2023 Option Period 2 04/12/2023 - 04/11/2024 Option Period 3 04/12/2024 - 04/11/2025 Option Period 4 04/12/2025 - 04/11/2026 Option to Extend 6 Months Under FAR 52.217-8 Option to Extend Services (OP to Ext) 04/12/2026 - 10/11/2026

EPA’s OW/OWGWDW/DWIDD has requested an estimated increase5 in the overall task order cost ceiling in the amount of $10,948,500.01 and an overall task order labor hour ceiling increase in the amount of 76,250 labor hours. The requested increases are for Option Periods 3, 4, and Option to Extend Under FAR 52.217-8 (see section 3. Description of Supplies and/or Services Required to Meet the Agency’s Needs for a breakdown of estimated ceiling increases by option period).

3. Description of Supplies and/or Services Required to Meet the Agency’s Needs (including estimated value):

The program office is requesting an increase in labor cost and labor hour ceiling to support an accelerated schedule for the development and implementation of EPA’s DW-SFTIES such that the system implements before the current task order Option Period 4 expiration date of April 11, 20266 as well as increases in data system support requirements predicated by 1) Agency National Primary Drinking Water Regulations (NPDWRs) rule implementations, changes, and revisions and 2) Congressional mandates such as the Investment and Jobs Act (IIJA) (Public Law 117-58), also referred to as the Bipartisan Infrastructure Law7 and the Water Infrastructure Improvements for the Nation (WIIN) Act)8. All increases are based on Government estimates only. The Government intends to request a revised quote from Systalex upon the approval and execution of this document.

Increases in labor cost and labor hour ceilings will be applied to Option Periods 3 and 4 as well as the Option to Extend 6 Months Under FAR 52.217-8 Option to Extend Services. At the task order level, the amount of increase is $10,948,500.01, increasing the total task order cost ceiling from $61,499,210.27 to $72,447,710.58, or approximately 18%. The estimated cost ceiling increase of $4,079,400.00 will increase Option Period 3’s cost ceiling from $11,397,565.09 to $15,476,965.09, or approximately 36%. The estimated cost ceiling increase of $4,579,400.00 will increase Option Period 4’s cost ceiling from $11,658,365.89 to $16,237,765.89, or approximately 39%. The estimated cost ceiling increase of $2,289,700.00 will increase Option to Extend 6 Months Under FAR 52.217-8 Option to Extend Services cost ceiling from $5,829,182.94 to $8,118,882.95, or approximately 39%. Estimated cost increases and percentages at the period of performance level and by CLIN are depicted in the tables below:

5 All increases are estimates only and based on the Government’s estimate of cost and labor hours.

6 This date does not include task order Option to Extend 6 Months Under FAR 52.217-8 Option to Extend Services with a period of performance of April 12, 2026 thru October 11, 2026. FAR 52.217-8 allows for the continuation of services within the limits and at the rates specified in the task order, not to exceed a total of 6 months, should the Government require services to be continued past the Option Period 4 expiration date.

7 The Bipartisan Infrastructure Law makes a historic investment in drinking water and wastewater infrastructure, to deliver clean drinking water to all American families and help to eliminate the nation's lead service lines. Read more about funding for climate, energy, and the environment.

8 The WIIN Act, enacted on December 16, 2016, addresses, supports, and improves America's drinking water infrastructure. The WIIN Act added section 1414(c)(5), “Exceedance of Lead Level at Households,” to section 1414(c) of the Safe Drinking Water Act. Section 1414(c)(5)(B) requires EPA to forward data and information to the owner/operator of a public water systems and the primacy agency when EPA develops or receives certain data from a source other than a state or public water system, indicating that the drinking water of a household exceeds the action level for lead.

Table 1 68HERD21F0106 - Estimated Cost Ceiling Increases

Period of Performance Current Cost Ceiling

Estimated Cost Ceiling

Estimated Increase - $

Estimated Increase - %

Base 04/12/2021 - 04/11/2022 $ 10,578,046.45 $ 10,578,046.45 $ - 0%

OP 1 04/12/2022 - 04/11/2023 $ 10,893,422.34 $ 10,893,422.34 $ - 0%

OP 2 04/12/2023 - 04/11/2024 $ 11,142,627.86 $ 11,142,627.86 $ - 0%

OP 3 04/12/2024 - 04/11/2025 $ 11,397,565.09 $ 15,476,965.09 $ 4,079,400.00 36%

OP 4 04/12/2025-04/11/2026 $ 11,658,365.89 $ 16,237,765.89 $ 4,579,400.00 39%

OP to Ext 04/12/2026 - 10/11/2026 $ 5,829,182.94 $ 8,118,882.95 $ 2,289,700.00 39%

Total $ 61,499,210.57 $ 72,447,710.58 $ 10,948,500.00 18%

Table 2.A 68HERD21F0106 -Breakdown of Estimated Cost Increases - by CLIN

CLIN x001 PWS Tasks 1 - 4 (Task 1 - Program and Project Management; Task 2 New Software Application Design, Development, and Deployment; Task 3 - Software Application Operations and Maintenance; Task 4 - Program Implementation) )

Current Cost Ceiling Estimated Cost

Ceiling Estimated Increase -

Estimated Increase -

OP3 $ 7,711,661.70 $ 10,211,661.70 $ 2,500,000.00 32%

OP4 $ 7,889,029.92 $ 10,889,029.92 $ 3,000,000.00 38%

Opt to Ext $ 3,944,514.96 $ 5,444,514.96 $ 1,500,000.00 38% Total $ 7,000,000.00

CLIN x004 Safe Drinking Water Information System (SDWIS) Modernization (Reference to - DWPD PWS Task 2 New Software Applications 23. Expected Systems and Applications)

Estimated Increase -

Estimated Increase -

OP3 $ 3,627,503.39 $ 5,127,503.39 $ 1,500,000.00 41%

OP4 $ 3,710,935.97 $ 5,210,935.97 $ 1,500,000.00 40%

Opt to Ext $ 1,855,467.98 $ 2,605,467.99 $ 750,000.01 40% Total $ 3,750,000.01

CLIN x005 Other Level Materials (OLM) (Materials and Travel)

Estimated Increase -

Estimated Increase -

OP3 $ 14,000.00 $ 93,400.00 $ 79,400.00 567%

OP4 $ 14,000.00 $ 93,400.00 $ 79,400.00 567%

Opt to Ext $ 7,000.00 $ 46,700.00 $ 39,700.00 567% Total $ 198,500.00

TOTAL ESTIAMTED INCREASE $ 10,948,500.01

Table 2.B 68HERD21F0106 CLIN x005 Other Level Materials (OLM) Estimated Increases - by SubCLIN

CLIN x005 SubCLIN x005AA Travel (Not to Exceed)

Current Cost Ceiling Estimated Cost Ceiling Estimated Increase -

Estimated Increase

OP3 $ 7,000.00 $ 85,000.00 $ 78,000.00 1114%

OP4 $ 7,000.00 $ 85,000.00 $ 78,000.00 1114%

Opt to Ext $ 3,500.00 $ 42,500.00 $ 39,000.00 1114% Total $ 195,000.00

CLIN x005 SubCLIN x005AB Materials (Not to Exceed)

Current Cost Ceiling Estimated Cost Ceiling Estimated Increase -

Estimated Increase

OP3 $ 7,000.00 $ 8,400.00 $ 1,400.00 20%

OP4 $ 7,000.00 $ 8,400.00 $ 1,400.00 20%

Opt to Ext $ 3,500.00 $ 4,200.00 $ 700.00 20% Total $ 3,500.00

TOTAL ESTIMATED INCREASE $ 198,500.00

The second purpose is to request an increase in labor hour ceilings for Option Periods 3, 4 and Option to Extend 6 Months Under FAR 52.217-8 Option to Extend Services. At the task order level, the amount of increase to the labor hour ceiling is 75,250 hours, increasing the total task order labor hour ceiling from 443,850 to 520,100 or approximately 17%. The estimated labor hour ceiling increase of 28,100 will increase Option Period 3’s labor hour ceiling from 80,900 to 109,000, or approximately 35%. The estimated labor hour ceiling increase of 32,100 will increase Option Period 4’s labor hour ceiling from 80,900 to 113,000, or approximately 40%. The estimated labor hour ceiling increase of 16,050 will increase Option to Extend 6 Months Under FAR 52.217-8 Option to Extend Services labor hour ceiling from 40,450 to 56,500, or approximately 40%. This estimated increase is an estimate only and does not include any changes to the labor categories of labor rates as accepted at task order award. Estimated labor hour increases and percentages at the period of performance level and by CLIN are depicted in the tables below:

Table 3 68HERD21F0106 – Estimated Labor Hour Ceiling Increases

Period of Performance Current Labor Hour Ceiling

Revised Labor Hour Ceiling

Estimated Increase - #

Estimated Increase - %

Base 04/12/2021 - 04/11/2022 79,800 79,800 - 0%

OP 1 04/12/2022 - 04/11/2023 80,900 80,900 - 0%

OP 2 04/12/2023 - 04/11/2024 80,900 80,900 - 0%

OP 3 04/12/2024 - 04/11/2025 80,900 109,000 28,100 35%

OP 4 04/12/2025-04/11/2026 80,900 113,000 32,100 40%

OP to Ext 04/12/2026 - 10/11/2026 40,450 56,500 16,050 40%

Total Estimated Increase 443,850 520,100 76,250 17%

Table 4 68HERD21F0106 – Estimated Increase for Not-to-Exceed Labor Hours - by CLIN

CLIN x001 PWS Tasks 1 - 4

Current Labor Hour Ceiling

Estimated Labor Hour Ceiling

Estimated Increase

Estimated Increase -

OP3 54,800 73,000 18,200 33%

OP4 54,800 77,000 22,200 41%

Opt to Ext 27,400 38,500 11,100 41%

Total 51,500

CLIN x004 PWS Tasks 2 &

Appendix B Item 23

Current Labor Hour Ceiling

Estimated Labor Hour Ceiling

Estimated Increase

Estimated Increase -

OP3 26,100 36,000 9,900 38%

OP4 26,100 36,000 9,900 38%

Opt to Ext 13,050 18,000 4,950 38%

Total 24,750

TOTAL ESTIMATED INCREASE 76,250

4. Identification of the Justification/Rational for Limiting Sources and Demonstration of the Contractor’s Unique Qualifications to Provide the Required Supply/Service:

FAR 8.405-6 Limiting Sources requires an ordering activity to justify its actions when restricting competition. The specific circumstance that justifies restriction for an increase in task order cost and labor hour ceilings is FAR 8.405-6 Limiting sources.

Performance Work Statement (PWS) Cost and Hour Ceiling Increases - CLIN x001 PWS Tasks 1 – 4 and CLIN x004 PWS Tasks 2 & Appendix B Item 23

The need for the requested labor cost and labor hour ceiling increases is threefold. The first will be to accelerate the development and implementation of EPA’s DW-SFTIES such that the system implements before the current task order Option Period 4 expiration date of April 11, 2026. The estimated initial completion date of January 2025 was recently revised to April 2026, following a scheduled 6-month re-baselining review. The EPA’s Chief Information Officer (CIO)9 and OW Deputy Assistant Administrator (DAA) expressed concerns with the April 2026 completion date coinciding with the end of the task order;

identifying the period where in the current task order expires and a new task order begins as a period of high risk as it pertains to the successful implementation of the DW-SFTIES software application. Delays or unsuccessful attempts in DW-SFTIES implementation poses public health risks associated with various stakeholders as numerous drinking water program management data systems are antiquated and beginning to fail. If these data systems fail, stakeholder’s ability to oversee and ensure safe drinking water provision by public water systems will be severely impaired. Thus, a need to act quickly and immediately is imperative in order to fully support the PWSS program. Adequate support from the EPA is essential in order for states as well as territorial and tribal primacy entities to implement public health protection requirement of the SDWA.

9 Engagement with EPA’s Office of Mission Support (OMS) Enterprise Infrastructure (EI) is part of the process throughout systems/software development and data management lifecycles.

The second purpose is to support the following new Agency NPDWRs which will increase data system support requirements, another set of project funding demands exceeding the current task order cost ceiling(s) (the start of this demand has already occurred via data system preparation work to support the requirements of these rules):

• PFAS (per-and polyfluoroalkyl substances) Rule: prevent companies from starting or resuming the manufacture or processing of 329 per- and poly-fluoroalkyl substances (PFAS) that have not been made or used for many years without a complete EPA review and risk determination. Thus strengthening protections for communities and drinking water supplies located near the 1,740 permitted hazardous waste facilities across the nation (anticipated finalization - March 2024)

• Consumer Confidence Reports Rule Revisions: revisions would strengthen the Consumer Confidence Report (CCR) Rule making annual drinking water quality reports with important public health information more accessible to residents and businesses across the country (currently published in the Office of the Federal Register’s (OFR) Federal Register; anticipated finalization - March 2024)

• Lead and Copper Rule Improvements (LCRI): purpose is to strengthen public health protections, reduce complexity, and streamline implementation (currently published in the OFR’s Federal Register; anticipated finalization - Summer/Fall 2024)

Thirdly, Congressional mandates such as the IIJA (Public Law 117-58), also referred to as the BIL, and WIIN Act, have added significant extra data system support requirements, resulting in project funding demand exceeding the cost and labor hour ceiling of this task order.

The overall scope of the requirement remains unchanged; however, the volume and acceleration of performance will be increased significantly due the need to successfully deploy DW-SFTIES by mid-2025;

an increase in data systems support volume in order to support enforcement of the Agency’s NPDWRs as they pertain to PFAS, CCRR Rule, and LCRI; and Congressional mandates as described above.

Following is a list of Congressional mandates that have added signification extra data system support requirements:

1. Infrastructure Investment and Jobs Act (IIJA) (Public Law 117-58), otherwise referred to as the Bipartisan Infrastructure Law (BIL)

2. 2023 Omnibus Bill – Congressionally Mandated Projects (also known as Earmarks)

3. Water Infrastructure Improvements for the Nation (WIIN) Act

Following is a list of new Agency NPDWRs (with estimated finalization period shown in parentheses) that are anticipated to add more extra data system support requirements and data system preparation work to support the requirements of these rules:

1. PFAS (per-and polyfluoroalkyl substances) Rule (March 2024)

2. Consumer Confidence Reports Rule Revisions (March 2024)

3. Lead and Copper Rule Improvements (LCRI) (Summer/Fall 2024)

Performance provided must continue to adhere to Federal Statutes and EPA Information Management (IM) Directives, including but not limited to, EPA’s Web, Geospatial, and Enterprise Data Management Policy, Procedures, and Standards, and other agency policy, procedures, and standards. Acquisitions supporting information collections covered by Title 40 of the CFR shall adhere to EPA’s Information Collection Policy and Cross-Media Electronic Reporting Rule (CROMERR) and Implementation Procedure.

The program office has submitted a revised Performance Work Statement (PWS). Changes include the renaming of the OW / OGWDW’s Drinking Water Protection Division (DWPD) to DWIDD; the identification of Congressional mandates and Agency NPDWRs triggering an increase in the volume of data system support; and clarification of management and technical services, enhancement and support of DWIDD projects as listed in PWS Appendix B Current IT Systems and Software Applications.

Other Level Materials (OLM) Cost Ceiling Increases - CLIN x005 SubCLIN x005AA Travel (Not to Exceed) and CLIN x005 SubCLIN x005AB Materials (Not to Exceed)

The requested estimated increase in Order Level Materials (OLM) costs are based on the need to meet the development and implementation acceleration needs for EPA’s DW-SFTIES, as described above, as well as supporting new Agency NPDWRs (PFAS Rule, CCR Rule, and LCRI) and fully adhere to Congressional mandates which have added significant extra data system support requirements.

The current per period of performance CLIN x005 SubCLIN x005AA Travel NTE amount is $7,000.00 which supports the cost for two (2) contractor personnel to travel from the west coast (the majority of project leads for CLIN 4 are geographically located) to the Washington DC area for a 5-day period. The contractor personnel support the primary EPA PWSS annual conference, a 3-day event. The other two (2) days have been historically used to meet/collaborate with the program office’s user acceptance team. With the increased volume of contractor support, it is anticipated there will be a greater need for contractor travel in support of DW-SFTIES support and adherence to new Agency NPDWRs (PFAS Rule, CCR Rule, and LCRI) and Congressional mandates.

The revised CLIN x005 SubCLIN x005AA Travel cost, estimated, is calculated as follows:

- 6 participants x $3,500 each participant = $21,000.00

- 4 events for each of Option Period 3 and 4 = $85,000.00 (rounded up from $84,000.00)

- Option to Extend Months Under FAR 52.217-8 Option to Extend Services = $42,500.00

(1/2 of the Option Period 4 cost)

The current per period of performance CLIN x005 SubCLIN x005AB Materials NTE amount is $7,000.00.

Historically, for this task order, CLIN x005 SubCLIN x005AB Materials cost have been approximately $6.936.24, or just under the NTE amount of $7,000.00. This cost is comprised of various Amazon Web Service (AWS) charges supportive of the PWSS IT system. It is anticipated AWS fees will increase slightly, or average about $700 per month, with the implementation of DW-SFTIES and additional support for the PWSS IT system.

It is in the best interest of the government to prevent itself from incurring additional cost due to ramp down and ramp up costs, experience a loss in productivity, from endangering the EPA’s ability to make its deadlines for implementation, and to remain compliant to the referenced statutes, policy, and rules. No other contractor is in the position to begin performance in a timely manner to provide an adequate increase to the level of performance needed in order to expedite delivery of DW-SFTIES, to provide additional data system support as required by congressional mandates and the Agency’s NPDWRs, and to comply with Congressional mandates, i.e., IIJA and the WIIN Act. Systalex has been providing services to the EPA’s DWPD in support of DW-SFTIES DME effort since task order award in April 2022. This translates to an intimate knowledge of the underpinnings of the DW-SFTIES software application. Transitioning from one contractor to another would be costly to the Government and could result in the unsuccessful deployment of DW-SFTIES. In addition, the EPA CIO has expressed concern about the deployment of DW-SFTIES as, under the current DME schedule, it coincides with the expiration of the current task order, April 2026, which could lead to an increased risk of a failed deployment. The suggested resolution is to allow Systalex to accelerate performance in order to complete DME and deploy the software application at a time when Systalex is fully in control of the deployment and can respond quickly and knowledgably to any problems that may arise.

5. Determination by the Contracting Officer that the Order Represents the Best Value Consistent with FAR 8.404(d):

The Contracting Officer (CO) has reviewed the Independent Government Estimate (IGE) for an estimated increase in cost ceiling in the total amount of $12,318,500.00 along with an estimated labor hour ceiling increase in the total amount of 87,350 labor hours.

It should be noted that the IGE, upon which this LSJ has been prepared, is reflective of the Government’s estimate only and does not directly or indirectly imply the acceptance of any increases by the contractor.

Upon approval of this Limited Sources Justification, the CO will enter into negotiations with the contractor by way of a submission of a request for quote (RFQ) based on the revised PWS. Any agreed to increases in ceiling will be applied to the current task order Option Periods 3, 4, and Option to Extend 6 Months Under FAR 52.217-8 Option to Extend Services. The labor categories and hourly labor rates shall be in accordance with the terms and conditions established at task order award.

6. Description of the Market Research Conducted Among Schedule Holders and the Results of a Statement of the Reason Market Research Was Not Conducted:

N/A

7. Other Facts Supporting the Justification:

None at this time.

8. Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers that Led to Competition Before Any Subsequent Acquisition For the Supplies or Services:

There are no barriers to competition. The increase in cost and labor hour ceilings, as opposed to awarding the additional work to a new contractor, is more cost and time effective for the EPA. The original task award was competed via GSA e-Buy as a small business set-aside, and fair opportunity was given at the time of task order award.

9. Ordering Activity Contracting Officer’s Certification:

The Contracting Officer certifies that this justification is accurate and complete to the best of their knowledge and belief as noted by their signature below.

Attachments:

1. 47QTCA20D0006 / 68HERD21F0106 Attachment No. 1 Performance Work Statement DWIDD IT

Systems Support Services, revised 2/02/2024

10. TASK ORDER CONTRACTING OFFICER’S REPRESENTATIVE’S CERTIFICATION:

I hereby certify that the justification and supporting data are accurate and complete to the best of my knowledge and belief.

Percy A. Addo Date Office of Water (OW) Office of Ground Water and Drinking Water (OGWDW) Drinking Water Infrastructure Development Division (DID) Drinking Water Information Systems Branch (DWISB)

11. APPROVING OFFICIAL CERTIFICATION:

The approving official certifies that this justification is accurate and complete in accordance with FAR 8.405-6(c) as noted by their signature below.

RECOMMENDED BY:

Heather R. Pinney. CPCM Date Contracting Officer IT Infrastructure, Development, and Operations Branch Information Technology Acquisition Division Office of Acquisition Solutions (OAS)

REVIEWED BY:

Lenora Hilliard Date Contracting Officer/Section Supervisor IT Infrastructure, Development, and Operations Branch Information Technology Acquisition Division

Kevin S. Logan Date Contracting Officer/Branch Manager IT Infrastructure, Development, and Operations Branch Information Technology Acquisition Division

Rodney-Daryl Jones, CPM Date Contracting Officer/Division Director Information Technology Acquisition Division

APPROVED BY:

Tommie L. Madison Agency Advocate for Competition Date Partnership & Development Division (PDD)