ROME DF Consolidation Final Redacted.pdf

Rev.: 12/2020

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Goddard Space Flight Center (GSFC)

Determination and Findings (D&F) for Consolidation of Requirements

Findings

I. Requirement Specific Information

A. Proposed/New Requirement

1. Description of Services:

The purpose of this contract is to provide facilities services that include, but are not limited to: Facilities Operations and Maintenance (O&M) services, Architect-Engineering (A-E) services, Construction services, and Facilities Information Resources (IR) services at GSFC Greenbelt located in Greenbelt, MD and GSFC Wallops Flight Facility (WFF) located at Wallops Island, VA.

Facilities include office buildings, technical facilities such as mission operations rooms, clean rooms, integration and test spaces, laboratories, launch facilities, an airfield, and warehouses. Supporting these facilities are electrical power, water, wastewater, storm water, steam, chilled water, fire alarm, geothermal, and other utilities.

This acquisition meets the definition of consolidation as defined in FAR subpart 2.1, as it will satisfy two or more requirements for services that have been performed under two or more separate contracts, each of which was lower in cost than the total cost of the contract for which offers will be solicited.

2. Identify whether the requirement will be competed or sole source:

This acquisition will be procured as a competitive 8(a) set-aside, based upon the results of market research and the small business specialist determination.

3. Solicitation Number, Contract Name, or Contract Number if known:

80GSFC22R0011, Repairs, Operations, Maintenance and Engineering (ROME) Services contract.

4. Contract Vehicle (e.g., contract, task order, IDIQ contract):

The contract vehicle will be a single award IDIQ with cost-plus-fixed fee (CPFF) and firm-fixed price (FFP) task orders.

provide maintenance, operations, and engineering of Langley Research Center’s (LaRC) institutional facilities and highly technical research facilities. In April 2021, IDIQ task orders were awarded under CMOE to provide O&M support for the WFF and Navy tenant organization, at Wallops Island, VA. An estimated of the work performed under this contract in support of the WFF and Navy is anticipated to be performed under the ROME contract. The contract expires on January 31, 2024.

The WFF Annual Task expires on April 14, 2023.

C. Is this a contract/order as a result of a Product Service Line (PSL) in accordance with

Procurement Information Circular (PIC) 18-01?

X Yes. If so, provide the PSL: 561210 Facilities O&M.

No.

II. Justification

A. Market research has been conducted (FAR 7.107-3(b)). See attached NASA Form (NF) 1787A, Market Research Report.

B. Quantify the specific benefits of the proposed consolidation/consolidated requirement by completing each of the following tasks (each task must be completed) (FAR 7.107-3(c)):

1. Compute the contract cost savings or reduction:

Price Reduction for Services:

The cost of performance of these ROME requirements is predominantly labor associated with service contract employees. A significant price reduction for services resulting from competition is unlikely based on the predominance of bargaining unit employees and the provisions of 41 U.S.C. chapter 67, Service Contract Labor Standards, which require successor contractors performing on contracts in excess of $2,500 for substantially the same services performed in the same locality to pay wages and fringe benefits (including accrued wages and benefits and prospective increases) at least equal to those contained in any bona fide collective bargaining agreement entered into under the predecessor contract.

Note: Pursuant to 29 C.F.R. 4.163, specific contract requirements from one contract may be broken out and placed in a new contract or combined with requirements from other contracts into a consolidated contract. The protections afforded service employees under 41 U.S.C. chapter 67, Service Contract Labor Standards, are not lost or negated because of contract reconfigurations or consolidations, and the predecessor contractor’s collectively bargained rates follow identifiable contract work requirements into new or consolidated contracts, provided that the new or consolidated contract is for services which were furnished in the same locality under a predecessor contract.

However, savings through reductions in work-year equivalents (WYE) for service employees, may be available. Some labor positions can likely be performed remotely from one site to provide services for both sites, thereby allowing economies of scale to reduce the overall number of staff to perform the work. This is especially true in the area of . NASA anticipates that a reduction of resources of approximately is possible. This would save an estimated

The Requirements Development Team also examined the potential for price reduction related to management efficiencies as a result of reducing multiple contracts to one. That examination determined

This could also result in the possible reduction of approximately and save an estimated

2. Compute the administrative or personnel cost savings and provide the supporting documentation for this computation:

Administrative Cost Reduction:

Note: The following cost savings are internal to the Government and generally are attributed to reductions associated with the procurement of Facilities services.

This acquisition is subject to PIC 18-01, Strategic Approach to Acquisition Strategies by Institutional PSL, and (1) supports the consolidation of GSFC’s facility contracts for two sites into one contract; (2) provides for the elimination of unnecessary redundant contracts for Facilities O&M services across the two sites of the same Center; (3) facilitates uniformity of requirements between the Center’s two sites; and (4) combines the minor A- E and Construction requirements with the O&M requirements as is typical at other NASA Centers. This acquisition significantly reduces the administrative cost associated with conducting market research, developing an acquisition strategy, preparing a solicitation, evaluating proposals, and awarding the contract, by eliminating the need for duplicative requirements development teams, source evaluation boards, and source selections.

Analysis: The average acquisition duration was examined for the following three contracts cited in section I.B.: FOMS III, FACETS III, and CMOE, as these contracts were most similar to the ROME acquisition in size and overall scope. The average acquisition duration of these contracts is approximately 474 days, when measured from release of the sources sought synopsis/request for information (RFI) (e.g., start of market research) to contract award. Individual acquisition durations based on this standard were as follows:

656 days for the FOMS III (May 19, 2016, to March 6, 2018) 377 days for the FACETS III (March 16, 2016, to March 28, 2017) costs. This will maximize spending ability and eliminate redundant contracts for goods and services through synchronization of institutional requirements. The benefits of this consolidation include a reduction in the number of buying locations, which is part of the agency-wide endeavor to implement the PSL approach. Accordingly, the expected benefits of the consolidation approach are critical to the Agency’s mission success in implementing MAP.

This consolidation is anticipated to achieve several benefits in the areas of both cost and quality. While it is difficult to quantify the actual cost savings at this time, some cost savings are predicted as a result of the reduction of duplicated efforts and operational efficiencies in contract administrative actions and an associated reduction in civil service labor (or efficiencies in civil service labor). In addition to the cost savings discussed above resulting from performing fewer procurements, consolidation of the requirements into one contract also allows a reduction of government resources required to perform contracting functions and to provide oversight for each contractor’s performance. These resources include contracting officers, contracting officer’s representatives (COR), and resource analysts. The consolidation would provide an opportunity to reallocate resources to provide support to other functions, contracts, projects etc., which increases efficiencies in a resource-constrained environment.

It is also anticipated that vendors will propose efficiencies and economies of scale through a competition for a larger procurement (rather than three smaller procurements) that will result in better pricing which will lead to cost savings. As discussed above, while it is difficult to quantify the actual cost savings at this time, efficiencies and economies of scale are expected through consolidation of functions that could be performed remotely from one site to provide services across the site. In addition to the GIS Technician, it is expected that the vendors will propose similar efficiencies and economies of scale as a result of consolidating the requirements. Similarly, it is expected that the vendors will produce efficiencies in their operations that could lead to the reduction of overhead costs.

The consolidation of the requirement will result in improved quality of services. Since the joining together of WFF under GSFC in 1980s, the GSFC Facilities Management Division has been struggling for decades to gain uniformity in policy, procedures, standards, and level of service between the two sites of GSFC. Having the O&M, A-E and Construction, and IR services for both sites finally under one single contract is a critical step towards finally achieving this uniformity. For many years the periods of performance for the various facility contracts were offset in a manner that would not permit the consolidation of requirements. With the expiration of the 10-year Wallops Institutional Consolidated Contract (WICC) at Wallops in 2021, GSFC finally has an opportunity to obtain facility services, especially O&M, combined under one contract. Consolidation of the requirements will result in a single management interface across all contract functions and sites, which avoids inconsistency in implementation of contract direction or resolution of performance issues, reducing the likelihood of lapses in facility service availability. Using the same techniques and methods across both sites reduces risk associated with multiple different practices being implemented at various locations.

Consolidation of the requirements also promotes consolidation of knowledge and experience in fewer personnel. This increases expertise, particularly in specialized trades, facilitating quicker and more successful resolution of O&M issues, which ultimately reduces the time facilities or equipment are not available to NASA users. Additional benefits include consistent service levels and reliability for NASA programs and projects, consistent preventive maintenance philosophy and maintenance plans for the facility equipment, and consistent service response times for service requests to the many employees at both sites.

These benefits, along with the benefits described above in Section B above, substantially exceed the benefits that would be derived from the alternative contracting approaches described below.

D. Identify alternative contracting approaches that have been considered that would involve a lesser degree of consolidation (FAR 7.107-2(a)(2)).

The alternative contracting approaches considered that would involve a lesser degree of consolidation is to procure the services sought under the ROME contract under two separate contracts as follows: (1) one contract for each GSFC site that provides for O&M services, A-E services, Construction services, and Facilities IR services or (2) one contract for O&M and Facilities IR services for both sites and another contract for A-E and Construction services for both sites.

The first alternative may result in some administrative cost savings as a result of reductions associated with the procurement of one less Facilities O&M services contract, however, those savings are not expected to be significant. While this approach may result in some cost savings and efficiencies from the reduction of one contract, it is not in the best interest of the government because any cost savings or efficiencies would be minimal. This approach is also inconsistent with the Agency’s efforts under MAP. This approach would preclude any cost efficiencies that might be gained by having a single contract, such as in the IR services scope, potential reduction of non-managerial administrative personnel, or any efficiencies to be gained in the contract administration functions of the contract. It would also not be conducive to improving uniformity of services between the two GSFC sites. Under this approach, the Government would need to interface with two separate contract management interfaces. Different contractors at the sites would also establish differing standards of maintenance for the facility equipment under performance-based contracts. Additionally, with institutional budget reductions, much of the construction program now consists of customer funded construction for their technical spaces. The demand for these projects is highly volatile depending on their mission needs. Separate contracts at each site would not allow for the flexibility of the contractor to assign available personnel and other resources to the site with the most need.

Furthermore, this approach does not allow for leveraging nationwide price competition or economies of scale, leading to increased cost for localized procurements. The other primary disadvantage to this approach is that it would result in much longer times to respond to the customer’s urgent needs for construction renovations of their critical facilities in response to new or changing mission programs.

The second alternative may result in some administrative cost savings as a result of reductions associated with the procurement of one less Facilities O&M services contract, however, those savings are not expected to be significant. While this approach may result in some cost savings and efficiencies from the reduction of one contract, it is not in the best interest of the government because any cost savings or efficiencies would be minimal. This approach furthers some of the Agency’s efforts under MAP, however, is not consistent with the approach taken by most NASA Centers to combine the minor A-E and Construction requirements with the O&M requirements in furtherance of the Agency’s mission critical MAP efforts. Under this approach, there could be cost efficiencies that might be gained by having a single contract for Facilities O&M services for both sites, such as in the IR services scope or in the administrative functions of the contract. It would also provide an opportunity to improve uniformity of services between the two GSFC sites. However, under this approach, the Government would still need to interface with two separate contract management interfaces.

E. Describe the impacts of the acquisition strategy on contracting with small business concerns; be sure to specifically address: The annual amount that was previously obligated to small businesses that will no longer be obligated as a result of the planned consolidation; and the change in the number of small businesses that have prime-level contracts with NASA as a result of the planned consolidation.

The annual amount that was previously obligated to small businesses was approximately

. As a result of the planned consolidation being an 8(a) small business set-aside, approximately is anticipated to be obligated annually to small business under the ROME procurement. The ROME procurement will consolidate two large business contractors, and one 8(a) contractor into one 8(a) contract.

F. Select all of the steps taken to include small business concerns in the acquisition strategy for the planned consolidation. In addition to numbers 1 and 2 below, include any other steps taken. Check all that apply below.

1. Incorporated recommended small business subcontracting goals in the draft and final request for proposal (RFP), in accordance with NPD 5000.2 Small Business Subcontracting Goals and NFS 1815.304(c)(4)(B).

2. Evaluation of offerors’ small business subcontracting commitment as a part of the evaluation criteria, NFS 1815.304(c)(4)(C).

3. Other steps taken to include small business concerns: In addition to procuring this acquisition as a competitive 8(a) small business set-aside, the Government will add release of a draft RFP for industry comment consistent with NFS 1815.201(c)(6)(A).

III. Determination

In accordance with the findings provided above, I determine that it is in the best interest of the Agency to consolidate the requirements. This written determination demonstrates that this consolidation is necessary and justified because the expected benefits are critical to the agency’s mission success and the procurement strategy provides for the maximum practicable participation by small business.