SAM.gov Mod P00002_ Justification and Approval_Redacted.pdf

JUSTIFICATION AND APPROVAL

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

Contract 47QFRA26C0001

Modification P00002 - SAT PGS Delta Upgrade

Building Automation System (BAS) Installation & Maintenance Bridge in support of:

Department of Defense (DoD) Defense Information Systems Agency (DISA)

United States (U.S.) General Services Administration (GSA) Federal Acquisition Service (FAS)

Assisted Acquisition Services (AAS) Army

Controlled by AAS Contracting Officer Rosalind Cherry (rosalind.cherry@gsa.gov)

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The General Services Administration (GSA) Assisted Acquisition Services (AAS) makes this Justification for Other Than Full and Open Competition orders pursuant to Federal Acquisition Regulation (FAR) 6.104 (GSA Class Deviation Revolutionary FAR Overhaul

(RFO)-2025-06).

1. Identification of Agency and Contracting Activity:

Agency:

GSA AAS acting in support of Department of Defense (DoD), Defense Information Systems Agency (DISA)

Contracting Activity:

GSA AAS Contracting Office (FABAD) AAS Army Sector 1 Division 4

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

DoD and AAS Contracting Office proposes to modify the existing BAS contract awarded to SPEC, LLC to add approximately $832,204.09 in additional BAS work necessary to support DISA Computing Services data center operations located at the

The existing contract provides Firm-Fixed Price (FFP), Time and Materials (T&M), and Direct Reimbursable Travel services for BAS installation, preventive and emergency maintenance, system modifications, and related support at DISA data centers. The contract was awarded on a sole-source basis to maintain continuity of mission-critical services while the Government conducts the competitive follow-on acquisition.

The proposed modification will add a separate, non-several requirement at the for the replacement of existing BAS equipment and associated components. The effort will replace aging and failing equipment, integrate the replacement equipment into the existing BAS environment, and align the system with the BAS configuration utilized at other DISA facilities to improve system reliability, maintainability, and response times.

The work is technically consistent with the existing PWS requirements for BAS maintenance, installation, and modification; however, the magnitude and approximately $832,204.09 value of the additional requirement were not contemplated at the time of the original contract award. Accordingly, the Government is separately justifying the use of other than full and open competition for this modification.

Due to the criticality of these systems, replacement must begin as soon as possible.

Furthermore, the additional work must be completed as an integrated effort because the individual tasks are interdependent and collectively produce a complete and usable result.

Delaying performance, dividing the work between contractors, or separately competing portions of the requirement at this stage would create significant performance, integration, schedule, and operational risks.

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4. An Identification of the Statutory Authority Permitting Other Than Full and Open Competition:

This modification will be issued pursuant to the authority of 41 United States Code (U.S.C.) 3304, as implemented by FAR 6.103-1 (GSA Class Deviation RFO-2025-06), based on the determination that only one responsible source can satisfy the Government’s requirement within the required timeframe without unacceptable delay to the agency’s mission.

While the additional work is technically related to the BAS services being performed under the current contract, the magnitude and value of the proposed modification were not contemplated as part of the original award. Therefore, the Government is separately documenting the basis for use of other than full and open competition for this modification.

5. A Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Requires Use of the Authority Cited:

The circumstances surrounding this requirement necessitate use of other than full and open competition because SPEC, LLC is currently performing the BAS contract and is positioned to perform the additional work within the required timeframe with the least disruption to DISA’s mission-critical operations.

SPEC currently possesses the site-specific knowledge, system familiarity, access, technical documentation, established procedures, and understanding of the existing BAS environment necessary to immediately integrate the additional requirement into ongoing contract performance.

Awarding the additional requirement to another contractor at this stage would require time for solicitation, evaluation, award, security and site access processing, transfer of system information, familiarization with the existing BAS environment, coordination with the incumbent, and transition of technical and procedural knowledge. These activities would result in unacceptable delay in accomplishing the required work and could increase integration and operational risk.

The proposed modification involves a non-severable effort that must be coordinated with the existing BAS infrastructure and ongoing contract activities. Introducing a second contractor to perform an interconnected portion of the BAS requirement would create additional interface, accountability, integration, schedule, and system configuration risks.

Accordingly, based on the required completion timeframe and the need to avoid disruption to mission-critical BAS operations, SPEC, LLC is the only responsible source that can meet the Government’s immediate requirement without unacceptable delay.

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6. A Description of Efforts Made to Ensure that Offers are Solicited From as Many Potential Sources as Practicable:

The Government previously conducted extensive market research for the BAS follow-on requirement, including Request for Information (RFI), review of available Government-wide contract vehicles, GSA Multiple Award Schedule research, and industry capability assessments.

Those efforts demonstrated that other vendors may possess general capability to perform BAS services. However, the current action concerns a time-sensitive modification to the existing contract for a discrete non-severable effort that must be integrated with ongoing BAS performance.

The Government will publicize the proposed contract action and/or the approved justification in accordance with applicable FAR and GSA requirements.

7. A Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable:

The Contracting Officer (CO) will determine the price for the proposed modification to be fair and reasonable prior to execution of the modification.

The Government will evaluate the contractor’s proposed labor, materials, equipment, subcontractor costs, travel, and other applicable elements using appropriate price and /or cost analysis techniques. The analysis may include comparison to existing contract rates, historical prices, independent Government estimates, published commercial or market pricing, subcontractor quotations, and other relevant data.

The estimated value of the proposed modification is approximately $832,204.09. The existing contract value is approximately $1,509,848.64. Following execution of the proposed modification, the estimated total contract value will be approximately $2,342,052.73.

No modification will be executed until the CO determines that the price is fair and reasonable.

8. A Description of the Market Research Conducted and the Results or a Statement of the Reason Market Research was not Conducted:

Market research for the underlying BAS requirement was conducted in accordance with FAR Part 10 (GSA Class Deviation RFO-2025-10) and included review of historical acquisition information, available Government contract vehicles, industry capability, and technical input.

The Government previously issued RFIs through SAM.gov and GSA's Market Research as a Service (MRAS) tool and received responses from multiple vendors. The results demonstrated the existence of multiple vendors capable of competing for the long-term BAS follow-on requirement.

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However, the present action is distinguishable from the long-term competitive follow-on acquisition. The proposed modification addresses an immediate, non-severable BAS requirement that must be accomplished in conjunction with ongoing contract performance and within the required operational timeframe.

Based on the existing market research, technical assessment of the additional requirement, current contract performance, required schedule, and transition considerations, the Government determined that conducting a separate competition for this discrete modification would not meet the Government's immediate need and would result in unacceptable delay.

The Government continues to pursue competition for the long-term BAS follow-on requirement.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition:

The proposed modification is necessary to address a mission requirement identified during performance of the current contract.

Although the technical nature of the additional work is consistent with the type of BAS installation, maintenance, modification, and upgrade services included within the existing requirement, the approximately $832,204.09 increase represents a significant addition to the value of the current contract that was not contemplated at the time of the original award. For this reason, the Government is separately justifying the modification rather than relying solely upon the justification supporting the original award.

Delaying the work to conduct a separate procurement would jeopardize the Government's ability to complete the required BAS effort within the necessary timeframe and could adversely affect DISA data center operations.

Use of the incumbent contractor will also reduce technical interface risks associated with having multiple contractors simultaneously performing interconnected work on the BAS infrastructure and will provide clear responsibility for system configuration, integration, testing, and completion of the non-severable effort.

10.A Listing of the Sources, if any, That Expressed, In Writing, An Interest in the Acquisition:

The Government's prior market research identified multiple sources interested in the broader BAS requirement. However, no source other than the incumbent contractor has been identified that can perform the immediate non-severable modification within the required timeframe without the transition, integration, and operational delays described above.

Should a source express interest in response to any required public notice associated with this action, the Contracting Officer will consider the information provided prior to execution of the modification, as applicable.

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