Sole Source Justification - Hazmat Registration.pdf

U.S. Department of Transportation (US DOT) 693JK325F00028N Pipeline and Hazardous Materials Safety Administration (PHMSA) Sole Source Justification

SOLE SOURCE JUSTIFICATION

FOR AWARDING REDEVELOPMENT / MODERNIZATION OF PHMSA’s OFFICE OF THE

HAZARDOUS MATERIALS SAFETY (OHMS) – REGISTRATION MODULE CONTRACT

Task Order #693JK325F00028N

Redevelopment / Modernization of PHMSA OHMS’s Registration Module

This Sole Source Justification (SSJ) is prepared pursuant to the authority of 41 U.S.C. § 3304(a)(1)) as set forth under FAR Part 6.302 - Circumstances permitting other than full and open competition, subsection FAR Part 6.302-1 – Only one responsible source and no other supplies or services will satisfy agency requirements, FAR Part 16 - Time-and-Materials, Labor-Hour, and Letter Contracts. Further, the sections follow the content required by FAR Part 6.303-2.

1. Agency & Contracting Authority:

Acquisition Services Division Pipeline and Hazardous Materials Safety Administration (PHMSA) Department of Transportation Washington, DC 20590

2. Nature of Action Being Approved:

This action is to award a new task order for redevelopment / modernization, deployment and data migration of OHMS’s Registration Module. The modernized Registration module will be an integral part of USDOT - FMCSA MOTUS system.

About MOTUS:

The Federal Motor Carrier Safety Administration (FMCSA) Office of Registration (Office) supports all FMCSA registration-related programs and activities. This primarily includes monitoring and ensuring regulatory compliance across the Agency for many Entities (e.g., MC, Broker, Intermodal Equipment Provider [IEP], Cargo Tank Facilities, Shipper and/or FF), each with a distinct set of requirements.

The Office also oversees motor carrier and commercial motor vehicle financial responsibility requirements (commercial insurance and self-insurance), process agent requirements, trust funds and surety bonds for brokers and freight forwarders.

The authorities and regulations governing these entities were not enacted all once, but as a result of numerous provisions added or subtracted by multiple Congressional actions and regulatory changes over time. While FMCSA was created as a separate Agency within USDOT in the year 2000, some of FMCSA’s registration-related authorities were transferred from the Interstate Commerce Commission created by the Interstate Commerce Act of 1887. The result is a set of complex provisions and exceptions that can overwhelm a new entity applying for operating authority. A key challenge of developing URS will be to improve current processes and procedures while always maintaining regulatory and policy compliance to a wide range of stakeholders.

About PHMSA Registrations:

The Pipeline and Hazardous Materials Safety Administration (PHMSA) oversees the regulation and safety compliance of hazardous materials transportation. Currently, PHMSA utilizes the Hazmat

Registration application to manage registration and compliance for entities involved in hazardous materials transportation.

3. Description of Supplies or Services:

The contractor will develop and manage the migration of PHMSA’s Hazmat Registration application into the FMCSA MOTUS system by using requirements list (attached) to create a detailed road map, prioritized product backlog, and an agile release plan developed in coordination with FMCSA and PHMSA stakeholders. Beginning with a thorough assessment, the contractor will review existing systems and documentation, hold stakeholder sessions to refine business requirements and migration goals, and produce a phased release plan to guide development and deployments. Using iterative agile development, the contractor will design and build the Hazmat Registration module within MOTUS, conduct continuous integration and configuration management in FMCSA environments, and execute rigorous functional, security, and performance testing including UAT and regression tests. Concurrently, the contractor will execute a comprehensive data migration strategy—extracting, cleansing, transforming, validating, and loading legacy registration and file data into MOTUS—documenting data mappings, performing dry runs, and implementing archiving in accordance with federal records standards. The contractor will ensure the system meets FMCSA technical and security requirements (including ATO/NIST/FIPS-related activities), perform performance optimization and vulnerability remediation, and manage defects through resolution to maintain production stability. Finally, the contractor will produce and maintain all required documentation, deliver deployment and cutover support, and provide training materials and transition assistance to PHMSA staff and industry users for successful adoption.

Full description of services can be found in the Requirement Matrix and SOO (attached)

4. Statutory Authority (including the proposed contractor’s unique qualifications or the nature of the acquisition that requires use of the authority cited)

In accordance with 41 U.S.C. 3304(a)(1), as set forth in FAR Part 6.302-1, PHMSA has determined that only one responsible source and no other supplies or services will satisfy agency requirements, and the Task Order needs to be awarded to Changeis. The BPA (693JJ423R000004) was awarded in accordance with the applicable competition procedures and was not previously issued under sole-source or limited-sources procedures.

The complexity of the work and associated integration challenges as well as compressed timelines for the release of new registration module is compelling PHMSA to award this new work to Changeis. The reasons are illustrated below:

a. Institutional Knowledge:

• Prior knowledge of the MOTUS application and its technical stack is the primary and most compelling reason to award this contract to the incumbent vendor currently performing MOTUS development/modernization work for FMCSA.

• Their existing familiarity with the system architecture, data flows, integration points, and known constraints reduces the risk of integration issues and accelerates delivery timelines.

• Institutional knowledge of prior design decisions, workarounds, and vendor-developed artifacts eliminates the typical “ramp-up” learning curve that new vendors experience, enabling immediate productive work.

• Their awareness of historical pitfalls, regulatory touchpoints, and FMCSA-specific requirements increases the likelihood of a successful implementation and reduces rework.

• Continuity with the incumbent can translate into lower overall cost (fewer schedule overruns, reduced transition time, and fewer integration defects) and improved outcomes for the project.

b. Cost Avoidance:

• Transitioning to a new vendor would require duplicative costs for training, onboarding, software licensing, and system reconfiguration. It would also result in unacceptable delays in fulfilling the agency’s requirements.

• The cost of soliciting and evaluating competition outweighs the benefits, given that the incumbent provides excellent services and holds favorable terms.

• Significant savings and efficiencies will be realized since the incumbent already have intimate knowledge of the system and requirements.

c. Extended Onboarding Timelines:

• Immediate project kick-off: Personnel associated with the incumbent vendor will be able to commence modernization efforts immediately upon contract award, significantly reducing delays typically caused by extended onboarding timelines.

• Established stakeholder relationships: The Changeis team has cultivated effective working relationships with FMCSA key stakeholders, ensuring clear and efficient communication channels. This fosters alignment on project objectives and facilitates faster decision-making within tight timelines.

• Knowledge of organizational context: New contractors would face steep learning curves understanding FMCSA/PHMSA’s Registration program terminology, internal processes, and team dynamics. These have already been internalized by Changeis, reducing risk and ramp-up time.

• Continuity and responsiveness: Experienced team members are immediately available to troubleshoot, answer questions, and resolve challenges, minimizing project disruptions and maintaining steady progress.

• Collaborative culture: Through ongoing workshops and feedback sessions, the team fosters a supportive environment that promotes rapid adaptation, innovation, and problem-solving.

• Smooth integration of new members: When onboarding new personnel, the existing team’s expertise facilitates quicker assimilation, further sustaining project momentum.

• Compressed Timelines: PHMSA’s Hazardous Material Registration (HMR) cycle runs July 1– June 30, with early registration beginning May 1. The modernized, integrated Registration module must be deployed before the May 1, 2026, early-registration window. To provide sufficient time for comprehensive outreach, user engagement, and thorough validation, all development work must be completed by the end of March 2026, followed by intensive User Acceptance Testing and remediation in April 2026.

For these reasons—risk reduction, schedule acceleration, cost avoidance, avoidance of unacceptable delays, and increased probability of successful delivery—continuing with the original contractor is needed.

5. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under 5.202 applies.

PHMSA conducted a review its pool of Software Engineering Services (SWES) BPA holders and determined that, aside from the incumbent, no vendor possesses the necessary familiarity with the existing system, configurations, and the specialized registration and permit processes required to successfully perform this work. This limitation is compounded by the United States Department of Transportation (USDOT) mandate requiring implementation by July 2025, which eliminates the feasibility of onboarding and ramping up an unfamiliar vendor without incurring unacceptable schedule delays and operational risks.

6. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer has reviewed the Independent Government Cost Estimate (IGCE) in comparison to current GSA Labor Rates for similar services and has determined the anticipated costs of this work to be fair and reasonable.

7. A description of the market research conducted (see part 10) and the results or a statement of the reason market research was not conducted.

PHMSA conducted market research to identify potential sources capable of fulfilling the requirement. As part of this process, PHMSA reviewed the Software Engineering Services (SWES) list to evaluate all qualified vendors with relevant expertise. Our assessment involved examining vendor capabilities, prior performance records, and domain-specific experience related to the MOTUS application and its operational environment. The review determined that no other vendor possesses the unique combination of qualifications required to successfully execute this effort.

Specifically, our analysis confirmed the absence of any alternative provider that offers:

• Direct, hands-on experience with the MOTUS application – including demonstrated proficiency in system configuration, troubleshooting, and enhancement.

• Working knowledge of the MOTUS system architecture – encompassing its technical framework, integrations, and operational dependencies.

• Comprehensive understanding of Federal and Department of Transportation (DOT) registration and compliance processes – particularly those applicable to industries engaged in the transportation of hazardous materials.

• Proven capacity to meet an aggressive implementation timeline – with the ability to mobilize resources immediately to ensure timely completion of mission-critical milestones.

https://www.acquisition.gov/far/part-5#FAR_Subpart_5_2 https://www.acquisition.gov/far/part-5#FAR_5_202 https://www.acquisition.gov/far/part-10#FAR_Part_10

The results of this market research confirm that only the incumbent vendor meets all these criteria without introducing substantial risk to schedule, compliance, or operational continuity.

8. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

Since the requirement is tailored towards integration of PHMSA’s Registration System with FMCSA MOTUS System, PHMSA has not reached out to US DOT’s Software Engineering Support Services (SWES) Blanket Purchase Agreement (BPA)’s participating vendors.

9. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

PHMSA will assess opportunities to broaden competition for future acquisitions by documenting incumbent processes, capturing technical specifications, and ensuring that sufficient system and operational knowledge is transferred to government staff. Where feasible, PHMSA will update and standardize system documentation, evaluate potential training for alternative vendors, and explore modular or open-architecture solutions to reduce reliance on proprietary knowledge. These actions will help enable full and open competition for similar requirements in future procurements.

10. Technical Personnel Certification - FAR Part 6.303-2(c):

The signature below of the technical representatives certifies that the supporting technical data specified in this document is complete and accurate and justify the acquisition of the services from

ITG.

11. Contracting Officer Certification – FAR Part 6.303-2(b)(12) The Contracting Officer’s signature below certifies that the justification is accurate and complete to the best of her knowledge and belief.

12. Approval of Advocate for Competition for the procuring activity FAR 6.304(a)(2)

The signature of PHMSA’s Competition Advocate below approves this justification.

CERTIFICATION:

I certify that the facts and representations under my cognizance which are included in this Justification, along with any other supporting data, which form a basis for this Justification are complete and accurate.

Amit Joshi Date PHF-30 Information Resources Management [Technical Personnel]

CONTRACTING OFFICER CERTIFICATION:

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

Stephen Jones Date PHF-20 Acquisitions Services Division [Contracting Officer]

COMPETITION ADVOCATE APPROVAL:

I approve this Justification as being accurate and complete to the best of my knowledge and belief.

Michael Reles Date PHMSA’s Chief Financial Officer (CFO) [PHMSA’s Competition Advocate]