JA JBSA Final-redacted 10.9.26_.pdf

DEFENSE LOGISTICS AGENCY

ENERGY

8725 JOHN J. KINGMAN ROAD

FORT BELVOIR, VIRGINIA 22060-6222

J&A Tracking Number: 26-0002

Justification for Other than Full and Open Competition

1. Summary/Introduction:

The Defense Logistics Agency (DLA) Energy, a Major Subordinate Command of DLA, is the contracting activity for Bulk Petroleum Supply Chain Services for the Department of Defense (DoD). This Justification & Approval (J&A) is for the acquisition of Contractor-Owned, Contractor-Operated (COCO) retail/bulk fuel services at Joint Base San Antonio (JBSA), TX. JBSA includes two retail sites – Fort Sam Houston (FSH) and Camp Bullis. These retail sites include land lease optimization COCO facilities and services to operate, maintain, manage and provide retail/bulk fuel services. An expired contract for these services (SPE603-19-C-5011) was awarded to TRC Government Services LLC. (TRC) on September 25, 2019 for a four-year base period, two five-year option periods, one four-year option period, and a six-month extension option. The following justification is presented to support the decision to award a new sole source contract to TRC with a three-year base performance period beginning on June 01, 2026, through May 31, 2029, two five-year option periods from June 01, 2029, through May 31, 2039. The Independent Government’s Cost estimated total dollar value for this acquisition is .

2. Nature and/or description of the action being approved (FAR 6.104-1(a)(2)):

The action being approved is a J&A authorizing other than full and open competition for the procurement of retail/bulk fuel services for a three-year base period and two five-year option periods. This procurement is being conducted using the procedures outlined in FAR 6.103-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. This will be awarded as a new contract utilizing the Defense Working Capital Fund for fiscal year 2026. The use of other than full and open competition is critical and necessary to reinstating the mission of installing these new retail sites at JBSA, TX. Market Research and review of capability statements, indicates that only one vendor, TRC, has the infrastructure in place, ready workforce, and experience to meet the requirements of this solicitation.

Transitioning to a new contractor could disrupt the mission and a new contractor would face significant delays in acquiring the necessary infrastructure, permits, and personnel to commence performance by the beginning of the anticipated period of performance.

Additionally, there are also environmental concerns and issues that would further complicate a transition to a vendor other than TRC. Any potential cost savings from a competitive award are outweighed by risks of nonperformance associated with bringing in a new contractor. The incumbent contractor is the only contractor which can provide

Justification for Other Than Full and Open Competition (Cont’d)

(SPE603-26-R-0531- TRC GOVERNMENT SERVICES)

unfinished facilities creates additional costs for the Government. In accordance with FAR 6.305(a), the justification and approval will be redacted and posted to the System for Award Management (SAM) website within 14 days of contract award.

7. Determination by the contracting officer that the anticipated cost to the

Government will be fair and reasonable (FAR 6.104-1(a)(7)):

The Contracting Officer is in possession of an independent government estimate that is the basis for anticipated costs. This estimate utilizes the current wage determinations to anticipate labor costs which makeup the majority of expected costs in a contract for services. Additionally, the Government has already addressed additional costs owed to the contractor because of startup delays via processing of submitted requests for equitable adjustment under the expired contract. Any additional anticipated costs associated with remobilization have been factored into the estimate. The Contracting Officer anticipates that the cost to the Government will be fair and reasonable in accordance with FAR 15.404-1(b)(5) based on comparison of proposed prices with independent Government cost estimates. In addition, in accordance with FAR 15.402 (a)(2), the Contracting Officer will further validate the fair and reasonableness of the proposed cost by requesting, if necessary, other than certified cost or pricing data, prioritizing data available within the Government and from sources other than the offeror.

8. Description of the market research conducted and the results or a statement of the reason market research was not conducted (FAR 6.104-1(a)(8)):

In compliance with FAR Part 10, DLA Energy conducted thorough market research to identify potential sources and alternative solutions for this requirement.

The Government issued a Sources Sought Notice (SSN) (SPE603-26-R-5X10) on November 6, 2025, to SAM.gov for retail/bulk fuel services. Some of the included questions were how long it would take to build necessary facilities and if any offeror could meet the phase-in time of June 01, 2026 that will be required to commence performance. The SSN closed on November 21, 2025. At the time of closing there were five respondents. The first respondent asked to confirm that contract SPE603-19-C-5011 is the current incumbent contract associated with the retail fuel services. The Government responded and confirmed that the current incumbent is under contract SPE603-19-C- 5011, however did not submit a capability statement. The second respondent advised that they were an interested party and were instructed by the Government to provide responses to seven questions as described in the SSN. The Government reviewed the responses and the information provided did not adequately demonstrate capability. The third respondent provided a company overview and past performance; however, they did not respond to the seven questions in the SSN failing to demonstrate capability. The fourth respondent responded to the seven questions, provided a capability statement, and past performance. However, the phase-in period provided exceeded the Government’s need and was for 12 months. The fifth respondent responded to the seven questions, provided a capability statement and past performance. However, the phase-in period provided exceeded the Government needed and the timeline was for 13 months. The responses received from the SSN failed to show there were sufficient other qualified vendors to perform a competitive acquisition. Therefore, the Contracting Officer has no reasonable expectation that any contractor other than TRC can meet the Government requirement for this acquisition.

Based on a finding that no other vendors are capable of performing, DLA Energy issued a notice of intent to sole source on February 26, 2026. This notice was posted to SAM for fifteen days with a closing date of March 13, 2026. DLA Energy received no responses to the posted notice.

9. Any other facts supporting the use of other than full and open competition, such as

(FAR 6.104-1(a)(9)):

(i) Explanation of why technical data packages, specifications, engineering descriptions, statements of work, or purchase descriptions suitable for full and open competition have not been developed or are not available.

Not Applicable

(ii) When 6.103-1 is cited for follow-on acquisitions as described in 6.103-1(c)(2), an estimate of the cost to the Government that would be duplicated and how the estimate was derived.

Not Applicable.

(iii) When 6.103-2 is cited, estimated cost, or other rationale as to the extent and nature of the harm to the Government.

Not Applicable.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition (FAR 6.104-1(a)(10)):

Deltek, Kore Logisitics, Nelogis, Orange, and RV Global all expressed interest in this acquisition by submitting either clarifying questions and capability statements, but all vendors other than TRC, failed to demonstrate adequate capability to satisfy the requirement. The list of sources can be found in the contract file under tab 8.

11. A statement of the actions, if any the agency may take to remove or overcome barriers to competition before any subsequent acquisition for the supplies or services are required (FAR 6.104-1(b)(11)):

There are no known actions that will allow DLA Energy to overcome the competition barriers for this requirement.

I hereby certify that the data which forms the basis for this justification is accurate and complete to the best of my knowledge and belief.

I hereby certify that the data which forms the basis for this justification is accurate and complete and that the purchase request covers only the minimum requirements to satisfy the needs of the Government.

I have reviewed and concur with this Justification

Director, Bulk Petroleum Supply Chain Services

Approved: