Special_Notice_Consolidation__V1_4_17_26_(SAM_gov-executed)_1.pdf

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Department of Interior Contract Consolidation Determination and Findings

1. Purchase Request Number: TBD

2. Solicitation Number: RFP No. 140L0125R0010

3. Contracting activity/agency: DOI BLM-WHBP HQ722

4. Project Name: Wild Horse Burro Program (WHBP) Support Services for Off-Range Pastures (ORP) in 4 states

5. Description of supplies or services required to meet agency needs.

Contract Details

• Type of Contract: Firm Fixed Price (FFP) Indefinite Delivery Indefinite Quantity (IDIQ) contracts. Multiple IDIQ.

• Period of Performance (POP): Five (5) or ten (10) years.

• NAICS Code: 115210 - Support Activities for Animal Production.

• Size Standard: $11.0 million.

• Contract Ceiling: $226,000,000.00.

Background and Changes Previously, these requirements were primarily performed under Cooperative Agreements.

However, following the 2016 OIG Audit (see eFile A14 Market Research-OIG Report No. 2016- WR-027), the agency made several changes:

• Transitioned from Agreements to Contracts.

• Centralized the majority of the Wild Horse and Burro Program (WHBP) procurement actions from the states to the National Operations Center (NOC) and then to Headquarters (HQ722).

Consolidation Benefits The consolidation into one requirements document aims to improve quality by standardizing the Statements of Work (SOW), which previously varied slightly in terms and inspections.

Implications

• Regional/National Contract Implications: The consolidation supports the government’s mission objectives on both regional and national levels.

• Small Business and Socio-Economic Concerns: The potential effects on small businesses and socio-economic concerns are considered and addressed.

This consolidation improves government efficiency in labor (programmatic and acquisition) and time across planning, solicitation, contract administration, closeouts, and audits. Instead of multiple RFPs and requirement documents, there will be one RFP and PWS using consistent terminology, expectations, standards, incentives, inspections, and submittals. The program plans to use this document for future ORP requirements. Future ORP RFP is anticipated in 2028, Version 1.0 RFP ORP 4.17.2026 Page 2 of 4 with nationwide or larger geographical areas such as RFP 140L0125R0001 and will include

On/Off Ramping procurement approach.

Currently, there are approximately fifty-five (55) ORP contracts providing care for approximately 42,000 wild horses. Fifteen (15) of these contracts, covering about 12,600 horses, will end between June 30, 2026 and December 30, 2027. The goal of this acquisition is to secure enough ORP space to continue caring for the 12,600 horses from expiring contracts and to obtain approximately 3,400 additional space horses.

The total horse requirement is to contract for daily services for approximately 50,000 wild horses.

Contractors shall provide services for a daily quantity, not to exceed (NTE), chosen by the Offeror within the BLM range of 200 to 10,000 wild horses. No single vendor can meet the entire need for horses, so multiple awards will be necessary. The BLM identified 10,000 as the maximum number each vendor can provided, based on historical data related to the quality of animal care.

Soliciting multiple RFPs to cover the services provided by the 13 contractors for 15 expiring contracts and the additional 12,600 head capacity is inefficient. Consolidation allows the government to issue one solicitation, enabling contractors to submit a single proposal, significantly streamlining the process.

6. Market Research In accordance with FAR 7.107-2, I have reviewed this requirement and associated market research and determined that consolidation of the referenced contract requirements is both necessary and justified. My review resulted in the following findings:

Market Research was conducted by reviewing existing contracts, posting a Sources Sought Notice on SAM.gov as well as surveying Incumbent Contractors. We received 2 responses to our sources sought notices. All the respondents providing business size, identified as a small business. The contracting officer reviewed and determined that the contractor pool would not change if we solicited each requirement individual. The market research indicates that a consolidation of the requirement is in the best interest of the government.

In addition, the Small Business Administration resource tools of the Dynamic Business Search obtained on April 9, 2026 resulted in 83 potential vendors and a BLM Industry Day was conducted on January 24, 2024. Please see the analysis prepared in the eFile A14 Market Research and the associated data documented within it, specifically in the Tables and Attachments.

7. Any alternative contracting approaches and rationale for rejection:

The following alternative contracting approaches were considered by either the Program, Technical Specification Writer and Customer-Rob Sharp, Solicitors, or the Acquisition Office:

• Cooperative Agreements

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• Sole Source Set Aside

• Standalone Contracts with Option Periods versus Indefinite Delivery Indefinite Quantity

(IDIQ)

• IDIQ: Single Award versus Multiple Award

• RFP: Individual versus Multiple

Cooperative Agreements were discussed; however, based on the OIG findings as well as the time constraints to review and remove prior determinations and policies the program and acquisition office determined it was not viable for this requirement. However, the program will continue to research rescinding or revising BLM policies on the use of Cooperative Agreements for future WHBP requirements.

Sole Source was considered; however, in accordance with FAR 6.302 there was no authority to support the justification of a sole source.

Standalone contracts were also considered. However, at the time of award, the time and quantity of WHB, as well as the associated shipping location and date, are unknown. While the

BLM plans based on statistics and reports, various factors such as environment conditions, reproduction rates, and political and budget impacts can change, causing shifts in program priorities. This creates a significant need for flexibility. Timing and flexibility are critical to the

WHBP since On-Range Gathers are restricted to certain times of the year due to environmental constraints, like the weather. These On-Range Gathers then affect other WHBP support services, including Off-Range Corrals and Off-Range Pastures. Furthermore, some incumbents have their ORP facilities within the same geographical location (cities or counties).

As such, IDIQ contracts are a viable contract solution. Previously BLM issued multiple awards off one RFP and the TO were then non-competitively awarded to contractors. In addition, BLM issued several different RFP for the same services in less than a five-year period. However, this requirement anticipates issuing multiple awards throughout the 4 states off one RFP which will result in increased competitive pressure to Offerors and may result in providing cost reductions to the established IDIQ unit rates. BLM will competitively issue TO amongst the awardees in accordance with the FAR and the RFP Task Ordering process.

If this is not approved, the government would have to solicit multiple individual contracts which would significantly increase the administrative burden greater than 10 percent. The government would have to create at a minimum 15 individual solicitation packages, and the contractors would have to bid on each one individually. This could potentially impact small business competition due to contractors not wanting to bid on all the requirements. This would significantly put mission success at jeopardy.

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8. Any negative impact by the acquisition strategy on contracting with small business concerns has been identified:

There is no impact identified to small business concerns due to all incumbents and most of the interested vendors are small businesses.

9. Considerations, Facts, and Reasoning Supporting the Determination:

Specific benefits of consolidation include:

• Reduction in multiple acquisition cycle times due to one RFP versus multiple.

• Labor hour cost reduction and time savings for all BLM departments involved (program, acquisitions, budget/finance, solicitors, and internal auditors) at each step of the process: procurement, award, contract administration, audits, closeout.

• Consistent and improved quality of care to WHB due to use of the same requirements scope with established terminology, inspections, and submittal used throughout the program.

• Consistent contract terms and conditions, resulting in quality improvements.

• Ability to require the same pricing schedule and submittals forms, resulting in same data and accurate data reports.

• Consistent data saves BLM time and labor cost in responses to FOIA inquires, protest, and audits.

• Continuity in technical scope, standards, and expectations throughout the WHBP requirements facilitates improved relations with the public, media, contractors, and congress.

No incumbent small businesses are displaced because of this consolidation. Please see eFile

A14 Market Research and attachments for additional supporting documentation.

10. Summary:

In conclusion, please be aware that the WHBP requested and supports this consolidation.

Issuing multiple individual RFP all with differing requirements resulted in different standards as well as start and end dates. This caused confusion in the industry, negative impacts to BLM and the animals. Issuing one consolidated RFP with the same requirements document provides for transparency, continuity, reduction in labor and time as well as improved quality of services to all parties involved and more importantly supports consistent quality of care to the animals.

It has been determined by the contracting officer that consolidating this requirement will have no impact on the small business contractor pool. This will significantly decrease the administrative burden on the government and the contractors due to efforts having to be duplicated for each requirement. Therefore, it is in the best interest for the government to consolidate this requirement.

Approvals and signatures on file