STORMS 1.5 LSJ Economy Efficiency_Redacted.pdf

OPOAM 3008.405-6(a)(2) Limited-Sources Justification (LSJ)

LSJ Template > SAT LSJ No: FY23-00113

Rev. 6.2021 2 order placed in accordance with the applicable Multiple Award Schedule ordering procedures. The original BPA was not issued under sole-source or limited-sources.

The current Storage, Transformation, and Optimization of Records Management Solutions (STORMS) BPA was competitively awarded in May 2018 and immediately thereafter, DHS commenced to utilize the non-NARA records transportation, storage, and disposition services available through the BPA. DHS also began utilizing the available industry expertise in clearing its massive records holding and records management backlog.

On June 29, 2019, NARA issued Memorandum M-19-21 announcing that it would cease accepting paper records by December 31, 2022. Due to the large volume of records that are created as part of DHS’s mission to secure the Homeland, this NARA requirement significantly increased demand for digitization services among the DHS components and provided by Iron Mountain as part of the STORMS BPA. On December 23, 2022, NARA issued Memorandum M-23-07 which extended the deadline for the transfer of permanent records to June 30, 2024, continuing the increased demand for digitization services among the DHS components.

The current competitively awarded BPA’s ordering period ends in August 2023. Awarding a limited sources logical follow-on BPA will allow DHS to receive uninterrupted records management and records handling support for a critical departmental function, both economically and efficiently.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with FAR 8.404(d).

The Contracting Officer has determined that issuing the proposed BPA to Iron Mountain Information Management LLC. for records management, transportation, conversion, scanning/digitization, physical storage, cloud-based storage and viewing, and destruction/archiving of departmental records support services is in the best interest of the Government. DHS has an estimated 800,000 cubic feet of physical records stored with Iron Mountain in NARA Certified facilities. The estimated cost of retrieving, transporting, and reshelving these records to a new location is $ Million. This figure amounts to of the ceiling for the proposed BPA. Over the course of the six-month base period of performance, and two (2) three-month option periods, these movement costs are not expected to be recovered through competition.

Retrieving, transporting, and reshelving all of DHS’s records would require substantial Government resources in the transition and would comprise a significant portion of the period of performance.

Given the effects of the recent Covid-19 pandemic and its impact on DHS operations in general and DHS records operations in particular, DHS would be significantly challenged to redirect the limited records management resources available, both personnel and

LSJ Template > SAT

Rev. 6.2021 3 funding, if records were to be retrieved from their current contractor storage location and transported and reshelved at the new vendor’s facility. Diverting these resources would leave other records management functions at risk.

There are multiple risks associated with moving the aforementioned records. These risks include:

Lack of Access: In moving the records, DHS and its Components would lose access to those records during packing, shipping, and unpacking. Due to the various records maintained, DHS risks the inability to perform some of its missions including National Security, providing immigration benefits, and preventing entry to dangerous individuals.

Coordination of Records: Due to DHS’s mission, different Components maintain records that are related and, in some cases, require being viewed collectively. In moving records, DHS risks having records spread among various sites, causing a lack of coordination and availability.

Contractor Space Available: If NARA certified space is not immediately available for all of DHS’s records, DHS Components would have to store records in their own facilities or make piecemeal individual contracts for records storage. Space for records storage is not currently available at DHS facilities and individual contracts risk increased cost.

Physical Damage: During the retrieval, transport, and restorage of records, DHS risks physical damage to the records. For example, a vehicle accident could cause loss of the records. This is a known risk as DHS Components have already suffered loss of records in vehicle accidents during transport by trusted agents, on a smaller scale.

Loss of Records: During the retrieval, transport, and restorage of records, DHS risks records being lost or misplaced. For example, lost immigration and naturalization records would cause great hardship and have a great impact on people’s lives.

This BPA will be placed in accordance with FAR 8.404, “Use of Multiple Award Schedules.” The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates. Discounts to these GSA schedule rates will be requested.

6. A description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

Market research was conducted between October 19, 2022 and April 3, 2023. Market Research consisted of interviewing members of the DHS Records Council, the DHS Component Records Officers, and the Integrated Procurement Team (IPT) made up of representatives from various components. Commercial databases, including the North American Industry Classification System, LSJ Template > SAT

Rev. 6.2021 4 and Government databases, including the GSA Library and GSA Advantage, were reviewed to help identify potential vendors. A Request for Information (RFI) was released to industry and vendor websites were reviewed to assess vendor capabilities. Market research indicated only Iron Mountain, LLC could perform these types of services at the quality required to meet the critical timeframes mentioned in Memorandum M-23-07.

DHS RIM and the Contracting Officer also reviewed GSA Multiple Award Schedule (MAS), Physical Records Management Services, MAS 493110RM and Electronic Records Management Solutions, MAS 518210ERM, to estimate the amount of funding that would be required to be expended for this logical follow-on effort.

The Market Research Report may be found in the Electronic Contract File System (ECFS) in Section 1.2.2.

7. Any other facts supporting the limited-sources justification.

In March 2022, the United States Secret Service (USSS) started the process for FedRAMP certification for the Iron Mountain record viewing system. The system provides cloud storage for digital records for viewing records online via a web browser. The FedRAMP includes an Authority to Operate issued by USSS and the projected approval was in April 2023. A system of this nature is a DHS requirement for the forthcoming BPA.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made. Include a statement of actions taken or that will be taken to increase competition for future acquisitions of the same item/service (e.g., the government intends to revise overly restrictive technical specifications, acquire data rights, or pursue some other means to increase future competition).

Due to the sheer volume of records, the decentralized, nationwide location of these records, and the resources required to move or process these records, the current acquisition situation is systemic in nature. DHS intends to recompete the STORMS requirement with award to be made in Fiscal Year 2024.

9. DHS intends to post this requirement on System for Award Management (SAM.gov) pursuant to FAR 8.405-6(a)(2)(i).