Vickery Gate Phase II - Limited Sources JA SIGNED - 7.13.26_Redacted.pdf

220 BINNEY

CAMBRIDGE, MA 02142

Volpe.DOT.gov

Limited-Source Justification and Approval for PR V3352345 Noncompetitive Acquisition of a Logical-follow on Federal Supply Schedule Orders (FSS)

Exceeding the Simplified Acquisition Threshold (SAT)

This acquisition is conducted under the authority of the Multiple Award Schedule (MAS) General Services Administration (GSA) Program pursuant to 40 U.S.C. 501 and applicable provisions of 41 U.S.C. Additionally, pursuant to Class Deviation No. 2026-22, Supplement to Certain Federal Acquisition Regulation (FAR) Deviations (Part 5, 8, 9, 12, 13, and 23), in Support of Executive Order 14275 on Restoring Common Sense to Federal Procurement (DOT_RFO_Deviation_Part- 8_0_0.pdf) and controlling FSS Ordering Procedures via GSAM/R subpart 538.71 (https://www.acquisition.gov/fss-ordering-procedures), 538.7104-3 Sole source justifications.

I. Contracting Activity

U.S. DOT Volpe National Transportation Systems Center V-221, Off-Site Engineering & R&D Contracts Patricia Barnett, Contracting Officer 617-494-2976 patricia.barnett@dot.gov

II. Nature and/or description of the action being processed.

Task order under GSA Contract No. 47QSWA22D0019 Contractor: Concentric Security LLC 7560 Main St Sykesville, Md 21784-7353 334-273-8558 dwachs@concentricsecurity.com

The contract type shall be Firm-Fixed-Price.

CLIN DESCRIPTION QUANTITY DELIVERY

00100 Schedule and Permits 1 NLT than 15 days after award.

00200 Installation Completion, As-Built Drawings 1 NLT 31 December 2026

TOTAL PRICE (BASE)

(CLINs 00100 – 00200)

OPTION CLINs

CLIN DESCRIPTION QUANTITY DELIVERY

00300 Sawcut, demo and replace (~480 sf) sidewalk/curb from the main barrier to side barriers, (~120 sf) sidewalk and curb from booth’s exit lane trench cut west to storm drain, Install sidewalk, curb and new (2) ADA crosswalk transitions on exit side.

1 TBD

00400 Sawcut, demo and replace (70ft? x 2ft?)

sidewalk/curb, including existing post/chain. Patch sidewalk, Install curb, Add 70ft of handrail (match handrail on exterior of blockhouse).

1 TBD

00500 Sawcut, demo pavement, excavate. Install non-rated bollards and concrete to grade on centerline between booth and perimeter. Could be auger or trenched with concrete to grade, etc.

1 TBD

00600 Repaint (4?) jersey barriers and move back on centerline between booth and perimeter.

1 TBD

00700 Sawcut, demo (~200sf) pavement of road centerline between booth and perimeter. Install pavement and conduit, quazite.

1 TBD

00800 Sawcut, demo (~150sf) pavement between centerline and north blockhouse. Install pavement and conduit.

1 TBD

00900 Sawcut, demo (~430sf) sidewalk/curb between south blockhouse and booth’s exit lane trench cut. Install curb. Restore with loam and grass.

1 TBD

IV. Identification of the justification/rationale for limiting sources and demonstration of the contractor's unique qualifications to provide the required supply/service.

Per the FAR Overhaul, FAR Subpart 8.4 - Ordering under the Federal Supply Schedule: 8.401 General: (a) The Federal Supply Schedule (FSS) program is directed and managed by GSA and provides Federal agencies with a simplified process to obtain commercial supplies and commercial services at prices associated with volume buying. Agencies must use the FSS, in accordance with

8.104. (b) When placing an order under the FSS, agencies must follow the ordering procedures established by GSA and found at subpart 538.71. GSA ordering procedures follow all statutory requirements, including the requirements of section 863 of the Duncan Hunter National Defense Authorization Act for Fiscal Year 2009, and have been coordinated with the Office of Federal Procurement Policy for consistency with governmentwide acquisition policy.

GSA subpart 538.7104-3 allows orders placed against FSS contracts to be exempt from the requirements in FAR Part 6. Subpart 538.7104-3 requires an ordering activity to justify its actions when awarding on a sole source basis in accordance with the subsection. For orders exceeding the SAT, the statutory exception supporting the placement of an order on a sole source basis, subpart 538.7104-3 (b)(1)(iii): “[t]he order should be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to an FSS order already issued on a competitive basis.” The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

Consideration for this Federal Supply Schedule order is limited to Concentric Security LLC pursuant to GSA subpart 538.7104-3 (b)(1)(iii).

Original GSA FSS task order award for USMMA Vickery Gate Phase I – Replacement Security Guard Booth.

Contract No. 47QSWA22D0019 Task Order No. 6913G623F50013N

The Phase I task order was placed on January 19, 2023 using applicable MAS ordering procedures competitively. It was not issued using sole-source or limited-sources procedures.

The work would have been completed under a single requirement but was divided into two phases solely due to funding constraints. The Phase II effort is within the scope, magnitude, and intent of the original Phase I competition and was contemplated in the original design. This work is based on a single design that has not changed since the issuance of the original contract. The first phase installed infrastructure, a new ballistic guard booth, and terminals and readers for the Lenel physical security access control system (PACS). This second phase completes the integration into the ballistic guard booth and physical security systems previously installed.

This second phase also installs the four active vehicle security barrier system controls and integrates the pedestrian access control portal into the ballistic guard booth. Access control for these systems will be controlled by the armed guard based on information provided by the Lenel PACS installed in Phase I. The passive vehicle security barriers are installed in conjunction with the active vehicle security barriers to provide a secure envelope at the USMMA primary entry control point for vehicles and pedestrians.

The Government has determined that award to a source other than Concentric would result in substantial duplication of cost and unacceptable delay GSA subpart 538.7104-3 (b)(1)(iii) . A follow-on to an FSS order already issued on a competitive basis is in the best interest of economy and efficiency in this case as it would avoid substantial duplication previously incurred costs, allowing the government to realize the cost savings and benefits associated with continued performance as futher detailed below in paragraph VII.

V. Determination that the Order Represents a Fair and Reasonable Price

In accordance with FAR 8.401 and GSA subpart 538.7104, the Contracting Officer will determine that the proposed price is fair and reasonable prior to award. Price reasonableness will be assessed through comparison to the Independent Government Cost Estimate (IGCE), historical pricing for Phase I and similar efforts, and review of applicable GSA MAS contract labor categories and rates.

The resulting order will be determined fair and reasonable in accordance with FAR 8.401 and GSA subpart 538.7104.

VI. Description of the market research conducted and the results.

Volpe Center technical and acquisition office staff from V-335 and V-221 conducted market research for this procurement between January and February 2025. The Government has confirmed that market conditions and integration requirements remain unchanged since the completion of market research. The tools used include a GSA Market Research as a Service (MRAS) RFI, which is similar to the SAM Sources Sought but is specific to GSA contract holders.

Three companies responded to the MRAS RFI, two of which requested inclusion on the Interested Vendors List. After review of the responses and coordination with technical personnel, Volpe determined that Phase II must align precisely with Phase I design and installation decisions (including system configuration, integration points, sequencing decisions, and site-specific implementation), and that limiting consideration to Concentric for Phase II is necessary to avoid substantial duplication of cost and schedule risk and is in the Government’s interest in economy and efficiency.

Phase I was competed among all 31 available PACS Schedule vendors in accordance with applicable MAS ordering procedures, and Concentric was the only respondent and successful awardee. Concentric is also the firm that developed the approved design for the agency’s multi-phase security project. Concentric successfully completed all Phase I work, providing excellent performance, as noted in CPARS, and demonstrates a superior understanding of the complex integration requirements associated with the facility’s security architecture.

Because Phase II must align precisely with Phase I design and installation decisions, including the system configuration, integration points, sequencing decisions, and site-specific implementation developed and executed during Phase I, Volpe determined that limiting consideration to Concentric for Phase II is necessary to avoid substantial duplication of cost and schedule risk and is in the Government’s interest in economy and efficiency.

VII. Other facts supporting the justification.

Because Concentric designed the system, executed Phase I, and retains essential knowledge of the project’s underlying engineering and proprietary configuration, competing Phase II separately would:

Create unacceptable technical risks to security continuity;

Require duplication of design and integration efforts already completed under the existing task order; and Potentially compromise system integrity by introducing non-uniform installation and integration approaches.

During the work in Phase I, Concentric gained specific knowledge of the utilities and operations of the USMMA security force. Working with the USMMA Director of Public Safety, the conceptual operational procedure was developed and configured by Concentric for Phase II implementation. Certain integration details and field conditions encountered during Phase I implementation were not required deliverables under the Phase I contract and would require additional validation and reengineering if a new contractor were introduced. The design drawings for the entire effort were not fully updated at the completion of Phase I, and validation of key infrastructure points where Phase II connections must be made would be required if a new contractor were introduced. The Government personnel who oversaw the initial phase are no longer with the Government. Timely completion of Phase II is dependent upon continuity with Phase I implementation.

If another contractor were brought in to complete Phase II, the Government would incur additional transition costs for the contractor to (i) reverse engineer/validate Phase I integration decisions, (ii) update drawings, (iii) develop and validate operating procedures with USMMA Public Safety, and

(iv) complete re-submittals and coordination. These transition activities would not only increase costs but would likely extend performance beyond the required schedule; current funding for this effort expires at the end of FY2026.

Re-competition would introduce unacceptable delays due to required transition activities (site familiarization, reverse engineering of Phase I integration decisions, re-submittals, and additional coordination with USMMA), which would reasonably extend completion beyond the required operational timeline and create continued risk during the interim. These transition efforts would constitute substantial duplication of cost and would not result in offsetting benefits sufficient to justify competition.

Given the nature of the work and its integration with Phase I design and installation decisions, awarding Phase II to a contractor other than Concentric would likely require significant re-engineering/reverse engineering and duplication of effort, creating substantial additional cost and schedule risk inconsistent with the Government’s interest in economy and efficiency. Therefore,