W911SG25RA009_Consolidation_DF_Fort Bliss_SWM_Redacted-.pdf

MAR 22

CONSOLIDATION OF CONTRACT REQUIREMENTS DETERMINATION

FOR THE DIRECTORATE OF PUBLIC WORKS (DPW) SOLID WASTE

MANAGEMENT SERVICES, FORT BLISS, TEXAS

(As prescribed by FAR 7.107-2 and AFARS 5107.107-2)

1. Rationale: Consolidation will provide substantial benefits to the Government.

However, due to the potential impact on small business participation, before pursuing an acquisition that is a consolidation of requirements with an estimated total dollar value exceeding $2 million, a written determination shall be made that the consolidation is necessary and justified in accordance with 15 U.S.C. 657q, after ensuring that:

(a) Market research has been conducted.

(b) Any alternative contracting approaches involving a lesser degree of consolidation have been identified;

(c) The determination is coordinated with the agency's Office of Small Business Programs;

(d) Any negative impact by the acquisition strategy on contracting with small business concerns has been identified; and

(e) Steps are taken to include small business concerns in the acquisition strategy.

2. Introduction: MICC-Fort Bliss plans to solicit offers SWM services at Fort Bliss, TX and has conducted market research that demonstrates consolidation of this procurement is both necessary and justified. FAR 2.102 defines consolidation as (1) a solicitation for a single contract, a multiple-award contract, a task order, or a delivery order to satisfy: (i) two or more requirements of the Federal agency for supplies or services that have been provided to or performed for the Federal agency under two or more separate contracts, each of which was lower in cost than the total cost of the contract for which offers are solicited; or (ii) requirements of the Federal agency for construction projects to be performed at two or more discrete sites; or; (2) separate contract as used in this definition, means a contract that has been performed by any business, including small and other than small business concerns.

3. Description of the Procurement Action: The Installation SWM Services requirement supports the critical Installation Management Command (IMCOM) Mission by supporting the Installation Management Campaign Plan's (2025 and Beyond) Line of Effort 2 - Effective Base Operations (BASOPS) Support Services. The Installation SWM Services requirement originates from a need to ensure Fort Bliss meets the Contractor Logistic Support (CLS) 403 requirement, the requirements under Individual State Regulation (ISR) 403 and State and Federal regulations for solid waste collection and competitively procured as a HUBZone set-aside. In accordance with FAR 19.203(c), a requirement accepted into the 8(a) program must remain within the program unless the Small Business Administration (SBA) releases it per 13 CFR Parts 124, 125, and 126.

Consolidating these requirements would remove from the HUBZone category, impacting the Government’s goal of 3% allocation to HUBZone.

MICC Fort Bliss recognizes the importance of small business participation and remains committed to fostering small business growth and diversity. Market research revealed an equal number of capable 8(a) and HUBZone vendors responded to the source sought notice, demonstrating strong interest and capability from both socioeconomic groups. However, consolidating these requirements under the 8(a) program would reduce HUBZone contract dollars, removing from the HUBZone category and impacting the Government’s HUBZone goal. To mitigate this reduction, MICC Fort Bliss has identified several construction contracts within our construction division that can be set aside for HUBZone small businesses, helping to offset the impact and ensure continued HUBZone participation. This approach not only supports the socioeconomic objectives under the 8(a) program, these additional HUBZone contract opportunities will help balance the government’s small business goals and simplifies the contract management.

5. Benefit Analysis: Consolidating the two contracts could achieve efficiencies by eliminating contractor and Government oversight labor redundancies. Utilizing a single contract and single quality control (QC) management system improves the waste stream analysis process, which improves route optimization and ensures properly sized containers to potentially reduce the quantity of scheduled container pick-ups. Improved QC and schedule coordination will also potentially ensure more material is recycled and less is sent to the landfill, which results in increased recycle revenue and reduced disposal and landfill costs/fees. A single contractor has more incentive to recycle since higher landfill diversion equates to lower landfill fees and operating costs.

The Fort Bliss recycling data table below shows that although annual pick-up quantities have increased, the weight of acceptable recyclable material has decreased.

Year Recycle Pick-ups Recycled Weight in Tons 2016 14,845 2,232 2017 15,127 2,138 2018 21,494 2,120 2019 24,594 1,961 2020 24,372 2,037 2021 24,540 1,974 2022 24,730 1,157

Coordinating optimization efforts is more difficult with separate contractors because separate contractors do not always agree on which containers or routes need to be adjusted. Separate contracts result in decreased awareness of the overall diversion effort because associated equipment and labor costs are not shared, and the waste

The cost table includes the items that will be reduced because of the consolidation, The projected total cost saving of over five years is substantial, as it not only lowers the overall cost of contracted services but also reduces the administrative burden on the Government by streamlining oversight and contract management.

The consolidation results in a reduction in personnel, equipment, and scheduled pickups, leading to decreased resources allocation for Government surveillances. This includes the potential elimination of one full time equivalent (FTE) dedicated to contract monitoring. The financial and administrative efficiencies gained offer clear, tangible benefits to the Government. Therefore, the consolidation should be considered “substantial” and advantageous moving forward with the consolidated acquisition strategy.

6. Alternative Contracting Approaches and Rationale for Rejection:

The Recycling and Refuse contracts have redundant requirements for pick-up and disposal of solid waste. The difference is the Recycling contract requires recyclable material to be separated from waste and sold at an off-base facility prior to disposal of the waste at a landfill whereas the Refuse contract only requires disposal of the waste at an approved landfill.

The contracting approaches are limited to:

1. Maintaining the status quo of separate contracts for waste disposal.

2. Pursue an Inter-Governmental Support Agreement (IGSA) within the Fort Bliss geographical area.

The Installation Solid Waste Management Services requirement will continue to be met, and the expected benefits will not change. As discussed in section 5 of this document, consolidation of the existing contracts provides substantial benefits with this option by:

a) Reducing labor and equipment inefficiencies and redundancies.

b) Enhancing quality control management and reducing the workload for

Government personnel responsible for administering the existing contracts.

c) Supports waste diversion goals by eliminating shared responsibilities between contractors and requires a single contractor to ensure route optimization and proper container sizes.

d) Improves efficiency by streamlining contract acquisition and administration, which reduces the workload by one (1) FTE.