Consolidation Determination DCRF C2CRE-B 20May2026 Redacted.pdf

CONSOLIDATION OF CONTRACT REQUIREMENTS DETERMINATION FOR

Contractor Logistics Support (CLS) for the JPM CBRN Integrated Early Warning (IEW) Defense CBRN Response Force (DCRF) and Command & Control CBRN Response Element (C2CRE-B) Missions

(As prescribed by RFO FAR 7.107 and AFARS 5107.107)

1. RATIONALE

Consolidation may provide substantial benefits to the Government. However, because of the potential impact on small business participation, before conducting 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 that would involve a lesser degree of consolidation have been identified;

(c) The determination is coordinated with the agency's Office of Small Disadvantaged Business Utilization or the 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

US Army Contracting Command Edgewood Division plans to solicit offers for Contractor Logistics Support (CLS) for the Joint Program Manager for Chemical, Biological, Radiological, Nuclear, and Explosives (JPM CBRN) Integrated Early Warning (IEW) program office and has conducted market research that demonstrates consolidation of this procurement to be both necessary and justified. FAR 2.102 defines consolidation as a solicitation for a single contract or task order to satisfy two or more requirements that have been provided to or performed for the Federal agency under two or more separate contracts. This action will consolidate requirements previously met by two separate Task Orders.

3. DESCRIPTION OF THE PROCUREMENT ACTION

This action will establish a single Task Order (TO) to provide comprehensive Contractor Logistics Support (CLS) for the Army National Guard Bureau (NGB) C2CRE-B mission and the active-duty Defense CBRN Response Force (DCRF) mission. The requirement will be competed as a single TO using Fair Opportunity procedures under the JE-CLaSS II IDIQ contract. The proposed North American Industry Classification System (NAICS) code is 811210 – Electronic and Precision Equipment Repair and Maintenance, with a corresponding size standard of $34M.

The primary objective is to ensure lifecycle sustainment for a wide range of Commercial Off-the- Shelf (COTS) equipment sets, ensuring the highest state of readiness for supported units. The proposed contract type is a Firm-Fixed-Price (FFP) with cost-reimbursable elements for travel and parts. The period of performance will consist of a base year with multiple option years. The two incumbent Task Orders being consolidated were both performed by small businesses. This consolidated action merges their scopes of work into a single, comprehensive requirement. The key tasks include program management, logistics information system (LIS) operation, Contract Vehicle: Task Order under JE-CLaSS II IDIQ contract. The market research indicates there are adequate sources available under the JE-CLaSS II IDIQ to provide CLS for the DCRF and C2CRE-B missions.

Contract type: Firm Fixed Price and Cost-Reimbursable for Travel, Materials and Other Direct Costs (ODCs).

Competition: Small Business set aside within JE CLaSS II within “Domain 1”.

Market research indicates that the requirement is within scope of the current JE-CLaSS II IDIQ contract. JE-CLaSS II IDIQ contractor pool has several experienced contractors that possess the capability to provide the required services. Based on this market research the JE-CLaSS II IDIQ contract is recommended to provide a competitive environment and lower price.

5. ALTERNATIVE CONTRACTING APPROACHES AND RATIONALE FOR

REJECTION

Two alternative contracting approaches were considered.

1- The first approach was to maintain the status quo by awarding two separate, smaller Task Orders to support the DCRF and C2CRE-B missions independently. This approach would continue the pre-existing acquisition strategy.

2- The second approach considered was to separate the tasks by function, meaning to award one task order for the support of the DCRF and C2CRE-B missions and one task order for warehousing.

However, after analysis, these alternatives were rejected because it fails to deliver the significant qualitative and quantitative benefits achievable through consolidation. Continuing with separate contracts perpetuates several negative impacts and forgoes key efficiencies, as detailed below.

Price/Cost: Forgoes economies of scale in the procurement of parts, consumables, and replacement equipment. It also necessitates duplicative contractor overhead and administrative costs.

Quality: Creates inconsistencies in maintenance standards, training delivery, and data reporting between the two missions. This fragmentation leads to a disjointed readiness posture and complicates the Government's ability to maintain a unified operational picture.

Administrative Efficiency: Doubles the Government's contract administration and oversight burden. It requires managing two contractor relationships, two separate warehouse facilities, two sets of invoices and reports, and conducting separate performance assessments, increasing the administrative cost and workload for Government personnel.

Acquisition Cycle Time: Requires the Government to conduct and manage two separate procurement actions, increasing the overall acquisition cycle time and delaying the implementation of a unified logistics solution.

Lack of Standardization: Two contractors result in different maintenance procedures, training programs, and data tracking within their respective Logistics Information Systems (LIS). This hinders the Government's ability to maintain a single, integrated readiness picture.

Continued use of two separate contracts: This alternative was rejected because it fails to deliver the significant qualitative and quantitative benefits achievable through consolidation. Continuing with separate contracts perpetuates several negative impacts, forgoes key efficiencies, and introduces unnecessary risk and operational friction that degrade overall mission readiness.

The conclusion to consolidate is directly driven by the operational necessity of a unified logistics chain for CBRN response forces. Managing DCRF and C2CRE-B logistics separately creates a disjointed supply chain, disjointed LIS data, and inconsistent equipment readiness standards. The facts demonstrate that a single logistics provider is required to achieve the standardized readiness picture and economies of scale mandated by current operational tempos. The benefits of this consolidation are not limited to administrative or personnel cost savings alone. As detailed above, the primary drivers include significant qualitative improvements to mission readiness, standardized data tracking, and tangible economies of scale in materiel procurement.

In summary, the facts leading to the conclusion to consolidate are driven by the operational necessity of a unified logistics chain. The alternative of separate contracts introduces unacceptable inefficiencies, increased costs, and risks to mission readiness that are mitigated through a single, comprehensive support contract.

6. CONSOLIDATION BENEFIT ANALYSIS

The consolidation of these requirements is projected to yield substantial benefits that are critical to the agency's mission success. The benefits, analyzed in accordance with the DoD Benefit Analysis Guidebook, are detailed below and are expected to substantially exceed those that could be derived from the alternative approach of separate contracts.

a. Qualitative Benefits (Critical to Mission Success) These benefits represent improvements in performance and efficiency that are vital to the successful execution of the DCRF and C2CRE-B missions.

Enhanced Mission Readiness & Interoperability: By placing all sustainment activities under a single contractor, the Government ensures a unified and consistently high state of readiness. A single point of accountability eliminates the risk of support gaps between the two forces. This directly enhances the interoperability and operational effectiveness of these critical national response assets.

Improved Technical Performance & Standardization: Consolidation enables the implementation of a single, standardized Logistics Information System (LIS), uniform maintenance and calibration procedures, and a consistent training program. This improves the quality and reliability of logistics support and provides the Government with standardized data for better decision-making.

Centralized Inventory & Supply Chain Management: A single contractor operating one warehouse provides total asset visibility over the entire inventory. This streamlines the supply chain, reduces the risk of parts shortages, optimizes the management of GFP, and allows for more effective handling of equipment obsolescence, ensuring equipment is always mission capable.

b. Quantitative Benefits (Cost & Administrative Savings) The quantitative benefits are projected to be equivalent to or greater than 10% of the estimated contract value, meeting the threshold for "substantial benefits" under RFO FAR 7.107-2(c)(3)(i).

For an estimated contract value of $25M over five years, the required savings threshold is $2.5M.

Reduction in Administrative & Oversight Costs: By moving from two contracts to one, the Government eliminates the need to administer a second contract and oversee a second facility.

The total estimated savings from this efficiency is $300,000 as described below:

- By moving from two contracts to one, the Government eliminates the need to administer a second contract and oversee a second facility. Consolidation reduces the time required for redundant monthly status report submissions, monthly program review meetings, Contract Data Requirements List (CDRL) reviews, and travel to multiple warehouses. We estimate this saves approximately Full-Time Equivalent (FTE) annually across key government program positions Program Manager, Logistics Lead, and Contracting Officer's Representative (COR). Based on an estimated fully burdened annual salary of

, this yields annual savings of $30,000 and 5-year savings of $150,000.

- Within the Program office, the COR relies on administrative staff to conduct monthly warehouse inventories, sign for received shipments on a weekly or more frequent basis, go on travel to oversee the contractor, plus attend all the same meetings mentioned above.

Total time for the administrative staff to support is another FTEs annually with an estimated fully burdened salary of , which yields annual savings of $30,000 and 5-year savings of $150,000.

Elimination of Duplicative Contractor Overhead: The consolidated contract will eliminate a redundant set of contractor-billed overhead costs (e.g., project manager, warehouse manager).

The total estimated savings from eliminating this overhead is $450,000 as described below:

Consolidation will allow for oversight of one contract versus two, reducing the contractor management headcount without impacting the direct labor support of the mission. If the Government maintains two contracts, the contractor must bill for redundant positions—such as two Project Managers, two Warehouse Managers, two Shipping Coordinators, etc. which significantly contributes to the overall overhead cost. Eliminating these redundant management roles reduces overall overhead by approximately FTEs each year. Based on an estimated

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(b) (5) average burdened salary cost of per year for these roles, this results in annual savings of $90,000 and 5-year savings of $450,000.

Economies of Scale in Procurement: By combining the procurement volume for parts and consumables, the contractor can negotiate better pricing, resulting in direct cost savings to the

Government. The total estimated savings from procurement efficiencies is $825,000 as described below:

- By combining the procurement volume for parts and consumables, the contractor can negotiate better pricing, resulting in direct cost savings for the Government. A conservative estimate of savings on a historical procurement budget of annually results in $135,000 in yearly savings, totaling $675,000 over five years.

- Furthermore, consolidating to a single inventory eliminates the need to hold duplicated safety stock and spare parts at two separate locations, and reduces the total volume of shipping materials required. This reduction in redundant inventory yields an additional estimated savings of $30,000 per year, totaling $150,000 over five years.

Efficiencies in combining warehouse space: Economy of scale warehouse spacing becomes cheaper per square foot when using a larger warehouse. This includes reduction in cleaning costs, only needing a certain amount of infrastructure (bathrooms, office space), security, and utilities.

The total estimated savings from warehouse efficiencies is $1,000,000 as described below:

Consolidating to one primary facility allows the contractor to significantly reduce facility costs.

While the net square footage required for actual equipment storage remains the same, combining the footprint eliminates the "dead space" and duplicative infrastructure required when operating two separate warehouses (e.g., eliminating a second forklift charging area, redundant meeting/break rooms, duplicative administrative office spaces, and a second set of utilities/security). Additionally, larger warehouses benefit from a lower cost per square foot

) compared to smaller warehouses ( ). Eliminating this redundant infrastructure and securing a lower rate saves the government up to $200,000 per year, or $1,000,000 over five years.

Total Estimated Savings: The aggregate of the quantitative benefits from efficiencies described above total $515,000 annually or total estimated savings of $2,575,000 for five years life of the contract.

This figure represents 10.30% of the total estimated contract value ($25M). In accordance with FAR 7.107-2(d)(1) and 7.107-2(c)(3)(i), benefits that are quantified in dollar amounts are considered substantial if the anticipated financial benefits are equivalent to ten percent of the estimated contract value (for contracts $94M or less).

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