CUI_YPG JA 2025_125_Redacted_.pdf

Control Number: MICC 2025-125

a. Background:

1) The current contract, W9124R-18-C-0001, was awarded on 30 May 2018 to TRAX for a four-year period of performance (base plus three option years). The MTSS contract supports approximately and directly supports fielding of the latest technology improvements for the Army’s critical warfighting equipment. The primary mission of YPG is to conduct integrated OT/DT systems testing and evaluation in natural environments. Testing in the natural environments often exposes performance deficiencies that artificial simulation methods fail to expose.

2) On 5 August 2025, the Army awarded a contract to TRAX following a competitive bidding process. Southwest Range Service, LLC subsequently filed a protest with the Government Accountability Office (GAO) under docket no. B-423843.1 on 20 August 2025, disputing the award. The Procuring Contracting Officer issued a stop-work order to TRAX on 22 August 2025. A decision from the GAO is anticipated by 28 November 2025 and a 3.5-month extension from 1 October 2025 through 14 January 2026 will accommodate the protest review process. TRAX, the incumbent, is the only source possessing the trained personnel assets, management team, institutional knowledge, equipment management, and other resources to continue the ongoing and upcoming test requirements at three different test centers for the proposed extension period. Delays in extending the contract would result in serious injury to the Government, financial and other, if not executed. The MTSS contract supports that will be significantly impacted by any lapse in contract support. Calculating the costs of testing delays is not feasible. These tests directly support fielding of the latest technology improvements for the Army’s critical war-fighting equipment.

b. Alternatives:

1) Suspension of Contract Support. The MTSS requirements are ongoing and critical to mission accomplishment. Suspension of contract support will cause critical disruption to the ATEC’s mission and delay or stop the fielding of critical equipment for the Warfighter resulting in a degradation of Readiness. Therefore, this alternative is not viable.

2) Use of In-House resources. ATEC lacks sufficient manpower, technical expertise, and resources to perform the required MTSS functions. The United States Army does not contemplate acquiring adequately trained personnel within the Government in the future. Attempting to initiate actions to increase the Government workforce to accomplish this mission would take years and result in mission failure during the time required to adequately recruit and staff a trained workforce. Therefore, this alternative is not viable.

3) Conduct a competitive acquisition for a bridge contract. A competitive bridge contract with a value would require a minimum of one-year to solicit, evaluate, negotiate, award a new contract, phase-in a new contractor, transfer and account for the large inventory of Government Furnished Property (GFP), verify data, obtain security clearances and allow for familiarization with ongoing tests. With less than one month until the expiration of the current contract, there is insufficient time to accomplish a competitive award. Additionally, there would be significant degradation in test support as the contractor would be required to transition during testing. Any contractor other than the incumbent does not have sufficient equipment or trained manpower readily available on short notice to seamlessly assume the performance of these ongoing tests and services. An award to any other source would result in unacceptable delays ranging from 12-18 months in fulfilling the YTC’s DT/OT mission.

Over 23,000 lines of GFP valued at over and spread over 3,000 square miles of the YPG test range would have to be inventoried and properly transferred.

Further, this action is a temporary solution to changeover this requirement to the competitive award. Therefore, this alternative is not viable.

c. Impact if justification is not approved: Disapproval of the J&A will result in a lapse in service and ATEC’s failure to execute its OT/DT testing mission in accordance with the approved testing schedule and create barriers to efficient processes and the risk of impacting the outcomes and data collected from various test missions. As discussed above, attempting to compete this requirement would result in unreasonable delays and would cause mission failure for YPG due to the lack of services.

7. Efforts to Obtain Competition: In accordance with FAR 5.202(a)(2), this action will not be synopsized 5.

a. Effective competition: Because this is a sole source action, effective competition is not applicable.

b. Subcontracting competition: Subcontracting goal achievement is an evaluated element for award fee and TRAX has met established goals. TRAX’s established purchasing procedures include stringent guidelines for competing subcontracts. Any requirements that they deem to be sole source are justified and approved by the Government prior to issuance of the subcontract. A review of TRAX’s subcontract files is included in the monthly contract surveillance reports. The Government will request a revised subcontracting plan covering the extension period and will coordinate review of this document with the Small Business Professional and Procurement Center Representative as required by FAR 19.705-4(d)(7), reviewing the subcontracting plan.

The approved plan revision will be incorporated and made a material part of the contract as required by FAR 19.705-5(a)(5), Awards involving subcontracting plans, prior to award of the modification. A copy of the award document will be provided to the Area Director for the Small Business Administration (SBA) Area Office where the contract will be performed as required by FAR 19.705-6(a) Post award responsibilities of the contracting officer, and a copy of the final negotiated subcontracting plan will be provided to the SBA Procurement Center Representative (PCF) as required by FAR 19.705-6(c).

8. Actions to Increase Competition:

a. This is an interim action to allow continued performance with the incumbent contractor during the time necessary to address the response to the GAO protest received on 20 August. The follow-on requirement was solicited as a competitive full and open action. Four vendors responded to the solicitation.

b. The protested acquisition was solicited as a competitive full and open action.

Four vendors responded to the solicitation with proposals. The Government’s market research and solicitation efforts to increase competition included:

1) The issuance of three Requests for Information (RFI) (one to solicit comments on the performance requirements, one soliciting input on small business subcontracting, and one seeking industry’s response to 19 questions related to the acquisition.

2) Contacted GSA to identify potential interest.

3) Conducted an Industry Day (16 attendees); reviewed Government databases (like GSA) for information on same /similar contracts and their contractors.

4) Conducted an internet search which identified 6 potential vendors.

9. Market Research: Extensive market research has been conducted for the follow-on requirement and competition was achieved. No further market research was performed for this extension. The extension of service is due to a protest to the follow-on contract and the Government’s need for continued performance of these critical services during the protest resolution period.

10. Interested Sources: No other vendor expressed interest in the bridge other than

TRAX.

11. Other Facts:

a. Procurement History: The MTSS requirement has historically been awarded to large businesses under full and open competitive procedures with a CPAF contract type.

b. Solicitation, W9124R-13-R-0001, received four proposals and award W9124R- 14-C-0004 was made to Jacobs Technology, Inc. (Jacobs) on 10 September 2014.

TRAX filed a protest with the GAO (Docket B-410441.1) on 23 September 2014 disputing the award. A suspension of work notice was issued to Jacobs the same day.

Over the next four years, the Army took corrective action in response to the protest with

Approval

Based on the foregoing justification, I hereby approve the procurement of Mission Test Support Services on other than full and open competition basis pursuant to the authority of Title 10 U.S.C. 3204(a)(2) as implemented by FAR Part 6.302-2 - Unusual and Compelling Urgency. The estimated value of the contract modification is for a 2.5-month base period of performance plus a one-month option from 1 October 2025 through 14 January 2026. The approval is subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.