W9127819F0037P00021_LSJ Tyndal AFB Phase I Modular Trailer Lease_Redacted.pdf

JUSTIFICATION REVIEW DOCUMENT – LIMITED SOURCES JUSTIFICATION (LSJ)

CONTROL #

Project/Equipment Modular Facility Lease and Dismantle/Removal, Phase I, Tyndall AFB, Florida

Authority: FAR 8.405-6(a)(1)(i)(b) AMOUNT

Prepared by:

Name: Sophia M. Chin

Telephone: 251-690-3349 Title: Contract Specialist

Contracting Officer

(See Sections 13-14 Below) Name: John C. Vandiver

Telephone: 251-441-5447 Title: Contracting Officer

Technical (See Section 11 Below)

Name: Steven E. Daniels Jr.

Telephone: 850-283-4305 Title: Project Manager

Requirements (See Section 12 Below)

Name: Steven E. Daniels Jr.

Telephone: 850-283-4305 Title: Chief, Tyndall Program Integration Office, Programs & Project Management Division

Signatures Are Required Below:

I have reviewed this justification and find it adequate to support other than full and open competition.

Deputy for Small

Business

Signature: Date: (See Signature)

Name: (See Signature) Telephone: (See Signature)

Project Manager (If no PM, use N/A)

Signature: Date: (See Signature)

NAME: Steven E. Daniels Jr. TELEPHONE: 850-283-4305

Office of Counsel (OC)

Name: (See Signature) Telephone: (See Signature)

Business Oversight Branch (BOB) Chief

Name: James K. Kiesling Telephone: 251-441-5591

Chief of Contracting

Office (CoCO)

Name: Carl Wade Telephone: 251-441-6501

DANIELS.STEVEN.

E.JR.

Digitally signed by

DANIELS.STEVEN.E.JR

Date: 2026.02.17 09:47:41 -06'00'

BRASFIELD.DAVID.CAR

LTON.JR.

Digitally signed by

BRASFIELD.DAVID.CARLTON.JR

Date: 2026.02.17 15:34:46 -06'00'

RODGERS.SONY

A.D.

Digitally signed by

RODGERS.SONYA.D.

Date: 2026.02.19 09:18:09 -06'00'

Date: 2026.02.19 13:33:15 -06'00'

Date: 2026.02.19 13:56:00 -06'00'

Limited-Sources Justification For

Other Than Full and Open Competition

1. Contracting Activity: U.S. Army Corps of Engineers (USACE), Mobile District, 100 Canal Street, Mobile, Alabama 36602.

2. Description of Action: Approval is requested for an out-of-scope modification to extend the period of performance by two years for firm fixed price task order W9127819F0037 for a Modular Facility Lease to support Phase I at Tyndall Air Force Base (AFB), Florida. The task order is currently funded with Air Force Operation and Maintenance (O&M) funding. Fiscal Year (FY) 2026 Air Force O&M funds are available for the first year of the extended period of performance requested by this Justification. Exercise of the additional requested option year will be dependent upon availability of Air Force O&M funding that is current at the time the options are exercised.

Contractor: Modular Management Group, Inc. (MMG) Cage Code: 46Y71 Address: 6602 Plaza Parkway, Fort Worth, TX, 76116-2400

3. Description of Supplies/Services: The modular facility supports the hurricane recovery effort at Tyndall AFB, Florida by providing office space for displaced Phase I employees while construction of new facilities is in progress. Due to its importance to National Security, it is essential that the AFB be returned to operational status as soon as possible. To accommodate this, temporary facilities were required to provide working space for the returning airmen. While efforts to repair the base have been underway since 2019, there was no confirmed time of completion on the repairs at the time of contract award. The repairs are behind schedule, and it is now expected that the repairs will require an additional two years for completion. The temporary leased facility consists of multiple modular trailers producing approximately 10,653 SF of administrative office space and housing up to 48 Government employees for Phase I. The original contract awarded to MMG provided for onsite construction of the modular facility and a base and four option lease periods that began 01 March 2019. The original contract was extended for two option lease periods that began on 01 March 2024. The Option Year 6 period ends 28 February 2026, but the new permanent facility is not complete. Therefore, the need for a temporary leased facility continues. In accordance with Department of the Air Force Guidance Memorandum to Department of the Air Force Instruction 32-1020 (Sep 2022), 14 years is the maximum allowable duration of use for Relocatable Facilities (RLFs) with Secretary of the Air Force (SAF) approval. A SAF memorandum dated 31 January 2024 approved an additional two years of a leasing arrangement, for a total of nine years. The requested modification will extend the period of performance by incorporating two additional one-year lease options, with the first of these, Option Year 7, beginning 1 March 2026, and the final, Option Year 8, ending 28 February 2028. The estimated cost for the two-year extension is as detailed below. The total contract value is increasing from

Table 1: Estimated Cost for Two-Year Extension

Period of Performance

Monthly Estimate

Annual Estimate

Option Year 5

03/01/2026 – 02/28/2027

Option Year 6

03/01/2027 – 02/28/2028

Total Estimate

4. Authority Cited: The statutory authority permitting acquisition of the requirement by other than full and open competition is FAR 8.405-6(a)(1)(i)(C) , ”[i]n the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedure. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.”

5. Reason for Authority Cited:

a. Background: On 10 October 2018, Hurricane Michael made landfall at Mexico Beach just to the east of the base. Air Force officials described the damage imparted to the base by the hurricane as “catastrophic”, with all the base’s facilities being declared “unlivable”. Task Order number W9127819F0037 under contract GS07F0222X was awarded on 11 December 2018 and was solicited unrestricted under GSA Federal Supply Schedule (FSS) Category 532490P, Lease/Rental of Pre-Engineered/Prefabricated Buildings and Structures to MMG to provide the installation of a modular facility with a base one-year lease, four one-year lease options, and option Contract Line Item Numbers (CLINS) to cover the dismantle/removal of the facility at the end of the contract term.

While efforts to repair the base were underway at time of award, there was no confirmed time of completion on the repairs. The current contract expires 28 February 2026;

however, the military construction projects this facility currently supports are behind and will not be completed for multiple years. A sample of the current ongoing construction projects this facility is supporting are listed below in Table 1. Some of these projects are on schedule while others have experienced delays. The reason for delay has varied project to project such as differing site conditions, user requested changes, and contractor non-performance.

The facilities of the Phase 1 contract provide office space for the 325 Civil Engineering (CE) maintenance group, the Air Force vehicle mechanic shop, and the Sand Dollar Inn.

New brick and mortar buildings are being built that will serve as an office for the occupants and will be complete 2026-2027. Failure to remain with the current contractor would create a significant logistical dilemma for the occupants. The customer would be required to unexpectedly relocate tenants around the AFB, for an unknown amount of time, with no feasible location to put them. Due to ongoing construction and rebuilding of facilities, there remains a shortage of available space to house tenants across Tyndall AFB until work on permanent facilities is completed.

Table 2: Ongoing Construction Projects at Tyndall AFB

Contract Number Project Title

W9127822C0023 DB Z5 CE_LRS Complexes W9127822C0008 Z1 F-35 Flightline Facilities W9127822C0011 DB Z2 OSS Radar/Firetruck Maint

W9127822C0012 DB Z3 WEG/HQ Maintenance Hngr Apron Fac.

W9127822C0004 DB Z3 WEG Subscale Drone Facility W9127822C0017 DB Z4 Site Devt. & Utilities PHs I & II

W9127823C0006 Z7 F-35 2PH Munitions Storage Facilities

W9127822C0007 DB Zone7 Munitions Storage Area 7000

W912HN21D3000

W9127822F0121 DB Z9 Marina

W912HN21D3000

W912HN21F3006 DB Z10 Tyndall Lodging

W912HN21D3000

W912HN22F3002

DB Z11 Chapel and Community Commons

W9127822D0047 W9127822F0175 DB Z12 Fire Station # 4

W9127822C0010 DB Z5 CE Maint. Shops & Storage Fac.

*This is not an inclusive list of all projects but a sample of some of the current ongoing construction projects.

b. Justification: The Government requires an immediate facility to house up to 48 personnel that are working across various critical projects for Tyndall AFB. This facility is already on site provided by MMG under the current expiring contract. Therefore, in the interest of economy and efficiency, the extension of the contract is a logical follow-on, as MMG can meet the Government’s minimum needs for an immediate facility without significant disruption. Award to any other source would result in both unacceptable delays and substantial duplication of costs that would not be recovered by competition based on the following:

1) An award to another contractor would disrupt operations at Tyndall AFB for 14 months (two months for MMG to tear down the current RLF, and a minimum of 8-12 months for a new contractor to construct the new RLF). Market research conducted by contacting other contractors (

) providing facilities at Tyndall AFB and MacDill AFB confirmed that there are still supply chain issues resulting from Covid and longer lead times for certain components, such as electrical panels and A/C units, which delay the manufacturing process.

2) There is limited space for temporary facilities on the AFB which has required temporary facilities to be relocated when they are in the way of construction.

Therefore, these facilities would have to be removed before a replacement facility could be installed in its location. The existing facility is owned by MMG.

Therefore, they are the only available source capable of leasing the existing facility remaining to the Government. There are no other means of fulfilling this requirement, on a competitive or non-competitive basis, without causing substantial harm to the USACE, the Air Force customer, and its missions. A 14-month displacement would delay the construction of rebuilding Tyndall AFB by delaying submittal responses and processing. Therefore, in the interest of economy and efficiency, MMG can meet the Government’s minimum need of immediately having facilities available and ready for use.

3) It is further determined that a procurement to any other contractor would result in a substantial duplication of cost. Any procurement with another contractor would require the Government to expend on the option for MMG to dismantle the current RLFs and an additional estimated for the installation and removal of a new RLF, which was the original cost for MMG to provide the RLF. The total cost to reprocure this contract would be approximately for the additional set up and tear down of buildings and is not expected to be recovered in competition. In addition to the to get a new building on site there would be additional costs of the rental period which are expected to match the costs to award to MMG.

Feasible Alternatives:

Reprocure the requirement by soliciting for a replacement facility/lease through competitive process. This alternative is rejected because it would not satisfy the government's requirement for an immediate facility. The tenant would need to vacate the current facility, and there is no alternate location available to house these mission critical functions until such time as a new facility and lease can be established. Additionally, the current facility would have to be removed in its entirety at the expiration of the contract on 28 February 2026. As further detailed in paragraph b.

Justification above, the limited space due to the ongoing construction does not allow for a new replacement facility to be placed until the existing facility is removed.

of the facility and its removal when the facility is no longer needed. Purchasing the modular facility offers a cost-effective solution but is not feasible for this Air Force customer for multiple reasons.

i. First, Air Force Civil Engineer Center (AFCEC) does not support the purchase of temporary facilities per Department of the Air Force Guidance Memorandum (DAFGM) to Department of the Air Force Instruction (DAFI) 32-1020 (DAFI32-1020_DAFGM2022-01, 8.3.1) because an RLF is used as a tool for meeting a temporary facility requirement and not a solution to an enduring facility requirement, nor does the AFB have a place to locate the RLF when construction has been completed.

ii. Second, RLFs may be used to satisfy facility requirements for response to disaster relief (DAFI32-1020_DAFGM2022-01, 8.4.2) and in advance of a future facility solution (a programmed MILCON or renovation project, personnel relocation, etc.)

(DAFI32-1020_DAFGM2022-01, 8.4.3). In this case, the RLF was procured to house personnel due to the destruction of Tyndall AFB from Hurricane Michael, and the rebuilding of Tyndall AFB has been authorized, and funds have been appropriated by Congress.

Therefore, the RLF may be retained in use only until construction of the permanent facility is complete.

iii. Finally, the continued operation and maintenance of the relocatable facilities is not feasible because in accordance with DoD policy, an RLF is a piece of general equipment used as a facility on a temporary basis and is specifically designed and constructed to be readily erected, disassembled, transported, stored and re-used.

(DAFI32-1020_DAFGM2022-01, 8.2).

3) USACE leases an Off-Base facility and relocates the current tenants. While this alternative was considered, it was rejected due to the following reasons:

i. A USACE Mobile District Supervisory Realty Specialist confirmed that it would take approximately six months to solicit for and execute a new lease for a facility of this size.

ii. In accordance with Executive Order 14222 "Implementing the President's Department of Government Efficiency Cost Efficiency Initiative”, the Office of the Secretary of Defense (OSD) intends to reduce administrative and warehousing lease cost by 30%. As such, all new government leases require OSD approval which would delay the process for leasing new a new facility.

iii. The AFB is located between two coastal resort towns, Panama City and Mexico Beach, FL, which do not have this type of commercial office space available, and there are no other alternative spaces available within a 12-mile distance of the AFB that is capable of housing the current tenants.

iv. This alternative would displace the current tenants until a new facility could be located and leased, as the current facility would have to be removed at the expiration of the contract on 28 February 2026.

d. Impact: This facility houses up to 48 Government personnel working across various projects for Tyndall AFB. Currently, Phase I has no space to relocate on Tyndall AFB. If the Government had to remove the current facilities and re procure through another contractor, it would result in non-recoverable costs to the Government of approximately which is the difference between the cost of extending the period of performance of the current contract by two years and de-mobilizing the current facility and reprocuring a new facility with a new contractor, and an estimated 14 months of downtime. If this LSJ is not approved, the customer would be displaced with no feasible place to relocate. This displacement would create various communication, organizational and logistical issues for the current occupants, the CE maintenance group and the Lodging administration, as neither of these entities have complete permanent structures to house their operations. Both entities are necessary for the daily operations at Tyndall

AFB.

6. Market Research: A Special Notice W9127826L002 was posted to GSA eBuy and SAM.gov on 14 October 2025 with a response date of 29 October 2025, which stated the Government’s intent to extend the current contract and to determine if any interested parties were available to perform the requirements of this LSJ. No responses were received from the Notice posted on SAM.gov. Only one response was received from the Notice posted on GSA eBuy which provided a capability statement only with no specific information regarding the contractor’s capability to perform this requirement. As discussed in paragraph 6.a. above, there are 31 vendors listed under the GSA FSS Category this award was made under. None of those vendors responded to the special notice.

9. Interested Sources: Based on the market research results, no other qualified sources, other than MMG, have expressed interest in this action.

10. Other Facts: Discuss any other facts supporting the use of other than full and open competition, such as the following:

a. Procurement history:

(1) Contract number and date of the last award: W9127819F0073 awarded on 11 December 2018.

(2) Competitive status of this action: This action was initially a competitive GSA FSS award.

b. Other facts: N/A

7. Technical Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Name: Steven E. Daniels Jr.

Title: Project Manager

Date:

See Signature

Signature

8. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Name: Steven E. Daniels Jr.

Title: Chief, Tyndall Program Integration Office, Programs and Project Management Division

9. Best Value Determination: I hereby determine that the anticipated cost to the Government for this order provides the best value to the government. Pricing review will be based on maintaining the same or lower lease rates than those originally proposed, reviewed and evaluated for the award of task order no. W9127819F0037, which are still considered to be fair and reasonable.

Name: John C. Vandiver Title: Contracting Officer

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Name: John C. Vandiver Title: Contracting Officer

DANIELS.STEVEN

.E.JR.

Digitally signed by

DANIELS.STEVEN.E.JR.

Date: 2026.02.17 09:48:37 -06'00'

DANIELS.STEVEN.E

.JR.

Digitally signed by

DANIELS.STEVEN.E.JR.

Date: 2026.02.17 09:53:39 -06'00'

Digitally signed by

VANDIVER.JOHN.C.

Date: 2026.02.19 11:05:35 -06'00'

Digitally signed by

VANDIVER.JOHN.C.

Date: 2026.02.19 11:06:11 -06'00'

Approval

Based on the foregoing justification, I hereby approve limiting the sources in the extension of the lease and dismantle/removal of modular facility from Modular Management Group, Inc. on an other than full and open competition basis pursuant to the authority of 41 United States Code (U.S.C.) 4106(c) as implemented by FAR 8.405-6(a)(1)(i)(C) and pursuant to the authority of FAR 8.405-6(d)(1) in the estimated amount of . The approval is subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Approved By:

Date: See Signature

JOHN C. VANDIVER

Contracting Officer U.S. Army Corps of Engineers, Mobile District

Digitally signed by

VANDIVER.JOHN.C.

Date: 2026.02.19 11:06:35 -06'00'