26BA015 Consolidation DF ORWA_CLAM_2026_Redacted.pdf

DEPARTMENT OF THE ARMY

DETERMINATION AND FINDINGS

CONSOLIDATION MEMORANDUM

FOR

FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

Procurement Sensitive – For Official Use Only

The Federal Acquisition Regulation (FAR) 2.101 defines “Consolidation or consolidated requirement” as follows:

“Consolidation or consolidated requirement --

(1) Means 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 (Services)

(ii) Requirements of the Federal agency for construction projects to be performed at two or more discrete sites. (Construction) Consolidation of requirements with a total value exceeding $2 Million must be justified.

(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.”

I have reviewed this requirement and associated market research and determined that consolidation, in accordance with 15 U.S.C 657q, FAR 2.101, RFO FAR 7.107-2, AFARS 5107.107-2, and UAI 5107.107 is both necessary and justified. My review resulted in the following findings:

FINDINGS

1. Introduction: U. S. Army Corps of Engineers (USACE), Portland District (NWP), plans to solicit bids for a single Firm-Fixed-Price (FFP) Construction Contract for Oregon and Washington Clamshell Maintenance Dredging 2026, for performance in Oregon and Washington. The dredging project includes mandatory and optional work at a total of fourteen (14) locations. Locations include: four in Oregon (Chetco River, Port Orford, Skipanon River, and Oregon Slough) and ten in Washington (Baker Bay, USCG Station Cape Disappointment, Chinook, Skamokawa Creek, Wahkiakum Ferry Channel, Willow Grove Boat Basin, Longview Turning Basin, Old Mouth Cowlitz, Port of Longview, Old Mouth Cowlitz River, and the Columbia River at Vancouver Lower Anchorage). As the Port of Longview and Willow Grove Boat Basin work is “Work For Others” via MOA with the Port, for purposes of this D&F, Willow Grove Boat Basin and Port of Longview work will be combined to be considered one area in Longview. The estimated contract value is $11.63M including all optional CLINs and excluding any contingency. The primary North American Industry Classification System (NAICS) code that will be used under this contract is 237990 (Dredging and Surface Cleanup Activities). Current market research demonstrates that consolidation of these procurements is both necessary, justified, and will satisfy USACE requirements for construction projects performed at two (2) or more discrete sites. Market research associated with this procurement is attached.

2. Description of Procurement Action:

a. Project Description: The requirements of the proposed FFP Construction Contract include maintenance clamshell dredging at fourteen (14) authorized project sites, as identified in the previous paragraph. Approximately 488,100 cubic yards will be dredged under mandatory and optional line items within the fourteen (14) project areas. Dredged material will be placed at designated in-water placement sites to include ocean and river disposal.

The proposed solicitation will be issued as a Total Small Business Set-aside, Invitation for Bids (IFB). The total estimated award value for the contract is $11.63M for all CLINs. The proposed contract period of performance will be from 1 May 2026 to 31 January 2027.

The proposed solicitation is for clamshell dredging work. A clamshell dredge consists of a crane mounted onto a barge that uses a mechanical bucket to dig material from the bottom and then places the material

CONSOLIDATION MEMORANDUM

FOR

FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

into a scow located nearby. A scow is a barge that is configured like an open box to hold the material until it is towed to the material placement site by an attendant tug. These locations cannot be effectively or safely dredged with a hopper dredge. The constraints of channel width, the configuration of the channels, and the limited project depths make hopper dredging either very difficult or a very ineffective method to accomplish this work. With these constraints and the need to use a placement site one to four miles from the dredging site, the most effective way to dredge these projects has been with a clamshell dredge paired with a bottom dump scow.

b. Acquisition Strategy/Procurement Summary: The PDT has determined that a project delivery method of invitation for bids (IFB) solicitation, and the award of a single firm fixed-price (FFP) “C” contract that consolidates the requirements for dredging at a total of fourteen (14) project locations in Oregon and Washington consisting is the best means to serve the projects’ missions. The contract will be funded by a single FY26 O&M funding stream with six (6) individual funding accounts, and one non-federal stream to be issued by The Port of Longview. The overall project consists solely of maintenance dredging work.

Small Business is the set-aside being utilized for this acquisition.

c. Applicability of Consolidation: 15 U.S.C. §657q and FAR 2.101 defines consolidation or consolidated requirement as 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. The definition applies to this procurement because one consolidated “C” contract will be used to perform dredging, which is a construction activity, at multiple discrete project sites.

d. Procurement History: The project locations consolidated under this requirement have been dredged with contracted clamshell dredges since 2006. Prior to 2006, the USACE dredge SANDWICK dredged the sites included in this requirement, which allowed more significant but less frequent mechanical dredging to be done by contracted dredges. Records show that the SANDWICK last dredged in 2002.

However, since 2002, the government has excessed the equipment, and as such the dredge is no longer in use by USACE. Historical mechanical dredging contracts since FY 2006 that included the projects to be dredged under this requirement are identified in the table below. These mechanical dredging requirements were solicited as FFP Invitation for Bids (IFB). Most of these requirements were awarded to small businesses.

Table 1 Historical Clamshell Dredging Contracts

Contract Contractor Business Size

Locations Included in Contract

Total Contract Price

W9127N16C0029 J.E. McAmis Small Port Orford, Charleston, Baker Bay, Skipanon

$2,955,000.00

W9127N17C0017 J.E. McAmis Small Baker Bay $506,200.00 W9127N17C0033 J.E. McAmis Small Port Orford, Baker Bay, Chinook $2,019,100.00

W9127N18C0072 J.E. McAmis Small Rogue River, Port Orford, Baker Bay, Astoria Turning Basin

$2,727,500.00

W9127N18C0084 J.E. McAmis Small Longview Turning Basin $90,750.00 W9127N19C0020 J.E. McAmis Small Port Orford, Charleston, Winchester Bay, Baker Bay, Astoria Turning Basin, and Skipanon

$2,625,000.00

CONSOLIDATION MEMORANDUM

FOR

FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

W9127N19C0021 J.E. McAmis Small Skamokawa Creek, Westport Slough, Wahkiakum Ferry Crossing, Longview Turning Basin, Old Mouth Cowlitz, Oregon Slough, and Vancouver Turning Basin.

$4,426,200.00

W9127N20C0020 J.E. McAmis Small Chetco River, Rogue River, Port Orford, Charleston Harbor, Baker Bay, Chinook, and Longview Turning Basin

$3,728,441.76

W9127N21C0033 HME

Construction

Small Port Orford, Baker Bay, Lake River, Old Mouth Cowlitz, Longview Turning Basin

$1,394,590.00

W9127N22C0014 American Construction

Small Port Orford and Skipanon River, Baker Bay and Chinook

$2,903,500.00

W9127N23C0010 HME

Construction

Small Port Orford, Winchester Bay, Depot Slough, Astoria, Baker Bay and Longview

$4,827,750.00

W9127N24C0013 Dutra Group Large Port Orford, Charleston Channel, Baker Bay, Chinook, Port of Longview, Longview Turning Basin, Old Mouth Cowlitz, Vancouver Lower Anchorage

$7,639,555.00

W9127N25BA002 HME Small Port Orford, Charleston Channel, Baker Bay, Chinook, Port of Longview, Longview Turning Basin, Kalama Anchorage, Vancouver Anchorage, Old Mouth Cowlitz

$8,677,000.00

e. Requirements Being Consolidated: As stated above in section 2 (a) Project Description, maintenance mechanical dredging in fourteen (14) locations is being consolidated into a single firm fixed-price (FFP) contract. The following are the associated dollar values inclusive of mobilization costs for each requirement’s total dredging need: Dredging 9,000 cubic yards at Chetco River, OR, has an estimated value of $153,000.00. Dredging 20,000 cubic yards at Port Orford, OR, has an estimated value of $380,000. Dredging 90,000 cubic yards at Baker Bay, WA has an estimated value of $1,680,00.

Dredging 15,000 cubic yards at USCG Station Cape Disappointment has an estimated value of $275,000.

Dredging 100,000 cubic yards at Chinook, WA has an estimated value of $1,970,000. Dredging of 120,000 cubic yards at Skipanon River has an estimated value of $2,130,000. Dredging of 30,000 cubic yards at Skamokawa Creek, WA has an estimated value of $530,000. Dredging of 7,000 cubic yards at Wahkiakum Ferry Channel, WA has an estimated total value of $123,000. Optional dredging of 3,100 cubic yards at Willow Grove Boat Basin, WA has an estimated total value of $58,200. Dredging of 5,000 cubic yards at Longview Turning Basin, WA has an estimated value of $146,000. Optional dredging of 14,000 cubic yards at Port of Longview, WA has an estimated total value of $430,000. Dredging of 13,000 cubic yards at Old Mouth Cowlitz, WA has an estimated total value of $263,000. Dredging of 55,000 cubic yards at Lower Vancouver Anchorage, WA has an estimated total value of $1,050,000. Dredging of 7,000 cubic yards at Oregon Slough Lower, OR has an estimated total value of $131,000. Total cost of all dredging is estimated to be $9,319,200.00.

CONSOLIDATION MEMORANDUM

FOR

FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

and the estimated cost of mandatory mobilization and demobilization for the consolidated contract to be $2,000,000, plus optional incremental mobilization and demobilization CLINs of $100,000, and optional

CLINs for third party surveys totaling $210,000; total contract cost of $11,629,200.00. Conditional hydro-surveys taken in the authorized navigation channels indicate that there is more material above the federally authorized project depth in each location than the fiscal year funding available for this requirement will allow to be dredged. Therefore, the contract quantities and value will not increase appreciably even if there is additional in-fill into the channels.

f. Rationale for Consolidation: Utilizing a contract that consolidates dredging requirements of fourteen

(14) different projects within the region into one contract is necessary to meet mission objectives. It will ensure that successful completion of critical dredging will be performed at all needed sites within the environmentally coordinated work windows. A single contract will ensure cost effective use of limited project funds by reducing acquisition costs by between $30,594 (Alt 1) and $397,723 (Alt 2) depending on level of reduced consolidation, as well as reducing contractor mobilization and demobilization costs by up to an estimated $894,537 (Alt 1) to $7,500,000 (Alt 2), again depending on level of reduced consolidation, in comparison to no consolidation, and minimizing contract support and administration costs by up to $392,419 (Alt 1) and $2,168,793 (Alt 2) based on estimates submitted by Channels and Harbors Dredging Contracts group (See table 6 for cost breakdown). Therefore, and as further discussed below, the quantifiable benefits of consolidation exceed the threshold set forth in RFO FAR 7.107-2(c)(3)(i) and the expected benefits of the consolidated approach are critical to the agency’s mission success.

It would be heavily time/effort consuming in terms of the necessary resources required to write, advertise, and award two or more separate contracts quickly enough to complete the required dredging work within the environmentally coordinated work windows which have an overall start and end date of 1 May 2026 (Port Orford) and to 31 January 2027 (Kalama and Vancouver / Columbia River projects).

Furthermore, six (6) work locations (Wahkiakum Ferry Channel, Willow Grove Boat Basin, Old Mouth Cowlitz, Longview Turning Basin, Port of Longview, and Oregon Slough Lower) have a relatively small dredging requirement in terms of total required cubic yardage to be dredged. If awarded as a separate contracts, the projects would bear the full cost of mobilization and demobilization. Given the amount of funding currently available, neither project would have sufficient funding to execute the mission.

Consolidating the fourteen (14) work areas will allow the smaller sites to proportionately cost-share the mobilization and demobilization costs with the larger project sites. This will help to maximize the total amount of actual dredging that can be accomplished with the limited funding that is available.

There are no regional or national contract implications for consolidating these projects into one contract.

The market research conducted for this requirement indicates that there are at least three (3) capable small businesses with an interest in bidding on this dredging requirement, and such the Government has a reasonable expectation that there will be adequate price competition. Therefore, this consolidated requirement will be advertised as a Total Small Business Set-aside. Consolidation of the dredging requirements will have no effect on small business concerns. As discussed above, without consolidation, funding and environmental scheduling constraints will prevent the Government from awarding separate contracts for all fourteen (14) sites. Therefore, and as further discussed below, the quantifiable benefits of consolidation exceed the threshold set forth in RFO FAR 7.107-2(c)(3)(i) and the expected benefits of the consolidated approach are critical to the agency’s mission success.

g. Funding: The work at the eleven (11) federal project areas within this contract will be funded per the work plan budget for each individual project site as appropriated by Congress. Type of funds is Civil Works Operations and Maintenance (O&M) FY 2026. The non-federal optional work will be funded by funds issued by The Port of Longview based on stipulations of the approved MOA.

CONSOLIDATION MEMORANDUM

FOR

FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

3. Applicable Statutes/Regulations: 15 U.S.C. § 657q, RFO FAR 7.107-2 Consolidation, AFARS 5107.107-2, Consolidation, and UAI 5107.107 Consolidation of contract requirements.

4. Results of Market Research:

The following market research methods were used to examine the mechanical dredging marketplace:

Past procurement history, Sources sought posted to SAM.gov, Correspondence with prior SB KTR’s, and SBA Dynamic Small Business Search.

a. Market Research Conducted: A review of relevant procurement history back to 2006 shows that this type of work has almost exclusively been performed by a small business, with exception in only 3 of the 23 contracts over 17 years. Both large and small businesses have demonstrated the capability to dredge multiple project locations, such as the ones considered for this requirement, under one contract. T small dredging firms, Hickey Marine Enterprises (HME)and American Construction have performed dredging work most recently at the sites contained under this consolidation. These small firms are known to NWP as capable of performing the work contained under the proposed consolidated contract.

The Contract Specialist conducted an SBA Dynamic Small Business Search to supplement the procurement history review. The search parameters included small business firms located in Washington, Oregon, and California with a NAICS code of 237990 and keyword “dredging.” The results showed twenty-five (25) companies, including companies that had successfully completed work at these sites in the past such as HME and American Construction, as well as other companies that had either worked with NWP on other dredging requirements or had bid on past projects such as Camenzind Dutra JV.

After posting a Sources Sought to SAM.gov, the contract specialist contacted seven (7) small business firms (American Construction, Camenzind Dredging, HME, Duwamish-Pacific JV, R.E. Staite Engineering, West Coast Contractors, and Western Marine Construction) that were prior bidders on dredging work in the past at the sites (or similar sites) contained under this consolidation and last year’s offerors. Via email inquiry, an individual from each company who represented its interests was informed of the general scope and timeframe of the requirement. Three of the seven firms indicated their availability and interest in submitting bids for a potential solicitation containing clamshell dredging work at the sites in this consolidation if it was solicited. Upon receiving three (3) favorable results indicating small business interest and intent to bid on this project, no further firms were contacted. In past jobs with NWP, these firms have made use of the same equipment that will be needed on the current consolidated job.

As a result of market research, the Government determined that there is a reasonable expectation of receiving at least two (2) bids from capable small businesses. Therefore, it was recommended that this consolidated requirement be set aside for small business as a Total Small Business Set-aside.

Table 2 Companies Contacted During Market Research

Company Business Size Owns Dredges Capable of Completing Work

Interested in Bidding

American Construction

Small Yes Yes

HME Construction, Inc

Small Yes Yes

Camenzind Dutra JV, LLC

Small Yes Yes

Duwamish-Pacific JV Small Yes No

R.E Staite Engineering, Inc

Small Yes No

CONSOLIDATION MEMORANDUM

FOR

FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

West Coast Contractors

Small Yes No

Western Marine Construction, Inc

Small Yes No

b. Impacts of Consolidation on Small Business: Consolidation of these clamshell dredging requirements will have no effect on small business. Historically, clamshell dredging at these sites was almost always performed by a small business. Past performance and market research shows that available and interested small businesses can perform the work to be consolidated under this requirement. A solicitation, done as a Total Small Business Set-aside, will result in a contract that is suitable for award to small business. Any small business capable of performing the work will be able to submit a bid. The solicitation will not be open to competition from large business.

5. Alternative Contracting Approaches Considered and Rationale for Rejection

a. Alternative 1 – Less Consolidation: Consolidation by Geographic Area. An alternative contracting approach considered is to consolidate projects and group them by their projected duration and their geographic area. This would separate out the two (2) Oregon Coastal projects, and the twelve (12) Columbia River projects and solicit them as two separate contracts. Under this alternative, the consolidation for one contract would be Chetco River and Port Orford, on the Oregon Coast, and the other would be Baker Bay, Cape Disappointment, Chinook, Skipanon River, Skamokawa Creek, Wahkiakum Ferry Channel, Willow Grove Boat Basin, Longview Turning Basin, Port of Longview, Old Mouth Cowlitz, Lower Vancouver Anchorage, and Oregon Slough Lower. The following factors were taken into consideration when analyzing this alternative.

(i) Quality. There are no advantages or disadvantages in terms of quality in selecting this alternative since contractors would be required to accomplish the work to the same level of quality.

(ii) Acquisition Cycle. The solicitation and award of two (2) clamshell dredging contracts by NWP rather than only one (1) contract under the recommended alternative of consolidation of all fourteen (14) work areas would require twice the number of total acquisition man hours to complete the work.

According to the NWD PALT Master spreadsheet (current as of January 2025), the most likely time required to complete a complex IFB is 200 hours. Under this alternative, two (2) IFBs would require a total acquisition time of 400 hours to complete, which is significantly more than 200 hours for one consolidated contract.

(iii) Cost. Differences in cost between this alternative and the recommendation for consolidation are significant. Consolidating contracts only by geographic area is at a disadvantage in terms of cost compared to total consolidation of current clamshell dredging requirements. Under this alternative, more resources would be required to award and administer two contracts instead of only one contract. Instead of Contracting Division acquisition costs of $30,594.08 as per the NWP Labor Budget Model for an IFB of the “most likely” complexity category, costs would double to $61,188.16. Contract support and administrative costs would also increase under this alternative. Under full consolidation, the costs for developing the requirements as well as administration of the construction are estimated by Navigation Division – Waterways Maintenance Section to total $2,661,297. Under this alternative of less consolidation these costs would rise because of administrating two construction sites simultaneously to an estimated total of $3,053,717 a difference of $392,419.

Differences in mobilization and demobilization costs under this alternative compared to under consolidation are also substantial. The estimated difference in costs under this alternative as compared to under the recommended consolidation is an increase of approximately $894,561 since two separate contracts would be issued with multiple contractors having to mobilize and demobilize from the location of the contractor’s origin as opposed to from one site to the next. Based on the amount of funding currently

CONSOLIDATION MEMORANDUM

FOR

FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

available, this increase in cost would not allow award of two (2) separate contracts consolidated by geographic area.

The table below provides a summary of the cost savings discussed above and demonstrates that the quantifiable benefits in dollar amounts are substantial and exceed the standards set forth in RFO FAR 7.107-2(c)(3)(i).

Table 3 Cost Savings Consolidation versus Alternative 1

Cost Cost Under Consolidation

Cost Under Alternative

Cost Savings

Cost Savings as a Percentage of Total Contract Value ($11.63M)

CT Labor $30,594 $61,188 $30,594 0.26%

Support and Administrative $2,661,297 $3,053,717 $392,419 3.37%

Mobilization/Demobilization $2,100,000 $2,994,561 $894,561 7.69%

TOTAL $4,791,891 $6,109,466 $1,317,575 11.33%

As shown, total cost savings are 11.33% percent of the total estimated contract value of $11.63M. This exceeds the 10 percent standard in the RFO FAR 7.107-2(c)(3)(i) by 1.33 percentage points.

(iv) Terms and Conditions. It is not anticipated that the Government will secure better terms or conditions by selecting this alternative.

(v) Other Benefits. One benefit of this alternative is additional opportunities for more than one

(1) contractor since two (2) contracts would be awarded rather than only one. However, as previously mentioned, the amount of funding that is currently available is inadequate to support awarding more than one contract to dredge at all fourteen (14) sites. Therefore, it is likely that one of the contracts for some number of the sites will not be able to be awarded, and the work within that contract will not be completed.

(vi) Conclusion. The alternative contracting approach to consolidate by geographic area is not in the best interest of the Government. It increases procurement and administrative costs in comparison to the recommended option and provides no benefit to small business. Additionally, it increases mobilization and demobilization costs since two contracts would be awarded, each with its own mobilization and demobilization costs. It puts the dredging mission in jeopardy due the limited funding available for this work. Under this alternative, it is certain that some areas will not be dredged due to the limited funding that is available. The most economical way to accomplish the needed dredging that will ensure adequate funding is the recommended overall consolidation rather than consolidation by geographic area.

b. Alternative 2 – No Consolidation: Fourteen (14) Standalone Contracts. An alternative contracting approach considered is to solicit fourteen (14) standalone contracts, one for each project work area. As with the proposed consolidation and Alt 1, because the Port of Longview work and Willow Grove Boat Basin is non-federal work for The Port of Longview, it cannot be solicited on their own and must be consolidated with the federal Longview Turning Basin work. The following factors were taken into consideration when analyzing this alternative.

(i) Quality. There are no tangible advantages or disadvantages in terms of quality in selecting this alternative since contractors would be required to accomplish the work to the same level of quality.

CONSOLIDATION MEMORANDUM

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FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

(ii) Acquisition Cycle. The solicitation and award of fourteen (14) clamshell dredging contracts by

NWP rather than only one (1) contract under the proposed consolidation would require fourteen times the number of total acquisition man hours to complete the work. According to the NWD PALT Master spreadsheet (current as of January 2025), the most likely time required to complete a complex IFB is 200 hours. Under this alternative, fourteen (14) IFBs would require a total acquisition time of 2800 hours to complete, which is significantly more than 200 hours for one consolidated contract.

(iii) Cost. Differences in cost between this alternative and the recommendation for consolidation are significant. Consolidating contracts only by geographic area is at a disadvantage in terms of cost compared to total consolidation of current clamshell dredging requirements. Under this alternative, more resources would be required to award and administer fourteen (14) contracts instead of only one contract.

Instead of Contracting Division acquisition costs of $30,594 as per the NWP Labor Budget Model for an IFB of the “most likely” complexity category, costs would be 428,317, fourteen times the amount under the proposed consolidation. Contract support and administrative costs would also increase under this alternative. Under full consolidation, the costs for developing the requirements, including support from NVW-W and ENC-CV as well as administration of the construction are estimated by Navigation Division – Waterways Maintenance Section to total $2,661,297 Under this alternative of no consolidation these costs would rise as a result of administrating fourteen (14) construction sites simultaneously to an estimated total of $4,830,090, a difference of $2,168,793.

Differences in mobilization and demobilization costs under this alternative compared to under consolidation are also substantial. The estimated difference in costs under this alternative as compared to under the recommended consolidation is an increase of approximately $7,500,00 since fourteen (14) separate contracts would be issued with multiple contractors having to mobilize and demobilize from the location of the contractor’s origin as opposed to from one site to the next. Based on the amount of funding currently available, this increase in cost would not allow award of fourteen (14) separate contracts consolidated by geographic area.

The table below provides a summary of the cost savings discussed above and demonstrates that the quantifiable benefits in dollar amounts are substantial and exceed the standards set forth in RFO FAR 7.107-2(c)(3)(i).

Table 4 Cost Savings Consolidation versus Alternative 2

Cost Under Consolidation

Cost Under Alternative 2

Cost Savings

Cost Savings as a Percentage of Total Contract Value ($11.63M)

CT Labor $30,594 $428,317 $397,723 3.42%

Support and Administrative $2,661,297 $4,830,090 $2,168,793 18.65%

Mobilization/Demobilization $2,100,000 $9,600,000 $7,500,000 64.49%

TOTAL $4,791,891 $14,858,407 $10,066,516 86.56%

As shown, total cost savings are 86.56 percent of the total estimated contract value of $11.63M. This exceeds the 10 percent standard in the RFO FAR 7.107-2(c)(3)(i) by over 76 percentage points.

(iv) Terms and Conditions. It is not anticipated that the Government will secure significantly better terms or conditions by selecting this alternative.

CONSOLIDATION MEMORANDUM

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FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

(v) Other Benefits. One benefit of this alternative is additional opportunities for more than one

(1) contractor since fourteen (14) contracts would be awarded rather than only one. However, as previously mentioned, the amount of funding that is currently available is inadequate to support awarding more than one contract. Therefore, a potential that one of more of the contracts would not be able to be awarded due to lack of funding. Additionally, there is limited capability in terms of number of firms and equipment within industry to support all the contracts.

(vi) Conclusion. The alternative contracting approach to have no consolidation and solicit fourteen (14) standalone contracts is not in the best interest of the Government. It increases procurement and administrative costs in comparison to the recommended option and provides no benefit to small business. Additionally, it increases mobilization and demobilization costs since fourteen contracts would be awarded, each with its own mobilization and demobilization costs. It puts the dredging mission in jeopardy due the limited funding available for this work. Under this alternative, it is certain that some areas will not be dredged due to the limited funding that is available. The most economical way to accomplish the needed dredging that will ensure adequate funding is the recommended overall consolidation rather than consolidation by geographic area.

c. Summary of Alternatives: The considered alternatives are summarized in Table 5.

Table 5 - Summary of Alternatives Selected

Alternative Advantages Disadvantages

One Consolidated Contract (All fourteen worksites in one contract action)

1. Procurement and administrative cost savings to the Government.

2. Mobilization and demobilization cost savings of $894,561 compared to Alternative 1 and $7,500,000 compared to Alternative 2.

3. Ensures all work locations will be dredged given limited project funds.

4. Increased total cubic yardage able to be dredged due to cost savings produced by consolidation

1. Limited to one small business contractor

Alternative 1 Advantages Disadvantages Consolidation By Geographic Area

1. Potential for additional opportunities for other small business contractors provided market research shows there would be sufficient competition.

1. Higher procurement and administrative costs to the Government

2. Higher mobilization and demobilization costs to the Government than compared to full consolidation.

3. Possible failure to dredge all required sites due to insufficient project funding

4. Possible lessened competition due to contractors choosing to bid on only one or the other solicitation

5. Decreased total cubic yardage dredged due to more dredging funding going to pay for mobilization and demobilization

Alternative 2 Advantages Disadvantages

CONSOLIDATION MEMORANDUM

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FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

No Consolidation 1. Potential for additional opportunities for other small business contractors provided market research shows there would be sufficient competition.

1. Higher procurement and administrative costs to the Government

2. Higher mobilization and demobilization costs to the Government than compared to full consolidation.

3. Possible failure to dredge all required sites due to insufficient project funding

4. Lack of capability within industry to support seven separate contracts

5. Decreased total cubic yardage dredged due to more dredging funding going to pay for mobilization and demobilization

Table 6 – Analysis Summary

Benefit Consolidation Alternative 1 Alternative 2

Total Contract Cost $11,629,200.00 $13,369,297.40 $19,664,736.00

Quality No Difference No Difference No Difference

Acquisition Cycle 200 Hours 400 Hours 2800 Hours

Terms and Conditions No Difference No Difference No Difference

Cost: Lowest Medium High

CT Labor $30,594.08 $61,188.16 $428,317.12

Support and Administrative $2,661,297 $3,053,717 $4,830,090

Mobilization/Demobilization $2,100,000 $2,994,561 $9,600,000

TOTAL $4,791,891 $6,109,466 $14,858,407

Total Percent of Contract

41.21%

45.70% 75.56%

Cost Saving Percentage of Total Contract Value

NA

11.33% 86.56%

The proposed use of a single consolidated contract provides the greatest benefits to the Government in terms of project completion. It ensures that there will be adequate time and funding for all fourteen (14)

CONSOLIDATION MEMORANDUM

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FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

Federal projects within the requirement to be dredged. It ensures that more material will be dredged due to less funds being allocated for mobilization and demobilization. It reduces the Government procurement and administrative costs, as well as the cost mobilization and demobilization, and ensures robust competition between small business dredging contractors. The alternative strategies outlined are more costly and do not ensure that all sites will be dredged as it is very likely that either alternative would exceed current project funding. Multiple contracts would offer the potential for additional opportunities to small business contractors, but this benefit is not a certainty. If the recommended consolidation is not approved, some projects requiring dredging will not be dredged, and mobilization and demobilization costs will be millions of dollars higher. Mission objectives necessitate a consolidated contract and the benefits of this approach exceed the benefits of the other alternatives considered. Consolidating this contract will provide total savings to the Government in terms of procurement, support, and mobilization costs of $1,317,575 compared to Alternative 1, and $10,066,516 compared to Alternative 2; and as such, the quantifiable benefits exceed the standards set forth in RFO FAR 7.107-2(c)(3)(i).

6. Bundling Analysis:

a. Bundling in accordance with (IAW) FAR 2.101 and RFO FAR 7.107, and 15 U.S. Code 657q - When the procuring activity intends to proceed with a bundled or substantially bundled acquisition, it must document the acquisition strategy to include a determination that bundling is necessary and justified, when compared to the benefits that could be derived from meeting the agency’s requirements through separate smaller contracts.

b. Definition. FAR 2.101 defines “bundling” as a subset of consolidation that combines two or more requirements for supplies or services, previously provided or performed under separate smaller contracts (see paragraph (2) of this definition), into a solicitation for a single contract, a multiple-award contract, or a task or delivery order that is likely to be unsuitable for award to a small business concern (even if it is suitable for award to a small business with a Small Business Teaming Arrangement) due to--

(i) The diversity, size, or specialized nature of the elements of the performance specified;

(ii) The aggregate dollar value of the anticipated award;

(iii) The geographical dispersion of the contract performance sites; or

(iv) Any combination of the factors described in paragraphs (1)(i), (ii), and (iii) of this definition.

c. Applicability of FAR Bundling Definition. In reference to the definition of bundling in FAR 2.101, this contract does not meet the definition of “bundling” because these requirements are suitable for award to a Small Business concern even if they are combined into one contract.

7. The Competition in Contracting Act (CICA) Bundling Principle.

This principle, as developed by Government Accountability Office (GAO) case law, focuses on whether the combined requirement (new, old, or otherwise) restricts competition, and whether the agency is consolidating or bundling a new requirement unnecessarily. In order to justify CICA Bundling the agency must show “a reasonable basis for why the bundling is necessary to meet the agency need.” (Vantex Serv., Inc., B-290415, August 8, 2002, and Outdoor Venture Corp., B-299675; 8-299676, July 19, 2007.)

By consolidating contract requirements, this acquisition strategy will restrict competition, but only to the extent necessary to efficiently meet the minimum needs of the government. The rationale outlined in paragraph 5 of this document makes clear that this level of consolidation is necessary to meet the

CONSOLIDATION MEMORANDUM

FOR

FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

Procurement Sensitive – For Official Use Only

GLYNN.JAMES.RO Digitally signed by

GLYNN.JAMES.ROBERT.11630862

1258608867

Digitally signed by

Date: 2026.05.14 11:40:30 -07'00' minimum needs of the Government and does not restrict competition unnecessarily.

8. Considerations, Facts and Reasoning Supporting the Determination: All facts, considerations and rationale have been addressed previously in this determination. The DD Form 2579 will be routed to the Contracting Officer for approval once this consolidation memo is approved and final with all signatures. It is anticipated that all concur that consolidation of this requirement is both necessary and justified.

9. Summary: Consolidation of Oregon/Washington Clamshell Maintenance Dredging 2026 requirements into a single contract will provide the greatest benefit to the Government and ensure timely execution of necessary clamshell dredging work in Oregon and Washington. The quantifiable benefits of consolidation considering all contract costs, to include dredging, mobilization and demobilization, procurement costs, and support and administration costs; $1,317,576 or 11.33% percent compared to Alternative 1, and $10,066,516 or 86.56% percent compared to Alternative 2, in comparison to the estimated contract value, and therefore alternative exceeds the standard in RFO FAR 7.107-2(c)(3)(i) and are further supplemented by the qualitative benefits. Therefore, consolidation of Oregon/Washington Clamshell Maintenance Dredging 2025 requirements into a single contract is necessary and justified.

Enclosures:

(1) Dynamic Small Business Search Results

(2) Market Research Report

District Coordination:

LASICH.BRANDON.MATTH

EW.1255369012

Digitally signed by

LASICH.BRANDON.MATTHEW.1255369012

Date: 2026.05.14 12:28:42 -07'00'

Brandon Lasich Date Contracting Officer

James Glynn Date NWP Deputy for Small Business Programs

Digitally signed by

LEE.JESSE.CHRISTOPHER.154824

PHER.1548246381 6381

Date: 2026.05.15 11:10:45 -07'00'

Jesse Lee Date NWP Office of Counsel

Alec Bittner Date CENWP-NAV, Dredging Contracts, Technical Lead

LEE.JESSE.CHRISTO

CONSOLIDATION MEMORANDUM

FOR

FIRM FIXED-PRICE CONSTRUCTION CONTRACT

OREGON/WASHINGTON CLAMSHELL MAINTENANCE DREDGING 2026

DETERMINATION

Upon the basis of the findings above, I hereby determine, pursuant to the authority of 15 U.S.C. §657q, the Federal Acquisition Regulation 2.101 and 7.107-2, and the Army Federal Acquisition Regulation Supplement 5107.107 “Consolidation of Contract Requirements,” that the proposed consolidation of the requirements for an invitation for bids (IFB) for a single Firm-Fixed-Price (FFP) Construction Contract for Oregon/Washington Clamshell Maintenance Dredging 2026 with a total capacity of $10M is both necessary and justified; and I certify that small business concerns have been taken into consideration in accordance with 15 U.S.C. §657q(c)(1)(E).

Mitchell Johnson Date Chief of the Contracting Office (CoCO)