Redacted CM Roofing MATOC.pdf

CONSOLIDATION OF CONTRACT REQUIREMENTS DETERMINATION FOR

$99 MILLION SMALL BUSINESS (SB) FACILITIES SUSTANIANMENT,

RESTORATION AND MODERNIZATION (FSRM) ROOFING

INDEFINITE DELIVERY/INDEFINITE QUANTITY (ID/IQ)

MULTIPLE AWARD TASK ORDER CONTRACT (MATOC) FOR THE FRONT RANGE

(COLORADO AND WYOMING) REGION

U.S. ARMY CORPS OF ENGINEERS, OMAHA DISTRICT

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

RATIONALE

1. 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 (M), 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.

I have reviewed this requirement and associated market research, and determined that consolidation, in accordance with 15 U.S.C. § 657q, is both necessary and justified. My determination is based on the following information:

This acquisition for multiple construction efforts will be performed at multiple discrete sites; therefore, it is consolidated. The market research definitively establishes a lack of ready, willing, and able firms within the SDVOSB, HUBZone, and WOSB categories with the requisite experience and nationwide mobilization capability. By consolidating into a single, general Small Business (SB) set-aside pool, the Government maximizes competition, captures highly qualified small business firms, and ensures access to the most technically sound and cost-competitive solutions. This streamlined approach is critical to the agency’s mission success for time-sensitive roofing repair.

2. Introduction: The USACE Omaha District (NWO) plans to solicit offers for a $99M SB Facilities Sustainment, Restoration and Modernization (FSRM) Roofing MATOC for the Front Range (Colorado and Wyoming) region, U.S Army Corps of Engineers, Omaha District (NWO).

Work will be performed in the Front Range Region (Colorado and Wyoming) based on customer needs. Additional key external stakeholders are the respective military services (Air Force, Army, etc.) and end-users at the installation level. The proposed MATOC will have a three (3) year base and one (1) two (2) year option period with a possible 6 month extension. The preponderance of work for the anticipated contract is defined by North American Industry Classification System (NAICS) 238160 – Roofing Contractors (small business size standard of $19M). The Omaha District has conducted market research that demonstrates consolidation of this procurement to be 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;

(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.

This acquisition is considered a consolidated acquisition since the follow-on task orders will result in construction projects at two or more discrete construction sites.

Consolidation will be done to the minimum amount necessary. Consolidation is necessary for efficiency, streamlining project execution, expediting the delivery schedule, and capitalizing on lessons learned advantages. By procuring a MATOC for these vital construction needs for multiple sites and requirements, the requirements will fully be satisfied, and efficiencies will increase as redundant and unnecessary contract actions will decrease.

By utilizing a portfolio of SB contractors to complete construction activities, the process will be expedited, resulting in faster resolution and greater efficiency in executing construction repairs and installations. Additionally, having a single pool of contractors responsible for these small construction repairs and installations will allow them to become more efficient by advancing further along the learning curve. As multiple task orders are awarded over the period of the MATOC it is anticipated that a single pool of contractors will gain experience working with USACE and at DoD facilities, which will allow the contractors to refine their processes, resulting in reduction of errors, creating a faster execution period, and overall lower costs to the government over time. As a

Military PM Branch of NWO advised that execution under this next-generation MATOC is strategically planned for late FY27 award to support EOFY requirements, establishing an initial baseline of . Because the contract will be awarded late in the fiscal year, the five (5) year Period of Performance will span across six fiscal years, concluding in late FY32. The types of work to be performed are expected to remain steady or consistently increase. Taking annual inflation (3%) plus other cost growth factors (1%) into consideration, it is expected that this MATOC will support the execution of projects totaling the following estimated amounts over the course of the contract’s lifespan:

a.

Estimated Combined Capacity (rounded): $99,000,000

**Storm Contingency – A significant portion of the 1st Generation Roofing MATOC, approximately $30 million of the $49 million contract, was utilized in its inaugural year to address extensive roof damage from a major hailstorm at Fort Carson and the U.S. Air Force Academy. Subsequently, a hailstorm in FY 2025 at F.E. Warren Air Force Base caused additional damages with estimates exceeding $30 million. This contingency fund is established to ensure the District is prepared to respond effectively to severe, unscheduled storm events, that impact roofing infrastructure at military facilities, particularly along the Front Range, without compromising the capacity for planned workloads.

This procurement will be a Small Business set-aside, competitively negotiated procurement in accordance with RFO FAR Part 15 procedures with the Best Value Trade-Off (BVTO) procurement method. The offerors providing the best value to the Government will be awarded contracts. The proposed FSRM Roofing MATOC will target up to firms for the MATOC pool. The MATOC will allow for Firm Fixed Price (FFP) task orders. The contracts under the MATOC will be construction contracts.

MATOC task orders will be executed in accordance with RFO FAR 16.507 – Additional Ordering Procedures for MATOCs, which includes providing each awardee with a fair opportunity to compete for each order, unless an exception exists, and its application is justified.

4. Results of Market Research: A variety of market research methods were used to determine the number and capabilities of firms interested in competing for this contract.

Market research techniques included a review of the procurement history of previous acquisitions and a Dynamic Small Business Search. (

a. Procurement History: In the previous generations of this acquisition, the FSRM Roofing MATOCs demonstrated that small business firms were capable of executing these types of projects. Over the last iteration of these MATOCs, SB firms have become familiar with the work, customers, and area of operations.

b. Dynamic Small Business Search: DSBS search was conducted on 13

November 2025 using the search criteria of NAICS code 238160, States of Colorado, Kansas, New Mexico, Oklahoma, Utah, Iowa, Montana, North Dakota, South Dakota, Nebraska, Wisconsin, Minnesota, Missouri, and Wyoming, keyword Roof, with a bonding capacity of $5M per contract and $10M aggregate.

The DSBS search returned with Small Businesses identified. It is noted that several of the business firms fall into several small business categories, and the breakdown is as follows:

- Small Businesses (to include all small business categories listed below)

- 8(a)

- HUBZone

- SDVOSB/VOSB

- EDWOSB

- WOSB

Within the socio-economic categories 8(a), HUBZone, EDWOSB, WOSB, and SDVOSB, the contractor's capabilities statement and performance history were reviewed. The results are as follows: overall Small Businesses did not have an active SBA certifications listed, so the business size was unable to be determined. had specific roofing projects listed, with projects between $200k-$2.5M, with a $20k project listed, and with experience listed between $30k-$400K. The remaining either had no information on prior projects or appeared to have general contracting capabilities to include building renovations, plumbing/HVAC, electrical and mechanical upgrades, paving, bridges and roads, architectural design, etc.

8(a) contractors found in the DSBS search, had specific roofing project listed on their company website, which indicated the project was at of the contractors are currently no longer in the 8(a) program and the final contractors, based on SBA performance history and company websites, have not demonstrated the ability to perform roofing type working. HUBZone contractors found in the DSBS search, had a specific roofing project listed in their performance history with a significant roofing project of $6.5M, either had no information on prior projects or appeared to have general contracting capabilities. Of the EDWOSB contractors found in the DSBS search, were determined to have roofing experience and appeared to have general contracting capabilities or no

The following factors were also taken into consideration when analyzing this alternative:

i. Quality. The following advantages and disadvantages were identified, related to quality, in selecting this alternative. Relying on stand-alone contracts would severely compromise the quality of the Government's response, as the delayed mobilization would exacerbate infrastructure degradation and required roofing repairs. This alternative will increase the number of stand-alone contract awards, thus significantly increasing the amount of time and documentation needed for procurement actions. This substantial increase in acquisition workload, compromises the overall quality of awards throughout the year. This is especially true in the fourth quarter when numerous other actions are being executed, which compromises the execution of awards at the end of the fiscal year. Stand-alone contracts provide less incentive for the contractor to provide a quality end product under the acquisition since it is a one-off project. In contrast, through the task order process for a MATOC, a MATOC pool member will strive to control cost and schedule growth and provide a quality product keeping in mind there is an opportunity for follow-on task orders. The overall increased quality of contractors on MATOCs compared to stand-alone contracts will therefore result in less rework and delays. Contractors often attempt to recover at least a portion of their additional costs from rework and delays through claims. There are no advantages in terms of quality by selecting this alternative. With the potential of stand-alone contracts, the quality is likely to vary.

Additionally, if more contractors are awarded contracts, the likelihood those firms “stealing” key personnel from one another increases significantly, thus increasing the likelihood of schedule slippage, safety issues, project re-work and the costs associated with these risks. NWO and the Military Branch has experience working this program, developed relationships with contractors in this business line, and streamlined processes and procedures over the last nine (9) years of managing this program.

Finally, if NWO chooses to issue a Request for Proposal for each project, it must ensure that the source selection criteria effectively differentiate the most qualified firm from other offerors. Additionally, consideration must be given to the limited availability of Government technical experts, who may not be able to participate on multiple Source Selection Evaluation Boards simultaneously without impacting project quality. Furthermore, while these experts are involved in source selection activities, their capacity to manage and support awarded projects will be reduced, further compromising the quality of those

Government will secure better terms or conditions by selecting this alternative.

iv. Other Benefits. This alternative allows for maximum opportunities for contractors to compete on each individual project, while the other strategies provide opportunities only for contractors included in a SATOC or MATOC. However, this strategy will also require each contractor to prepare a comprehensive proposal for each stand-alone contract. Through market research and industry engagements, it has been communicated that the cost to prepare and complete a competitive stand-alone contract proposal (labor and administrative costs) is significantly more compared to a task order proposal, due to the increase in proposal requirements for a competitive stand-alone contract. These additional costs may discourage some contractors from proposing on stand-alone contracts, resulting in decreased competition, and potentially increased contract costs. This can be a substantial cost to the industry when proposing on multiple stand-alone contracts which provide a lesser chance of obtaining an award compared to multiple awards under a MATOC, which has simplified ordering procedures. Or the offerors may only pursue the most attractive projects resulting in some projects having very limited competition.

Another risk of procuring stand-alone contracts is having significant re-procurement costs if a contractor does not perform. When a stand-alone contract has a poor performing contractor, another acquisition will need to be procured in order to fulfill the requirements, which doubles the procurement cost. A MATOC minimizes this risk by not only pre-selecting qualified and capable contractors at the solicitation level, but also having the ability to consider past performance on previous task orders during the ordering process.

A final risk of procuring stand-alone contracts is the impact on responsiveness. Awarding new stand-alone contracts rather than issuing a task order under an ID/IQ, introduces significant time delays that ultimately affect the Districts responsiveness to address roofing issues on military installations. These unnecessary time delays could impact soldiers and ultimately lead to mission failure if response times are not adequate. To prioritize responsiveness, leveraging an ID/IQ will ensure accelerated delivery while maintaining compliance with procurement regulations.

vi. Conclusion. This alternative is not in the best interest of the Government. Stand-alone, non-consolidated, contracts do not offer any significant advantages. To address the urgent requirement in a timely and effective manner, the project team prioritized responsiveness by leveraging an existing ID/IQ contract. Issuing a task order under an ID/IQ enables rapid acquisition and avoids the significant delays typically associated with awarding a new standalone contract. In contrast, pursuing a regular contract action would require full solicitation development, evaluation, and award processes, which could add weeks or even months to the timeline—ultimately jeopardizing mission readiness and timely execution. By utilizing the ID/IQ vehicle, we ensure accelerated delivery while maintaining compliance with procurement regulations. Additionally, this alternative will not result in lower contract award costs. Stand-alone contracts offer significant schedule risks, and increased levels of effort and costs to procure the contract.

B. Alternative 2: Less Consolidation - Award SATOCs for each individual installation, VA and NIST, within the Front Range AOR (Area of Responsibility) Another alternative contracting approach that contains less consolidation would be to procure roofing requirements with individual SATOCs for each installation.

Each contract will consist of a smaller maximum capacity dollar threshold (e.g.

etc.) Taking into consideration the number of Omaha District’s existing stakeholders, at least nine (9) SATOCs would need to be established in order to sustain the potential roofing requirements.

i. Acquisition Cost Savings or Price Reduction: In this alternative, there would be nine (9) SATOCs.

Contracting - Based upon the NWD Fee Estimates for Contracting Services, dated 17 January 2025 ( the average cost to execute a complex , higher dollar values, and may require significant negotiations, more documentation, and additional reviews) D-B SATOC is

. The cost to execute nine (9) SATOCs is $ This includes the cost for PDT coordination, acquisition strategy preparation, SSEB coordination, SSDD development, reviews, and other document preparation and administration. Execution of task orders will be at a cost of $ per task order (based on NWD Fee Estimates for Contracting Services, dated 17 January 2025, for a routine SATOC task order), or $

Project Management - Based upon the data received from the NWO Military Branch (Attachment #3), the average PM cost to execute nine (9) SATOCs is $ per SATOC, or a total of $ (discounting contract management costs and SSAC participation). The cost to execute task orders is $ per task order or This includes the cost for meeting coordination, acquisition strategy development, IGE development, negotiations, stakeholder coordination, and contract administration. Another aspect of the additional labor resource requirements for task orders is the additional trained staff needed to evaluate the significant number of proposals expected on every project.

anticipated workload is higher, thus leaving the less desirable SATOCs with the risk of no competition to award a SATOC to. The cost risk lies within the administration of a contract whether used or not; and the cost risk to the contractor to tie up bonding capacities and maintain resources to mobilize to those areas if a lack of work is realized or little or no work is projected. Additionally, the use of SATOCs eliminates prices competition at the task order level, which ultimately could drive pricing up.

Furthermore, by incorporating the different installations into one MATOC for the Front Range region, it will not only allow greater coverage flexibility, but also allow USACE to manage any gap in workload that a particular installation may face.

C. Alternative 3 (Recommended): This recommended alternative contracting approach, which contains the most consolidation, would be to procure one (1) Small Business D-B/D-B- B MATOC with a target of contractors in the pool.

i. Acquisition Cost Savings or Price Reduction: In the recommended alternative, there would be one (1) MATOC with a target of contracts.

Contracting – Based upon the NWD Fee Estimates for Contracting Services, dated 17 January 2025 ( the average cost to execute a complex , higher dollar values, and may require significant negotiations, more documentation, and additional reviews) D- B MATOC is This includes costs for meeting coordination, acquisition plan preparation, BCOES review, IGE development, SSEB coordination, SSDD development, and other document preparation and administration. Execution of task orders will be at a cost of per task order (based on NWD Fee Estimates for Contracting Services, dated 17 January 2025, for a routine MATOC task order), or

Project Management - Based upon the data received from the NWO Military Branch ( the average PM cost to execute a MATOC is (discounting contract management costs and SSAC Participation). The cost to execute task orders is $ per task order, or $ This includes the cost for meeting coordination, acquisition strategy development, IGE development, SSEB training and coordination and convening of the SSEB, stakeholder coordination, and contract administration.

Administrative (Closeout) Cost – Based upon the NWD Fee Estimates for Contracting Services, dated 17 January 2025, the cost to closeout a routine base contract or task order is . The cost to execute base contracts and task orders closeout actions over a 5-year period is $ This includes cost to complete and review closeout documents,

v. Other Benefits. This alternative allows multiple firms to compete on each task order awarded under this MATOC, which in turn reduces the overall project cost. The contract awardees would also become familiar with the anticipated work associated with FSRM construction requirements.

NWO cannot completely anticipate the exact requirements of each installation over the next five (5) years, so one MATOC for the entire geographic area is the most effective and efficient way to execute the expected workload for the Government.

The recommended strategy provides the following substantial benefits which support the program:

Mission readiness and capability to perform under this type of MATOC is an expectation that has been determined successful and beneficial to the military installations, the warfighter, and USACE Omaha District.

Without the consistency of this acquisition approach, specifically due to the required expediency of the program, there is a high risk of poor performance or lack of execution which would have a ripple effect on base support operations, logistical and training support, and most importantly, mission efficiency all of which are not viable given the operational tempo of our warfighters and their mission.

Allows for greater opportunities for MATOC pool contractors to compete on each individual task order.

Provides a contracting vehicle that minimizes acquisition planning and faster execution response times.

Minimizes contract execution cost; both in terms of Federal labor in the planning, procurement, and execution phase as well as in terms of contract price.

Contractors will be motivated to provide the best pricing in order to get into the MATOC pool and in order to win task order awards.

Shortens contracting lead time by allowing NWO to concentrate its manpower efforts in soliciting and awarding a single MATOC.

Assures operational continuity by minimizing the number of contractors accessing the active work zone at any given time period.

vi. Conclusion. This alternative provides the Government with the best chance for mission success. The proposed $99M SB FSRM Roofing MATOC would best meet the needs of both the USACE and other mobilizations and de-mobilization costs factored into each proposal.

a viable SATOC pool since the costs for a firm to prepare a proposal may not warrant the anticipated small amount of work for that region.

-Aggregate acquisition cycle costs and procurement time are higher than the single

SB MATOC.

-No competition at the task order level, which increases the risk of higher prices

-Risk is greater that a region may run out of SATOC contract capacity if work in concentrated in specific areas thus impacting mission requirements.

3.) Recommended:

Award one (1) SB FSRM Roofing D-B/D-B-B ID/IQ MATOC to cover Omaha Districts Front Range Region

-A single MATOC allows for an accelerated learning curve that enhances processes, efficiencies, and quality.

-A single MATOC assures NWO that the most qualified FSRM Roofing contractors will pursue this acquisition in order to be included in the MATOC pool.

-A single MATOC will provide for less administrative burden since there will be a limited number of contractors working similar projects under multiple task orders.

-MATOC pool members have a strong incentive to maintain high levels of performance, quality, and

-MATOC pool member must cover large geographic area. Some contractors may prefer more opportunities or more desirable locations at a higher overall expense and duration to the Government.

responsiveness in order to remain competitive for future task order opportunities.

-A single MATOC would ensure that NWO had available contract capacity for end-of-year and late arriving requirements.

-Acquisition cycle costs and procurement time are reduced.

-Price competition at the task order level

7. Bundling:

a) 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, 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 (i) through (iii) of this definition.

b) Applicability of FAR Bundling Definition. Based on the extensive market research documented in Section 4, it has been determined that the consolidated requirement is suitable for award to multiple small businesses, therefore it does not meet the definition of bundling.

8. Considerations, Facts, Reasoning Supporting the Determination: All facts, considerations and rationale have been covered previously in the findings. The DD2579 has been signed by

. All concur that consolidation of this requirement is necessary. See

9. Summary: Since this MATOC is vital to addressing FSRM Roofing repairs mission across the Front Range Region, any delays would result in diminished agility, survivability, responsiveness and effectiveness of the military mission and its supporting functions which could ultimately lead to mission degradation.

Based on the requirements of the FSRM Program, the recommended MATOC provides the most efficiency and best path forward to support the program. The SB MATOC discussed within this document is the most cost and time efficient, while delivering the highest quality results. It has been determined that the proposed consolidation of requirements awarded under the $99M SB FSRM Roofing MATOC provides the right strategy to support the program. For this procurement, both the qualitative and quantifiable benefits are documented below, but the quantifiable benefits do not exceed the 5% threshold set forth outlined in RFO FAR 7.107-2(c)(3). The consolidated approach is essential to mission success IAW RFO 7.107-2(e)(1). As shown in Table 12A above, the calculated cost savings for Alternative 1 vs Alternative 3 is 1.75% and for Alternative 2 vs Alternative 3 is 3.25%.

However, IAW RFO FAR 7.107-2(e)(1), the expected benefits of the consolidated approach are critical to the agency’s mission success, and the procurement strategy provides maximum practicable participation by small business is necessary and justified since the benefits of this plan substantially exceed the benefits of any alternative contracting approach, as described above. None of the other alternatives would allow the Government to produce contracts at the desired level of quality and timeliness needed for mission execution.

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