B.04.21 - Consolidation Memo - W912HP27RA002 - FLETC Trade Cargo_Redacted.pdf

FOR OFFICIAL USE ONLY

SOURCE SELECTION INFORMATION – SEE RFO 2.101 AND 3.104

CONSOLIDATION OF CONTRACT REQUIREMENTS DETERMINATION

FOR

W912HP27RA002

TRADE & CARGO ACADEMY

DESIGN BID BUILD

C TYPE CONTRACT

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

1. RATIONALE: Consolidation may provide substantial benefits to the Government.

However, because of the potential impact on small business participation, before conducting an acquisition that is a consolidation of requirements with an estimated total dollar value exceeding $2 million, a written determination shall be made that the consolidation is necessary and justified in accordance with 15 U.S.C. 657q, after ensuring that--

(a) Market research has been conducted;

(b) Any alternative contracting approaches that would involve a lesser degree of consolidation have been identified;

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

(d) Any negative impact by the acquisition strategy on contracting with small business concerns has been identified; and

(e) Steps are taken to include small business concerns in the acquisition strategy.

2. Introduction: The U.S. Army Corps of Engineers, Charleston District (SAC), proposes to award a Stand-Alone C Type, Firm-Fixed Priced, Desing Bid Build contract in the amount of $ and has conducted market research that demonstrates consolidation of this procurement to be both necessary and justified. Pursuant to RFO 2.101, 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

(ii) requirements of the Federal agency for construction projects to be performed at two or more discrete sites.

FOR OFFICIAL USE ONLY

SOURCE SELECTION INFORMATION – SEE RFO 2.101 AND 3.104

(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 solicitation will allow SAC to meet construction requirements for a design bid build (DBB) project under North American Industry Classification System (NAICS) code 236220—Commercial and Institutional Building Construction. The work under this contract will be to support the Federal Law Enforcement Training Center (FLETC), in North Charleston, SC. This Determination and Findings (D&F) is submitted to justify the consolidation of requirements for DBB construction work under an approved Acquisition Plan to establish and outline management procedures for the acquisition of a new Trade & Cargo Academy as well as a new Cargo Security & Seized Property Training Facility for FLETC. SAC has conducted sufficient analysis and market research to demonstrate that consolidation is both necessary and justified.

3. Description of Procurement:

A. Project Description. FLETC is located in North Charleston, SC and has a requirement for a new Trade & Cargo Academy (TCA), to include hazardous material abatement and selective demolition of the current vacant 30,000 SF, three-story building, while preserving the existing main lobby and ensuring uninterrupted utility service to the occupied east wing. In its place, a new 28,400 SF, two-story, flood-resilient facility will be constructed. Due to poor soil quality and its location within FEMA Zone AE, the TCA will use a deep precast concrete pile foundation with pile-supported slabs, a heavy-duty steel frame to withstand high wind/seismic demands, a modern rainscreen envelope, and fully integrated building systems (HVAC, LED lighting, and security infrastructure). The interior will have space for instructional use on the first floor (including classrooms, an auditorium, and production spaces) and administrative open offices on the second floor.

FLETC also has a requirement for the construction of a new Cargo Security & Seized Property Training Facility (CSSPTF), a separate one-story 5,985 SF facility purpose-built to support U.S. Customs and Border Protection (CBP) training. Specifically designed for hands-on vehicle/cargo inspection, evidence processing, and simulated seized property storage, this site-adapted facility will also be elevated on a deep pile foundation to comply with stringent floodplain requirements. A key engineering focus for this site is the implementation of pile-supported stormwater piping under paved areas to mitigate soil settlement risks.

Both facilities are engineered for a minimum 40-year operational lifespan, integrating highly durable, low-maintenance coastal materials, and will comply fully with the latest federal energy conservation standards, DHS security criteria, and 2021 building codes.

These facilities are essential for the increased student enrollment and additional courses offered supporting FLETC Charleston.

B. Acquisition Plan/Procurement Summary. The proposed requirement will be a stand-alone C type contract, procured using the DBB process. The solicitation will be completed

FOR OFFICIAL USE ONLY

SOURCE SELECTION INFORMATION – SEE RFO 2.101 AND 3.104

on an unrestricted (full and open) basis. The period of performance will be 720 days and will include one option.

C. Applicability of Consolidation. This requirement meets the definition of consolidation because it will result in a solicitation for a contract to satisfy requirements for two construction projects to be performed at two or more discrete sites and the estimated total value of the contract exceeds $2M.

D. Requirements Being Consolidated. This requirement will support the construction and site work for two buildings at the FLETC site. The estimated dollar value of the project can be seen in Table 1 below.

Table 1 – Estimated Contract Cost

CLIN Description Total 0001 BASE BID: Demolition of a 30,000 sf 3-story Building 286 (West

Wing) and Construction of new 28,400 sf 2-story Trade and Cargo Academy (TCA) and associated site work.

0002 OPTION: Trade and Cargo Academy (TCA) Furniture Fixtures and Equipment (FF&E).

0003 OPTION: Construction of new 5,985 sf 1-story Cargo Security and Seized Property Training Facility (CSSPTF) and associated site work. Cargo Security and Seized Property Training Facility Furniture Fixtures and Equipment (FF&E).

TOTAL $

4. Results of Market Research:

A Sources Sought Notice was posted on SAM.gov from 29 July 2026 to 05 August 2026.

A total of 2 businesses responded. On 11 August 2026 the Sources Sought Notice was re-opened in order to allow for industry to have additional time to respond. Responses were due on 21 August 2026. Additionally, a virtual industry day was held on 20 August 2026 where this requirement was discussed with the roughly 200 contractors in attendance.

After the additional time to respond, a total of 7 responses were received. Of those 7, , 5 were listed as small business under NAICS 236220 and 4 were found to have SBA certifications of WOSB/EDWOSB (1 firm), HUBZone (1 firm) and 8(a) (2 firms). The technical review of all respondents' capabilities statements, relevant experience, and bonding capacity concluded that 2 firms are considered capable of performing the work as a prime contractor, one of which was a small business. See Table 2 for further information, note the table includes both the original responses as well as the additional responses to the sources sought.

FOR OFFICIAL USE ONLY

SOURCE SELECTION INFORMATION – SEE RFO 2.101 AND 3.104

Table 2 – Market Research Results

Contractor Similar

Experience Bonding Capability

Business Size Capable of Performing Requirement

FOR OFFICIAL USE ONLY

SOURCE SELECTION INFORMATION – SEE RFO 2.101 AND 3.104

down area, and therefore two Prime contractors would be competing for that space.

This approach externalizes coordination risk from the contractor to the Government and is not a prudent use of limited government resources. The reasons are outlined below.

Quality: The ability to work with a single contractor directly on one contract provides significant advantages in comparison to multiple stand-alone contracts. Due to the size of the project site and limited staging areas it would be difficult to have two contractors on site with their personnel and equipment completing both projects at the same time. Using two contractors to perform the work simultaneously would also require additional manpower and oversight from the Government when it is already in short supply. The project location is in a highly restricted area that is only accessible to individuals that are U.S. Citizens. Knowing that the construction market in the area is highly competitive it may be difficult for two highly qualified contractors to obtain enough personnel to successfully complete the project. There will also have to be attention to sequencing of work due to the limited space at FLETC, which would be even more difficult if there were two contractors.

Acquisition Cycle: The time required to award two stand-alone contracts would be administratively burdensome. Based on current milestones, it typically takes 120-150 days to complete one contract. This strategy constrains limited SAC resources due to increased effort in preparation and review of multiple full contract plans and specifications, source selection, contract document preparation, coordination with the Small Business Administration, and post-award plan review/acceptance. It is also important to note that these two projects need to be awarded timely due to future unrelated work at FLETC that will also need site access and potentially use of the same staging areas.

Terms and Conditions: There is no difference between the contractual terms and conditions or the RFP requirements and proposal submissions for a single “C” type contract vs multiple “C” type contracts.

Cost: Additional resources and greater oversight by the Government is also necessary when dealing with multiple contractors versus a single contractor. In addition to added direct costs for the Government, having two contractors perform the work doubles the Overhead, Mobilization, and Demobilization costs as well. All of these translate into a significant increase in time and costs for which there are no discernible benefits.

c. Alternative 3 – One Stand-Alone C Type Contract:

This approach was determined to be the most advantageous for satisfying the requirements of the customer. It provides the optimal balance of speed, cost-efficiency, and quality, ensuring mission success. The benefits of this approach are outlined below.

FOR OFFICIAL USE ONLY

SOURCE SELECTION INFORMATION – SEE RFO 2.101 AND 3.104

Attachments (Located in Paperless Contract File):

1. Acquisition Plan

2. Market Research

3. DD2579