Baseops JA.pdf

Control No:

CUI//SP-PROCURE//FEDCON

MICC Legal Counsel:

DSN:

Date: See digital signature

Director, MICC-Fort Belvoir:

DSN:

Date: See digital signature

Director, Field Directorate Office-Fort Sam Houston:

DSN:

Date: See digital signature

Director, Small Business Programs:

DSN:

Date: See digital signature

Alternate Advocate for Competition:

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Date: See digital signature

As part of IMCOM’s further refinement to the standardization of the BASOPS requirement that was first implemented under the current contract W91QV1-18-D-0007, additional adjustments were made to the standardized BASOPS requirement to now include waste management and pest control. The unanticipated addition of these adjustments by IMCOM required multiple levels of review that incurred several delays during the review process as these additions were debated before eventually reaching a consensus to add them, ultimately delaying delivery of the final requirements documentation by nine months. Additional time and effort were also spent identifying potential Energy Savings Performance requirements that could be removed from the standardized BASOPS requirement and handled separately with Energy Savings Performance Contracts. Upon realization that separating potential ESPC requirements from the BASOPS was accruing further unacceptable delay, this initiative was deferred for future deliberation. Due to the need to continue uninterrupted services, the only viable option at this time is to award a short-term bridge contract to the incumbent, Aleut O&M LLC until the follow-on contract is awarded by the IRC and the incoming vendor has been afforded the necessary 60-day transition time with the incumbent.

b. Alternatives.

1) Suspension of Operations. Suspension of operations is not a viable option.

The maintenance service provided by the current contract directly impacts multiple agencies’ missions located at Fort Belvoir. Suspending maintenance service will increase the risk of life, health and safety issues surrounding the possible functional failure of buildings and their equipment, jeopardizing missions of the occupants.

2) Compete the bridge contract. Competing the bridge contract is not a feasible option. For complex acquisitions such as BASOPS services, to compete a short-term bridge would require at least 330 days to make an award and execute a phase-in period. With the cost of a contract more than $20 million per year, it is unrealistic to solicit for services of this magnitude, award, and transition to a new contract prior to 20 March 2024. Due to the magnitude and complexity of the requirement and the time available before the current contract expires on 20 March 2024, the incumbent contractor, Aleut O&M Services, LLC, is the only available source that can provide services until a new competitively awarded contract can be executed in December 2024 and a transition can occur.

c. Impact if justification is not approved. Failure to approve this action will result in a break-in-service of base operations and maintenance across the Fort Belvoir installation that will negatively affect all Fort Belvoir tenants and risk mission failures across multiple agencies. The increased risk of experiencing building infrastructure failures due to lack of maintenance services for mission critical facilities like Tyson’s Corner Communication Tower, Suitland Communication Tower, and INSCOM facilities will negatively impact national security.

6. Efforts to Obtain Competition: A Sources Sought Notice was posted as a Special Notice to SAM.gov on 24 January 2024, seeking possible sources, with a closing date of 01 February 2024. Out of the 28 vendors that expressed interest, 4 were not 8(a) vendors; 12 were 8(a) vendors but 3 of those 8(a) vendors were late responding; and the remaining 12 were 8(a) Alaska Native or native Hawaiian owned vendors. Of the responses received, none of the vendors demonstrated the capability to perform the work as presented and within the time constraints presented in the Source Sought notice. While some responses provided recommendations to improve the Army’s approach to acquiring the identified items/services, none of them were effective approaches. Some Alaska Native and Native Hawaiian Owned corporations asserted that a direct award in accordance with DFARS 219.808-1, would reduce procurement lead time and avoid a protest of the bridge contract. This strategy would not address the required review process from the contracting activity nor the transition period of 60-days. No vendor was able to provide any recommendation to mitigate the review process or transition period. As such the inherent risk of competing this short-term bridge, or utilizing a direct award to an 8(a) contractor, has a high probability for a break-in-service. At this time a sole source award to the incumbent is the only procurement method that would prevent a break in these essential services.

Additionally, any new contractor would need to overlap with the incumbent contractor for a 60-day transition period. This would result in a substantial duplication of cost. The additional cost of having a new contractor working alongside the incumbent contractor during the transition period would be approximately $2.1 million dollars per month or approximately $4.2 million for the entire 60-day transition period.

A competitive procedure for this bridge would conservatively take a minimum of 330 days to award and the new vendor performing at full capability. The Assistant Secretary of the Army (Acquisition, Logistics and Technology) has established Procurement Acquisition Lead Times of 220 days after the release of an official solicitation for any contract within the threshold of $10 million to $100 million dollars. When added to 50 days for the pre-solicitation process and a 60-day transition period after award, the total estimated time for a procurement of this dollar value amounts to 330 days.

A non-competitive award utilizing the Small Business Administration 8(a) program would take conservatively 180 days to award. Adding an estimated 50 days for pre-solicitation activity, 70 days for lead time to award and a 60-day transition period after award, the total estimated time for a procurement of this dollar value amounts to 180 days.

Such scenarios would encounter a break-in-service and are not acceptable as base operations support disruptions will lead to the degradation of both the mission of all tenants on the installation and the physical security of the installation. For the aforementioned scenarios, the current incumbent is the only responsible source to keep continuity of services without a break-in-service.