Janitorial/Custodial Services for EPA RTP Campus

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (BRIDGE)
In accordance with FAR Subpart 6.302-2 for
Janitorial/Custodial Services for EPA Research Triangle Park Campus
(Contract No. 68HERC24C0045)

This document is being prepared pursuant to the content requirements prescribed in Federal Acquisition Regulation (FAR) Subpart FAR 6.303-2(b) and Environmental Protection Agency Acquisition Policy (EPAAP) Subsection 6.3.1 –Bridge Justification for Other Than Full and Open Competition (January 2018).

Identification of the agency and contracting activity:

U.S. Environmental Protection Agency (EPA), Office of Mission Support, Office of Acquisition Solutions (OAS), Cincinnati Acquisition Division (CAD)

Nature and/or description of the action being approved:

This is a bridge justification for other than full and open competition for a requirement for commercial custodial maintenance services to assist the Environmental Protection Agency (EPA) to support its facilities located in Research Triangle Park (RTP) and Chapel Hill, North Carolina under Contract 68HERC24C0045.

A description of the supplies or services required to meet the agency’s needs (including the estimated value):

The contractor shall continue to provide custodial maintenance services, five days a week, Monday through Friday, and occasional weekend work as required, for three locations involving eight building locations to include the following types of space: office, cafeteria, classroom, computer room, fitness center, library, research lab, patient treatment area, utility, vending, washrooms, and an early learning center. Services will be both interior and exterior in nature.
This is an extension of the bridge which was in effect from April 1, 2024-June 30, 2025. This extension is for one (1) additional month of services at the main RTP campus (July 2025).
Note that an Option already existed and has been exercised for services at the Chapel Hill facility for the month of July 2025.
The estimated value for this action is $212,803.21.

An identification of the statutory authority and FAR provision permitting other than full and open competition:

41 U.S.C. §3304(a)(2); FAR 6.302-2 Unusual and compelling urgency.

A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

There cannot be a lapse in service with custodial services due to concern for the health and safety the employees that perform their mission essential duties at the EPA RTP locations. The Government could face serious health, safety, and liability issues if a contract is not in place to maintain custodial services at the RTP facilities. An extension of the bridge contract to the current contractor is the only feasible solution to ensure there is not a gap in service while the Government awaits a size determination from the Small Business Administration (SBA) of the protested awardee.

A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under 5.202 applies:

In accordance with FAR 5.202(a)(2), the proposed contract action is made under the conditions and authority at FAR 6.302-2, unusual and compelling urgency. The Government would be seriously injured if the agency complies with the time period specified at FAR 5.203, 15 days. As stated above, the agency requires continued custodial services on July 1, 2025 to protect the health and safety of employees at EPA facilities.
A competitive acquisition for a long-term contract solution for these services was seemingly concluded. Contract 68HERC25C0048 was awarded on June 12, 2025, with an effective date of July 1, 2025. However, an unsuccessful offeror submitted a Size Protest to the Contracting Officer on June 20th, 2025, alleging the awardee exceeds the acquisition’s applicable size standard. The Size Protest was forwarded to SBA on June 20th, 2025. The U.S. EPA awaits SBA’s size determination of the contract awardee.
Due to these circumstances, the Government does not and could not possess enough time to reasonably acquire the services sought via this Justification from any source other than the current bridge contract holder. The Government did not receive the Size Protest until June 20th, 2025, and other protests could have been received through as late as June 24th, 2025.

A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The current contractor’s pricing is based on an established Collective Bargaining Agreement. Therefore, this extension would be based on the current pricing for the services which was determined to be fair and reasonable at the time of award and shall remain in effect during the bridge contract.

A description of the market research conducted (see part 10) and the results or a statement of the reason market research was not conducted:

Market Research was not conducted due to the fact this is a bridge justification with an unusual and compelling nature. The current contractor is available to perform the required services. There were no other feasible options available to avoid a gap in service.

Any other facts supporting the use of other than full and open competition:

N/A

A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

No sources expressed an interest in this specific extension because an intent to sole source was not posted due to the unusual and compelling circumstances. See exception cited above.
However, on a prior extension of this contract, the following firms expressed interest in providing these services: KRA Management Services, Inc.; Chaves Clean Solution Services JV LLC.

A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

Following a commercial competition among 8(a) firms, a contract was awarded on June 12th, 2025, to acquire these services on a long-term basis. Depending on how SBA rules on the Size Protest, the Agency anticipates either: (a) the competitively awarded contract will stand, or (b) a competitive contract award will be made to the eligible offeror whose offer represents the best value to the Government.
There are no barriers to future competitive acquisitions of these services.

The Contracting Officer certifies that this justification is accurate and complete to the best of her knowledge and belief.
 

Prepared by Greg Forrest, Contracting Officer

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (BRIDGE)
In accordance with FAR Subpart 6.302-2 for
Janitorial/Custodial Services for EPA Research Triangle Park Campus
(Contract No. 68HERC24C0045)

Reviewed By:
Tommie Madison, Agency Advocate for Competition

APPROVED:
______________________________ _______________
Pamela D. Legare                                 Date
Director, Office of Acquisition Solutions (OAS)
Head of Contracting Activity and Senior Procurement Executive