Description
Justification for Other than Full and Open Competition Part I ? Background 1. Date: April 2, 2015 2. Program Office: U.S. Environmental Protection Agency (EPA),Office of Solid Waste and Emergency Response (OSEWR), Office of Emergency Management (OEM) 3. COR: Ms. Portia Perry, (202)-564-2285 Lead Contract Officer?s Representative 4. Contract No. EP-W-08-036, Mission Support Contract for Regulation, Evaluation and Technical Support 5. Description of supplies or services required: The U.S. Environmental Protection Agency (EPA), Office of Emergency Management (OEM) has a requirement for Regulation, Evaluation and Technical Support performed by the contractor Systems Research Applications (SRA) International, Inc. The mission is to continue technical, evaluation, and regulatory development services to support EPA in developing and implementing prevention programs to reduce the risk of oil and hazardous substances to the environment and build preparedness capacity for responding to emergency events. 6. Period of Performance: May 5, 2015 ? August 4, 2015 7. Estimated Contract Amount: The purpose of this justification is to extend the period of performance of Award Term I under the current contract by three (3) months. This extension will not result in an increase in the contract ceilings for cost, fee and labor hours. The existing contract ceiling amounts for Award Term I in the amount of $8,285,026.50 for cost, $653,968.50 for fixed fee and 91,200 for labor hours remain unchanged. Upon expiration of Award Term I under the current contract on May 4, 2015, sufficient funds shall be obligated on the contract to ensure that there is no lapse in service under this mission critical contract. 8. Proposed Contractor: Systems Research Applications (SRA) International, Inc. 4300 Fair Lakes Court Fairfax, VA 22033-4232 Part II ? Justification Pursuant to the requirements of the Competition in Contracting Act (CICA), FAR Subpart 6.302-1 (Only one responsible source and no other supplies or services will satisfy agency requirements) prompts other than full and open competition. 1) Identification of the Agency and Contracting Activity. U.S. Environmental Protection Agency (EPA)/Office of Acquisition Management (OAM)/Office of Emergency Management 2) Nature and /or description of the action being approved. This action is to extend the existing contract for three months with Systems Research Applications (SRA) International, Inc. The EPA proposes to negotiate a 3-month contract extension on the basis of other than full and open competition. OEM has a requirement to continue technical, evaluation, and regulatory development services to support EPA in developing and implementing prevention programs to reduce the risk of oil and hazardous substances to the environment and build preparedness capacity for responding to emergency events. Those services include support to OEM in planning, implementing and evaluating the Agency?s chemical emergency preparedness, prevention, community right-to-know programs, and the Agency?s participation in national disaster and emergency preparedness and response programs, including counter-terrorism. This extension is necessary as the follow on, full and open competitive requirement is still in the proposal evaluation phase. This extension will ensure performance of critical services only until the re-competition process is completed. The Contracting Officer (CO) has determined that the only way to ensure these critical services go uninterrupted is to obtain support for these services with Systems Research Applications (SRA) International, Inc. This contractor is the only responsible contractor that can fulfill this requirement at this time because of the program office?s ongoing need for preparedness in the event of an emergency situation for which SRA currently plays an integral part. It would be more advantageous and cost effective to the Government to obtain services from SRA instead of the additional time and costs associated with locating another contractor who can perform work already in progress, in addition to the costs necessary to transition current, ongoing work to a new contractor. Proposed Contractor: Systems Research Applications (SRA) International, Inc. 4300 Fair Lakes Court Fairfax, VA 22033-4232 The estimated period of the three-month extension is from May 5, 2015 through August 4, 2015. The existing services are currently being performed by SRA under Contract No. EP-W-08-036. This contract was competed and awarded in accordance with FAR Part 15 procedures. Request for Proposals No. PR-HQ-08-10150 was synopsized and solicitation posted on Federal Business Opportunities (FedBizOpps) on October 26, 2007, and closed on January 29, 2008. Contract No. EP-W-08-036 was competitively awarded to Systems Research Applications (SRA) International, Inc. on May 2, 2008 and expires on May 4, 2015. 3) A description of the supplies or services required to meet the agency?s needs (including the estimated value). The critical mission of the support contract, provided by SRA, is to support OEM in its mission to reduce the risk of oil and hazardous substances to the environment and build preparedness capacity for responding to emergency events by leveraging management contract vehicles to achieve economies of scale while providing quality and timely services. SRA shall continue to support critical tasks currently being performed under EPA contract number EP-W-08-036, via work assignments. This extension combines those critical tasks and requires continued performance by SRA until the follow on contract is awarded. Furthermore, this extension does not allow for new work nor does it require performance of work that is not critical. The task areas under which SRA will continue performance are: ? Analytical Support. The contractor shall provide analytical support and obtain the necessary background information. The contractor shall provide assistance to EPA in preparing a variety of studies, regulations, technical analyses, compilations, general or technical guidance documents, other technical products and activities. ? Technical Assistance. The contractor shall provide technical assistance to EPA for a variety of projects and activities pursuant to OEM responsibilities in planning, implementing, and evaluating Agency responses. ? Conference/Meeting Support. The contractor shall provide logistical support for meetings, conferences, and workshops for all OEM activities under the SOW. The contractor shall facilitate national meetings related to OEM programs. ? Training Support. The contractor shall provide technical support for training and technical workshops for instruction and orientation in various aspects of OEM programs. ? Communications and Outreach Support. The contractor shall provide technical support for outreach activities which explain all OEM program activities. ? Program Evaluation Support. The contractor shall provide support to EPA for a variety of evaluative tasks concerning its programs. ? Management Systems and Planning Support. The contractor shall provide support in a variety of planning aspects and administrative options. 4) An identification of Statutory Authority Permitting Other than Full and Open Competition In accordance with 10 U.S.C. 2304(c) (1), 41 U.S.C. 253(c) (1), and FAR Subpart 6.302-1, it is determined that SRA is the only responsible source, and no other supplies or services will satisfy agency requirements at this time. A delay in extending this contract in order to complete the re-competition of services provided by the contract would place EPA at significant risk. The EPA currently does not possess the resources, financial or otherwise, to award a separate ?bridge contract? for technical, evaluation, and regulatory development services by May 4th 2015. It would take significant time and additional costs for another contractor to transition and assume the duties that SRA is currently performing. An example which highlights this fact is the inclusion of a 30-day transition plan as a matter of responsibility in the event that an offeror, other than the incumbent, receives the new award. Furthermore, there is no other EPA or Government-wide Acquisition Contracts (GWAC) available that provide the same or similar services that would satisfy the requirements under the current contract. The work performed under this contract provides critical services to the agency, and continuity of services is imperative at this time. A lapse in these critical services prior to the award of a new mission support contract would impact the EPA?s project timelines for overseeing the prevention programs to reduce the risk of oil and hazardous substances to the environment and build preparedness capacity for responding to emergency events and subject EPA to significant risks. 5) A demonstration that the proposed contractor?s unique qualifications or the nature of the acquisition requires use of the authority cited. According to the Contractor Performance Assessment Reporting System (CPARS) and the Past Performance Information Retrieval System (PPIRS), SRA has provided ?very good? to ?exceptional? service under this contract for over six years and possesses the institutional knowledge to provide uninterrupted and seamless support to OEM until the follow-on competitive award is in place. SRA has developed its capabilities during the course of performing under the current contract. Even under the best conditions, no other firm could acquire the knowledge and experience necessary to provide continued and timely services to support EPA in developing and implementing prevention programs (i.e., to reduce the risk of oil and hazardous substances to the environment and build preparedness capacity for responding to emergency events). The Pre-Solicitation Notice for SOL-HQ-15-00002 was posted on FedBizOpps on January 23, 2015. It is anticipated that the full solicitation for OEM?s Regulation, Evaluation, and Technical Support will be posted by the end of April 2015. 6) A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable. Upon approval, the Contracting Officer will post this justification as a special notice to FedBizOpps and FedConnect for 30 days to inform the general public and provide an opportunity for any interested parties to respond to the notice and actions therein. Any communications received in response to the notice will be reasonably considered. Furthermore, a solicitation for the re-acquisition of these services is currently in progress and OAM has conducted extensive outreach activities with industry by posting a pre-solicitation notice to promote and receive competition from additional sources. 7) A determination by the Contracting Officer that the anticipated cost to the Government will be Fair and Reasonable. At time of award, the labor rates and anticipated cost to the Government under the current contract EP-W-08-036 were determined to be fair and reasonable. The extension under the contract from May 5, 2015 through August 4, 2015 will incorporate the labor rates and escalation rate under the original contract for Award Term I. 8) A description of the market research. Extensive market research was conducted during the pre-award phase of the current contract. The Contracting Officer conducted market research to the extent that it researched in-house EPA contracts as well as other GWACs in search of sources that could readily perform the same or similar services that would satisfy the requirements under the current contract. Consequently, the Contracting Officer made the determination that there are no other EPA or GWACs that can readily satisfy the requirements under the current contract without benefit of a transition phase with the current contractor, which could result in untimely delays and quite possibly inferior performance, coupled with additional costs to the Government. 9) Any other facts supporting the use of other than full and open competition. Without the mission support contract services OEM would be unable to meet its responsibility of implementing preparedness, planning, prevention, response, and community right-to-know activities. SRA is the only responsible contractor with the corporate knowledge and critical information required to continue EPA?s efforts for the next three months in a timely, uninterrupted manner until the follow-on contract is awarded. A full and open competition to complete the remaining performance would cause unnecessary delay and additional costs. No barriers to future competition exist, as the 5-year follow-on contract is being competed using full and open competition. 10) A listing of sources, if any, that expressed in writing an interest in the acquisition. Based upon the rationale as contained in paragraphs 1 through 9 above, no other sources will be solicited for the period of the extension. 11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for supplies or services required. The Government will seek competition of future acquisitions for these services, thus eliminating the barriers to competition. Part III?CO?s Determination and Approval I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief. Therefore, I approve this action and deem it to be in the best interest of the Government in accordance with FAR 6.304(a)(2) and EPAAG 1.6.1.1, Item No. 8, Attachment A, June 2014. Recommended by: Meghan T. Meyers /s/ Contracting Officer Approved by: Lynette Gallion /s/ Contracting Officer, Team Leader