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JUSTIFICATION REVIEW DOCUMENT FAR SUBPART 13.5 SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS – SOLE SOURCE JUSTIFICATION AND APPROVAL Program/Equipment: Department of Public Works, Fort Benning, ... JUSTIFICATION REVIEW DOCUMENT FAR SUBPART 13.5 SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS – SOLE SOURCE JUSTIFICATION AND APPROVAL Program/Equipment: Department of Public Works, Fort Benning, GA, Grounds Maintenance Services. Authority: Simplified Procedures for Certain Commercial Items, 41 U.S.C. 1901 as implemented by FAR Subpart 13.5. Amount: $2,007,470 ***INFORMATION REDACTED*** FAR Subpart 13.5 Simplified Procedures for Certain Commercial Items Sole Source Justification and Approval 1. Contracting Activity: U.S. Army Mission and Installation Contracting Command (MICC)-Fort Benning, 6650 Meloy Drive, Fort Benning, GA 31905-1300. 2. Description of Action: The Fort Benning Department of Public Works (DPW), requests a firm-fixed-priced bridge contract for six (6) months with the incumbent contractor, U.S. Grounds Maintenance, Inc., 309 E 35th Ave., Bellevue, NE 68005-5601, to provide ground maintenance service on Fort Benning, Georgia. This bridge contract is required to maintain continuity of service of a bridge contract that will end 22 June, 2020 to address the immediate need for grounds maintenance service at Lawson Army Airfield (LAAF) and ranges. The Government projects award for June 2020 and fiscal year 2020, Operations and Maintenance, Army funds will be used for the base period. This action is a follow-on to contract W911SF-20-D-0008 which was awarded under other than full and open competition citing Unusual and Compelling Urgency under authority of Title 10 U.S.C. 2304(c)(2) as implemented by FAR Part 6.302-2. Paragraph, “Actions to Increase Competition” of the previous justification, stated: “Competition for this bridge contract is not possible given the time constraints to award a new contract prior to the start of the growing season at Fort Benning. The purpose of this bridge is to provide for urgent services during the time necessary to re-compete the requirement per FAR 6-302-2(d)(1)(i). The follow-on contract for this service will be competed as was the previous contract that expired.” 3. Description of Supplies/Services: This bridge contract will provide critical grounds maintenance service to LAAF and other key training areas for improved grounds, semiimproved grounds, and unimproved grounds for a period of six (6) months until a followon contract can be awarded. The average frequency of cutting will vary based on the area and season. The average cutting frequency may be every 7-10 days, 14-17 days, 21-30 days, or 30 days to maintain areas on Fort Benning. This includes LAAF, all facilities and ranges on Main Post, Benning Boulevard, Dixie Road, 101st Airborne Division Road, and other facilities and ranges in the various cantonment areas on the Fort Benning installation. The work performed in these areas by the Contractor shall include mowing grass, edging and trimming grass, removing grass trimmings from paved areas, irrigating, aerating lawn areas, applying fertilizer and/or lime, applying herbicide to lawn, airfields, training areas, ranges and landscape areas, maintaining plants, shrubs, and flowers, performing seasonal planting of plants and flowers, removing leaves, applying mulch, pruning trees, removing grass from cracks in sidewalks and pavements, and litter control. This contract is also being used to provide grounds maintenance services to the LSA and to the previously moth-balled barracks at North Kelley Hill and Sand Hill. Period of Performance: 29 June 2020 to 31 December 2020 Total Value: $ 2,007,470 4. Authority Cited: Simplified Procedures for Certain Commercial Items, 41 U.S.C. 1901 as implemented by FAR Subpart 13.5. 5. Reason for Authority Cited: The incumbent contractor, Grounds Maintenance, Inc., is the only source that can perform this requirement over the proposed period of performance. a. Background. Contract W911SF-20-D-0008 was awarded as a bridge contract with a period of performance from 23 March 2020 through 22 Jun 2020 to provide critical grounds maintenance service to Fort Benning after the expiration of W911SF-19- D-0001 on 31 December 2019 because there was inadequate time to competitively award a follow-on competitive contract with the growing season well underway at Fort Benning which began in March. Fort Benning is responsible for training over 80,000 Soldiers every year through the combination of the following courses and schools: Ranger School, Airborne School, Infantry One Station Unit Training (OSUT), Armor OSUT, NCO Academy, Advance Officer Training School, Officer Candidate Course, and the U.S. Army Sniper School. Fort Benning plays an instrumental role in training and preparing Soldiers for combat which is a critical capability in securing our nation security. Grounds Maintenance at LAAF is a high priority for the Garrison Commander. Lack of grounds maintenance around the airfields can contribute to restricted use of airfields and in turn affect training missions that rely on aircraft. The height of the grass at the airfield impacts the Navigational Aids (NAVAIDS) around critical areas. High grass also disrupts navigational signals for the Instrument Landing System, Fixed Based Precision Approach Radar and the Very High Frequency (VHF) Omnidirectional Range (VOR) system. Disruption of signals becomes a life and health safety issue for the aircrews and airfield. The priority of grounds maintenance at LAAF are the critical areas around the NAVAIDS, followed by the runway and taxiway areas, and signs and lights which are critical to guiding aircraft. At the time the initial bridge contract (W911SF-20-D-0008) was awarded on 23 March 2020, the height of the grass around the LAAF exceeded 12 inches. Some grass discourages flocking species from foraging on the airfield because reduced visibility disrupts inter-flock communication and flock integrity by reducing the ability to detect predators. However grass exceeding 12 inches attracts birds and rodents, which in turn attracts snakes and other predators. This increases the risk of aircrafts striking birds and other animals such as coyotes and deer. The best way to reduce this hazard is taking away the habitat and cover created by high grass. Grounds maintenance is also critical on certain ranges where Soldier trainees are conducting live fire exercises, to include weapon qualifications. High grass impedes the trainees’ field of view. Tall grass on Fort Benning at this time of the year can conceal the presence of snakes, rodents, deer, and other animals which poses a safety risk to the trainees. During COVID-19, the cancellation of permanent change of station (PCS) and other travel increased the number of Soldiers remaining on the installation.Therefore, ranges were used to provide additional training due the fact that the Soldiers could safely train while maintaining the required social distancing. b. COVID-19 Impact. COVID-19 has had a significant impact on services at Fort Benning. Some services have seen a reduction in support as installation access has become much more restrictive and the requirements to enter have been tightened. The incumbent contractor already has the required clearances and gate passes which allows them to enter the installation. While some services have been reduced, others, unknown at the time of bridgecontract W911SF-20-D-0008, emerged rapidly in response to COVID-19. For example,in March, because of its mission, Fort Benning engaged the Logistics Civil Augmentation Program to establish a remote Life Support Area (LSA) where incoming and outgoing Soldiers could quarantine for two weeks, away from the base population, as they prepared either to PCS to their next duty station or prepared to enter OSUT or other training. Also, Fort Benning reopened N. Kelley Hill and Sand Hill barracks to accommodate those stricken with COVID-19. Each of these actions were high priority and required intense support from this office. Each of these areas are large andrequired preparation and maintenance. The Grounds Maintenance contract was used to prepare the LSA. In preparation for the establishment of the LSA, the grounds maintenance contract was used to cut the grass in the area which had not been previously maintained. The grounds maintenance contract is still being used to maintain the LSA grounds for physical fitness. The Grounds Maintenance contract is also used to cut grass around N. Kelley Hill Barracks and Sand Hill Barracks where Soldiers live who are under COVID-19 quarantine or Soldiers who are in isolation due to testing positive to COVID-19. c. The requested period of performance for this bridge contract is 6 months beginning 29 June 2020 through 31 December 2020. The length of the period of performance is necessary to accommodate the increased OPTEMPO caused by COVID-19 and to manage the height of growing season at Fort Benning. The impact of COVID-19 on the operations at Fort Benning has and will continue to require significant contracting effort from this office. The COVID-19 pandemic seriously interrupted normal operations while adding COVID-19 response requirements unforeseen at the time of the award of bridge contract W911SF-20-D-0008, supra. It cannot be known at this time how much of an impact COVID-19 will continue to have on the OPTEMPO at MICC-Fort Benning, but it is reasonable to expect turbulence for the next 6 months as indicated by MICC Headquarters extending telework through December 31, 2020. Also, because the Grounds Maintenance contract is now supporting the COVID-19 requirements mentioned earlier and because last year Fort Benning experienced an unusually warm winter, coupled with the significant rainfall, extending the growing season well into December, a 6 month period of performance is necessary. Awarding this 6 month sole source bridge contract to the incumbent, will avoid a lapse in service of grounds maintenance, continue to provide COVID-19 support, provide the flexibility needed to focus on higher priority emerging COVID-19 requirements, and provide the time necessary for MICC-Fort Benning to competitively award a new contract. d. Alternatives. (1) Allowing the contract to expire and suspend services until the follow-on competitive contract is awarded. Not extending the contract will result in no grounds maintenance being performed to support the requirements mentioned supra. Failure to bridge the contract W911SF-20-D-0008 would allow the growth of grass and weeds affecting the appearance of Fort Benning. Although Fort Benning has a BASOPS contract that is currently providing grounds maintenance for the cemetery and small areas around buildings, modifying this contract to accommodate these requirements is not possible. The current contractor has the type of equipment, size of equipment and personnel needed to cut the massive amount of acres required on Fort Benning. The Installation has over 15,000 acres of grass cut every month which is required to prevent any impacts to training for the Soldiers. The BASOPS contractor is not equipped to cut this amount of acres. The BASOPS contractor has smaller finishing type mowers for maintaining much smaller areas. The also do not have bush hogs and tractors needed to cut 15,000 acres a month. In order to provide this type of service the BASOPS contractor would have to either rent or purchase heavy duty tractors which would increase the contract by several million dollars. The BASOPS contractor also does not have certified personnel on hand to apply the herbicides needed for weed control. (2) Perform services with Government Resources. This is not a viable option. DPW is not staffed to perform the services required thus rendering this alternative unrealistic and unachievable within the time available. (3) Award a new, competitively awarded, short term contract until the follow-on can be awarded. This is not a viable option at this time. Because of the increased OPTEMPO, and continued strong potential for higher priority efforts necessary to respond to COVID-19, there is not adequate time to complete a procurement for a competitive contract by the end of the current contract performance end date of 22 June 2020. e. Additional Supporting Information. On May 21, 2020 a notice of intent to sole source was posted on beta.SAM.gov for 30 days and no responses were received. Based on the lack of responses (none), the incumbent contractor, Grounds Maintenance, Inc. is the only source willing and able to perform this requirement over the proposed period of performance. Market research determined there is no other contractor with existing capability to mobilize sufficient personnel and equipment in the allotted time to maintain the standard of services required by this contract. Successful performance would require the contractor to have the equipment and personnel in place at the time of start of performance on 29 June 2020 to perform grounds maintenance on approximately 184,000 acres. The logistics involved would take at least 30 days before full performance could be started, provided there was time to complete a competitive procurement. Any lapse in service is unacceptable based upon the critical nature of this requirement. Also, the performance of grounds maintenance services for such large acreage requires a significant investment in equipment. Grounds Maintenance, Inc. invested $1.5 million in new equipment to perform grounds maintenance services for the approximately 184,000 acres on Fort Benning, GA. under contract W911SF-19-D-0001. It is not realistic to think that another contractor would make such a significant investment during the brief period of time that is covered by this interim bridge action. f. Impact if justification not approved. If this request is not approved, it would significantly impact on the core mission of Fort Benning. All Armor, Infantry, and Airborne training on the ranges would be delayed or stopped and LAAF would be rendered unusable for any aircraft operations, to include airborne training. 6. Efforts to Obtain Competition: As required by FAR 5.201, a notice of intent to sole source was posted on 21 May 2020 for 30 days on beta.SAM.gov. Completion of a competition for this bridge contract is not possible given the time constraints without incurring an unacceptable lapse in service for grounds maintenance during the pandemic and the growing season at Fort Benning, GA. 7. Actions to Increase Competition: The previous J&A for W911SF-20-D-0008 indicated that the 3 month bridge contract was sufficient to competitively award a follow on contract. This did not take into consideration the pandemic. Once COVID-19 struck, this office’s priorities and efforts focused on the COVID-19 response (i.e., LSA and N. Kelley Barracks). This took considerable effort. A present and contributing factor that prevented a competitive acquisition within the 3 months of the bridge contract was lack of staffing. Then and now the MICC-Fort Benning office is understaffed by 12 contracting personnel while having the second largest obligation requirement for a subordinate contracting office under Field Directorate Office-Fort Eustis. Still, once the turbulence created by COVID-19 and mass telework settled, this office posted the sole source notice on May 21, 2020, held a kick off meeting on May 29, 2020 and continues to move toward a competitive acquisition. A competitive award of the follow-on contract is projected by 25 December 2020. 8. Market Research: A notice of intent was posted on 21 May 2020 for 30 days ending 21 June 2020. During those 30 days there was no feedback from any contractor that they were interested in this 6 month requirement. 9. Interested Sources: The notice of intent was posted on 21 May 2020. To date, no other sources have written to express interest in the acquisition. 10. Other Facts: a. Procurement History: Contract W911SF-20-D-0008 / Contractor: U.S. Grounds Maintenance, Inc. / Award Date: 23 Mar 2020 / Competitive Status: FAR 6.302-2, Urgent and Compelling Contract: W911SF-19-D-0001 / Contractor: U.S. Grounds Maintenance, Inc. / Award Date: 17 October 2018 / Competitive Status: Full and Open Competition after exclusion of sources, Small Business Set Aside Contract: W911SF-18-P-0014 / Contractor: Roberts Treescaping, LLC / Award Date: 22 February 2018 / Competitive Status: FAR 6.302-1, Only one source Contract: W911SF-14-C-0015 / Contractor: Residential Enhancements, LLC / Award Date: 29 September 2014 / Competitive Status: FAR 6.302-5, 8(a) sole source Contract: W911SF-12-D-0004 / Contractor: Roberts Treescaping, LLC / Award Date: 9 February 2012 / Competitive Status: Full and Open Competition after exclusion of sources, Small Business Set Aside Contract: W911SF-11-D-0008 / Contractor: U.S. Grounds Maintenance, Inc. / Award Date: 9 June 2011 / Competitive Status: Full and Open Competition after exclusion of sources, Small Business Set Aside 11. Technical Certification: I certify that the supporting data under my cognizance which are includeded in the justification are accurate and complete to the best of my knowledge and belief. ***SIGNATURE REDACTED*** 12. Requirement Certification: I certify that the supporting data unde my cognizance which are includeded in the justification are accurate and complete to the best of my knowledge and belief. ***SIGNATURE REDACTED*** 13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable. This determination will be made using price analysis, historical data and fair market price comparisons. As pat of this basis, certified cost or pricing data will not be required in accordance with FAR 15.403, as this is a commercial item being acquired. ***SIGNATURE REDACTED*** 14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief. ***SIGNATURE REDACTED*** Approval Based on the foregoing justification, I hereby approve the procurement of grounds maintenance services on a sole source basis pursuant to the authority of the Simplified Procedures for Certain Commercial Items, 41 U.S.C. 1901 as implemented by FAR Subpart 13.5. The estimated value of the contract is $2 million for a period up to six (6) months from 29 June 2020 to 31 December 2020. The approval is subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition. *Signed By: SCOTT D. KUKES, Alternate to the Command Advocate for Competition U.S. Army Mission and Installation Contracting Command, JBSA Fort Sam Houston, TX