JUSTIFICATION FOR OTHER THAN FULL & OPEN COMPETITION MODIFICATION TO EXTEND PERIOD OF PERFORMANCE AND INCREASE MAXIMUM ORDERING LIMITATION REGARDING ENVIRONMENTAL CONSULTING SERVICES BPA

1. Identification of the Contracting Activity and specific identification of this document as a - Justification for other than full and open competition: The contracting activity is the General Services Administration (GSA), Public Buildings Service (PBS), Acquisition Management Division, Program Support Branch (7PQA), 819 Taylor Street, Fort Worth, TX 76102. This document serves as the Justification for Other than Full and Open Competition. 2. Nature and/or description of action being approved: This justification for other than full and open competition is to enter a modification to extend the period of performance by six (6) months to 1/15/25 and increase the Maximum Ordering Limitation (MOL) by $2,000,000. This Blanket Purchase Agreement (BPA) for Environmental Consulting Services is a single award to small business utilizing the Federal Supply Schedule and encompasses all states in the Greater Southwest Region 7. 3. Description of supplies or services required to meet the Agency's needs (including the estimated value): On July 15, 2019, the Program Support Branch awarded a Blanket Purchase Agreement (BPA) utilizing the GSA Federal Supply Schedule (FSS) under the Environmental Services category to provide Environmental Consulting Services within the states of Arkansas, Louisiana, Oklahoma, New Mexico, and Texas. This negotiated procurement was accomplished by using a vendor evaluation plan which resulted in the award of a firm-fixed price Blanket Purchase Agreement (BPA) to the contractor quoting the best value to the Government. The Environmental Consulting Services BPA was for a period of one (1) year from the issuance of the BPA, with four 1-year option periods. The estimated value of this BPA had a maximum total combined value of $5,000,000 over five (5) years. There was no minimum guarantee of work and historically the total calls issued from June 2014 to July 2019 were $3,013,779. In accordance with FAR 8.405-3(a)(3)(iv)(B) and (C), the administrative cost of multiple awards and the scope and complexity of the requirement(s) were not deemed to be cost efficient or practical to support multiple award BPAs as there would not be enough work to support multiple contractors. The expected cost in the administration of multiple award contracts outweighed the expected benefits of making multiple awards, therefore multiple awards were not deemed to be in the best interest of the Government. Throughout this current five-year period the awarded BPA has been utilized and all options have been exercised. The acquisition team fully anticipated award of a new BPA prior to the expiration of the current BPA, however, there have been delays due to unforeseeable circumstances. The planning of subject re-procurement began in July 2023. During the planning stages, the Contracting Team has consulted with customers who utilize these BPAs for task order delivery to gain a better understanding of any improvements or changes that may be beneficial for the new procurement. After recurring and ongoing consultation, meetings and deliberation, a consensus of internal stakeholders deemed it necessary to update the Statement of Work to reflect a more accurate description of contractual needs and requirements. All appropriate feedback has been incorporated and an updated Statement of Work is promptly being finalized as consensus has been achieved. Additionally, the current BPA has received more use than in the past. As mentioned above, the total calls issued against it during the preceding five (5) year period from June 2014 to July 2019 totaled only $3,013,779. Currently, $4,896,724 in call orders have been issued against the current BPA. Due to the circumstances as described above, the current BPA needs to be extended to ensuresupport continues to allow the Acquisition Management Division the ability to meet the mission of its clients. In accordance with FAR 6.302-2(d) Unusual and Compelling Urgency, Period of Performance: the total period of performance awarded under this authority will not exceed one year. The current BPA awarded to Quaternary Resource Investigations, LLC, a small business, will be extended six (6) months from July 14, 2024, to January 15, 2025, to allow for the necessary additional time required for procurement of the new BPA and to ensure that the Government's requirements are met in the interim. In a comprehensive effort, the procurement team has also agreed upon the amount needed to render a seamless transition for environmental services to continue and optimize performance. The agreement is to increase the value of this current BPA by $2,000,000. This increase will accommodate the cited Total Need as well as provide coverage for any additional work that may occur prior to the new procurement award. 4. Identification of the statutory authority permitting other than full and open competition. This justification is being requested under the authority at FAR 6.302-2, Unusual and Compelling Urgency. 5. Demonstration that the proposed contractor's unique qualifications or nature of the acquisition requires use of the authority cited. GSA has been working on the procurement for a new Blanket Purchase Agreement (BPA) and fully anticipated award prior to the expiration of the current BPA. However, due to unexpected delays in response to changes in the Statement of Work (SOW), the follow-on BPA will not be awarded prior to the expiration of the current BPA. The current small business BPA expires on July 14, 2024; therefore, an extension of the current BPA is required to support the timeframe needed to complete the follow-on BPA and to ensure support will remain consistent. A lapse in contractual coverage would most likely result in a significant cost impact to the Government. The BPA in question provides an efficient and competitive procurement vehicle to achieve environmental service requirements because this BPA is often a necessary precursor in all construction projects and lack of such would cause a potential delay in the timeliness of construction projects and would likely result in extended procurement time, cost, and risk on behalf of the Government. This would jeopardize the Acquisition Management Division's mission to support the requirements of its customers in the most timely, practical, and efficient manner. A lapse in coverage, even for a brief period, would result in the following negative impacts: a) Significant delays in environmental services and subsequent construction requirement awards. The PALT for a call order against a BPA is 45-60 days depending on the estimated value whereas the PALT for an unrestricted contract is either 180 or 250 days depending on the estimated value. The additional procurement time would result in increased cost to the government, administrative burden, further delay and would jeopardize the mission of the customer. Many of the upcoming projects are time-sensitive and delays in accomplishing the work will result in the customer agency not meeting mission objectives. b) The loss of competitive pricing resulting in the government paying more through alternative procurement methods. If this BPA isn't available, most of our requirements would be issued through sole source contracts or unrestricted competition. This would detract from the benefits of competition, and we may not receive the best value available when a requirement is competed. Lack of competition could result in paying higher prices for requirements and result in unnecessary additional costs to the government. c) A loss of expertise in performance. Many projects are located at potentially complex work sites and may be remote. The current contractor was evaluated and awarded this BPA on a best-value basis with technical factors being significantly more important than price. If various contractors are awarded individual environmental projects at these complex sites, there would be a higher risk on performance. This would require program staff to spend more time monitoring work resulting in additional costs for project oversight. Additionally, more contractor-initiated modifications are also more likely as a result of new contractors being unaware of the usual issues that arise at typical work sites. Modifications after award place the government at risk for additional costs and delays to the construction schedule. d) Delays in starting services or performance because of possible delays in obtaining security clearances. The current BPA contractor already has many of the required clearances for the types of projects we execute which allows for work to start immediately after award. If new contractors are required for each project, the security clearance process would result in significant delays. 6. 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 described in FAR 6.302-2(c)(1) Unusual and Compelling Urgency which maintains - justifications may be made and approved after contract award when preparation and approval prior to award would unreasonably delay the acquisition. This modification for an extension and MOL increase would be issued to the current BPA contractor performing these environmental services in GSA PBS Region 7. The follow-on BPA will be competed amongst firms on the Federal Supply Schedule with the appropriate NAICS code to ensure maximum competition. 7. Determination by the Contracting Officer that the anticipated cost will be fair and reasonable: The anticipated cost was deemed to be fair and reasonable at time of contract award. General Services Administration (GSA), Public Buildings Service (PBS) submitted a Request for Quotes (RFQ) to solicit Environmental Consulting Services under SIN codes 899-1, 899-7, and 899-8 for the purpose of entering into a single-award Blanket Purchase Agreement (BPA) under an existing GSA schedule contract. Any firms that were interested in competing for this effort were encouraged to participate by submitting their quotation. The contractor will continue to charge the prenegotiated rates appropriate for Option Year IV during this extension. 8. Description of market research: Market research was conducted to award this BPA as a total small business set-aside and Federal Supply Schedules were utilized. In accordance with FAR Part 8 - Required Sources of Supplies and Services, FSS are a mandatory source to be used before going open market. Also, in accordance with GSA Administrator, Dan Tangherlini's memorandum dated October 11, 2012, existing GSA acquisition vehicles should be used before establishing new contracts for similar products or services. (Memo entitled - 06 Updated Preferred Use of Existing GSA Contract Vehicles 2012 10 11). 9. Any other facts supporting the use of other than full and open competition: The extension of the current BPA is in the best interest of the government. The lapse in this BPA vehicle to execute environmental services would significantly injure the government financially. It would also jeopardize the mission of AMD and the customer agencies it serves as GSA may not be able to meet the needs of the customer agencies in a most efficient and timely manner. 10. A listing of sources, if any, that expressed, in writing, an interest in the acquisition: None. 11. Statement of the actions, if any, the Agency may take to remove or overcome any barriers to competition before any subsequent acquisition for required supplies of services: The new procurement of Environmental Consulting Services will include a higher maximum ordering limitation in response to client needs. It will be competed to the maximum extent practicable to fulfill ongoing requirements for Environmental Investigations, Industrial Hygiene Investigations and Comprehensive Asbestos Surveys to support the mission of GSA Property Management Services, PBS, Region 7.