Interpretation of Definition: Consolidation of Contract Requirements V2.0

Hello All,

I have been searching WIFCON for information on the interpretation of consolidation want to piggyback off a post from 2013 (link provided at the bottom of the post). Essentially I am wondering if I am over interpreting the definition of consolidation. FAR 2.101 states:

“Consolidation or consolidated requirement”--

(1) Means a solicitation for a single contract, a multiple-award contract, a task order, or a delivery order to satisfy--

(2) Separate contract as used in this definition, means a contract that has been performed by any business, including small and other than small business concerns.

(i) Two or more requirements of the Federal agency for supplies or services that have been provided to or performed for the Federal agency under two or more separate contracts, each of which was lower in cost than the total cost of the contract for which offers are solicited; or

(ii) Requirements of the Federal agency for construction projects to be performed at two or more discrete sites."

(Bold for emphasis)

Below is the scenario: 

You have three separate contracts, each for a separate requirement, with the following costs:

1. $900,000

2. $100,000

3. $100,000

You plan to consolidate them into a single contract with total costs of $700,000.

Because Contract #1 cost $900,000 and is higher than the new requirement ($700k), is this an immediate "no, not consolidation" per the FAR definition? Or is it consolidation even though Contract #1 doesn't meet the full definition (because the cost is higher), Contract #2 and #3 do meet the definition? 

2013 discussion: