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Consolidation approval.

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I am having trouble determining who would sign my J&A for Consolidation.

I work for a Navy laboratory and I have a consolidation that is estimated to be $20 million. 

I am confused by the language in Annex 4 which says "Approval granted to increase current consolidation of contract approval thresholds from $2 Million to no more than $50 Million for STRL and less than $100 Million for Head of Contracting Activity (HCA)."

Is it saying that the threshold established in FAR 7.107-2(a) is raised from $2 million to $50 million and is approved by the HCA if between $50 and $100 million? If so, who is the approving authority for below $50 million, the KO?

If the threshold is raised to $50 million, does that mean the stricter requirements of FAR 7.107-2(a) are not required and there is a lower threshold for justification required implied by the increase in the threshold?

Or, am I mistaken, who is the approval authority for less than $2 million and the justification requirements?

I am on a small procurement team and no one has done this before so I'm in the dark and curious.

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16 hours ago, Don Mansfield said:

I'm confused, too. It doesn't make sense.

Having said that, I think the deviation relieves STRL from having to comply with FAR 7.107-2 for contracts < $50 million.

So no need for a determination in writing?

Having said that, would it be best to still make a determination? Or, if factoring in the possibility of this being protested it would be best not to document that.

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46 minutes ago, Don Mansfield said:

Well, ASN(RDA) relieved STRL from the burden of the making the determination. How do you think they would react if you did it anyway?

I don't know...

I've never had any interaction with ASN(RDA).

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