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In sum, following its decision to cancel the exclusive-use procurement in April 2017, the agency was left without a stand-alone contract vehicle to procure SEAT flight services for guaranteed, extended periods of time, as it anticipated it would have in place. 21.5(a); Poly-Pacific Techs., Inc., B-296029, June 1, 2005, 2005 CPD 105 at 3. Although challenges to the relaxation of contract requirements are less common than challenges to contract modifications that enlarge a contracts scope of work, our Office recognizes that both fall within the scope of this exception, and we will consider whether modification of performance requirements result in work that should be subject to competition. In determining whether a modification triggers the competition requirements in CICA, our Office looks to whether there is a material difference between the modified contract and the contract that was originally awarded. The changes to the purchase descriptions of the boats and motors are relatively minor when viewed against the entirety of all of the contract specifications and performance requirements. The contract remains a five-year contract as awarded in 2013, and will expire on September 24, 2018. In addition, the downward equitable adjustment extending the option year ordering prices to the following years prices for the remaining years of the contract is relatively small, and is a function of the contracts first article approval clause operating precisely as the contract intended. See Emergent Bio Solutions, Inc., B-402576, June 8, 2010, 2010 CPD 136 at 10-11 (modification to contract did not change the original objectives of the contract given the broadly defined developmental nature of the requirement for an anthrax vaccine).

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