01_Justification_for_Other_Than_Full_and_Open_Competition-Final_Redacted.pdf

Solicitation Number: 140R4026Q0163 Page 1 of 5

WBR 1406.303-1 Template 1 eFile - B02

(06/2026)

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION

Updated IAW Revolutionary FAR Overhaul 6 and DOI-AAAP-F006

Updated IAW Revolutionary FAR Overhaul 13 and DOI-AAAP-F013

In accordance with Revolutionary FAR Overhaul 6.103, the proposed contractual action is pursuant to the statutory authority identified in paragraph 4. This template is required for actions over the Simplified Acquisition Threshold (unless the procurement is acquired as a sole source IAW GSAM/R 538.7104-3 or is an Exception to Fair Opportunity IAW FAR 16.505(b)(2)).

1. Agency and Contracting Activity (FAR 6.104-1(a)(1)). U.S. Department of the Interior, Bureau of Reclamation, Acquisition Management Division (AMD)

2. Nature/Description of Action (FAR 6.104-1(a)(2)). The Bureau of Reclamation, Glen Canyon Field Division, seeks to procure one compressor pump to enhance redundancy in the High Pressure Governor Air System at Glen Canyon Dam, located approximately one mile west of Page, Arizona, on Highway 89.

3. Description of Supplies/Services (FAR 6.104-1(a)(3)). One Ingersoll Rand Type 30 Series High Pressure Reciprocating Air compressor pump BARE 15T2 W/LOS with standard filter silencer. Delivery is required as soon as possible. The estimated value of the procurement is .

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4. Statutory Authority Permitting Other than Full and Open Competition (FAR 6.104- 1(a)(4)). (Check one)

Authority FAR Coverage Application

41 U.S.C. 3304(a)(1) FAR 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements

41 U.S.C. 3304(a)(1) FAR 6.103-1(d) Application for brand-name descriptions

41 U.S.C. 3304(a)(2) FAR 6.103-2 Unusual and compelling urgency

41 U.S.C. 3304(a)(3) FAR 6.103-3 Industrial mobilization; engineering, developmental or research capability; or expert services

41 U.S.C. 3304(a)(4) FAR 6.103-4 International Agreement

41 U.S.C. 3304(a)(5) FAR 6.103-5 Authorized or required by statute

41 U.S.C. 3304(a)(6) FAR 6.103-6 National Security

41 U.S.C. 3304(a)(7) FAR 6.103-7 Public Interest

5. Demonstration of Contractor’s Unique Qualifications (FAR 6.104-1(a)(5)).

This is a brand name requirement. It does not limit competition to one contractor.

6. Description of efforts made to maximize competition (FAR 6.104-1(a)(6)).

The Government researched alternative manufacturers to determine whether a non-brand-name product could meet the required physical compatibility, motor, and performance specifications. Quincy Compressor's QB series is the only Quincy model rated for the required 580 psig, but its minimum configuration at that pressure delivers approximately

102.8 cfm — roughly double the Government's required 52 cfm. Gardner Denver's 15 hp compressor pump does not match the physical footprint required to fit within the existing Ingersoll Rand Series 30 compressor assembly. Bauer Compressors' Medium-Pressure Systems line includes units rated for 580 psig, but only in a 20–100 hp range that does not match the Government's required configuration; Bauer's High-Pressure Systems line (5,000–6,000 psig) uses a fundamentally different mechanical design not suitable for, or safely adaptable to, the Government's requirement. Hydro-Pac's product line is oriented toward specialized gas compression applications (e.g., hydrogen compression, cylinder filling, isostatic pressing) and does not offer a comparable general-purpose compressor pump.

This research confirmed that no alternative manufacturer offers a product compatible with the existing Ingersoll Rand Series 30 compressor without modification, further supporting the necessity of the brand-name requirement. Notwithstanding this restriction, the acquisition will be publicly synopsized through the Governmentwide Point of Entry (GPE) and solicited as a total small business set-aside. Market research identified two (2)

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(06/2026) small business concerns capable of supplying the required Ingersoll Rand Type 30 Series pump; however, the solicitation is not restricted to only those two sources, and all responsible small business sources may submit a quote for consideration.

7. Determination of Fair and Reasonable Cost (FAR 6.104-1(a)(7)).

The Contracting Officer anticipates that the price resulting from this acquisition will be fair and reasonable. Although solicited as a brand-name requirement, competition will not be restricted to a single source — two (2) small business concerns capable of supplying the required item have been identified, and the requirement will be competed among those sources, and any other responsible small business that responds to the public solicitation, as a total small business set-aside.

Price reasonableness will be determined through price analysis in accordance with FAR 15.404-1(b)(2), specifically by comparing proposed prices received in response to the solicitation against one another (FAR 15.404-1(b)(2)(i)) and against the Contracting Officer's Independent Government Estimate (IGE) of . If adequate price competition is obtained (two or more responsible small business offers competitive in terms of price), that competition, in comparison with the IGE, will serve as the primary basis for the fair and reasonable price determination. If adequate competition is not obtained, the Contracting Officer will perform additional price analysis, which may include comparison with prices paid under other contracts for the same or similar items and/or a request for additional pricing information from the offeror.

8. Description of Market Research Conducted (FAR 6.104-1(a)(8)).

The Contracting Officer conducted market research to determine whether this requirement could be met through full and open competition among multiple manufacturers, rather than a brand-name restriction. This included consultation with the technical point of contact on compatibility requirements — mounting dimensions, motor horsepower, and outlet port/piping configuration — and review of manufacturer product literature for Quincy Compressor, Gardner Denver, Bauer Compressors, and Hydro-Pac (findings detailed in Section 6, above). The research also identified two (2) small business concerns capable of supplying the required Ingersoll Rand Type 30 Series pump.

Based on this research, no alternative manufacturer offers a pump that is physically, mechanically, and operationally compatible with the existing compressor without modification to the frame, motor interface, or piping — modifications that would introduce unacceptable cost, delay, and risk to a critical, continuously operating dam safety system. The Government therefore determined that a brand-name restriction to the Ingersoll Rand Type 30 Series is necessary, while competing the requirement among multiple identified small business sources as a total small business set-aside. For future replacement or modernization of this system, the Government will consider whether standardizing on more broadly compatible equipment could increase competition in later acquisitions, balanced against reliability and integration needs.

9. Any Other Supporting Facts (FAR 6.104-1(a)(9)).

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The Ingersoll Rand Type 30 Series High Pressure Reciprocating Air Compressor pump, BARE 15T2 W/LOS, is essential to meet the Government's requirement because the replacement pump must be installed into an existing Ingersoll Rand Series 30 compressor unit as part of the High Pressure Governor Air System at Glen Canyon Dam. Three compatibility requirements drive this necessity: (1) mounting compatibility — the pump's mounting points must match the existing compressor assembly's dimensions, as a mismatch would prevent installation without modifying the compressor frame; (2) motor compatibility

— the pump must match the existing motor's horsepower rating, since a lower-horsepower pump would be unable to adequately drive the system, while a higher-horsepower pump would risk exceeding the motor's rated capacity, causing damage, overload, or premature failure; and (3) piping compatibility — the pump's outlet port dimensions must match the existing high-pressure piping configuration, as a mismatch would require reconfiguring piping in a critical 580 psig system, introducing added cost, schedule delay, and risk of error.

As detailed in Sections 6 and 8, market research confirmed that other manufacturers' compressor pumps, while potentially similar in general function, do not match the mounting dimensions, motor compatibility, or outlet port configuration required to install directly into the existing compressor without modification — modifications that are not practical for a critical, continuously operating dam safety system. Accordingly, the Government has determined that the Ingersoll Rand Type 30 Series pump is essential to meet its minimum needs, and that no other manufacturer's product can be modified to meet these needs without unacceptable cost, delay, or risk.

10. Listing of Interested Sources (FAR 6.104-1(a)(10)). None

11. Actions Taken to Remove Barriers to Competition (FAR 6.104-1(a)(11)).

As detailed above, market research confirmed that no viable alternative to the Ingersoll Rand Type 30 Series pump exists that would meet the Government's compatibility requirements without significant modification, added cost, schedule delay, and risk to a critical dam safety system. To preserve competition to the maximum extent practicable within this constraint, the requirement is being competed as a total small business set-aside among the two (2) small business concerns identified, and the solicitation will be publicly posted to the GPE to provide notice to any additional capable small business sources.

For future acquisitions of this type, the Government will consider: evaluating, at the time of future equipment replacement, whether replacing the entire compressor unit (rather than only the pump) with a more broadly available make/model would enable multi-manufacturer competition on subsequent replacement parts; encouraging program/engineering staff to weigh long-term parts availability and multi-vendor compatibility in standardization decisions for critical infrastructure, balanced against reliability and integration needs; and continuing to conduct market research on future requirements of this nature to confirm whether compatible alternatives have entered the market since the original equipment was installed.