1.5.1-J A Redacted.pdf

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3006.301-90

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

J&A-25-0356

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) in accordance with the requirements of FAR 6.303-1. The justification for the use of the statutory authority under FAR Subpart 6.3 is based on the following facts and rationale required under FAR 6.303-2 as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), U.S. Immigration and Customs Enforcement (ICE), Office of Acquisition Management (OAQ), proposes to enter into a contract on behalf of the Office of Asset and Facilities Management (OAFM) on a basis of other than full and open competition.

2. Nature and/or description of the action being approved.

(a) Type of action: Firm-Fixed-Price (FFP); Purchase Order

(b) Amount of the current J&A: $1,158,404.00

(c) Brief Description: ICE intends to procure, on a sole source basis, upfitting and graphic wrap design and application for newly purchased law enforcement vehicles from the following vendor:

Castle Hill Partners, Inc.

311 W Duane Avenue, Sunnyvale, CA 94085

UEI: W32AQK4BCKG3

CAGE/NCAGE: 14QV0

Expiration date in SAM.gov: 08/14/2026

3. Description of Supplies/Services.

The scope of this acquisition is for the upfitting and graphic wrap design and application of law enforcement vehicles; eighteen (18) 2025 Chevrolet Tahoe sport utility vehicles, one (1) Ford Raptor truck and one (1) Yukon sports utility vehicle. The said vehicles will be utilized for the purpose of supporting newly recruited individuals in the positions of Inspection, Investigation, Enforcement, and Compliance Officers, and Enforcement and Removal (ERO) Deportation Officers, under code 1801, as well as Criminal Investigator, and Homeland Security Investigation (HSI) Investigators, under position code 1811.

Period Time Total Base 30 Days $1,158,404.00

Total $1,158,404.00

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

4. Identification of statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 41 U.S.C. §3304 as implemented by:

FAR Subsection 6.302-1: Only one responsible source and no other supplies or services will satisfy agency requirements.

6.302-2: Unusual and compelling urgency.

6.302-3: Industrial mobilization; engineering, development, or research capability; or expert services.

6.302-4: International agreement.

6.302-5: Authorized or required by statute.

6.302-6: National security.

6.302-7: Public interest.

This requirement does not facilitate the response to or recovery from a natural disaster, act of terrorism, or other man-made disaster. The applicable period of performance limitation for this requirement is FAR 6.302-2(d).

5. Demonstration that the nature of the acquisition requires use of the authority cited.

ICE/OAQ intends to procure services for upfitting and graphic wrap design and application of recently purchased ICE vehicles for law enforcement use, eighteen (18), 2025 Chevrolet Tahoe sport utility vehicles, one (1) 2025 Ford Raptor truck and one (1) 2025 Yukon sports utility vehicle. Pursuant to FAR 6.302-2: The agency’s need for the services is so urgent and compelling that providing full and open competition would result in unacceptable delays and seriously hinder the Government’s recruiting initiative.

This requirement is fully supported by USC Title 8 and HR.1 One Big Beautiful Bill Act (OBBBA) statute, as well as the Presidential Executive order Restoring Law and Order in the District of Columbia. The procurement of marked law enforcement vehicles is critical to ensure newly recruited officers/agents are fully equipped and operational without delay.

The unusual and compelling urgency is driven by the immediate need to equip and deploy newly recruited officers with properly marked and up-fitted law enforcement vehicles. Without these services, vehicles cannot be safely or legally deployed, leaving officers idle and undermining recruitment timelines, public safety, and mission readiness. Delays in vehicle availability would create operational gaps, liability risks, and hinder enforcement operations.

Currently, there are no strategic sourcing vehicles in place for such procurements. Due to the urgent and time-sensitive nature of this requirement, alternative sources are not feasible, as they are unable to meet the immediate delivery timeline critical to ICE’s operational needs.

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

Competitive procedures would result in unacceptable delays and fail to ensure the timely acquisition of the required services.

Based on the unusual and compelling urgency stated above, the sole source procurement method/strategy must be pursued to meet mission-critical timelines. FAR 6.302-2 which permits sole source procurements when the Government need for the supply or service is of such an unusual and compelling urgency that the Government would be seriously injured unless the agency is permitted to limit the number of sources from which it solicits bids or proposals. In this instance, the absence of a strategic sourcing vehicle, and vendors confirmation of their inability to fulfill the need within the required timeframe, necessitates this exception to full and open competition. Additionally, vendors who indicated potential compatibility to meet the timeline, were not resisted in SAM.gov, a prerequisite for conducting business with the federal Government.

The timeframe required is immediate deployment of marked and upfitted ICE law enforcement vehicles to the field, to support the onboarding of new recruits. Any delay would prevent these officers from being properly equipped, resulting in idle personnel, lost enforcement capacity, and heightened risk to public and officer safety. Market research confirmed that vendors capable of performing were either unable to meet the accelerated window or not eligible to receive an award due to lack of SAM registration.

Failure to approve this J&A will prevent timely upfitting and wrapping of the recently purchased law enforcement vehicles, essential for newly hired staff. Without these services, the agency’s operational readiness will be degraded, and its capacity to effectively support USC Title 8 operations will be significantly reduced. This directly impacts mission success in meeting the anticipated surge in staffing and enforcement requirements projected from 2026 through 2029.

This constitutes the “serious injury” to the Government contemplated under FAR 6.302-2. The immediate upfitting and wrapping of these vehicles is critical to operational readiness, officer safety, and ICE’s ability to field new personnel. Without properly marked and equipped vehicles newly hired staff cannot be deployed to the field, delaying the enforcement surge required to meet statutory and operational demands. Such delays create an operational gap that diminishes enforcement, undermines recruitment objectives, and places both public and officer safety at risk.

The urgency of this timeframe is therefore unavoidable; if the vehicles are not upfitted and wrapped immediately, ICE’s ability to put new officers on the streets is lost, directly impairing mission success.

Castle Hill Partners Inc. is uniquely positioned to fulfill this requirement, having confirmed their ability to fulfill ICE’s requirement by having the necessary capacity within the specified immediate delivery timeframe. Unlike other sources consulted, that are unable to meet the urgent delivery schedule or only perform partial services, upfitting or graphic wrap design and application, Castle Hill Partners LLC. can provide both services without delay. Given the critical need to support ongoing hiring efforts, proceeding with Castle Hill Partners Inc. as the sole source vendor is both justified and in the best interest of the Government. The Government acknowledges concern regarding quality and cost, while Castle Hill Partners is the only vendor able to perform both services within the immediate urgent timeframe, ICE will not rely solely on their representation. The Contracting Officer will ensure that a detailed Statement of Work with performance specifications is incorporated into the award. The first vehicle completed will undergo inspection of workmanship, compliance with agency standards, and safety requirements

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304 prior to acceptance and continued performance. This approach mitigates risks by confirming that quality matches cost while maintaining the operational urgency required under FAR 6.302-2.

Given the urgent operational need, limited vendor capacity to meet the full specification and the requirement for immediate delivery timeline, competition is impracticable. An award to the identified vendor is necessary to ensure mission readiness and continuity of staffing operations.

6. Description of efforts made to ensure that offers are solicited from as many potential sources as is practicable.

OAQ intends to publicize this requirement, prior to award, as required by subpart 5.2 by posting a notice on sam.gov on _________________(insert month/day/year)].

OAQ does not intend to publicize this requirement, prior to award, based on the following 5.202(a)(2).

The intent of this procurement is to ensure that only the most reliable services are acquired by ICE within the required timeframe to support mission critical activities. Given their immediate ability to meet all technical specifications and delivery requirements, this can only be achieved through Castle Hill Partners INC.

7. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer (CO) determines that the anticipated cost to the Government will be fair and reasonable based on a comparison of the proposed pricing with prevailing industry standards for similar vehicle wrapping services.

8. Description of market research.

Market research was conducted in response to ICE Deputy Director’s request for the immediate graphic wrap design and application of ICE law enforcement vehicles on Friday, August 7, 2025.

ICE conducted market research to evaluate potential sources via telephone, e-mail, and internet searches, to assess availability, delivery, timelines and compliance with required specifications.

While several vendors offered these services most were unable to meet the agency's full specification within the required time frame due to short notice, lack of registration in SAM.gov or inability to perform both services, upfitting and wrapping. Ultimately, only one vendor was able to meet all the requirements including the delivery timeline.

9. Any other facts supporting the use of other than full and open competition.

None.

10. A listing of the sources, if any that expressed, in writing, an interest in the acquisition.

Although a synopsis was not issued on sam.gov, market research efforts identified several vendors that expressed an interest to the Contracting Officer. However, only Castle Hill Partners INC. demonstrated the ability to meet the required specifications and the urgent delivery timeframe.