1.5.1-JA 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-26-0035

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-11) and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO

6.103 is justified by the following facts and rationale required under RFO 6.104-1 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) Nature of action: OAQ intends to procure, on a sole source basis, two hundred (200) detainee transport inserts including installation.

(b) Name and address of the contractor:

Holman Parts Distribution, Inc.

9040 Burrough Dover LN Pennsauken, New Jersey 08110

(c) Contract Type: Firm Fixed Price

(d) Estimated total value (including options):

Period Time Total Base 182 Days $10,000,000.00

Total $10,000,000.00

(e) Type of Funding: 705/90540

(f) Year of Funding: 2026

(g) Solicitation Number: 70CMSW26R00000004

(h) Background information about the requirement: The One Big Beautiful Bill Act (OB3) contained funds for ICE Fleet Modernization. OAFM worked with GSA to procure most of the new vehicles, including 200 Mid Roof Ford Transit Vans. GSA then contracted with Holman to upfit these vans using a standard law enforcement package. ICE also needed detainee insert units in the vans, which are not offered as an upfit by GSA.

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

3. Description of Supplies/Services.

The scope of this acquisition is two hundred (200) Detainee Transport Inserts, including accessories and installation services, at an estimated value of $10,000,000. These self-contained inserts are compartments that convert cargo and passenger vans into heavy-duty inmate transport while ensuring officer and passenger safety. The compartment accommodates from 8 to 12 detainees.

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(a)(1) as implemented by the RFO Subpart 6.103-1 entitled “Only one responsible source and no other supplies or services will satisfy agency requirements.”

5. Identification of Exception to the Buy American Statute: N/A

6. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

ICE/OAFM intends to procure detainee transport inserts including accessories and installation services through the sole source acquisition under the authorities of 41 U.S.C.

3304(a)(1), Use of non-competitive procedures, and 40 U.S.C. 501, Services for Executive Agencies.

The intent of this procurement is to ensure reliable detainee transport equipment inserts and associated equipment to support ICE mission critical operations. As Ford Motor Company will utilize Holman Parts Distribution, Inc. to upfit the 200 GSA procured vans, it is operationally critical to award the associated detainee transport inserts and equipment to Holman to ensure completion of all remaining upfitting requirements by the same contractor.

Consequently, avoiding the imminent risk of voiding original equipment manufacturer (OEM) vehicle warranty.

Holman Parts Distribution, Inc. has a contractual arrangement with the Ford Motor Company to provide law enforcement motor vehicle upfit (LU options) to Government leased and purchased motor vehicles without voiding the original equipment manufacturer (OEM) vehicle warranty. Holman Parts Distribution, Inc. upfits Ford law enforcement vehicles to OEM modifier bulletins and to meet Department of Transportation (DoT) and Federal Motor Vehicle Safety Standard (FMVSS), eliminating the possibility of unsafe upfitting that is a common practice with other non-OEM contracted law enforcement upfit vendors.

On an annual basis Holman Parts Distribution, Inc. provides Ford with upfits to all Government leased or purchased Ford law enforcement vehicles though the General Services Administration (GSA) FedSLEVES program. The GSA Fleet FedSLEVES program consists of the Department of Interior (DoI), Department of War (DoW), DHS, Department of Justice (DoJ) and other Federal Law Enforcement agencies and organizations.

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

ICE will procure two hundred (200) Ford Transit 350 Mid Roof 148” wheelbase vans through the mandatory source, GSA Fleet. All vehicles will be upfitted by Holman Parts Distribution, Inc., as Ford’s subcontractor, per the GSA FedSLEVES standard LU50 upfit.

To complete the LU50 upfit, the vans will need to be taken apart to install the items and wires required. ICE ERO also requires two hundred (200) detainee transport inserts along with other accessories, including camera video systems, sound deadening insulation, lighting, and HVAC adapters. The detainee transport inserts and associated accessories delineated above are neither included in the Ford nor Holman GSA contract and therefore the GSA cannot procure them. Consequently, ICE may separately award a supply and installation contract on a sole source basis to Holman for the detainee transport inserts and associated accessories necessary to meet mission requirement.

No other sources are capable of providing both the detainee transport inserts and associated installation concurrently with the law enforcement upfitting while retaining the Ford warranty. Use of an alternative source would require the LU50 upfit to be fully completed, the vans delivered to another vendor and then deconstructed again to complete the detainee transport upfits. The additional shipment and deconstruction would result in delivery delays, increased cost, and increased risk of damage to the upfit equipment installed by Holman Parts Distribution, Inc. Awarding to Holman Parts Distribution, Inc. will, allow the 200 vehicles to be assembled at a single location, and ensure uniform installation and application of required equipment while retaining the Ford warranty.

Failure to approve this J&A will result in significant disruption to ICE’s USC Title 8 responsibilities and activities. Additionally, all 200 detainee transport vans support HR.1 OBBBA and are mission critical and essential for transporting detainees safely to multiple locations. Without timely access to these resources, ICE’s ability to safely and efficiently transport detainees will be severely hindered, ultimately impacting the agency’s ability to fulfill its mission.

7. 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, by posting a notice on sam.gov on or around January 14, 2026.

8. 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 price will be fair and reasonable based on a comparison of the proposed pricing to published online price lists for similar commercial products and services, and the Independent Government Cost Estimate

(IGCE).

9. Description of market research.

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. 3304

Market research was conducted from October 2022 to December 2025. The market research included reviewing acquisition history, searching mandatory sources, and contacting industry. In 2023, ICE OAFM worked to build out an ERO “Test” Detainee Transport Van, in collaboration with Ford, GSA, and Holman Parts Distribution Inc. The “Test” van was a success and since then, ICE OAFM has been working to further the production of the ERO Detainee Transport Van. In August of 2025, the ICE Deputy Director (DD) ordered ICE to procure 1500 marked vehicles consisting of 1300 SUVs and 200 Vans. As the GSA is the mandatory source for the procurement of all non-tactical vehicles per 41 CFR 101-26.501, so the purchase of the vehicles and standard law enforcement upfit will be handled through GSA. ICE requires these vehicles to be fully upfitted, including the detainee inserts, within 182 days after receipt of award of the detainee inserts. Therefore, ICE cannot use another vendor to perform this portion of the upfit, as the vehicles would need to be transported mid-upfit.

This sole source award will provide a significant reduction in the engineering time taken to develop layouts, installation plans, and installation processes that are required to install emergency equipment, detainee transport inserts, and accessories.

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

Annually, ICE OAFM Fleet procures Government motor vehicles through the GSA Fleet, which also provides special manufacturer approved law enforcement upfitting options. As Holman is Ford’s subcontractor for upfits, these special options do not void vehicle warranties and are covered under the same 3-year/36000-mile warranty as the base motor vehicles’ bumper-to-bumper warranty.

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

N/A

12. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for supplies or services required.

To promote future competition, the agency will consider the reliance on advanced acquisition planning to allow for sufficient lead time in subsequent procurements. This may include using a different make, model van, earlier market research, coordination with GSA, and forecasting future vehicle needs to enable competitive procedures when urgency is not a limiting factor.

After award of this action, DHS intends to post the approved/signed justification pursuant to 6.301.

After award of this action, DHS does not intend to post the approved/signed justification in accordance with 6.301(e).