1.5.1-SSJ-Final-WASRange-REDACTED_Redacted.pdf

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3006.301-90

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 USC 3304 (A): USE OF NONCOMPETITIVE PROCEDURES

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J&A-26-0162

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-110F

1) 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 Enforcement Removal Operations (ERO), Washington D.C Field Office 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 Purchase Order

(b) Amount the current J&A is justifying:

(c) Brief Description: OAQ intends to procure, on a sole source basis, access to a local shooting facility, allowing ICE officers the ability to conduct firearm training, practice, and qualifications. This action is being taken pursuant to the authority of FAR 6.103-1.

The vendor listed below is the only company that can provide the required services:

FREEDOM RVA OPERATIONS LLC

6020 W Broad ST

Richmond, Virginia 23230-2222

3. Description of the supplies or services required to meet the agencies needs (including estimated value):

The Department of Homeland Security, U.S. Immigration & Customs Enforcement (ICE), Enforcement and Removal Operations (ERO), Washington D.C has a requirement for use of a Gun Range facility within a 15-mile radius of the ICE/ERO Richmond Sub-Office that enables the organization to conduct quarterly firearms and tactical training and qualification courses for officers in the region. ICE officers are required to qualify proficiently every quarter with their assigned firearms, failure to do so can result in relinquishment of firearm use.

1 FAR Class Deviation 25-11 is implemented as a result of Revolutionary FAR Overhaul, referred as RFO, following Executive Order 14275, Restoring Common Sense to Federal Procurement. All citations in this document follow applicable DHS RFO Deviations therefore are referred as RFO.

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 USC 3304 (A): USE OF NONCOMPETITIVE PROCEDURES

Page - 3 - of 5 from the Washington D.C Richmond Field Office location (the Richmond Field Office is located at 9200 Arboretum Parkway, Suite 140, North Chesterfield, VA 23236). Second, the shooting facility must be located within approximately five (5)-miles of a trauma center/hospital equipped to treat any level of severity of trauma by an onsite trauma surgeon 24 hours a day, seven days a week. Finally, third, the shooting facility must also have the capability to meet specific needs including, but not limited to, handgun and rifle shooting capabilities (e.g. delineated shooting range distances, shooter maneuverability, etc.), classroom access, and tactical training facility access. Freedom RVA Operations LLC is the only responsible source capable of meeting these requirements and no other range is able to provide this combined unique services will would satisfy the agency’s minimum requirement.

Market research included a comprehensive analysis including outreach to multiple gun ranges including Virginia Shooting Sports and Green Top Gun Range within the Richmond area of responsibility (AOR). Each facilities capabilities were assessed against the government’s requirements, which included proximity to the field office location, range distance up to 100 yards for both handguns and long guns, classroom and mat room facilities, a tactical shoot house, flexible scheduling, and proximity to a trauma center. The shooting facility operated by Freedom RVA Operations LLC is located approximately 13 miles from the Richmond Field Office and is also located approximately five (5) miles from a trauma center. The shooting facility operated by Freedom RVA Operations LLC is the only range able to meet all of the SOW minimum requirements. No portion of the work can be segregated to allow for competition, as the requirements are interdependent and must be provided by a single contractor at a single location. Utilizing multiple vendors for different aspects of the requirement (e.g., one for range access, another for classroom space) was deemed unworkable due to the need for integrated, secure, and exclusive facilities to ensure officer safety, training efficiency, and compliance with agency standards.

Failure to approve this J&A would result in ICE ERO Richmond being unable to conduct mandatory firearms qualifications, defensive tactics, and advanced tactical training in compliance with agency standards. This would directly impact officer safety, readiness, and the ability to carry out law enforcement operations. Lack of appropriate training facilities could also lead to non-compliance with federal training mandates, increased liability, and diminished operational effectiveness.

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

OAQ intends to make this justification publicly available pursuant to FAR 6.301 on Sam.gov within 14 days after contract award.

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

The contracting officer determines that the anticipated price will be fair and reasonable based on a comparison of proposed price to commercial pricelists as well as historical prices paid, JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 USC 3304 (A): USE OF NONCOMPETITIVE PROCEDURES

Page - 4 - of 5 whether by the Government or other than the Government, for the same or similar items.

8. Description of Market Research.

Market research was conducted collaboratively between the Program Office and OAQ.

Shooting facility services, such as the services required under this effort, are considered a commercial item and are services of a type offered and sold competitively in the commercial marketplace.

Comprehensive market research was conducted between September 2025 and April 2026 to identify potential sources capable of meeting DHS/ICE/ERO Washington D.C Field Office’s firearms and tactical training facility requirements. A broad internet search was conducted for shooting ranges in the proximity of the Richmond field office and were narrowed down based on the primary requirements of shooting range distances, capacity for classroom instruction and tactical exercises, allowable firearms, proximity to a trauma center, and proximity to the field office location. After the initial broad search, the Program Office identified potential facilities to contact for more information on their offerings these included Virginia Shooting Sports, Green Top Gun Range, and Freedom Outdoors assessing each facility’s technical and operational capabilities against DHS/ICE/ERO’s mandatory criteria.

The market research determined that no other vendors could fully satisfy all requirements.

Facilities such as Virginia Shooting Sports and Green Top Gun Range lacked critical training spaces, sufficient range lengths, or were located too far from the ICE/ERO Richmond Sub- Office and trauma centers. Only Freedom Outdoors which is also a small business, was found to meet all technical, operational, and safety requirements.

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

N/A.

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

N/A

11. 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.

The program office and OAQ will conduct ongoing market research to see if there are any other local shooting facilities can meet the requirements of the SOW. If so, OAQ will compete future contract actions for these services.