A05_Under SAT-Exception to Fair Opportunity_12444026Q0220_Redacted.pdf

United States Department of Agriculture Item Peculiar to One Manufacturer

Under the Simplified Acquisition Threshold Identification Number: 12444026Q0220

Rev. 3/10/26

In accordance with the Revolutionary Federal Acquisition Regulation (FAR) Federal Acquisition Regulation (FAR) 16.507-6 (d)(1), the following documents exception to fair opportunity.

(1) Mission Area and Contracting Activity.

Requisition Number: 1174489

Requesting Activity Agency: USDA, Agricultural Research Service (ARS)

Contracting Activity:

(2) Brief Description of Supplies or Services

The USDA Agricultural Research Service requires acquisition of a high-volume, high-accuracy, image-based seed counter capable of processing large batches of corn seed (up to 1500 g) at speeds of approximately 75 seeds per second, while capturing individual seed image metrics (area, length, width) and exporting data in .csv or Excel formats.

The equipment will be used for large-scale grain sample processing, seed inventory management, and high-resolution phenotyping necessary for ARS research programs. It must seamlessly integrate with barcode scanners and laboratory balances to collect mass and identification data concurrently.

This acquisition enhances operational efficiency, ensures highly accurate data capture (≥99.9% accuracy), and provides capabilities not currently available in the laboratory.

(3) Suggested Source

(4) Identify the exception to fair opportunity.

The statutory authority supporting the placement of an order or establishment of a Blanket Purchase Agreement (BPA) that exceeds the micro-purchase threshold on a sole source basis is: FAR 16.507-7 - Items Peculiar to One Manufacturer

(5) Demonstrate that the proposed contractor's unique qualifications or the nature of the acquisition requires using the authority cited.

Only the Ball-Coleman Seed Counter meets the ARS technical requirements. Market research showed that alternative seed counters either:

• do not support large batch sizes (~1500 g),

• cannot achieve required speeds (75 seeds/sec for corn),

• lack high-resolution image-based per-seed measurement capability, or

• cannot export full-sample measurement datasets.

Ball-Coleman is uniquely capable of providing the full required feature set. The Ball-Coleman counter delivers image-based detection, 99.9% accuracy, simultaneous mass-capture, barcode integration, and large-batch hopper capacity—all explicitly required and not matched by any discovered competitor.

Only one comparable machine exists (Data Technologies S-25), but it is foreign-manufactured and not acceptable. ARS excluded this device because detailed specifications were limited, it did not meet batch-size requirements and was manufactured in Israel—making it non-compliant with domestic sourcing objectives.

The Ball-Coleman system is sold primarily by the manufacturer and only one verified U.S. reseller.

No other U.S. distributors were found during extensive market research. The system must be compatible with ARS workflows and existing research pipelines. Its export formats, data structures, imaging specifications, and barcode integration are already aligned with ARS templates and downstream data software, reducing operational burden and ensuring accuracy.

Given these constraints, restricting competition is necessary to meet ARS’ minimum technical requirements and ensure compatibility with existing lab processes.

(6) Describe market research conducted and the results or the reason why no market research was conducted.

ARS conducted extensive market research including:

• Hands-on evaluation of a Ball-Coleman counter at the Iowa State University Seed Science Center.

The device demonstrated required performance and data capabilities.

• Internet searches, product literature review, and use of AI-assisted tools to identify comparable machines. No other U.S.-made machines matched the required specifications.

• Review of GSA Advantage, AbilityOne, USDA-wide contracts, Federal Prison Industries, SEWP, NITAAC, STARS, VETS, Alliant, and SBA Dynamic Small Business Search—none listed any comparable seed counting technology.

• Evaluation of Data Technologies S-25 (Israel). It was excluded due to foreign manufacture, limited specification transparency, and insufficient performance capabilities.

• Outreach to knowledgeable individuals in the seed-technology field who confirmed Ball-Coleman as the only known solution with required capabilities.

Market research conclusively supports restricting competition to Ball Technologies and Sciotex as the only viable domestic sources.

Certifications & Approvals

(1) Technical / Requirements Personnel Certification I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

(2) Contracting Officer’s Certification I certify that the data supporting the exception to fair opportunity accurate and complete to the best of my knowledge and belief. I hereby approve this justification.