Sole Source Justification Redacted.pdf

Version 5.0 May 2026

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

USING SIMPLIFIED PROCEDURES FOR THE ACQUISITION OF COMMERCIAL

PRODUCTS AND SERVICES EXCEEDING THE SIMPLIFIED ACQUISITION

THRESHOLD

(AUTHORITY: RFO 12.201-1, 41 U.S.C. 1901)

Identification Number: REQUIREMENTS-26-1909

1. Identification of the agency and contracting activity.

The National Oceanic and Atmospheric Administration (NOAA) Acquisition and Grants Office (AGO), Eastern Acquisition Division (EAD), proposes to enter into a contract on the basis of other than full and open competition using simplified procedures for the acquisition of commercial products and services in support of the National Ocean Service (NOS), Office of National Marine Sanctuaries (ONMS).

2. The nature and/or description of the action being approved.

NOAA, AGO, EAD intends to award a sole source contract to The Mariners’ Museum and Park (TMMP) for professional conservation services to conduct ongoing active and preventative conservation care of the USS Monitor Collection, a federally owned NOAA Heritage Asset. This is a follow-on requirement to the previous contract, 1305M220PNCND0281. The planned contract type is Firm-Fixed-Price (FFP), with a 12-month base period and four 12-month option periods.

3. A description of supplies or services required to meet the agency’s needs (including the estimated value).

The NOS, ONMS requires professional archaeological conservation services for the ongoing, long-term stabilization and preventative care of the federally owned USS Monitor Collection. This collection includes over 5,000 individual artifacts composed of diverse materials such as ferrous metals, wood, leather, and textiles. The objects range in scale from small buttons to massive archaeological assemblies, including 25-ton propulsion engines and a 115-ton rotating gun turret.

Due to nearly 140 years of marine burial, these artifacts require an intensely diverse and complex approach to conservation, including initial stabilization, electrochemical treatments, and mechanical cleaning. All conservation activities occur at TMMP in Newport News, VA, within the Batten Conservation Complex. The total estimated value of this procurement, including the base period and all option periods, is $8,620,040. The anticipated period of performance consists of one 12-month base period and four 12-month option periods, running from September 15, 2026, to September 14, 2031. These services ensure the long-term physical stability of the artifacts for future research, archaeological interpretation, and public display, which are integral to the ONMS’ mission to conserve, protect, and enhance the biodiversity, ecological integrity, and cultural legacy of sanctuary sites.

4. An identification of the statutory authority permitting other than full and open competition.

41 U.S.C. 1901, using simplified procedures up to $9M, in accordance with Revolutionary Federal Acquisition Regulation (RFO) 12.201-1. In accordance with RFO 12.102, only one source is available to meet the government’s needs, as further described herein.

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

Only one source - Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

Specifically, TMMP is the only source capable of providing the highly specialized archaeological conservation services required for the USS Monitor Collection.

Following the designation of the Monitor as the first National Marine Sanctuary in 1975, NOAA sought a strategic location for the curation and conservation of recovered materials, ultimately designating TMMP as the official repository in 1987. TMMP is an accredited institution recognized worldwide and is designated by Congress as one of America’s National Maritime Museums. TMMP houses the USS Monitor Center and the Batten Conservation Laboratory Complex, recognized as the world’s largest marine archaeological metals conservation facility. The 62,500-square-foot facility was built specifically to conserve the Monitor and contains custom-built equipment designed exclusively for this collection, including:

Custom Treatment Tanks: Designed with experts from Newport News Shipbuilding, these tanks have capacities up to 90,000 gallons to treat massive artifacts such as the 120-ton revolving gun turret, the 25-ton propulsion engine, and the Dahlgren shell guns.

Heavy-Lift Infrastructure: The lab contains a 40/5 ton overhead gantry crane essential for maneuvering and disassembling these large-scale archaeological assemblies.

Advanced Monitoring Systems: TMMP developed a proprietary desalination (chloride) monitoring system on a scale not utilized in any other marine laboratory in the country, allowing for the precise tracking of chloride extraction during treatment.

TMMP possesses the largest body of institutional memory related to the Monitor Collection. For decades, they have employed a specialized team of experts in maritime artifact conservation, collections management, and analytical chemistry. This team maintains the formal collections database, monitors climate data for the over 5,000 artifacts currently in storage and display, and manages the complex long-term preventive care regimens required for stability.

Altering the current conservation plan by relocating the collection would be counterproductive and likely result in irreparable damage and total loss of these National Historic Landmark artifacts. Due to 140 years of marine burial, many artifacts, particularly cast-iron components like the Dahlgren guns and engine cylinders, are highly graphitized. Much of the original ferrous content has been lost, leaving only a brittle carbon structure prone to fracture. The artifacts are currently in a state of chemical equilibrium within specialized treatment environments; any movement would introduce mechanical stress and environmental fluctuations that would lead to permanent structural failure.

Relocating the collection is both cost-prohibitive and technically unfeasible, as no other conservation laboratory possesses the specialized treatment capacity or co-located industrial expertise of TMMP. Therefore, TMMP is the only source available to meet the government’s needs and the only identified solution to continue the decades-long conservation mission at the only facility capable of ensuring the collection's long-term survival.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by RFO Part 5 and, if not, which exception under RFO Part 5 applies.

A Notice of Intent (NOI), accompanied by the Performance Work Statement (PWS), was posted to the governmentwide point of entry at SAM.gov on April 27, 2026. The notice established a response due date of May 1, 2026, providing industry with the opportunity to submit affirmative responses and capability statements. The NOI requested that interested vendors demonstrate a comprehensive understanding of the requirement under North American Industry Classification System code 541690 (Other Scientific and Technical Consulting Services), specifically addressing the capability to provide professional conservation services for 210 tons of marine archaeological material.

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

Prior to award of the proposed contract, a price quote shall be obtained from the contractor and a price analysis will be performed and documented to sufficiently determine that the cost to the Government of the proposed acquisition will be fair and reasonable. The Contracting Officer determines that the anticipated prices will be fair and reasonable based on the following measures to be taken prior to award:

Historical Comparison: The proposed labor rates for the defined labor categories (Fabrication Specialist, Conservator I/II, and Senior Conservator) will be compared to the rates found reasonable under the previous contracts, EA-133C-15-SE-1330 and

1305M220PNCND0281.

Independent Government Estimate (IGE): The contractor's quote will be compared against the detailed IGE developed for this requirement, which accounts for specialized industrial-scale facility costs and professional conservation expertise.

8. The market research conducted (see RFO Part 10) and the results or a statement of the reason market research was not conducted.

Market research was conducted by the EAD and ONMS to identify available sources and to evaluate the availability of the marketplace to meet the requirements.

As stated in Section 6, a NOI to award a sole source contract to TMMP was posted to SAM.gov on April 27, 2026 with a response due date of May 1, 2026. Vendors were to provide affirmative responses demonstrating an understanding of the requirement and statements of capability demonstrating their ability to meet the requirement. The Government received two responses from the NOI: BHPE, LLC and New Roots Historic Restoration LLC.

BHPE, LLC submitted an email confirming their interest in participating as a vendor and stated they were coordinating with departments to provide requested information. They referred the Government to their website for a general capabilities statement. The CO examined the communication from BHPE, LLC, and while the business expressed interest, BHPE, LLC did not submit a formal capability statement or narrative demonstrating that they possess the specialized industrial facilities, heavy-lift equipment (e.g., 40/5 ton crane), or the 90,000-gallon treatment tanks mandated by the PWS. Furthermore, the business did not address the critical requirement of providing services at the current location to avoid the irreparable damage and destabilization risks associated with relocating the 210-ton collection.

New Roots Historic Restoration LLC submitted an introductory letter in response to the NOI.

While the firm demonstrates significant expertise in architectural restoration, masonry, and cemetery conservation, they are determined not capable of fulfilling this requirement. Their capabilities are tailored toward the preservation of historic buildings and monuments rather than the high-complexity, industrial-scale conservation of waterlogged marine archaeological artifacts.

Specifically, the business does not possess the specialized wet-laboratory infrastructure, heavy-lift machinery, or metal fabrication expertise necessary to manage 210 tons of Civil War heritage assets. Furthermore, as the artifacts are currently stabilized at TMMP, New Roots Historic Restoration LLC lacks the co-located facilities required to perform the work without risking the physical integrity of the collection.

Therefore, based on the results of market research, the Government determined that a limited number of businesses are available but none possess the capabilities required to perform this procurement.

9. Any other facts supporting using other than full and open competition.

All pertinent facts have been documented within other sections of this document. There are no additional facts to be reported in this section.

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

As discussed in Section 6 and 8 above, a NOI was posted to SAM.gov on April 27, 2026, with a response due date of May 1, 2026. Vendors were to provide affirmative responses demonstrating an understanding of the requirement and statements of capability demonstrating their ability to meet the requirement. The Government received two responses in writing from the NOI: BHPE, LLC and New Roots Historic Restoration LLC.

As discussed in Section 8 above, the information submitted from both businesses was reviewed, which determined that neither business is capable of performing this procurement. TMMP remains the only responsible source capable of fulfilling the agency’s needs without causing a catastrophic risk of loss to these National Heritage Assets.

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 the supplies or services required.

The Government will conduct market research annually to gauge any changes to the marketplace regarding capabilities for future requirements; however, it is unlikely that any subsequent acquisitions for the same requirement will be competitive procurements because of the highly specialized and unique nature of this requirement.