1305M326C0018 JOFOC FE__Redacted.pdf

being located within sample delivery proximity to NEFSC and having the necessary staff and laboratory to perform the requirement. No other vendors have access to the Haddock Aging Model, which are the building blocks of this requirement. To utilize another company would be to erase 10 years’ worth of progress, duplicate previous research efforts and time, as well as eliminate the current base model and require the re-calibration of the base model for a universal model.

GMGI and NEFSC have been collaborating on projects (e.g. epigenetic ageing, summer internships) for approximately 10 years. In 2018 the collaboration began on a research mode for an alternative ageing method. At the beginning, the collaboration was unfunded and followed a trial by error path, which is characteristic of a new, untested technology and ultimately resolved several issues such as sample size, tissue type and preservation, sampling design, etc. Over the years of collaboration, finding a local species of fish to establish the development of the aging model was critical to advancing the model. The local haddock species was chosen for the model because it allowed confident ageing data to be used for the development and validation of the initial (all loci) and final (reduced loci) models. Currently, advancing the Haddock Aging Model is essential for NEFSC to age three (3) Northwest Atlantic fish species to have the ability to age the Goosefish. First, the haddock fish is prioritized for development of the initial ageing model. Then the Atlantic cod, and black sea bass are prioritized for the validation step using the new model. Finally, the Goosefish is prioritized as the proof-of-concept species, using the models previous local regional fish species to determine age. GMGI and NOAA have a long-term partnership in epigenetic ageing, leading to a shared published article on Haddock age prediction. GMGI’s experience with this species of fish makes their research efforts invaluable to NEFSC.

GMGI is located within the regional office of the NEFSC Population Biology Branch in Woods Hole, Massachusetts. This is important as a significant variable for this requirement is proximity to NEFSC Population Biology Branch office in Woods Hole, Massachusetts. This allows NEFSC the ability to deliver samples in-person at high-quality conditions. A sample delivery requires special shipping methods (e.g. dry ice, ethanol) that require costly special considerations when working with commercial shippers, even domestically. The frozen fish samples are collected over a series of months, making the transportation duration a mission critical component to avoid contaminated samples for DNA extractions. GMGI is currently the only known company that can conduct this work.

GMGI employs Bioinformaticians, whom have analytical expertise specializing in epigenetic aging, and they use a NovaSeq machine, which is necessary for high-capacity, high-throughput projects such as whole genome sequencing (compared to a MiSeq). GMGI satisfies the requirement with knowledgeable scientists and in-house equipment to build, test, and evaluate different models. The model can now be applied to other species as part of research as well as in a future operational mode. Therefore, the Haddock Epigenetic Model established with GMGI is ready for application and meets the requirement expressed by NOAA Fisheries leadership to accelerates epigenetic methods for fishery stock assessment and management decisions.

If the requirement is not solicited from GMGI, the mission would be adversely impacted because the NEFSC would need to establish a new epigenetic method that identifies age-correlated methylation sites, and deliver predictive algorithms, when the Haddock Epigenetic Model is already established. Getting a new vendor “up to speed” with experience servicing the required northeastern regional fish species would be expensive and time consuming for the Government. Therefore, it is in the best interest of the Government to sole source the requirement to GMGI.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as possible, 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.

WAD posted a sources sought notice (SSN) for development and validation of epigenetic aging models for Northwest Atlantic fish species to SAM.gov on May 20, 2026. The notice closed on June 5, 2026, and two (2) responses were received from Begini Howard Private Equity (BHPE) and Aetas Epigenetic Ageing, LLC (Aetas).

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

Market research was conducted by NEFSC and WAD to identify available sources and to evaluate the availability of the marketplace to meet the requirement. Based on the results of market research, the government determined that GMGI is the only source available that possesses the capability to meet the proposed requirement. The results of the market research are detailed in the Market Research Report (MRR) (attached).

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 NEFSC and WAD to identify available sources and to evaluate the availability of the marketplace to meet the requirement. Based on the results of market research, the Government determined that GMGI is the only source available that possesses the capability to meet the proposed requirement. The results of the market research are detailed in the Market Research Report (MRR) (attached).

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

All facts have been documented in herein. There are no additional facts to be reported in this section.

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

In response to the SSN, previously mentioned in Section 6, two (2) email submissions from BHPE and Aetas were received.

The expression of interest BHPE provided was vague and lacked explanation of relative capabilities. The NEFSC Technical Point of Contact (POC) also reviewed their website for more information and was ultimately found to be not capable of providing these services.

Aetas submitted an in-depth capabilities statement and answered the NEFSC technical point of contact’s questions, which specifically asked about Aetas’ experience with next-generation sequencing techniques to quantify DNA methylation levels, experience sequencing haddock, Atlantic cod, black sea bass, their location relative to NEFSC, and whether they staff a Bioinformatician. Aetas’s email response stated they have experience with next-generation sequencing techniques, do not have experience with the required northeastern species. Their laboratory is also located in Corpus Christi, Texas and they staff a Bioinformatician. Although Aetas has experience performing epigenetic clock testing services on various southeastern region species with the Southeast Fisheries Science

Center (SEFSC) in the Gulf of America, they do not have experience servicing the required northeastern region fish species.

Due to numerous variables (e.g. water temperatures and migration patterns) that generate a species genetic makeup, sampling in the southeast region provides entirely different sample results, even for the same species, than in the northeast region. According to NEFSC, if Aetas or another contractor without experience with NE fish species were to be awarded this requirement, estimated lead time needed for them to become proficient is approximately two (2) years, which would duplicate the invested research NEFSC has already established, resulting in a high risk of failure to NEFSC’s mission.

Lastly, Aetas’s laboratory is located in southern Texas, which does not meet the in-person NEFSC sample delivery requirement. Instead, delivery from NEFSC to the Aetas laboratory would require a specialized shipping method (e.g. dry ice, ethanol), incur costly special considerations for NEFSC, and significantly increase sample contamination risk.

Due to the combination of regional biological differences, a projected two-year learning curve that duplicates existing research, and severe logistical risks associated with long-distance sample transit, Aetas is not currently capable of performing the required services in accordance with the statement of work.

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 to gauge any changes to the marketplace regarding capabilities for future requirements. This requirement is for ongoing services and is expected to be recompeted in three (3) years. If additional sources become available during that time, the Government will seek competition for future acquisitions for these services.