Last Updated 03/03/2026

U.S. COAST GUARD JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

COMMERCIAL PRODUCTS AND SERVICES AT OR BELOW THE SAT

FAR 12.102(a), FAR Class Deviation 25-21 Rev. 1 for FAR Part 12

PURCHASE REQUEST OR REQUISITION NUMBER:

61200PR260044987

ESTIMATED TOTAL VALUE, INCLUDING OPTIONS:

(Over Micro-Purchase Threshold, but up to the SAT)

AUTHORITY JUSTIFICATION TYPE

Restricting Competition FAR 12.102(a), FAR Class Deviation 25-21 Rev. 1 for FAR Part 12

☒ Only One Source Is Available (e.g., urgency, exclusive licensing agreements, or industrial mobilization).

☐ Brand Name - Items peculiar to one manufacturer: The particular brand name, product, or feature is essential to the Government’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s needs

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED AND THE INTENDED USE: The

U.S. Coast Guard (USCG) Training Center (TRACEN) Petaluma has a critical requirement for annual aquatic vegetation management, including targeted aquatic herbicide application, systematic water quality monitoring, and post-treatment compliance reporting at the 8.5-acre (approx. 370,000 square feet) Lake Recreational Area. The primary objective is to control invasive species, specifically Water Primrose (Ludwigia), and restore ecological balance while complying with federal, state, and local environmental protection regulations.

SUGGESTED SOURCE NAME, ADDRESS, & UNIQUE ENTITY IDENTIFIER (UEI):

Waterworks Industries, Inc., 930 Shiloh Rd. Bldg. 38, Suite D, Windsor, CA 95492.

UEI: U8MAL58F7317

RATIONALE FOR JUSTIFICATION TYPE SELECTED ABOVE TO INCLUDE RELEVANT

INFORMATION GAINED THROUGH YOUR MARKET RESEARCH TO SUPPORT THE

JUSTIFICATION TYPE: Waterworks Industries, Inc. holds and manages the active regional Group Aquatic

Pesticide Application Plan (APAP) permit (NPDES Permit No. CAG990005) regulated by the California State

Water Resources Control Board (SWRCB) for Sonoma County, which legally covers USCG TRACEN Petaluma's lake area. They are the only contractor authorized to perform herbicide applications under this specific group permit. Attempting to secure an individual APAP permit or transfer coverage to an alternative contractor would require drafting a new APAP, paying additional regulatory fees, and undergoing a mandatory public review process by the SWRCB taking 90 to 180 days. This administrative delay would push herbicide treatment past the critical seasonal biological window for controlling invasive Water Primrose (Ludwigia), resulting in exponential vegetative growth, severe depletion of dissolved oxygen, and catastrophic localized fish kills. This would cause an unacceptable degradation of the recreational lake ecosystem and violate local environmental health codes.

Therefore, Waterworks Industries, Inc. is the only source capable of performing the required treatments without introducing unacceptable regulatory delays, substantial duplication of administrative/permitting costs, and ecological harm.

https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-12#FAR_12_102 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-12#FAR_12_102

Last Updated 03/03/2026

CONTRACTING OFFICER - FAIR AND REASONABLE PRICE DETERMINATION METHODS:

☐ MARKET RESEARCH

☒ COMPARISON OF PROPOSED PRICE WITH PRICES FOUND REASONABLE ON PREVIOUS PURCHASES

☐ CURRENT PRICE LIST

☐ COMPARISON WITH SIMILAR ITEMS IN A RELATED INDUSTRY

☒ COMPARISON TO IGCE

☒ CONTRACTING OFFICER’S PERSONAL KNOWLEDGE (EXPLAIN)

OTHER (EXPLAIN) : The Contracting Officer will determine the proposed price fair and reasonable through a comparison of the contractor's quote to the Independent Government Cost Estimate (IGCE), historical pricing for similar services previously performed at TRACEN Petaluma, and market research analyzing regional rates for commercial aquatic herbicide application and monitoring services in Sonoma County.

SIGNATURE AND TITLE OF TECHNICAL AND REQUIREMENTS POC

Michael Cignetti, Environmental Protection Specialist

DATE

8/11/2026

SIGNATURE OF CONTRACTING OFFICER

Amanda Distasio

DATE