J&A_70Z02318CPUD66500_P00001_Redact.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

Under 41 U.S.C 1901

Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

Procurement of Tailoring Services

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 13.5 and in accordance with the requirements of FAR 13.501, the justification for the use of the statutory authority under FAR Subpart 13.5 is justified by the following facts and rationale required under FAR 6.303-2 as follows:

1. Agency and Contracting Activity.

The United States Coast Guard (USCG), Office of Contract Operations, Formal Contracts Division I (CG-9121), proposes to modify contract 70Z02318CPUD66500 for continuity of support, on a basis other than full and open competition.

2. Nature and/or Description of the Action being Approved.

Formal Contracts Division I (CG-9121) seeks approval to award a modification on a sole source basis to Front Line Apparel Group for the continuation of tailoring services for USCG trainees/recruits at Coast Guard Training Center Cape May. Training Center Cape May (TCCM) provides military training to Coast Guard personnel (active duty recruits and reservist) and Direct Entry Petty Officer Training (DEPOT) personnel. These trainees are considered “accession” personnel entering or returning to military service. During accession training, a variety of uniforms are issued for wear during military training at

TCCM.

Contract 70Z02318CPUD66500 was awarded on a sole source basis to Front Line Apparel Group on 04/21/2018 in the amount of $575,000, with a contract period of performance of 04/21/2018 to 04/20/2019. The contract period of performance will be extended for an additional six months with a new period of performance of 04/21/2018 to 10/20/2019. These services are considered commercial in nature and will be procured using the procedures listed in FAR Part 12 and FAR 13.5 Simplified Acquisition Procedures for Certain Commercial items. There are no changes to the scope of work as a result of this action.

The following information is provided:

(a) This action will be a Firm Fixed Price (FFP) contract modification

(b) Estimated total value:

Original amount awarded on base year: $575,000 Additional six months: $287,502 for a total award of (base plus six month modification): $862,502.00

(c) Type of funding: AFC-12 Other non-payroll expenses.

(d) Year of funding: 2019

(e) The vendor that will support this effort is Front Line Apparel Group, 5 Shaw’s Cove

Ste 220, New London, CT 06320-4974

3. Description of Supplies/Services.

This is a non-personnel services contract to provide all furnished fitting, alteration/tailoring, and garment pressing services for accession personnel (trainees/recruits) at USCG Training Center Cape May, NJ. Accession personnel uniforms are required to meet the standards set forth in the Coast Guard Uniform Regulation COMDTINST M1020.6I (series). Therefore, tailoring services performed by a contractor must be in accordance with uniform regulation standards.

4. Identification of Statutory Authority Permitting Other Than Full and Open

Competition.

This acquisition is being conducted under the authority of 41 U.S.C. 1901(c), as implemented by the Federal Acquisition Regulation (FAR) 13.501 (a)

5. Demonstration that the Nature of the Acquisition Require Use of the Authority Cited.

A Government shutdown occurred from 12/22/2019 to 01/25/2019 and created a major barrier and time delay to the solicitation process of this requirement. There is a continual flow of accession personnel that report to TCCM for training. To ensure that this vital mission is accomplished, a contractor that is familiar with USCG uniform regulations and capable of handling the volume of work is needed for the continual influx of personnel.

The lack of this service would prevent uniformed personnel from meeting the uniform regulations and prevent them from having properly fitted clothing when performing their duties at operational units (e.g. ships, small boats, and aircraft). Improperly fitted uniforms around operational units is a safety hazard that jeopardizes the safety of personnel and equipment. Uniforms that are too long and dangle can get caught in machinery or cause tripping hazards. Uniforms that are too short or do not cover enough area of the skin do not afford the proper protection against abrasions, electrical dangers, or burns. In addition, improperly fitted uniforms may impede other personal protective equipment (PPE) such as live vests and firefighting gear. Front Line Group is the only vendor able to provide short-term apparel cut and sew tailoring to TCCM.

6. Description of Efforts Made to Ensure that Offers are Solicited from as Many

Potential Sources as is Practicable.

A survey of the market revealed that no other source would be able to continue services under these circumstances. The USCG utilizes the Department of Homeland Security Acquisition Planning Forecast System (APFS) to help industry identify procurement opportunities as early in the acquisition process as possible. The USCG published APFS Record 2018043212 on 10/29/18 to notify and update industry of the forecasted opportunity of the follow on contract. A sources sought was posted on 02/05/2019 with a response date of 02/18/2019 to better understand the market place of small businesses. The results of the sources sought are as follows:

Number Name

No other responses received in reference to sources sought

To ensure competition, the follow-on solicitation will be released on FBO.gov.

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(s) will be fair and reasonable based on the current contract, which was determined to be fair and reasonable.

Furthermore, fair and reasonableness may be based on comparison of prices compared to historical prices paid, current price lists, and catalog prices.

8. Description of Market Research.

Market research was performed and is continually being updated. Four (4) local companies were contacted by phone to gauge interest, all stated that they could not currently perform in a timely manner, at the volume needed at the Training Center location. Currently there is difficulty finding businesses in the tailoring field that have the ability to meet this need. A sources sought was posted on 02/05/2019 with a response date of 02/18/2019 to better understand the market place of small businesses that could perform this service. This service is not available through GSA or a DHS Strategic Sourcing Vehicle.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

Although the industry shows that there are other tailors, none can meet the Government’s requirement. Therefore, it is in the best interest of the Government to issue a six (6) month extension to contract 70Z02318CPUD66500 to ensure continuity of services for Cape May Training Center while working on the follow-on contract award.

10. A Listing of the Sources, if Any That Expressed, in Writing, an Interest in the

Acquisition.

None:

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 Government intends to solicit and award a follow-on contract as 100% Small Business set-aside. Thus, there are no barriers to future competition.

12. Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Date

13. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

ate

14. Legal Review and Concurrence:

I have reviewed this justification and find it legally sufficient.

APPROVAL: