Attachment_6_-_JA_Redacted.pdf

- 1 -

Justification for Other Than Full and Open Competition Under 10 U.S.C. 2304(c) (7)

Solicitation No. 70Z08518RP4501600

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.3 and in accordance with the requirements of FAR 6.303-1, the justification for the use of the statutory authority under FAR Subpart 6.3 is justified by the following facts and rationale required under FAR 6.303-2 as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), Surface Forces Logistics Center (SFLC), Long Range Enforcement Product Line (LRE PL), proposes to enter into a contract on a basis other than full and open competition.

2. Nature and/or description of the action being approved.

USCG SFLC LREPL intends to procure, on a Service Disabled Veteran Owned Small Business sole source basis, labor and materials to perform the Fiscal Year (FY) 2018 dockside repairs of USCGC HAMILTON (WMSL 753) by awarding a firm-fixed price commercial contract at an estimated cost of Type of FY18 funding that will be used s AFC 45 Depot-Level Maintenance and AFC 30, Operation and Maintenance funds.

The proposed contractor is: J Goodison Company Inc., 244 Burlingham Avenue, North Kingstown, RI 02852. J Goodison Company Inc. is a certified Service Disabled Veteran Owned Small Business

3. Description of Supplies/Services.

The requirement is to procure necessary labor, material, services, equipment, supplies, power, accessories, and facilities necessary to perform dockside repairs and alterations to the vessel, in accordance with the solicitation, schedule and specifications to perform the FY2018 dockside repairs of USCGC HAMILTON at an estimated cost of This is a firm-fixed price commercial contract with a period of performance of 21February 2018 through 15May2018 that will be performed at the USCGC HAMILTON’s homeport at North Charleston, South Carolina.

A. Significant work to be accomplished:

General Welding, Provide-Optional Tanks (MP Fuel Service), Clean and Inspect Galley Grease Fire Extinguishing System, Inspect and Test Gas Turbine Module Fixed CO2 Fire Extinguishing System, Inspect and Test Heptafluoropropane (HFP) Fire Extinguishing System, Inspect and Test Water Mist Fire Extinguishing System, Inspect and Test Cargo Handling Elevator Biannual, Inspect and Repair Forward and Aft Capstans, Annual Maintenance, Perform Oily Water Separator (OWS) System, Inspect and Groom

- 2 -

Portable Brow Storage, Relocate Tanks (Water Mist), Preserve “100%”-Optional Tanks (Water Mist), Preserve “Partial” Temporary Services, Dockside, Home Pier Deck Covering (Phoenix One Step); Renew Flex Hose Assemblies, Renew Surfaces, Preserve Grey and Black Water Vent Piping, Modify QAATDR/QAWTDR, Replace (NSC3&F) QAWTDR, Modify Vacuum Collection Holding Tank, Clean and Inspect Vacuum Collection Holding Tank, Preserve “Partial”-Optional Vacuum Collection Holding Tanks, Preserve “100%”-Optional

4. Identification of the justification and the rationale.

The statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c)(5) Authorized or Required by Statute as implemented by Federal Acquisition Regulation (FAR) Subpart 6.302-5(b)(6).

5. Demonstration that the nature of the acquisition requires use of the authority cited.

In support of small businesses in the United States through Federal contracting the USCG conducts market research in order to set-aside a percentage of acquisitions for award to small and disadvantaged businesses. The USCG complied with FAR 19.203, “Relationship among small business programs”.

The FAR provides that “[t]here is no order of precedence among the 8(a) Program (subpart 19.8), HUB Zone Program (subpart 19.13), Service-Disabled Veteran-Owned Small Business (SDVOSB) Procurement Program (subpart 19.14), or the Women-Owned Small Business (WOSB) Program (subpart 19.15).” FAR § 19.203(a). In determining which socioeconomic program to use, the contracting officer considered, (1) the results of market research performed to determine if there are socioeconomic firms capable of satisfying the agency’s requirement, and (2) the agency’s progress in fulfilling its small business goals. FAR § 19.203(d). The Contracting Officer determined that there is sufficient evidence the SDVOSB, J Goodison Company Inc. , is capable of satisfying the USCG’s requirements and aligns with the USCG progress in fulfilling its small business goals.

J Goodison Company Inc. is determined to be a responsible contractor with respect to performance of this contract opportunity and the contracting officer does not have a reasonable expectation that 2 or more small business concerns owned and controlled by service- disable veterans will submit offers for this contract opportunity. The anticipated award price of the contract will not exceed $3,000,000.00 and, in the estimation of the contracting officer, the contract award can be made at a fair and reasonable price.

- 3 -

This requirement cannot be satisfied through award to (1) Federal Prison Industries, Inc. (see Subpart 8.6); (2) Ability One participating non-profit agencies for the blind or severely disabled (see Subpart 8.7); (b) an orders under an indefinite-delivery contract (see subpart 16.5); or (c) an order against a Federal Supply Schedule (see subpart 8.4); nor is this requirement currently being performed by an 8(a) participant or been accepted by the SBA for performance under the authority of the 8(a) program. Thus this sole source approach meets the requirements of 15 USC 657f.

6. A description of the efforts made to ensure that offers are solicited from as many potential sources as is practicable.

This procurement was posted on the DHS-Acquisition Planning Forecast System (APFS) No.

2017038241 at http://apfs.dhs.gov. Additionally, as required by FAR Subpart 5.2 a sources sought notice was posted on the Federal Business Opportunities (FedBizOpps) site on 08August2017 detailing the work and asking for interested parties to respond if they were capable and available to perform the dockside. The notice closed on 08September2017. Six businesses responded that they were interested in this acquisition.

Upon approval of this document a notice of intent to award a Service Disabled Veteran Owned Small Business sole-source contract for this acquisition to J Goodison Company Inc. will be posted on FedBizOpps.

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 prices will be fair and reasonable based on price analysis including comparisons with the Independent Government Estimate and previous acquisition history of docksides for the USCGC HAMILTON. The solicitation will also include FAR clause 15.403-3, “Requiring Data Other than Certified Cost or Pricing Data” to allow the request for such information to support the contractor’s pricing during negotiations, as necessary.

8. Description of market research.

Market research was conducted which included checks of the following databases: Fedlog, General Services Administration schedules, DHS-wide and Multi-Component Contract Vehicles with DHS Strategic Sourcing Program Office and/or on DHS Enterprise-wide Contract Vehicle Portal, System for Award Management, Small Business Administration Search, Past Performance Information Retrieval System, and Contract Workbook Database. Previous acquisitions for docksides for the USCGC HAMILTON were also reviewed.

A sources sought notice was issued on 08August2017 to the Federal Business Opportunities website. Six interested vendors responded to the notice. Six were small business. Out of those six small businesses one was in the Service Disabled Veteran Owned Small Business program; that business is J Goodison Company Inc. J Goodison Company Inc. is a SBA certified Service Disabled Veteran Owned small business.

- 4 -

In the process of conducting market research for this procurement there were one 8(a), one Small Disadvantaged Veteran Owned Small Businesses, one Women Owned Small Business, two small business concerns, and two HUB Zone small businesses that expressed interest in performing the USCGC HAMILTON dockside.

9. Any other facts supporting the use of other than full and open competition.

Awarding this requirement as a sole-source Small Disadvantaged Veteran Owned Small Businesses contract supports DHS-wide and USCG small business socioeconomic goals.

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

A sources sought notice was issued on 08August2017 to the Federal Business Opportunities website. The following vendors responded to the notice.

1. Colonna’s Shipyard Inc.

400 East Indian River Road Norfolk, VA 23523 POC: Ana Nowland anowland@colonnaship.com

(757) 545-2414 Ext 299 Small Business Concern

2. G I Industrial, LLC 2100 Columbia Street Portsmouth, VA 23704 POC: Roland Carpenter roland@giindustrial-marine.com (757)-673-1368 SBA Certified 8 (a) Program Participant HUBzone Certified Program Participant

3. IMS-Pacific Partners LLC (IMS-PAC) 2320 Main Street Chula Vista, CA 91911 POC: Claudio Rivas Claudio_rivas@msn.com POC: Larry Samano ls@imships.com

(619) 336-1758 HUBzone Concern

4. J Goodison Company Inc.

244 Burlingham Avenue North Kingstown, RI 02852;

POC: Chris Braga – chris@jgoodison.com

(401) 667-5938 Service Disabled Veteran Owned Small Business

- 5 -

5. STILTEN

9800 Centre Pkwy. Ste. 570 Houston, TX 77036 POC: Lina Manrique lina.manrique@stilten.com

(855) 784-5836 x111 Woman Owned Small Business Concern (WOSBC).

6. 3MC MOBILE & MECHANICAL REPAIR

PO Box 366, Hilliard FL 32046, United States Mike Walsh mikew@3mcmobile.com 843-302-1593 Paul McCarthy paul3mcmobilerepair@gmail.com 774-238-1788 Tammi Hadden info@3mcmobile.com 904-845-3405

(G) Small Business Concern

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.

No actions are necessary since this is in support of small business socioeconomic goals and is required by the FAR to be considered before providing for a total small business set-aside or full and open competition. It would be in the best interest of the USCG to continue to look for other interested Small Disadvantaged Veteran Owned small businesses so that this may be procured as a Small Disadvantaged Veteran Owned Small Businesses set-aside in the future.