2-Justification_and_Approva_MIDGETT_No. 2_SSDG_OVERHAUL.pdf

Last Updated 09/01/26 1

JUSTIFICATION AND APPROVAL FOR

OTHER THAN FULL AND OPEN COMPETITION

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by Federal Acquisition Regulation (FAR) 12.102(b), FAR Class Deviation 25-21 Rev. 1 for FAR Part 121, FAR 6.104, FAR Class Deviation 25-11 for FAR Part 6, the following facts and rationale are presented in accordance with Revolutionary FAR Overhaul (RFO) 6.104 requirements:

1. Agency and Contracting Activity.

Department of Homeland Security, United States Coast Guard (USCG), and Coast Guard Surface (SEA) Contracting Branch 2 (CGSEA-C22) in support of the Long-Range Enforcer (LRE) Product Line prepared this justification.

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

Surface Forces Logistics Center (SFLC) has a requirement on restricted competition basis (Brand Name), to provide onsite technical and engineering services, logistical support for the service, overhaul, and repair of Caterpillar Ship’s Service Diesel Generators (SSDG) model D3512 onboard CGC MIDGETT (757WMSL), homeported in Honolulu, HI.

The Technical Representative must be an authorized/licensed OEM Service Provider for Caterpillar Marine diesel engines/generator, to accomplish the following:

• Provide manufacturer's proprietary systems/equipment information, software, and tools.

• Assist with and ensure compliance with manufacturer's procedures and standards during disassembly, inspection, repair, modification, calibration, and reassembly of the equipment/systems.

• Accessing Original Equipment Manufacturer (OEM) proprietary information, software, and tools pertinent to tasking in accordance with the specification.

• Generating a Computer Aided Marine Performance Analysis Report (CAMPAR) with the diagnostic test data and recommendations for the diesel engines.

1 In this document, citations to RFO Parts 12, 6, 10, 15, and 25 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-21 Rev. 1 for FAR Part 12, FAR Class Deviation 25-11 for FAR Part 6, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 Rev. 1 for FAR Part 15, and FAR Class Deviation 26-09, Rev. 1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), which was implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

Last Updated 09/01/26 2

• Conducting Marine Engine Performance diagnostic testing (CAMPAR or load bank testing), ensuring compliance with OEM, U.S. Coast Guard, OSHA, and other pertinent procedures and standards.

• Providing genuine, OEM-approved parts.

• Perform the Major Overhaul on #2 Ship Service Diesel Generator

(SSDG) Caterpillar 3512B.

• Renew the crankshaft of the #2 Ship Service Diesel Generator

(SSDG) Caterpillar 3512B

(a) Name and address of the contractor: OEM Certified Service Provider for Caterpillar Marine (Brand Name).

(b) Contract Type: Indefinite Delivery Vehicle (IDV) Contract, with Firm Fixed-Price Task Orders.

(d) Estimated total value (including options): $865,643.00

(e) Type of funding: Operations and support funds

(f) Year of funding: Fiscal Year 2027

(g) Solicitation number: 70ZU0227QLREP0002

(h) Background information about the requirement: CGC MIDGETT’s #2 SSDG experienced high crankcase pressure with oil/smoke vapor protruding from lube oil dipstick ports and crankcase vents. Ships Force attempted minor dynamic troubleshooting, but vapor generation was too rapid to continue operation of the engine. The SSDG was tagged out and opened (and remained open) for further investigation work and repairs. Ships force and organic subject matter experts were unable to identify the root cause of the failure without proprietary systems information and OEM technical experts on scene. The cutter submitted DISCREP #26048 requesting Depot Level assistance from LREPL.

(i) The Coast Guard will provide the following GFE:

1. Crankshaft, 2815-01-511-2837, P/N 128-6786, QTY: 001

i. Description of Supplies/Services. (1) Perform the Major Overhaul on #2 Ship Service Diesel Generator (SSDG) Caterpillar 3512B, Root Cause Failure Analysis (RCFA), and Run-in/Commissioning service on Caterpillar genset model D3512, (2) Caterpillar (CAT) Ship Service Diesel Generator, Crankshaft Renewal. This work will restore the cutter’s full complement of Ship Service Diesel Generators to ensure sufficient redundancy in supplying power to the cutter’s extensive, complex, and vital electrical systems.

ii. Identification of Statutory Authority Permitting Other Than Full and Open Competition. The statutory authority permitting other than full and open competition is

Last Updated 09/01/26 3

Authority. 41 U.S.C. 1901. As implemented by RFO 12.102(b) and RFO 6.103-1(d) Only one responsible source and no other supplies or services will satisfy agency requirements (Brand Name).

iii. Identification of Exception to the Buy American Statute. The exception to the Buy

American statute permitting the purchase of articles that are not domestic end products is RFO 25.103(b)(2) Nonavailability.

iv. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

(a) Authorized OEM Certified Caterpillar Marine Service Providers are the only source of proprietary information, parts, and technical services required to support the overhaul, service, and repair of engine model D3512, as Caterpillar is the original equipment manufacturer (OEM). Caterpillar will not share or sell any proprietary information or data. There are no other firms that possess the manufacturer’s drawings, specifications, or proprietary information which would be able to perform services to maintain Caterpillar engines.

• CGC MIDGETT’s #2 SSDG is powered by a Caterpillar 3512B diesel engine. In addition to a successful overhaul, one of the requirements of the scope of work is a consolidated failure analysis investigation. Authorized OEM Certified Caterpillar Marine Dealerships are the only source of proprietary information, and technical services required to support the overhaul, service, and repair of engine model D3512 IAW SOW Work Item 1: Perform the Major Overhaul on #2 Ship Service Diesel Generator (SSDG) Caterpillar 3512B, and Work Item 2 Renew the crankshaft of the #2 Ship Service Diesel Generator (SSDG) Caterpillar 3512B as Caterpillar is the original equipment manufacturer (OEM).

(b) USCG Organic resources were explored, however, they do not possess the proprietary systems information to determine the root cause of the original failure, nor conduct the center section overhaul without access to the proprietary drawings and information; organic resources are unable to accomplish scope of work.

Caterpillar retains the proprietary technical data necessary to maintain and repair 3512B engines to Caterpillar standards. Caterpillar remains the OEM technical authority for failure investigations and engineering support associated with equipment within its scope of supply.

(c) If the requested services are not provided, CGC MIDGETT will not be able deploy on time to provide critical USCG surface asset coverage in the Arctic region. This coverage is mandated by Congressional statute and includes the Coast Guard Statutory missions of Maritime Law Enforcement, Search and Rescue operations, and Maritime Border Control.

Last Updated 09/01/26 4

v. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

(a) APFS F2026075153 was published on October 5, 2026.

(b) SSN USCGC_MIDGETT_SSDG_Overhaul_Repairs was published to SAM.gov on August 28, 2026, with an expiration date of September 02, 2026. Eight (8) responses were received from vendors interested in the sources sought notice (SSN). 07 were received while the SSN was open and 01 was received after SSN closed. The responses are listed in paragraph 11 of this document.

vi. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable. The Contracting Officer anticipates that the price will be fair and reasonable based on comparison of proposed prices received in response to the Request For Proposal, comparison with the Independent Government Estimate and extensive acquisition history with Caterpillar and authorized OEM Certified Caterpillar Marine Dealers as subcontracted Technical Representatives. Additionally, if necessary, in accordance with DHS policy, the offeror may be required to submit Data Other than Certified Cost or pricing Data (FAR 15.403-3) to support price negotiations.

vii. Description of Market Research. On August 28, 2026, the USCG posted Sources Sought on SAM.gov, with a deadline of September 2, 2026. Eight interested vendors expressed interest in responding to the notice. It is important to make clear that the purpose of the notice was not to find a substitute for Caterpillar, but rather to look for vendors who could supply a Caterpillar OEM representative to carry out this task. The results of the market research made it abundantly evident that there are several vendors who can complete this task; nonetheless, the need for an OEM from Caterpillar continues to be the most crucial aspect of this requirement. APFS F2026075153 was published on October 5, 2026

viii. Any Other Facts Supporting the Use of Other Than Full and Open Competition. No additional facts identified to support the use of Other Than Full and Open Competition, other than those identified above.

ix. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the Acquisition.

Name 1i: BHPE LLC's

UEI: UPDJHPJUYQ71

Vendor POC: Ruth McGehee (Procurement Director) Phone Number: 405.205.5384 Email: ss@bh.pe Website: BHPE — Federal facilities, industrial & supply contracting | CAGE 9SWS7 Estimate: N/A Business Size Category: Service-Disabled Veteran-Owned Business, Veteran-Owned Business, Indian Economic Enterprise, Native American Owned, Minority-Owned Business, DOT Certified DBE

Name 2: PACIFIC SHIPYARDS

INTERNATIONAL, LLC

UEI: K84MXRVQ8BW5

Vendor POC: lsdimaya@pacificshipyards.com Phone Number: (808) 848-6211 Email: info@pacificshipyards.com Website: www.pacificshipyards.com Estimate: N/A Business Size Category: Minority-Owned Business, Asian-Pacific American Owned Ordering Vehicle Name and Number, if applicable:

mailto:ss@bh.pe https://bh.pe/ https://bh.pe/ https://www.pacificshipyards.com/

Last Updated 09/01/26 5

Ordering Vehicle Name and Number, if applicable:

Name 3: Crescent Harbor Repair, LLC

UEI: KJWPGJJNB858

Vendor POC: Brandon Smith Phone Number: 717-480-0284 Email: brandon.smith@crescent-harbor-repair.com Website: www.crescentharborrepair.com Estimate: N/A Business Size Category: small business Ordering Vehicle Name and Number, if applicable:

Name 4: Hawthorne Machinery Company

UEI: H33DK44BJZE1

Vendor POC: Mike Stumpo Phone Number: 858-376-6836 Email: mstumpo@hawthornecat.com Website: San Diego Caterpillar Equipment Sales, Service & Rentals | HI & CA Estimate: N/A Business Size Category: Small Business Concern under NAICS 336611 Ordering Vehicle Name and Number, if applicable:

Name 5: Regal Service Company

UEI: K5MNF84HN6H3

Vendor POC: Christopher Caliedo, President Phone Number: (808) 236-4772 Email: ccaliedo@regalservicecompany.com Website: www.regalservicecompany.com Estimate: N/A Business Size Category: small business Ordering Vehicle Name and Number, if applicable:

Name 6: Parts Life

UEI: CME4NQ4ZSDY9

Vendor POC: Andrew Klitchko Phone Number: (856) 786-8675 ext. 1346 Email: jeanniew@partslifeinc.com Website: http://www.partslifeinc.com Estimate: N/A Business Size Category: small business Ordering Vehicle Name and Number, if applicable:

Name 7: SCP USA CORP

UEI: C5DQLLM3AX77

Vendor POC: Nathan Peters Phone Number: 727-642-2979 Email: nathan.peters@scpusacorp.com Website: Unknown Estimate: N/A Business Size Category: Veteran-Owned Business Ordering Vehicle Name and Number, if applicable:

Name 8: Guardian Systems, LLC

UEI: FLT5LFGMM741

Vendor POC: Ryan H. Brown Phone Number: (757) 814.6502 Email: rbrown@guardian-systems.net Website: https://www.guardiansystems.us/ Estimate: N/A Business Size Category: Service-Disabled Veteran Owned Small Business (SDVOSB) Ordering Vehicle Name and Number, if applicable:

12. 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.

Since Caterpillar Inc continues to retain ownership of the proprietary information and parts necessary for maintaining Caterpillar engines and will not sell proprietary data or technical information, it may not be possible to obtain competition in future procurements. However, the Coast Guard will continue to seek access to the technical data sufficient to enable competition.

13. Technical/Requirements Personnel Certification.

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

http://www.wwwcrescentharborrepair.com/ https://www.hawthornecat.com/ https://www.hawthornecat.com/ http://www.regalservicecompany.com/ mailto:nathan.peters@scpusacorp.com https://www.guardiansystems.us/

Last Updated 09/01/26 6

ENG3 John J. Webber

22OCT2026

Technical Representative

14. Contracting Officer’s Certification (Approval)

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.

Ambrocio Alvarez 21OCT2026 Contracting Officer

15. Approval

Shreena L. Morris Date Procuring Activity Advocate for Competition (PAAC) i List entity names as they appear in SAM.gov.