4d_Justification for Other Than Full and Open.pdf

March 8, 2023 Version

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIMPLIFIED ACQUISITION PROCEDURES (SAP) FAR 13.106-1(b)

SOLICITATIONS MAY BE LIMITED TO ONE SOURCE ONLY IF THE CONTRACTING OFFICER DETERMINES THAT ONLY ONE SOURCE IS REASONABLY AVAILABLE. THIS DETERMINATION MUST BE SUPPORTED WITH FULL JUSTIFICATION FOR SOLE SOURCE FROM THE CUSTOMER. WHEN THE CUSTOMER DESCRIBES AN ITEM WITH A PURCHASE DESCRIPTION WHICH LIMITS THE AVAILABILITY TO ONE SOURCE, THE JUSTIFICATION MUST EXPLAIN WHY THE ITEM IS THE ONLY ONE THAT WILL MEET THE GOVERNMENT’S REQUIREMENT. STATEMENTS SUCH AS "ONLY KNOWN SOURCE" OR "ONLY SOURCE WHICH CAN MEET THE REQUIRED DELIVERY DATE" ARE INADEQUATE TO

SUPPORT A SOLE SOURCE PURCHASE.

PURCHASE REQUEST OR REQUISITION

NUMBER

75407PR240000001

PROJECT/TASK

NUMBER

ESTIMATED AMOUNT (Over Micro- Purchase Threshold, but up to the SAT) $24,740.15

CITE AUTHORITY & JUSTIFICATION TYPE – READ FAR 6.302 TO DETERMINE APPROPRIATE TYPE

10 U.S.C. § 3204(a)(1)

ONLY ONE RESPONSIBLE SOURCE AND NO OTHER SUPPLIES OR SERVICES WILL SATISFY

AGENCY REQUIREMENTS.

☐ 10 U.S.C. § 3204(a)(2) UNUSUAL AND COMPELLING URGENCY

10 U.S.C. § 3204(a)(3)

INDUSTRIAL MOBILIZATION; ENGINEERING, DEVELOPMENTAL, OR RESEARCH CAPABILITY; OR

EXPERT SERVICES

☐ 10 U.S.C. § 3204(a)(4) INTERNATIONAL AGREEMENT

☐ 10 U.S.C. § 3204(a)(5) AUTHORIZED OR REQUIRED BY STATUTE

☐ 10 U.S.C. § 3204(a)(6) NATIONAL SECURITY

☐ 10 U.S.C. § 3204(a)(7) PUBLIC INTEREST [SECRETARY OF HOMELAND SECURITY NEEDS TO APPROVE THIS DOC]

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE.

Soundproof siding and insulation is required to replace damaged materials on small arms firing range (SAFR).

UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON NO OTHER

SUPPLIES OR SERVICES CAN BE USED.

This system is comprised of a layer of 2” Troy Wool and 2” Troy Board with approximately 10 fasteners per board. The system is unique in that it reduces noise levels across all octaves from 125 Hz to 8000 Hz and is guaranteed to meet noise exposure limits as specified in Occupational Safety and Health Administration (OSHA) guidelines, as well as the USAF Shooting Range Engineering Technical Letter. It is also the only acoustic system approved by the US Air Force for anti-ricochet and anti-splatter for 5.56 and 7.62 rounds. This waterproof and mold resistant Portland cement base wood fiber board surface can be vacuumed or hosed down. It also meets the stringent 2012 NFPA 286 corner fire test and is UL approved with a smoke developed and flame spread of ZERO, providing a safer environment if tracers are fired.

The National Institute for Occupational Safety and Health (NIOSH) has recently published a NIOSH Alert on Preventing Occupational Exposures to Lead and Noise at indoor firing ranges. According to NIOSH, “the noise exposures found in firing ranges are principally due to the direct exposure to the shock wave expanding outwards from the chamber and muzzle of the weapon. Secondary exposures occur from the reflections off the walls, …” “Within the range gallery, the presence or absence of absorptive materials will govern the removal of reverberant energy thus increasing or decreasing the reverberations times.”

A DESCRIPTION OF EFFORTS MADE TO ENSURE THAT QUOTATIONS OR OFFERS ARE SOLICITED FROM AS MANY

POTENTIAL SOURCES AS PRACTICABLE (INCLUDE YOUR MARKET RESEARCH EFFORTS HERE).

Technical conformance and sustainability are the primary factors under consideration. Research indicates that other potential sources for these products do exist but are not capable of meeting all anti-ricochet and anti-splatter properties, as well as high absorption of sound across all octaves from 125 Hz to 8000 Hz in an indoor/outdoor environment. For sustainability and durability, the system maintains its acoustic qualities until such time that 50% of a 2’ x 7’-10.5” x 2” board is destroyed by errant rounds. The ability to meet current and future training requirements is very important and procurement of other acoustics system poses unnecessary and unacceptable risks to the USCG live-fire training requirement which is not in the best interest of the Government.

REASON THAT SUGGESTED SOURCE IS THE ONLY SOURCE WHICH CAN PROVIDE THE SUPPLIES OR SERVICES.

NAVFAC, the USAF, and the USMC P398 dynamic shooting program office have researched other manufacturers and have observed field tested installations used by multiple Department of Defense Agencies and commercial entities. Only the Troy System provides the performance, and sustainability required to meet the maintenance and sustainability requirements. These performance characteristics were also determined by an independent Case Study initiated by the USACE. The Troy System was the only acoustic system given the USACE excellent rating for use in a shooting range. It is also the only acoustic system approved by the US Air Force for anti-ricochet and anti-splatter for 5.56 and 7.62 rounds. As per the Civil Engineering Manual COMDTINST M11000.11 we are to follow the guidance of the USAF Technical letter 11-18 for firing ranges.

March 8, 2023 Version

EXPLAIN WHY AN ADEQUATE PURCHASE DESCRIPTION OR OTHER INFORMATION SUITABLE TO SOLICIT BY FULL

AND OPEN COMPETITION HAS NOT BEEN DEVELOPED OR ARE NOT AVAILABLE.

Potential consequences of using other than the Troy System will result in increased risk of personnel exposure to excess noise exposure limits and ricochets. All other shooting range acoustic materials designed for indoor/outdoor use made by other manufacturers do not stand up to the elements as well as the Troy System. Independent acoustical test analysis at other Department of Defense facilities show that the Troy System is far superior in a shooting range environment. All the other systems require the use of two layers of fire-resistant marine grade plywood to meet the Troy System standard for anti-ricochet and anti-splatter. Plywood degrades at a faster rate than the Portland cementitious wood fiber board over the life cycle of the acoustic system.

Troy Acoustics has been sole sourced by the USAF, USMC and the USACE since their system was the only system guaranteed to meet their criteria. In most cases acoustic testing was required upon completion to assure compliance.

Currently Troy Acoustics’ products are installed. The SAFR system requirement includes a minimum coverage of 25 yards in front of the firing line on all side walls and ceiling and coverage of 5 yards behind the firing line on all side walls and ceiling. If different items are procured significant portions of undamaged materials would need to be removed due the potential risk of ricochet to personnel from the mismatch of materials. Additionally, excess materials currently on hand have an estimated value of $7500.

PROVIDE A STATEMENT OF ACTIONS, IF ANY, THE GOVERNMENT MAY TAKE TO REMOVE OR OVERCOME ANY

BARRIERS TO COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED.

For the reasons set forth in this document NAVFAC MIDLANT and the USAF Combat Arms Program have already determined that this product is the best suited to remove potential hazards from personnel and property while maintaining the stringent requirements of a SAFR. Furthermore, the USCG is to follow the guidance of the USAF Technical letter 11-18 for firing ranges IAW COMDTINST M11000.11. If other potential sources emerge, the USAF is responsible for assessing whether competition for future requirements has merit and is feasible. Until that time, Troy Acoustics should be the sole source of supply for all future USCG FORCECOM Armory Cape Cod purchases of supplies covered by this document.

SIGNATURE AND TITLE OF CUSTOMER

GM1 Kyle Honning

CODE

TELEPHONE NUMBER

508-968-6886

DATE

24OCT2023

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE NUMBER

DATE