8. Limiting-Competition-under-SAT_ACC Signed.pdf

Control No: 22-117

Version – February 2017

Memorandum for Record – Limiting Competition at or below the Simplified

Acquisition Threshold

1. Contracting Activity: RCO-Kunsan, ROK.

2. Description of Action: 8 MXS Clausing Brand 18” x 60” Engine Lathe

Nature: New Requirement Follow-on Requirement

Contract Vehicle: Purchase Order Number: W90VN7-22-TBD

Blanket Purchase Agreement (BPA) Number _______________ Order/BPA# _______ against FSS Contract #_____ _________ Order #___________ against Multiple Award IDIQ Contract Name or #______________

Order #_______ against a single award IDC Contract

Modification # _______ to existing PO/TO/DO/Call Order

Pricing/Contract Type: Fixed Price Time & Materials/Labor Hours Cost Reimbursable Hybrid

Funds: Operations & Maintenance, Army (OMA) Other Funds: ________

FY: 22

Name of Proposed Contractor(s) and Address: TBD; Name Brand item - Clausing

CLAUSING INDUSTRIAL, INC.

3963 Emerald Drive Kalamazoo, MI 49001

ERC Services, INC

387 GOLFVIEW LN STE 100

HIGHLAND HEIGHTS, OH 44143

Clausing Industrial INC 3963 Emerald Dr Kalamazoo, MI 49001

Brand Name Buy: Yes No

3. Description of Services or Supplies:

Purchase and shipment of 1 EA 18” x 60” Profession Gap Bed lathe with an assortment of accessories for holding/cutting material and a 2-axis Digital Read Out (DRO) installed.

4. Authority:

FAR 13.106-1(b)(1): For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

Or

FAR 8.405-6(a)(1)(i)(B) and 8.405-6(b)(1)Brand Name FAR 8.405-6(a)(1)(i)(A) Urgency FAR 8.405-6(a)(1)(i)(B) Only One Source is Capable FAR 8.405-6(a)(1)(i)(C) Logical Follow-on

Or

FAR 16.505(b)(2)(i)(B) Only One Awardee is Capable FAR 16.505(a)(4) Brand Name FAR 16.505(b)(2)(i)(A) Urgency FAR 16.505(b)(2)(i)(C) Logical Follow-on FAR 16.505(b)(2)(i)(D) Minimum Guarantee

5. Reasons for Authority Cited:

Clausing is the only manual machining lathe that can accommodate required work for aircraft part fabrication for mission requirements on Kunsan. Other lathes do not offer specific options like the correct 2-axis DRO installed and calibrated, including a 5C collet set for different size materials in increments of 1/64” and the option of 3-jaw, 4-jaw, and 6-jaw chucks for holding larger/odd-shaped material and parts. Competitor lathes do not offer a single lathe that can fitted with all the required items included in this quote. Multiple lathes would be required to match the capability of this single lathe.

Additionally, the manual machine market is consolidating due to acquisitions of older manufacturers and the emergence of Computer Numerically Controlled (CNC) Mills and lathes have becoming more readily available. Unfortunately due to mission requirements CNC lathes do not increase capability but hinder it.

6. Publicizing Contract Actions: For FAR Part 13 actions, the public display and synopsis requirements of FAR 5.101 and FAR 5.203 do not apply due to the $ threshold, apply and will be followed, or do not apply due to an exception at 5.202(a)(13).

Requirement to post justification in accordance with FAR 8.405-6(b)(3), FAR 13.105(c), or FAR 16.505(a)(4)(iii)(A)

Action is NOT a brand name restriction and is under $150K, no posting required

Action is a brand name restriction, under $25K, no posting required Action is a brand name restriction, over $25K. It will be redacted and posted with the solicitation.

Action is a brand name restriction over $25K but will not be posted due to exception:

FAR 6.305(f) FAR 8.405-6(b)(3)(iii)(A)

FAR 8.405-6(b)(3)(iii)(B) FAR 8.405-6(b)(3)(iii)(C) FAR 16.505(a)(4)(iii(C)

7. Market Research:

There are several vendors that can provide 1 EA 18” x 60” Profession Gap Bed lathe with an assortment of accessories

Search on SAM.GOV results in at least five(5) Clausing dealers. Additionally, a search conducted in Prices Paid Portal showed that 21 procurements of Clausing Industries products were contracted across DOD since 2010. References:

• SAM.GOV

• Prices Paid Portal

8. Other Facts:

The manual machine market is consolidating due to acquisitions of older manufacturers and the emergence of Computer Numerically Controlled (CNC) Mills and lathes have becoming more readily available. While other companies starting up, they do not have the support or accessories that can match Clausing’s capabilities. This shortfall is prevalent through fabrication worldwide.

8 MXS currently possess multiple other Clausing machines in their shop and this will allow for more standardization when it comes to acquiring parts and services.

9. Technical/Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Typed Name: MAJ Titus, Nathaniel Date:31 https://sam.gov/search/?page=1&pageSize=25&sort=-modifiedDate&sfm%5BsimpleSearch%5D%5BkeywordRadio%5D=ALL&sfm%5BsimpleSearch%5D%5BkeywordTags%5D%5B0%5D%5Bkey%5D=clausing&sfm%5BsimpleSearch%5D%5BkeywordTags%5D%5B0%5D%5Bvalue%5D=clausing&sfm%5Bstatus%5D%5Bis_active%5D=true https://p3.cap.gsa.gov/gui/banana/dashboard-include.jsp#/dashboard?query=JnE9Q2xhdXNpbmcmcS5vcD1BTkQmcS5hbHQ9KiZkZWZUeXBlPWVkaXNtYXg%3D

Title: Contract Specialist

Signature:

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10. Contracting Officer Certification/Approval:

I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable based upon Price analysis conducted by reviewing past procurement actions of Motorola.

I certify that this justification is accurate and complete to the best of my knowledge and belief, and that completing this purchase as a sole source is in the best interest of the Government. Additionally, I approve this justification to limit competition subject to the availability of funds and provided that the services or supplies herein described have otherwise been authorized for acquisition.

Typed Name: SSG Robert Anderson Date: 31AUG22 Title: Contracting Officer

Signature:

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