A16_JOFOC_Under_SAT_JOFL_-_Tractor_Repair_-_redacted_1.pdf

Last updated 6/2/2016

ATTACHMENT 2

JUSTIFICATION & APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION

for SIMPLIFIED ACQUISITIONS OVER THE MICROPURCHASE THRESHOLD (See FAR

Part 2) UP TO SAT

(See RFO FAR 12.102 (a))

Date: August 28, 2026

PR Number: 0044055128

1. Nature and/or description of the item/service being procured and its intended use (include the anticipated cost):

National Park Service (NPS) – Johnstown Flood National Memorial (JOFL) has an emergency requirement for the repair of the transmission case for the only tractor the park currently has. The tractor transmission case has a significant crack and is unsafe to operate in its current condition. The tractor was taken to the nearest Kioti repair shop Forshey AG and Industrial (Golden Rule Equipment LLC) in

Martinsburg Pa to have the tractor looked at and receive an estimate for repairs. Forsheys is the closest authorized repair center for Koiti tractors.

On April 21, 2026 the diagnosis of the repair was more significant than originally thought, as it was discovered that the cab needed to be raised and the tractor needed to be split. The entire rear half of the transmission needs to be removed and reinstalled into the new case. All the bearings and gaskets will also need to be replaced as the old ones cannot be reused along with draining and replacement of the hydraulic fluid. Golden Rule Equipment LLC in Martinsburg provided an estimate for the repairs at:

2. Sole Source Justification rationale (Check one and explain below):

______ Only one responsible source.

__X____ Urgent and compelling circumstances exist. Include critical delivery or performance dates, and when you became aware of the requirement. Provide a specific statement of the impact on

Government operations, financial or otherwise, if the required delivery or performance dates are not met.

______ Other _____________________________________________________

Explain:

In accordance with Revolutionary FAR overhaul (RFO), which was implemented through DOI-AAAP-

F012 and RFO FAR 12.102 (a) For acquisitions valued at or below the simplified acquisition threshold

(SAT), document the decision that only one source is available and the basis for the decision.

The tractor in question is the only tractor for the park. The tractor is the main piece of equipment that is used to brush hog fields and maintain the 14 miles of trails. This time of year, is critical to maintain the park’s trails and fields as it is the heightened season for visitor use.

As a result, the tractor must be repaired as quickly as possible, so JOFL is able to maintain the park for visitor use and enjoyment. With the tractor being down for an extended period it increases the risk of life and safety issues with the visitors. The trails travel through areas where significant line of sight views are necessary for safety, due to proximity to roads, intersections, steep cliffs, and wildlife. It also risks the natural resources that JOFL is designated to protect.

As noted above is Section 1, the tractor was taken to Golden Rule Equipment LLC for the initial diagnosis. Part of the diagnosis process required the removal of some parts of the transmission. As the tractor was partially disassembled, and because of the damage that was found there is a significant risk of increased damage should the truck be moved to another location. There is also a risk of increased costs with additional damage, towing, etc. should the vehicle be moved and break down in route to new location.

As authorized by RFO 1.102 (b)(2) awarding to only Golden Rule Equipment LLC is considered to be a business decision and in the best interest of the Government and poses the least amount of risk. They are an authorized Kioti Service provider and the closest Kioti Service provider to JOFL.

3. Market Research. Please explain the results or why one was not performed. State whether any other offers were received or anyone expressed interest:

Market Research conducted by the Contracting Officer, and only one (1) vendor, Golden Rule Equipment

LLC) in Martinsburg PA was identified and capable of responding to urgent repair requirements. The location of Martinsburg PA is the closest to JOFL. Golden Rule Equipment LLC in Martinsburg PA is registered in the System for Award Management (SAM) which is required by RFO 4.203-1 (b). While not required for an emergency per RFO (b)(4), it does make the overall award and payment process easier and quicker.

The CO conducted an SBA search for file purposes as the work needed to be completed, and the SBA search that revealed 342 vendors under the NAICS Code 811310 – Commercial and Industrial Machinery and Equipment (except Automotive and Electronic) Repair and Maintenance in state of PA, which to this

Contracting Officer (CO) reasonably concluded as the correct NAICS code to use. Of the 342 potential contractors only Golden Rule Equipment LLC was found to be a Certified Kioti Service Center that is registered in SAM.gov that is close to JOFL.

Per RFO 1.102 (a)(1) and EO 13834 on efficient federal operation, the Government is required to minimize administration operating costs and due things more efficiently, and since Golden Rule

Equipment LLC performed the initial diagnostics, which did require some disassembly, it is not considered efficient to pack tractor up for diagnostics and repair somewhere else they is further away.

While competition is preferred, only Golden Rule Equipment LLC was found to be a Certified Kioti

Service provider and the closest Kioti Service provider to JOFL.

4. If this is a determination for sole source, the contracting officer certifies:

a. Only one source is available, or urgent and compelling circumstances exist.

a. The anticipated price will be determined fair and reasonable per RFO 12.201-1 (e)(2) and using the price analysis techniques described in original FAR Part 13.106-3(a), as authorized by RFO

1.102 (b)(4), because the RFO does not fully address detailed price analysis techniques under

RFO Part 12 in this CO’s opinion, and creates inconsistencies, which can reasonably be eliminated by using the original FAR 13 fair and reasonable determinations for simplified acquisition procedures under the SAT.

(Signature) _______________________________________ (Date)__________________________

Type or Print Name: __________________________________________

Title:

(Signature) _______________________________________ (Date)

Type or Print Name: Brian McCabe

Contracting Officer

Over $50,000:(if applicable)

(Signature) _______________________________________ (Date) ______________________

Warranted Individual 1 Level Above Contracting Officer