Attachment 2 - Justification and Approval of Brand Name Items.pdf

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Lightning Protection System
Solicitation number
Lightning0001
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This is a Department of the Air Force Justification for Other Than Full and Open Competition (J&A) document for a non-competitive acquisition valued under $10 million. The contracting officer is SSgt. Kaylie Anderson of 21CONS/PKA, and the technical lead is SSgt. Michael H. Rogers. The document was signed on April 2-3, 2026.

The acquisition concerns a Firm Fixed Price Purchase Order to S&C Electric Supplies for Lightning Protection Systems (LPS) components to support 21CES (Civil Engineer Squadron). The specific items required are two Burndy Patriot High Performance 18 Volt Battery Actuated Tools with Kuefler Lightning attachments, two Burndy U-Die Kits, and one Hilti or Bosch SDS 1-1/8" Cordless Hammerdrill. These supplies are necessary to repair a damaged electrical system and bring it into compliance with DAFMAN 32-1065, including testing continuity and ground resistance with third-party inspection certification. The justification cites 10 U.S.C. 3204(a)(1) as statutory authority, claiming only one responsible source exists. The rationale emphasizes inventory compatibility—21CES currently stocks these specific brand names, and continued use prevents incompatibility issues and wasteful duplicate purchases of accessory items. A Sources Sought posted to SAM.gov from March 18-25, 2026 yielded two responses with no substantive information. Market research identified the appropriate NAICS code as 335931 (Current-Carrying Wiring Device Manufacturing) and PSC code 5920 (Fuses, Arrestors, Absorbers, and Protectors), revealing 1,398 active small businesses capable of supplying similar items. The document notes AbilityOne cannot supply these products and commits to researching alternative brand items and monitoring market availability for future procurements.

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File Type Posted
Attachment 1 - LPS Product List.xlsx XLSX spreadsheet
RFO FA251726Q0026 Lighning Protection System.pdf PDF

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Department of the Air Force: Justification for Other Than Full and Open Competition

CUI

March 2026 CUI Page 1 of 3March 2026 CUI Page 1 of 3

Dollar Value of this Acquisition: < $10M > $10M and < $100M > $100M and < $500M > $500M

CERTIFICATIONS: CO certification serves as J&A approval < $10M, See J&A Template Guidance at https://usaf.dps.mil/sites/ AFCC/AQCP/KnowledgeCenter/SitePages/DAF-Contracting-Compass/Part-6---Competition-Requirements.aspx for completing the J&A sections and J&A Approval Guidance

Date

02 April 2026

Contracting Officer (RFO 6.104-1(12)) SSgt. Kaylie Anderson

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Signature

Date

03 April 2026

Technical and Requirements Personnel (RFO 6.104(b)) SSgt. Michael H. Rogers

I certify that the supporting data herein, which is my responsibility, is accurate and complete.

Signature

COORDINATION Sign and Save Procedure

** The text in the signature blocks below is editable, including the title.

** To remove a row, click the "X" next to the signature block. CAUTION: Once removed, it can only be restored by downloading the BLANK FORM again.

APPROVALS ( RFO 6.104-2(a) Table 6-1 & R-DFARS 206.104-72 Table 206.1)

See J&A Template Guidance (https://usaf.dps.mil/sites/AFCC/AQCP/KnowledgeCenter/SitePages/DAF-Contracting-Compass/ Part-6---Competition-Requirements.aspx) - J&A Approval Guidelines

NOTE 1: A signature block will appear here (replacing these notes) based on the "Dollar Value of this Acquisition" selected above. Since most digital signatures that include date/time-stamps are redacted before they are made publicly available, always insert the date in the “Date” cell when affixing a digital signature to this document.

March 2026 CUI Page 2 of 3March 2026 CUI Page 2 of 3

I. Agency and Contracting Activity (RFO 6.104-1(a)(1)):

Agency: 21CES Contracting Activity: 21CONS/PKA

II. Nature and/or description of the action being approved (RFO 6.104-1(a)(2)):

This document approves the award of a Firm Fixed Price Purchase Order on a Limited Sources basis for S&C Electric Supplies in support of the 21CES. This justification is made on an individual basis. Below are the supplies listed to acquire. The first three are necessary to be Brand Name S&C Electric items:

2x Burndy Patriot High Performance 18 Volt Battery Actuated Tool - Kuefler Lightning 2x Burndy U-Die Kits 1x Hilti or Bosch SDS 1-1/8" Cordless Hammerdrill

These supplies will be needed to bring the damaged current system into compliance with DAFMAN 32-1065. The work requires compliance with various standards, testing continuity and ground resistance, and certification by a third-party inspector which is not included in this requirement.

III. Description of supplies/services required to meet agency needs (RFO 6.104-1(a)(3)):

Lightning Protection Systems (LPS) protect critical components necessary for mission readiness. If the building is struck by lightning, it could result in major electrical component failures, leaving the base reliant on generators. The safety of equipment and personnel could be compromised if major weather events occur.

IV. Statutory Authority Permitting Other Than Full and Open Competition (RFO 6.104-1(a)(4)):

10 U.S.C. 3204(a)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.

V. Rationale for Use of Authority (RFO 6.104-1(a)(5)):

The 21CES currently has batteries and spare parts in their inventory set to the above listed name brand items. Continuation of the use of these brand name items prevents incompatibility issues and reduce unnecessary and wasteful repeated purchases of other brand item accessories.

VI. Integrated Market Analysis and Efforts to Solicit Competition (RFO 6.104-1(a)(6), (8), and (10)):

A Sources Sought was posted to SAM.gov on March 18, 2026 and ended on March 25, 2026. We received 2 responses stating interest in providing the supplies, but no further information on any items in the list. A previous Market Research Report from Jan 2025, found 3 more sources who could provide supplies and service for that specific requirement. A search on the SBA.gov small business search found a total of 88 active small businesses under the NAICS 238290, increasing the probability of vendors being able to supply.

Upon CO review, a more appropriate NAICS and PSC code were recommended. The NAICS will be changed to 335931 - Current-Carrying Wiring Device Manufacturing and the PSC will be 5920 - Fuses, Arrestors, Absorbers, and Protectors.

Searching the SBA.gov under the updated NAICS of 335931, there are 1,398 active small businesses under this NAICS, increasing confidence of competition when soliciting.

AbilityOne cannot supply these products. None of the responses expressed any information for alternatives to the tools.

March 2026 CUI Page 3 of 3March 2026 CUI Page 3 of 3

VII. Determination of Fair and Reasonable Cost (RFO 6.104-1(a)(7)):

The Contracting Officer is responsible for evaluating, determining, and documenting the anticipated contract cost/price is fair and reasonable in accordance with RFO Subpart 15.4, Contract Pricing.

VIII. Any Other Facts Supporting the Justification (RFO 6.104-1(a)(9)):

N/A

IX. Actions to Overcome Barriers to Competition (RFO 6.104-1(a)(11):

Following this acquisition, 21CES will research alternatives to the brand name items listed above.

21CONS will continue to monitor and confirm market and industry availability and adhere to future regulations applicable to the base and the ongoing operations and maintenance.

March 2026 Page of Dollar Value of this Acquisition:

CERTIFICATIONS: CO certification serves as J&A approval < $10M, See J&A Template Guidance at https://usaf.dps.mil/sites/AFCC/AQCP/KnowledgeCenter/SitePages/DAF-Contracting-Compass/Part-6---Competition-Requirements.aspx for completing the J&A sections and J&A Approval Guidance

COORDINATION

** The text in the signature blocks below is editable, including the title.

** To remove a row, click the "X" next to the signature block. CAUTION: Once removed, it can only be restored by downloading the BLANK FORM again.

APPROVALS ( RFO 6.104-2(a) Table 6-1 & R-DFARS 206.104-72 Table 206.1) See J&A Template Guidance (https://usaf.dps.mil/sites/AFCC/AQCP/KnowledgeCenter/SitePages/DAF-Contracting-Compass/Part-6---Competition-Requirements.aspx) - J&A Approval Guidelines NOTE 1: A signature block will appear here (replacing these notes) based on the "Dollar Value of this Acquisition" selected above. Since most digital signatures that include date/time-stamps are redacted before they are made publicly available, always insert the date in the “Date” cell when affixing a digital signature to this document.

I. Agency and Contracting Activity (RFO 6.104-1(a)(1)):

II. Nature and/or description of the action being approved (RFO 6.104-1(a)(2)):

III. Description of supplies/services required to meet agency needs (RFO 6.104-1(a)(3)):

IV. Statutory Authority Permitting Other Than Full and Open Competition (RFO 6.104-1(a)(4)):

V. Rationale for Use of Authority (RFO 6.104-1(a)(5)):

VI. Integrated Market Analysis and Efforts to Solicit Competition (RFO 6.104-1(a)(6), (8), and (10)):

VII. Determination of Fair and Reasonable Cost (RFO 6.104-1(a)(7)):

VIII. Any Other Facts Supporting the Justification (RFO 6.104-1(a)(9)):

IX. Actions to Overcome Barriers to Competition (RFO 6.104-1(a)(11):

9.0.0.2.20120627.2.874785

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Date: 02 Apr 2026
Date: 03 Apr 2026
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Authority: 10 U.S.C. 3204(a)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.
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