B08_-_Attachment_2_-_Brand-Name_-_JOFOC_Ventrac_-_redacted.pdf

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 FAR 13.106-1)

Date: May 21, 2025 PR Number:

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

The National Park Service – Valley Forge National Historical Park (VAFO) Maintenance Division (MD) is required to maintain 2,400 acres of land for public use and recreation. VAFO has historically used a mowing contractor to maintain the high visitation areas of the park to include the Visitor Center, Administration/Theater and General George Washington’s Headquarters. Due to significant staffing reductions and higher-level reviews for contracts, the mowing contract for VAFO will not be awarded this year.

Without contractor’s help, VAFO needs to purchase new lawnmowing equipment that will be used by the Maintenance Division for all future lawn mowing. The lawn mowing equipment is critical to mission needs, for both public and employee safety, and will reduce fire risks due to high grass if not maintained. Due to the unique hilly landscape at VAFO, which has up to 30-degree slopes, and the lack of VAFO staff having Commercial Driver’s License (CDL)’s the type of lawn mowing equipment that is available is extremely limited.

The Ventrac by Venture Products, Inc (Ventrac) 4520N PRO has been identified as only commercially available piece of lawn mowing equipment that can be safely operated up to a 30-degree slope and not require a Commercial Driver’s License (CDL) to operate. Additionally, the Ventrac 4520N PRO has a lower horsepower rating, which allows any trained NPS employee regardless of grade the ability to safely operate the equipment.

The Ventrac 4520 PRO’s proprietary slope alarm and dual wheel kit enhances employee safety. The attachment control kit enables the use of the 95” and 72” mower decks and the suitcase weights helps to prevent getting stuck in muddy conditions.

The estimated value for the Ventrac 4250 PRO:

The estimated value for the 95” mowing deck MK960:

The estimated value for the 72” mowing deck MS720:

Total Cost:

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

______ Only one responsible source.

______ 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.

___X___ Other: Brand-name

Explain:

In accordance with Federal Acquisition Regulation 13.106-1(b)(1) For purchases not exceeding the simplified acquisition threshold (i) Contracting Officers may solicit from one source if the contracting officer determines that the circumstances of the contract action deem only one source reasonably available.

As stated above, due to a new lawn mowing services contract not being in place, VAFO requires new lawn mowing equipment. Having dedicated lawn mowing equipment for VAFO will save costs that are otherwise tied up with often unreliable lawn mowing service contracts that are difficult to establish with a level of consistency that can be better achieved with VAFO park staff.

Additionally, dedicated equipment, will significantly reduce the risk of wildland fire because to equipment will be readily available and the landscape can be maintained more often as required. With contracted services, it is difficult to have a contractor respond outside what the contract provides, without adding additional provisions and requirements that can be costly. Aside from the costs, there are also delays with contracted resources, as they may not be available to respond to urgent needs, like NPS staff could with dedicated lawnmowing equipment.

While there were other ride-on type lawn mowing equipment available from John Deere, Steniner, Cub Cadet and Toro to name a few. Many were found to offer similar features; however, none were found capable of safely operating on slopes up to 30 degrees, which the Ventrac was designed to do. While other ride-on type lawn mowing equipment were found to be available from other manufacturers, each manufacture has unique features, specifications and other details that are particular to that manufacture and were not found to meet the unique needs of VAFO.

Additionally, the brand-name specific Ventrac 4520 PRO is being used at other NPS Sites in Northeast Region that have similar slope characteristics to VAFO. Having the same manufacturer in the Northeast Region adds a commonality in service and repair items that can be interchanged between the lawn mowing equipment of the same manufacture; thereby reducing overall operating costs and down time. When a fleet is mixed with multiple manufactures, it requires storage for additional items, because often parts are not interchangeable between manufacturers.

Ventrac by Venture Products, Inc.is American Made, and in compliance with the By American Act. As stated in FAR 13.106-1 (b)(1)(i) as the requirement is less than the simplified acquisition threshold, Contracting Officers may solicit from one source if the circumstances of the contract action deem one source reasonably available, which includes brand-name, and market research indicates other companies’ similar products do not meet the agency’s need.

Only one source was found locally, but the brand name specific Ventrac equipment is essential to the Governments requirements.

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

Extensive Market Research was performed by the Contracting Officer (CO) in preparation of this requirement. The brand-name specific Ventrac by Venture Products, Inc. Ventrac 4250 Pro was not found to be available on GSA Schedules, so GSA Schedules were not considered for this requirement.

Ventrac by Venture Products, Inc. was found to be available from multiple sources on the Open Market.

As a result the solicitation will be issued on the open market, that restricts the requirement only to the brand-name specific Ventrac by Venture Products, Inc.

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.

b. The anticipated price will be determined fair and reasonable using the price analysis techniques described in FAR Part 13.106-3(a).

(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

6/2/2025

6/2/2025

Brent D. Coons, Chief of Fa

BRENT

COONS

Digitally signed by

BRENT COONS

Date: 2025.06.02 07:31:00 -04'00'

BRIAN

MCCABE

Digitally signed by BRIAN

MCCABE

Date: 2025.06.02 10:10:29 -06'00'