B08_Solicitation_140P1426Q0032-Roofing_Materials-_Attachment_2-Brand_Name_Justification.pdf

United States Department of the Interior

NATIONAL PARK SERVICE

CONTRACTING OPERATIONS - CENTRAL

1849 C Street NW Washington, DC 20240

Justification for Brand Name Products

Date: 2/4/2026

Project: Roof Coating Materials

1. Identifications

a. Agency: National Park Service

b. Contracting Office: NR Major Acquisition Buying Office

2. Description of the action being approved:

The National Park Service (NPS) shall be soliciting for Roof Coating Materials. The documents included with the solicitation call for specific brand name products that are peculiar to one manufacturer. This written justification provides approval for limiting competition to the listed brand name products as authorized by the Federal Acquisition Regulations (FAR).

3. Description of supplies and services:

Roof coating materials for replacing 3300 sq ft of roofing on comfort stations in Fish Creek and Rising Sun. The Government requires delivery of roofing materials compatible with existing SURECOAT roof coating systems installed on comfort station roofs. All materials shall be new, unused, and delivered in original manufacturer packaging.

4. Authority:

a. 41 U.S.C. 253(c)(1): Only one responsible source and no other supplies or services will satisfy agency requirements.

b. FAR Part 11.105: The Brand Name products are essential to the Government’s requirements, and market research indicates other companies’ similar products do not meet and cannot be modified to meet the agency’s needs.

c. FAR 6.302-1: The use of the name brand products are essential to the Government’s requirements, thereby precluding consideration of a product manufactured by another company.

5. The description of the product’s unique qualifications or the unique nature of the acquisition:

SURECOAT roofing materials are the only products compatible with the existing roof coating systems installed on the Park’s comfort station roofs. The Park has standardized on the SURECOAT system across more than twenty (20) facilities, and the specified materials are required to maintain system integrity, ensure proper adhesion and performance, and allow for consistent maintenance and repair. Roofing products from other manufacturers are not compatible with the existing SURECOAT system and may compromise performance, void manufacturer warranties, and increase lifecycle maintenance costs. For these reasons, only SURECOAT brand materials can meet the Government’s minimum requirements.

6. Efforts to obtain competition:

a. Efforts to ensure offers are solicited from as many potential sources as is practicable:

For acquisitions over $25,000 the solicitation will be issued on the Government’s Point of Entry, sam.gov.

b. Presolicitation notice per FAR 5.2:

For acquisitions over $25,000 a presolicitation notice shall be posted on the Government’s Point of Entry, sam.gov unless the exception noted at FAR Part 5.202(a)(13) applies.

7. Determination that costs will be fair & reasonable:

In accordance with FAR 13.106-3(a), the Government will determine price reasonableness through price analysis. Market research included a review of the SBA Dynamic Small Business Search (DSBS) under NAICS 324122, which identified approximately 73 small businesses capable of supplying roofing-related products. Although this acquisition is limited to SURECOAT brand materials to meet compatibility requirements, the existence of multiple small business suppliers within the applicable NAICS supports the reasonableness of market-based pricing.

Price reasonableness will be evaluated by comparing the proposed price to historical prices paid for the same or similar SURECOAT materials, reviewing current manufacturer or authorized distributor pricing, and confirming consistency with prevailing commercial market prices. Based on this analysis, the Government will determine that the proposed price is fair and reasonable.

8. Description of the market research conducted:

The Contracting Officer reviewed existing roof systems, historical maintenance records, and manufacturer technical specifications for the roof coating materials currently installed on comfort station roofs throughout the Park. This review confirmed that the Park has standardized on the SURECOAT roof coating system across more than twenty (20) facilities.

Additional market research included a review of roofing product manufacturers and suppliers identified through the SBA Dynamic Small Business Search (DSBS) under NAICS 324122. While multiple small businesses were identified as capable of supplying roofing-related products, no alternative manufacturers were identified whose products were compatible with the existing SURECOAT system or could be reasonably modified to meet the Government’s requirements without introducing technical risk, increased maintenance complexity, or potential warranty impacts.

Based on the results of this market research, no other products were determined to be capable of meeting the Government’s minimum needs, and the use of alternative products would require replacement or reconfiguration of existing roof systems, resulting in unnecessary cost and risk to the Government.

9. Other facts supporting other than full & open competition:

a. Reason why documents suitable for full & open competition have not been developed:

Documents suitable for full and open competition have not been developed because the Government’s minimum requirements are based on compatibility with existing roof coating systems already installed throughout the Park.

The Park has standardized the SURECOAT roofing system for more than twenty (20) comfort station roofs. Roofing materials from other manufacturers are not compatible with the existing SURECOAT system and cannot be reasonably substituted or modified without risking adhesion failure, system incompatibility, and potential voiding of manufacturer warranties. As a result, non–brand-name products cannot meet the Government’s requirements.

b. Data, estimated costs or other rationale as to the extent or harm to the Government:

Procuring roofing materials other than the specified SURECOAT products would result in increased costs and technical risk to the Government. Use of incompatible materials could require removal or replacement of existing roof coatings, additional labor, increased maintenance frequency, and potential premature roof failure. Introducing multiple roofing systems would also increase lifecycle maintenance costs, training requirements, and inventory complexity. These outcomes would result in unnecessary expense and operational risk to the Government and would not represent a prudent use of public funds.

10. Interested Sources:

Market research and prior procurement history indicate that SURECOAT, through its authorized distributors, is the only source capable of providing materials compatible with the Park’s existing roof coating systems. No other contractors or manufacturers have previously expressed interest in providing compatible alternative products that meet the Government’s minimum requirements.

11. Actions to remove barriers to competition in the future for similar acquisitions:

The Government will continue to evaluate roofing system requirements during future facility upgrades, new construction, or full roof replacement projects to determine whether competitive alternatives may be feasible. Where practicable, future acquisitions may be structured to allow for competition by selecting roofing systems during initial installation that permit the use of multiple compatible products. However, until existing roof systems reach the end of their useful life or are fully replaced, continued use of compatible materials is necessary to meet operational and maintenance requirements.

12. Certifications:

Technical / Requirements Certification:

I certify that any supporting data that is the responsibility of technical or requirements personnel (i.e. verifying the Government’s minimum needs or schedule requirements or other rationale for other than full and open competition) and which form a basis for the justification have been certified as complete and accurate:

(Signature)________________________________________ (Date) _______________________

(Type or Print Name): __________________________________________________

(Title):

Up to $50,000

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

(Signature) _______________________________________ (Date) _______________________

(Type or Print Name): __________________________________________________

Contracting Officer

Eric Hagen

Maintenance Mechanice Supervisor

2/4/2026