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This is a Determination & Findings (D&F) document for a sole-source procurement by the Army Research Laboratory (ARL). The procuring activity seeks to acquire one hydrogen generator (Nel Hydrogen model S40), associated parts, and one year of preventative maintenance from Proton Energy Systems, Inc. d/b/a Nel Hydrogen US, located in Wallingford, Connecticut (CAGE Code 1UZE7). The estimated total contract value is $120,328.50, and the contracting officer is Alex Cheatham, who signed the document on January 15, 2026.

The justification for sole-source procurement is based on "other reasoning" supporting the necessity of an identical hydrogen generator unit. The Radiofrequency Devices and Circuits Branch at ARL's Sensors and Electron Devices Directorate requires this equipment to supply hydrogen for diamond deposition reactors used in mission-critical research. A Nel Hydrogen model S40 unit was previously purchased and integrated into the laboratory's hydrogen gas supply system; a second identical unit is required for seamless integration into the same manifold system. Design variations between different manufacturers would create operational inconsistencies and compromise the ability to produce high-quality electronic-grade diamond material, directly impacting RF device performance. The diamond reactors are manufactured by Element Six, a United Kingdom-based supplier, and Element Six specifically uses Nel Hydrogen systems in their production facilities. Market research conducted by Dr. Elias Garratt from August 1 to September 1, 2025, through consultations with subject matter experts and Element Six's Capital Projects Manager, determined that Nel Hydrogen is the only company capable of meeting the government's minimum requirements. The fair and reasonable price determination has been approved.

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DETERMINATION & FINDINGS FOR OTHER THAN FULL & OPEN COMPETITION

(ACTIONS SAT AND BELOW)

1. DESCRIPTION OF PROPOSED PROCUREMENT: One (1) hydrogen generator, associated parts, and one (1) year of preventative maintenance.

2. PROPOSED CONTRACTOR/MANUFACTURER:

Proton Energy Systems, Inc d/b/a Nel Hydrogen US 10 Technology Drive, Wallingford, CT 06492 CAGE Code: 1UZE7

3. ESTIMATED TOTAL VALUE: $120,328.50

4. STATUTORY AUTHORITY PERMITTING CONTRACTING WITHOUT PROVIDING FOR FULL

AND OPEN COMPETITION: The statutory authority permitting sole source is 41 USC 1901(e), implemented by FAR 13.106-1(b)(1)(i):

_X_ Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

___ Unusual and Compelling Urgency ___ Industrial Mobilization; Engineering, Developmental, or Research Capability; or Expert

Services ___ International Agreement ___ Authorized or Required by Statute ___ National Security ___ Public Interest

5. JUSTIFICATION FOR THE AUTHORITY CITED ABOVE:

The item(s) listed in section one above is available from only one source and competition is precluded for reasons indicated below. There are no substitutes available.

___ Compatibility: The item(s) must be compatible in all aspects (form, fit, and function) with existing systems presently installed. Describe the equipment you have now and how the new item/service must coordinate, connect, or interface with the existing system:

___ Proprietary: A patent, copyright, or proprietary data limits competition. The proprietary data are described as follows:

__ Experimental Continuity: The item(s) must be consistent with prior materials in order to ensure experimental continuity. Describe the conditions that necessitate the use of experimental continuity:

___ Warranty: Purchasing item(s) from another manufacturer/provider would void existing warranty. Provide a brief explanation for the use of th, is reason and the impact that would occur if the item was purchased from another manufacturer/provider:

___ Direct Replacement: These are “direct replacement” parts/components for existing equipment and no substitutes exist.

_X_ Other reasoning to support a sole-source buy:

The Radiofrequency (RF) Devices and Circuits Branch within the Sensors and Electron Devices Directorate (SEDD) at the Army Research Laboratory (ARL) requires one (1) hydrogen generator, associated parts, and one (1) year of preventative maintenance for mission critical research. The hydrogen generator is needed to provide a source of hydrogen for diamond deposition reactors. The hydrogen generator must also convert water into oxygen and hydrogen gas to provide a supply of hydrogen gas that will support the operation of diamond deposition reactors.

A nel Hydrogen/Proton Energy Systems hydrogen generator (model S40) was previously purchased to be integrated into the hydrogen gas supply system for the diamond reactors. The gas supply system consists of a hydrogen generator and purifier with hydrogen gas passed through a manifold which regulates and directs purified gas to the reactors. The branch requires a second, identical unit to supply hydrogen through the same system. Reliability is essential, and since this second generator will be integrated into the same manifold as the first, it is necessary to have an identical unit as first.

Variation in design between different hydrogen generator manufacturers can lead to inconsistencies in the operation and output of the reactors. Therefore, it is essential to have identical infrastructure for process control in order to have the ability to grow high quality material. If the team cannot grow and achieve high quality material this will result in inconsistent RF device performance and lead to project failure.

The diamond deposition reactors purchased by ARL are manufactured by Element Six, a leading diamond supplier based in the United Kingdom with offices and diamond growth facilities in the United States. Element Six is the world leading supplier of diamond for electronics and quantum materials and has been developing diamond for these applications for decades. ARL is working with Element Six to bring their electronic grade diamond material growth capability to ARL through the purchase of diamond deposition reactors. Along with these reactors ancillary equipment including the hydrogen generator is required to reproduce electronic grade diamond material. To minimize the risk of not achieving identical process conditions and therefore equivalent diamond material compared to that produced by Element Six, it is required to have as identical a setup to their production reactors as possible.

Therefore, the Government requires the nel Hydrogen systems to generate hydrogen to feed out deposition reactors. Nel Hydrogen systems have three key features required for electronic grade diamond growth: a load-following system which adapts to increases or decreases in hydrogen gas demands, a proton exchange membrane, and it does not require the use of caustic chemicals which can complicate and contaminate the growth process. If these requirements are not met, we risk subverting the mission and investments already made to establish a diamond lab capable of producing electronic grade diamond at ARL. This will also degrade device research in diamond and put the Government at a severe disadvantage compared to global competitors in the field of advanced electronics and electronic warfare development.

Market research was performed by Dr. Elias Garratt (ARL), Research Physicist for Radio-frequency Devices and Circuits Branch at ARL, with 15 years’ experience. Market research was conducted between 01 August 2025 to 01 September 2025 and was determined that the requirement was not available from UNICOR, AbilityOne, CHESS (not IT), or GSA. Efforts include contacting subject matter experts (SME’s) within the Government and industry, conducting interchange meetings to involve potential offerors early in the acquisition process. Specifically, Dr. Garratt conferred with Dr. Brenda VanMil (Research Physicist, ARL) and Dr. Brad Pate (Physicist, NRL) whom both have built crystal growth Silicon Carbide (SiC) and diamond laboratories themselves. Additionally, Dr. Garratt received specific guidance from Mike Cooper (Capital Projects Manager, Element Six) concerning the equipment needed to reproduce electronic grade diamond growth using their reactors. Mr. Cooper specifically referenced Nel Hydrogen as the manufacturer they use for supplying hydrogen to their reactors. In conclusion, market research found only one company, Nel Hydrogen, capable of fulfilling the Government’s minimum requirements of one (1) hydrogen generator that will seamlessly integrate into the systems already in place in the laboratory.

6. FAIR AND REASONABLE PRICE DETERMINATION:

It has been determined that the anticipated cost to the Government will be fair and reasonable and that approval of this recommendation is in the best interest of the government. This justification is accurate and complete to the best of my knowledge and belief.

1/15/2026

X Alex Cheatham

Contracting Officer (KO) Signed by: CHEATHAM.ALEXANDER.KNOPP.1539898600

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