B1921 Repair Power Unusual and Compelling Urgency_Red_Redacted.pdf

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

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

Agency: ACC Contracting Activity: 20th Contracting Squadron

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

This Justification and Approval authorizes the award of a sole source contract to Stanley Drake Construction for the repair and upgrade of electrical power infrastructure in Building 1921 at Shaw Air Force Base, South Carolina.

This requirement is necessary to support mission-critical operations directly enabling Operation EPIC FURY within the U.S. Central Command (CENTCOM) Area of Responsibility. The work includes replacement and integration of electrical distribution components, generator systems, transformers, automatic transfer switches, and associated infrastructure required to ensure reliable power to mission systems.

The work must be executed within a constrained operational window requiring coordinated outage periods and immediate restoration of full operational capability.

This acquisition will modernize and stabilize the electrical infrastructure supporting Building 1921, a mission-critical facility that enables secure operations, intelligence processing, and command and control functions. The requirement addresses identified deficiencies in system reliability, redundancy, and load capacity that currently limit the facility's ability to sustain continuous operations. These efforts ensure the facility can support current and emerging operational demands associated with Operation EPIC FURY. The work includes integration of new electrical systems with existing infrastructure, coordination with installation utilities, and execution within a tightly controlled outage window to minimize mission disruption.

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

This acquisition will provide construction services necessary to repair and upgrade electrical power systems supporting Building 1921. The scope includes procurement, installation, and integration of major electrical components such as generators, transformers, switchgear, UPS systems, and associated distribution infrastructure.

The requirement also includes coordination of outages, commissioning, and system validation to ensure continuity of mission operations supporting Operation EPIC FURY. The work must be performed in a manner that minimizes disruption to ongoing operations and meets all applicable UFC and installation requirements.

This acquisition will procure and install upgraded electrical distribution systems, standby generation capability, and power conditioning equipment necessary to ensure continuous and reliable power to mission-essential systems. The contractor will remove and replace deficient infrastructure, integrate automatic transfer capability to ensure seamless transition between primary and backup power sources, and install UPS systems to protect sensitive equipment from interruption. The effort includes coordination with base agencies and operational stakeholders to execute planned outages within approved timeframes and ensure immediate restoration of operational capability. All systems will undergo testing, commissioning, and validation to confirm functionality, compliance with design requirements, and readiness to support sustained operations. Required deliverables include submittals, stamped design documentation as applicable, and as-built drawings to support long-term sustainment.

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

10 U.S.C. 3204(a)(2), Unusual and compelling urgency.

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

Building 1921 is a mission-critical facility supporting ongoing operations under Operation EPIC FURY. The urgency of this requirement is a direct result of the rapidly increased operational tempo and unforeseen mission demands of Operation EPIC FURY, not a lack of advance planning by the Government. The existing electrical infrastructure, which has degraded faster than anticipated under this heightened strain, now presents a significant and immediate risk to mission continuity, operational capability, and force protection functions. As identified by operational leadership, the facility requires a controlled power outage of approximately eight (8) hours to execute the required upgrades, and this outage must occur within a narrow operational window aligned with these new, urgent mission requirements.

Failure to execute this requirement within the required timeframe will result in continued reliance on degraded electrical infrastructure, increasing the likelihood of unplanned power disruptions. Such disruptions would directly degrade command and control capabilities, interrupt SCIF-supported operations, and impair the ability to support real-time operational tasking within the CENTCOM Area of Responsibility. Loss of power to Building 1921 would result in immediate mission degradation, including loss of operational coordination, delayed decision-making cycles, and potential impacts to ongoing combat support activities.

An urgent requirement exists to complete these upgrades prior to mid-April operational milestones. This critical timeline is dictated by the mission itself; a standard competitive acquisition, which would require up to eight (8) months, would extend far beyond acceptable operational timelines and subject the mission to unacceptable risk.

Stanley Drake Construction is uniquely positioned to execute this requirement within the required timeframe. The firm is located in Sumter, South Carolina, in close proximity to Shaw Air Force Base, allowing rapid mobilization and continuous on-site management. The contractor has demonstrated the ability to perform the majority of work in-house and has already coordinated with manufacturers regarding long-lead electrical components and system integration.

Given the mission-critical nature of the facility, the constrained outage window, and the direct impact to Operation EPIC FURY, use of full and open competition would result in unacceptable delays and increased operational risk.

Therefore, the use of unusual and compelling urgency authority is required to ensure timely execution of the requirement and prevent mission degradation.

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

The statutory authority for this acquisition is 10 U.S.C. § 3204(a)(2), "Unusual and Compelling Urgency."

This justification is also supported by 10 U.S.C. § 3204(a)(1), as implemented by FAR 6.103-1, "Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements," as each vendor provides a unique and distinct capability.

Market research was conducted through a Sources Sought Notice and subsequent industry engagement. Multiple vendors expressed interest and provided capability statements for the requirement.

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However, based on current operational timelines and urgency constraints, only Stanley Drake Construction is capable of meeting the required execution schedule. The firm's proximity to Shaw Air Force Base, existing familiarity with Building 1921, and demonstrated ability to perform work in-house provide a unique capability to meet the Government's requirements within the required time frame.

Other vendors would require additional mobilization time, subcontracting coordination, and extended lead times, which are incompatible with the urgent operational need to support Operation EPIC FURY. Proceeding with a competitive acquisition would delay contract award and execution beyond the required operational window and increase the risk of mission disruption.

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)):

The operational imperative to prevent a catastrophic power failure at Building 1921 is magnified by the current conflict in the Middle East, which has already resulted in significant American casualties. As of 19 March 2026, approximately 13 U.S. service members have been killed and over 200 have been wounded. The command and control (C2) functions executed from this facility are directly responsible for coordinating the missions that protect U.S. forces and manage complex operations throughout the theater. A failure of the electrical system would not only halt these critical missions but would directly impair the command's ability to provide tactical oversight and support, thereby increasing the risk to personnel currently in harm's way. The prevention of further casualties is paramount, and ensuring the operational integrity of AFCENT's sole C2 node is a foundational component of that effort. Therefore, the time required for a standard competitive procurement process represents an unacceptable delay that puts American lives at further risk.

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

The Government will continue to conduct market research and industry outreach to identify additional capable sources for future requirements. Future acquisitions for similar requirements will be structured to allow for full and open competition where operational timelines permit.

Additionally, lessons learned from this acquisition will be incorporated into long-term planning efforts to reduce reliance on urgent procurement authorities and increase opportunities for competitive acquisition strategies.

The Government will continue to expand industry engagement through sources sought notices, Requests for Information (RFIs), and other outreach efforts to identify vendors capable of performing similar electrical infrastructure upgrades. Future requirements will be defined earlier in the planning cycle to allow for development of complete design packages, identification of long-lead materials, and alignment of operational schedules to support competitive acquisition strategies. The Government will also evaluate the use of strategic contracting vehicles, such as multiple-award IDIQ contracts, to increase competition and improve acquisition timelines. These actions are intended to reduce schedule constraints, mitigate risk associated with urgent procurements, and promote full and open competition for future requirements.