FY22_Patrol_Rifle_JFOC_Redacted.pdf

NPS-National Capital Area – USPP FY22 Rifle Page 3 of 5

Preserving unimpaired the natural and cultural resources and values of the national park system for the enjoyment, education, and inspiration of this and future generations.

that could possibly select a different rifle would be a substantial duplication of cost and time for the USPP. The government would not recover it through new competition.

Through the procurement process in FY21 the USPP found that LWRCi uses regional distributors for sales of its rifles. The distributor for the Washington, DC region is Atlantic Tactical. LWRCi will not directly bid on contracts, nor will they let other distributors bid on contracts to beat out the local distributor. For this follow-on contract for the continued replacement of rifles for USPP officers the rifle itself is a highly specialized piece of equipment due to the ambidextrous controls, cold hammer forged barrel, and short stroke piston operation system. The ambidextrous controls themselves are almost identical to the original design of the AR Stoner rifle. Many companies have sought to add ambidextrous controls to the base rifle design, but their additions have not matched the legacy control style called for in the FY21 rifle statement of work. During the FY21 source selection the LWRCi rifle was the only rifle to fully meet our statement of work characteristics. The rifle is the major component of the rifle kit, and due to it only being sold in the area through Atlantic Tactical they are the only responsible source for procurement in FY22.

The USPP has procured a large amount of replacement parts from the FY21 contract. We currently have these items stored in our armory in Washington, DC. These parts are specific to the LWRCi rifle and are not interchangeable with other AR style rifles. The USPP has received specialized training to install these replacement parts. Proceeding with an open market solicitation would be duplication of cost to the government in procuring replacement parts for a different rifle system. The government would not recover the cost of these replacement parts through new competition. Additionally, the USPP would have to duplicate storage areas in an already small area for the storage of different parts.

6. A Description of Efforts Made to Ensure That Offers Are Solicited from as Many

Potential Sources as is Practicable, Including Whether a Notice Was or Will Be Publicized as Required by FAR Subpart 5.2 and, If Not, Which Exception Under FAR 5.202 Applies:

In FY21 the USPP solicited an open market contract for the procurement of rifles to begin the replacement of rifles that exceeded their service life. This procurement was made available to all those who could meet Statement of Work (SOW) requirements. In FY21 the USPP made every effort to ensure that offers could be solicited from as many sources as possible. Only two sources responded and only Atlantic Tactical was technically acceptable. For FY22 the USPP seeks a follow-on contract for the FY21 rifle contract.

The solicitation will be posted on a Government Point of Entry (GPE) as a sole source procurement but will include the statement that other vendors may provide a quote if they can meet the requirements in the Statement of Work.

Through the previous rifle acquisition in FY21 the USPP has sufficiently ensured that as many potential sources as practicable were able to solicit offers for fulfilling the agencies need for rifles. In FY22 the USPP needs to order identical rifle kits to continue with current training and replacement.

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7. A Determination By the contracting officer That the Anticipated Cost to the Government Will Be Fair and Reasonable:

The Government estimate is based on Internet searches and the previous acquisition on contract 140P3021C0075. The Government requires additional rifle kits for new employees that will be hired in FY22 and FY23. The prices of the kits have not changed in since the last acquisition that was awarded 24 September 2021.

8. A Description of the Market Research Conducted (see FAR Part 10) and the Results or a Statement of the Reason Market Research Was Not Conducted:

Market research was conducted in FY21 for the replacement of rifles that have exceeded their service life. Market research from the FY21 rifle contract was reviewed by the contracting officer’s representative to confirm that it was still accurate. After it was reviewed it was found that no new market research was needed due to the short time between contracts.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition (see FAR

6.302-2 (9) (i) – (iii) for some examples):

None

10. A Listing of the Sources, If Any, That Expressed in Writing, an Interest in the Acquisition:

None

11. A Statement of the Actions, If Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for the Supplies or Services Required:

This action is a follow-on to the procurement of rifles in FY21. This action will replace many of the rifles that remain in the USPP inventory after the FY21 contract deliveries have been completed. Due to employee hiring and those rifles are a basic part of issue for new recruits the USPP will most likely submit additional procurement actions for identical rifles. At the end of the 10-year service life the USPP will begin to solicit open market bids for replacement rifles.

At this time all barriers to competition will be removed in order to find the best available product for the USPP.

12. 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): Carl Hiott Contracting Officer Representative

28 July 2022

CARL

HIOTT

Digitally signed by

CARL HIOTT

Date: 2022.07.28 15:33:05 -04'00'

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Preserving unimpaired the natural and cultural resources and values of the national park system for the enjoyment, education, and inspiration of this and future generations.

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

(Signature) _______________________________________ (Date) _______________________

Kathleen Waits Contracting Officer

Reviewed for Legal Sufficiency by Solicitor’s Office (over $500,000 or as requested):

(Signature) _______________________________________ (Date) _______________________

(Type or Print Name): _________________________________________________ Attorney-Advisor

Reviewed/Concur/Approved by: (if applicable)

(Signature) _______________________________________ (Date) _______________________

(Type or Print Name): _________________________________________________ Regional or Center Chief of Contracting

Approved by: (if applicable)

(Signature) _______________________________________ (Date) ______________________

(Type or Print Name): _________________________________________________ Bureau Competition Advocate

Approved by: (if applicable)

(Signature) _______________________________________ (Date) ______________________

(Type or Print Name): _________________________________________________ Head of the Contracting Activity

9 August 2022Kathleen WaitsKathleen Waits '00'04- 19:04:15 2022.08.09