CUI

Justification Review Document for Other than Full and Open Competition

Description of Supply / Service: The Contractor shall repair and retrofit the existing 40-foot rappel tower at Lightning Academy, Schofield Barracks, Oahu, Hawaii to make it code compliant. Work for this project includes, but is not limited to: repair damage caused by initial pull tests; remove existing paint to facilitate work and recoat in areas where coating was removed and on new members; repair welding in areas with exposed seams, ensuring there is no trapped moisture which would cause further corrosion; add grip texture to stair nosings; replace short bolts which are depressed within nuts with bolts of proper thread length; repair, relocate, and detail primary anchor points; replacement of hitching; add secondary anchors; add platform edge padding;

modify or replace floor grating to allow for proper connection details for anchors and hitching posts; retrofit of brace gusset plates and brace bolts; load testing of hitching posts and anchors.

Authority: 10 United States Code section 3204(a)(2) as implemented in Federal Acquisition Regulation 6.302-2(b), Unusual and compelling urgency.

Amount: The total combined contract capacity is estimated to be $ .

Prepared / Reviewed by:

Signature:

Typed Name: Jenna K. Lum DSN: 808-835-4378 Title: Contract Specialist Intern

Signature:

Typed Name: Tristin N. Suetsugu DSN: 808-835-4381 Title: Contracting Officer

Signature:

Typed Name: Geoffrey Ward DSN: 808-420-9125 Title: Technical Representative

Legal Counsel: I have reviewed the justification and find it legally sufficient.

Signature:

Typed Name: Jonathan A. Swanson DSN: 808-835-4426 Title: District Counsel

Justification and Approval for Other than Full and Open Competition

1. Contracting Activity: U.S. Army Corps of Engineers (USACE), Honolulu District

(POH)

2. Description of Action: Award a contract to repair the 40-foot rappel tower at the

Army 25th Infantry Division (25ID) Lightning Academy, Schofield Barracks, Oahu, Hawaii.

3. Description of Supplies/Services: The Contractor shall repair and retrofit the existing 40-foot rappel tower at Lightning Academy, Schofield Barracks, Oahu, Hawaii to make it code compliant. Work for this project includes, but is not limited to:

repair damage caused by initial pull tests; remove existing paint to facilitate work and recoat in areas where coating was removed and on new members; repair welding in areas with exposed seams, ensuring there is no trapped moisture which would cause further corrosion; add grip texture to stair nosings; replace short bolts which are depressed within nuts with bolts of proper thread length; repair, relocate, and detail primary anchor points; replacement of hitching; add secondary anchors; add platform edge padding; modify or replace floor grating to allow for proper connection details for anchors and hitching posts; retrofit of brace gusset plates and brace bolts;

load testing of hitching posts and anchors.

4. Authority Cited: 10 United States Code section 3204(a)(2) as implemented in

Federal Acquisition Regulation 6.302-2(a)(2), When the agency’s need for the supplies or services is of such an unusual and compelling urgency that the Government would be seriously injured unless the agency is permitted to limit the number of sources from which it solicits bids or proposals, full and open competition need not be provided for.

5. Reason for Authority Cited:

a. Background

Due to the compelling need of the rappel tower, USACE POH solicited this requirement as an 8(a) sole source to Sharon Zambo-Fan & Associates, Inc.

(SZF) on 11 September 2025 with the intention of awarding a contract in fiscal year (FY) 2025. During the site visit, it was discovered that the stakeholder had made modifications to the site, resulting in an increase in the estimated project cost. Consequently, the stakeholder required additional time to secure funding due to the Government shutdown from 1 October to 12 November, leading to the project's postponement to FY 2026, with an award date no later than 3 December 2025, as SZF would graduate from the 8(a) program on that date. On 3 December 2025, the USACE POH was notified by the stakeholder that they had received their allotment of funds and are now authorized to proceed with the project.

b. Justification

Per 10 USC 3204(a)(2), a contract can be awarded without full and open competition if the agency’s need for the supplies or services is of such an unusual and compelling urgency that the Government would be seriously injured unless the agency is permitted to limit the number of sources from which it solicits bids or proposals.

The 25ID requires the use of an operational, on-site rappel tower to provide critical training to all U.S. Forces within the Indo-Pacific by supporting the Programs of Instruction (POI) for the 25ID Lightning Academy's Air Assault, Rappel Master, and Jungle Operations Training Courses (JOTC). The existing 40-foot rappel tower at Schofield Barracks has been unusable for 22 months due to structural deficiencies that require repair. Due to the non-operational status of the rappel tower, training courses have been canceled which led to a complete loss of training opportunities for 140 soldiers, course capacity has been reduced which diminished the output of qualified personnel by approximately 50%, and an unsustainable reliance on a temporary alternate site at Marine Corps Base Hawaii (MCBH) has created significant logistical and operational burdens. This has created a compelling justification under 10 USC 3204(a)(2) for this other than full and open action. If the rappel tower is not repaired, combat effectiveness of 25ID will decrease and lower warfighter capabilities in the Indo-Pacific region.

The following list details the critical impacts of not having an operational, on-site rappel tower at the 25ID Lightning Academy:

1. Direct Degradation of Warfighting Skills. Air assault and vertical insertion/extraction are perishable skills that are tied to essential military missions. The inability to consistently train in these tasks leads to skill atrophy, which limits operational reach and tactical flexibility.

2. Erosion of Institutional Expertise. The lack of training has a cascading adverse effect. Lightning Academy courses are designed to create subject-matter experts who act as force multipliers within their home units. Without these experts, unit commanders do not have access to the specialized expertise required for complex operations.

3. Logistical and Financial Inefficiencies. The current reliance on the 28-foot rappel tower at MCBH is not a feasible long-term solution. Training capacity is limited to 50% and units must expend additional time, man-hours, fuel, and maintenance to transport personnel and equipment across Oahu. This dependence on an external installation also creates scheduling conflicts and administrative hurdles which makes training unpredictable and inefficient.

4. Potential Risk to Accreditation. The Air Assault Course and Rappel Master Course both require the use of a 40-foot rappel tower. Utilizing the 28-foot rappel tower at MCBH requires a semiannual exception to policy (ETP) with the U.S. Army Maneuver Center of Excellence. The Lightning Academy has obtained temporary ETP approval which allows these courses to utilize the 28-foot rappel tower at MCBH on the condition that the 40-foot rappel tower at Schofield Barracks will be remediated and operational to support future courses. Failure to repair the 40-foot rappel tower at Schofield Barracks immediately may place the accreditation of the Institutional Training Division and Lightning Academy at risk.

The 2025 Government shutdown created an unusual circumstance that prevented the consummation of the 8(a) contract prior to the selected contractor graduating from the 8(a) program. If the Government had not shutdown for 43 days in October 2025 and sufficient funds had been provided to USACE POH by 13 November 2025, a contract would have been awarded to SZF by 3 December 2025. SZF and their subconsultants are already familiar with this requirement as they have had multiple site visits and submitted proposed pricing. Resoliciting the requirement as a sole source to another contractor or as a competitive action will further delay the repair of the rappel tower and would not be in the Government’s best interest.

The critical need of an operational rappel tower and the unusual situation of the Government shutdown have created and met the justification needed per 10 USC 3204(a)(2).

c. Alternatives

There are no viable alternatives for this acquisition. An operational 40-foot rappel tower is essential for conducting required training in the Indo-Pacific region. At present, there are no other training facilities on the island of Oahu that feature a 40-foot rappel tower capable of accommodating the necessary number of trainees. Resoliciting this requirement as a sole source award to another contractor or as a competitive action will require scheduling another site visit and answering Requests for Information (RFIs).

d. Impact

If this justification is not approved, the risk of insufficient training would significantly increase, potentially resulting in reduced mission readiness and warfighting capability.

6. Efforts to Obtain Competition:

A notice as required by FAR 5.201 will not be published. Per FAR 5.202(a)(2), a notice required under FAR 5.201 is not required if the proposed contract action is made under the conditions described in FAR 6.302-2 and the Government would be seriously injured if the agency complies with the time periods specified in 5.203.

7. Actions to Increase Competition:

This justification supports a discrete requirement that will end when the project is complete. Therefore, there are no planned actions to increase competition for the requirement covered by this justification. POH will nevertheless evaluate the reasons and causes for increased requirements for rappel tower repair/retrofit not foreseen.

8. Market Research:

Market Research was conducted and an Independent Government Estimate (IGE) obtained. The full Market Research analysis report and IGE are included in Attachment 1.

9. Interested Sources: Reference Market Research analysis report included in

Attachment 1

10. Other Facts: N / A .

11. Technical Certification:

I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Signature:

Typed Name: Geoffrey Ward Title: Technical Lead

12. Requirements Certification:

I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Signature:

Deanna Yamada Project Manager

13. Fair and Reasonable Cost Determination and Contracting Officer Certification:

I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable.

Signature:

Tristin N. Suetsugu Contracting Officer

14. Contracting Officer Certification

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

Signature:

Tristin N. Suetsugu Contracting Officer

Attachment 1 – Market Research and Analysis

Based on the foregoing justification, I hereby approve the sole-source contract Award for the U.S. Army Corps of Engineers (USACE) Honolulu District Area of Responsibility on an other than full and open competition basis pursuant to the authority of 10 United States Code section 3204(a)(2) as implemented in Federal Acquisition Regulation 6.302-2(b), Unusual and compelling urgency.

APPROVAL:

Signature:

Tristin N. Suetsugu Contracting Officer