J1-Attachment-Justification-and-Approval Document_Redacted (JA) (5 Pages)_Redacted.pdf

Justification and Approval For Other than Full and Open Competition

Plan ID Number: 2026-LGD-0018

Form Updated 4/14/2023

Justification & Approval

As a legislative branch agency, the Library is subject to the competition and advertising requirements of 41 U.S.C. § 6101. Like the Competition in Contracting Act and the FAR, 41 U.S.C. § 6101 does not require competition when a contracting officer certifies that only one source or brand-name item is available, when dictated by public exigency, or when otherwise authorized by law.

This document sets forth the justification and approval for award of a contract or order by means providing for other than full and open competition per 41 U.S.C. § 6101, LCR 7-210, and, as applicable, FAR 6.302, FAR 13.106-1, FAR 8.405, and FAR 16.505. Contracting without competition shall not be justified on the basis of a lack of advance planning or concerns related to availability of funds.

This form shall be used to support instances where competition will be limited to a single source, a limited number of sources, including where a brand name product is required.

Part 1 – Identification

1. Contracting Agency and Activity: Library of Congress, Library Collections and Services Group, Discovery and Preservation Services, Preservation Directorate, Preservation Research and Testing Division

2. Nature of Action Being Approved

Contract (or modification) LoC or Leg Branch Order (or modification) GSA Schedule or GWAC: Identify Schedule/Contract Other: Identify

Plan ID Number: 2026-LGD-0018 Contractor (or Brand Name): Transcendent Imaging LLC Estimated Value (Base and all options):

Period of Performance: 4/1/26-3/31/27 (May be awarded early with a 12-month POP)

3. Description of Supplies or Services Required to Meet Library Needs

Describe the supplies or services that are required to meet the Library’s minimum needs and the delivery schedule required to meet those needs. Do not focus on a description of the program.

The Library requires the following supplies or services:

The Preservation Research and Testing Division (PRTD) seeks to acquire a 150-megapixel scientific monochromatic camera capable of image capture across the 350 – 1000 nanometers spectrum. The camera must be fully compatible with the existing Megavision hyperspectral imaging system currently in use in the Preservation Research and Testing laboratory. The increased resolution and dynamic range provided by this type of camera is necessary to support non-destructive analytical research, spectral materials characterization, and the mapping and assessment of environmental degradation parameters across a broad range of the Library’s collection materials. The purchase shall include all required components, including camera, bellows, connection hardware, cables, and mounting fixtures for installation, as well as shipping. The acquisition shall also include a one-year of repair and service support warranty.

The Library’s rational for contracting without providing for full and open competition is that Transcendent Imaging LLC. is the only responsible source whose supplies and services meet the Library’s specified requirements. Only this manufacturer can provide the specialized equipment that satisfied the required imaging capabilities. The Q15 camera is a specialized system that integrates seamlessly with the PRTD laboratory’s existing imaging infrastructure. Award to any other source would result in substantial duplication costs to the Government that would not be recovered through full and open competition. Accordingly, a sole source award to Transcendent Imaging LLC. is justified.

Part 2 – Program Office Justification & Approval

4. Authority for Contracting Without Competition Over $250,000 For this requirement over $250,000, under FAR part 6, the basis for contracting without providing for full and open competition is:

There is only one responsible source and no other supplies or services will satisfy Library requirements.

41 U.S.C. § 6101(b)(2)(C); FAR 6.302-1.

Library’s minimum needs can only be satisfied by contractor’s unique capabilities or products. FAR 6.302-1(b)(1).

Source controls copyrights, patents, raw materials, or secret processes cannot be acquired otherwise, or similar circumstances. FAR 6.302-

1(b)(2).

Other exception identified in FAR 6.302-1: Identify the exception

There is such unusual & compelling urgency that the Government would be seriously injured if competition is not limited.

41 U.S.C. § 6101(b)(2)(B); FAR 6.302-2. Option years are not permitted.

Source is expressly authorized or required by statute (e.g., AbilityOne, UNICOR, GPO, GSA Public Buildings Service, Appropriations Act, etc.) per 41 U.S.C. § 6101(b)(1) and FAR 6.302-5: Identify the authority

Other basis authorized in 41 U.S.C. § 6101(b) or FAR part 6.302: Identify the exception Library’s needs can only be satisfied by a brand-name product or item which is essential to the Government’s requirement. FAR 6.302-1(c).

The Product is listed on the Library of Congress Enterprise Architecture Repository (LCEAR) database (Attach applicable

IT Standard Data Sheet)

Up to and including $250,000 For this requirement up to $250,000, using simplified acquisition procedures under FAR part 13, the basis for contracting without providing for full and open competition is:

Only one responsible source is reasonably available to meet Library requirements. 41 U.S.C. § 6101(b); FAR 13.106-1.

Product or service is reasonably available from only one source.

Source controls copyrights, patents or other exclusive licensing arrangements.

Urgent circumstances; only one source can reasonably deliver by required date. Option years are not permitted.

Source is expressly authorized or required by statute: Identify the authority Library’s needs can only be satisfied by a brand-name product The Product is listed the Library of Congress Enterprise Architecture Repository (LCEAR) database (Attach applicable

IT Standard Data Sheet)

GSA Schedule Order For this GSA schedule order under FAR part 8, the basis for not competing among GSA schedule-holders and/or specifying a brand name product or item is:

An urgent and compelling need exists, and following GSA procedures would result in unacceptable delays.

FAR 8.405-6(a)(1)(i)(A).

Only one GSA source is capable of fulfilling the requirement at the level of quality required because the supplies or services are unique or highly specialized. FAR 8.405-6(a)(1)(i)(B).

In the interest of economy and efficiency, the new work is a logical follow-on to an original order that was placed competitively among GSA schedule-holders (i.e., the original order was not sole-source or limited-source.) FAR 8.405-6(a)(1)(i)(C)

Library’s needs can only be satisfied by a brand-name product The Product is listed on the Library of Congress Enterprise Architecture Repository (LCEAR) database (Attach applicable

Order Under Multiple Award Indefinite-Delivery Contract or GWAC For this order under FAR subpart 16.5, the basis for contracting without providing for full and open competition is:

The need is so urgent fair opportunity would result in unacceptable delays. 41 U.S.C. § 6101(b)(2)(C) and FAR 16.505(b)(2)(i)(A).

The Library’s minimum needs can only be satisfied by contractor’s unique capabilities or products. 41 U.S.C. § 6101(b)(1) and FAR

16.505(b)(2)(i)(B).

A logical follow-on order in the interest of economy and efficiency. 41 U.S.C. § 6101(b)(1) and FAR 16.505(b)(i)(2)(C).

To satisfy a minimum guarantee. 41 U.S.C. § 6101(b)(1) and FAR 16.505(b)(2)(D).

Authorized or required by statute. 41 U.S.C. § 6101(b)(1) and FAR 16.505(b)(2)(E).

The Library’s minimum needs can only be satisfied by a brand-name product or item which is essential to the Government’s requirement. 41

U.S.C. § 6101(b)(2)(B) and FAR 16.505(a)(4)(i).

The Product is listed on the Library of Congress Enterprise Architecture Repository (LCEAR) database (Attach applicable

5. Rationale for Contracting Without Competition

In supporting an action not providing for full and open competition, it is not sufficient to demonstrate that the contractor is exceptionally well qualified or even the best qualified, or that the required brand name product is well suited to the Library’s needs. The rationale must demonstrate that no one else, or no other competing product, can satisfactorily fulfill the Library’s requirement. Do not focus on the importance of the requirement; the issue is the rationale for not competing.

In supporting urgency, address the following: What are the unexpected facts or the unpredictable events that led to this situation? When is the required delivery or performance start date? Why this date? What specific harm to the Government will occur if the delivery is not made or performance not begun as scheduled? (Note that expiration of funds is not sufficient harm to justify not competing.) Demonstrate that the contract is only for items and quantities urgently needed until a competitive procurement action can be developed, or that a separate competitive follow-on is not practical.

In supporting a brand name justification, the brand name or feature must be essential to the Library’s requirements, and market research indicates that other company’s similar products or products with similar features cannot meet or be modified to meet the Library’s needs.

We are authorized to limit competition on the basis of the citation in section 4 because:

The Library's rationale for contracting without providing for fully and open competition is that only one responsible source, Transcendent Imaging LLC, and no other supplies or services will satisfy agency requirements, therefore full and open competition need not be provided for.

Transcendent Imaging LLC is the only responsible source that manufactures the Megavision Q15 150-megapixel high-resolution imaging camera system designed to meet the specific Library requirements of high-resolution, low-noise, scientific, archival, and technical imaging applications. This camera provides substantially greater resolution than typical consumer-grade cameras and meets the Library’s specialized imaging requirements while remaining fully compatible with the existing components in the research laboratory. The Q15 is the only camera from Transcendent that integrates seamlessly with the Library’s current hyperspectral imaging system and meets or exceeds the Library’s technical requirements. Installation of incompatible cameras from other manufacturers would void the existing warranty and maintenance agreement under Contract No. LCLGD25P0005, as verbally confirmed by a Megavision representative and other vendors.

The Q15 camera from Transcendent Imaging LLC enables seamless integration with the PRTD’s current Megavision hyperspectral imaging system and provides several key capabilities essential to the Library’s research applications. These include support for non-destructive analytical research, spectral materials characterization, and the mapping and assessment of environmental degradation parameters across broad range of the Library’s collection materials, substrates, and media, enabling the tracking of changes over time and environmental effects. Among the native monochrome cameras currently available on the market, only the Q15 offers 150-megapixel resolution, adequate dynamic range, and sufficient sensitivity to support both image capture and post-processing of cultural heritage materials, while also integrating fully with the PRTD’s existing hyperspectral imaging equipment and workflows.

Additionally, selection of the Q15 camera from Transcendent Imaging LLC ensures continued manufacturer support for all components of the hyperspectral imaging system. Installation of incompatible equipment from other manufacturers will void the current warranty and service agreement.

Supplies are deemed highly specialized equipment, the Q15 camera, and thereof it is likely that award to any other source would result in substantial duplication costs to the Government that are not expected to be recovered through competition. The duplication costs can be substantial if the Library purchases a camera that doesn’t seamlessly integrate with their existing systems, and it turns out to be incompatible. The Library may need to repurchase equipment they already own, paying twice for infrastructure that already exists.

Further, if the camera doesn’t work with current software, the Library would be required to purchase new software and licenses rebuilding software functionality the Library already paid for. And there would be engineer hours to redesign interfaces, custom firmware development, debugging and ongoing maintenance and testing. Bottom line, purchasing a camera that is not natively compatible with the Library’s existing equipment systems would result in significant duplication costs to the Government and this would be considered a high costs risk. Therefore, it is in the best interest of the Government that purchasing the Megavision Q15 150-megapixial camera from Transcendent Imaging is justified to contract without providing for full and open competition.

6. Actions to Overcome Barriers to Competition Before Subsequent Contract Is Required

State what actions, if any, the program office can take to overcome barriers to competition before a contracting for this requirement again, such as:

using action to provide time to develop specifications for a competitive procurement by a certain date; licensing copyrights or patents so other contractors may use the works; or breaking the requirement into parts that may be purchased competitively. If this is a one-time requirement, explain that action to increase future competition is not needed. If the source is expressly required by statute, state “Source is statutory.”

To increase competition, we will: This is a one-time requirement, and additional competition is not necessary for this action. Multiple alternative vendors offerings were evaluated, and no other equipment was identified that can meet all requirements for this instrumental acquisition.

14. Contracting Officer Certification I certify that, to the best of my knowledge and belief, this justification is accurate and complete. For those actions up to $750,000, I approve contracting without competition for this requirement.

James R. Robinson James R. Robinson 02/04/2026

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Signature

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