JA for SDT Engineering Services_Redacted.pdf

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Justification for Other than Full and Open Competition for Engineering Support Services
Solicitation number
70Z02323F45900001
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This is a Justification for Other Than Full and Open Competition document for a sole-source contract modification with THOR Solutions LLC.

The United States Coast Guard (USCG), Major Systems, seeks to extend engineering support services for the Assistant Commandant – Surface (CG-SEA) programs through a sole-source contract modification with THOR Solutions LLC, located at 2900 S Quincy St, Suite 100, Arlington, VA 22206. The contract is a Firm Fixed-Price arrangement funded through Procurement, Construction, and Improvements (PC&I) across fiscal years 2022-2029. The extension consists of three optional periods: Option 1 (23 May 2026 – 22 November 2026, 6 months), Option 2 (23 November 2026 – 22 February 2027, 3 months), and Option 3 (23 February 2027 – 22 May 2027, 3 months). The estimated total value and specific pricing are redacted in the document. Services include engineering, technical, and management support for the complete life cycle management of USCG surface assets (cutters and boats), encompassing acquisition, maintenance, upgrades, and sustainment of vessel configurations and performance characteristics. Deliverables include contract documentation development, technical plans, specifications, cost estimates, engineering and feasibility studies, design review support, performance feasibility studies, and designs for ships, boats, and shipboard systems supporting both existing and future vessel acquisition programs.

The justification cites 10 U.S.C. § 3204(b)(B) and FAR Subpart 6.103-1(c)(2)(ii) as authority for the sole-source procurement, asserting that THOR Solutions LLC is the only responsible source capable of satisfying agency requirements without introducing unacceptable delays to USCG mission execution. Market research conducted in Spring 2025 identified potential competitors among small businesses holding OASIS+ contracts; however, the document indicates that the follow-on requirement will be competed on GSA OASIS+ amongst small businesses. Fair and reasonable pricing will be determined through comparison with GSA commercial price lists, current prices for equivalent work adjusted for inflation, and an Independent Government Cost Estimate. The contracting officer, Christopher A. Katz, and technical representative, Richard C. Brady, have certified the accuracy and completeness of the supporting data.

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Last Updated 12/11/25 1

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

10 U.S.C. § 3204

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-11) and in accordance with the requirements of FAR 6.104 (FAR Class Deviation 25-11), the use of the statutory authority to pursue a sole-source contract is justified by the following facts and rationales required under FAR 6.104-1 (FAR Class Deviation 25-11) as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Major Systems.

2. Nature and/or Description of the Action being Approved.

(a) Nature of the action: USCG intends to procure, on a sole-source basis, an extension of engineering support services in support of Assistant Commandant – Surface (CG-SEA) programs.

(b) Name and address of the contractor: THOR Solutions LLC, 2900 S Quincy St, Suite 100, Arlington, VA 22206

(c) Type of action: Firm Fixed-Price, Negotiated Contract Modification

(d) Estimated total value (including options):

Option Period of Performance

Length Total Value

Option 1

23 May 2026 – 22 Nov 2026 6 mo.

Option 2 23 Nov 2026 – 22 Feb 2027

3 mo.

Option 3 23 Feb 2027 – 22 May 2027 3 mo.

Total

(e) Type of funding: Procurement, Construction, and Improvements (PC&I).

(f) Year of funding: 2022-2026, 2023-2027, 2024-2028, 2025-2029

(g) Solicitation number: N/A, this action will be a modification to an existing contract

(h) Background information about the requirement: The USCG Surface Assets

Division is responsible for the complete life cycle management of surface assets, Last Updated 12/11/25 2 including cutters and boats, from concept development through disposal. This includes acquisition, maintenance, upgrades, and sustainment of vessel configurations and performance characteristics. To support these efforts, the USCG requires contractor-provided engineering, technical, and management services to assist in surface asset acquisition, in-service sustainment, and human systems integration. These services are essential to ensure the effective design, operation, and maintenance of USCG vessels, enabling the Coast Guard to fulfill its mission requirements efficiently.

3. Description of Supplies/Services.

This contract provides engineering, technical, and management support services for USCG Surface Assets. These services support the complete life cycle management of surface assets described above. The services provided through this contract help ensure the effective acquisition, operation, and maintenance of USCG surface assets, enabling the USCG to meet mission requirements efficiently and effectively. The contract provides engineering technical and management support in studying, analyzing and evaluating engineering problems, and developing solutions. Contractor design support shall include, but not limited to, assisting in the development of contract documentation and assisting with the development of technical plans, specifications, cost estimates relating to the various categories of engineering support services, studies, and associated reports. Contractors may also be tasked, that can include, but not limited to, assisting in the preparation of a wide range of engineering and feasibility studies, providing engineering and technical support for design review, performance feasibility studies, and designs of ships, boat, and shipboard systems in support of existing and future vessel acquisition programs.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. § 3204(b)(B) implemented by the FAR Subpart 6.103-1(c)(2)(ii) (FAR Class Deviation 25-

11) entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements” as this is the only source which will not result in unacceptable delays in fulfilling the agency’s requirements.”

5. Identification of Exception to the Buy American Act.

Not Applicable.

6. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Require Use of the Authority Cited.

The authority cited under FAR Subpart 6.103-1 (FAR Class Deviation 25-11), "Only one responsible source and no other supplies or services will satisfy agency requirements," is justified due to the unique qualifications of the proposed contractor and the critical nature

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