JA - Turntable Modifications_Redacted.pdf

Justification and Approval For Other than Full and Open Competition

Plan ID Number: 2025-LGR-0150

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 of Congress, LCSG, RCS, NAVCC, PSS

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: 2025-LGR-0150 Contractor (or Brand Name): Endpoint Audio Labs Estimated Value (Base and all options):

Period of Performance: 08/012025 – 07/31/2026

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 National Audiovisual Conservation Center (NAVCC) of the Library of Congress develops, preserves and provides broad access to a comprehensive and valued collection of the world’s audiovisual heritage for the benefit of Congress and the nation’s citizens. The NAVCC uses state-of-the-art technologies to significantly increase preservation capacities and capabilities, and new large-scale digital acquisition and archiving systems for the global audiovisual community. The Audio Lab of the NAVCC replaced its Simon Yorke turntables with Technics SP-10R turntables with custom plinths, compatible with the SME M2-12R tone arms. Along with their products manufacturer warranties. The Technics SP-10R turntable system has been identified as uniquely capable of fulfilling the archival requirements of the Audio lab.

Endpoint was awarded the Audio Lab contract no. LCLGR25P0019 for the replacement of its Simon Yorke turntables. In support of this award, Endpoint is offering the Library an opportunity to modify the newly procured Technics SP-10R turntables. These proposed modifications would enhance key functional capabilities and deliver substantial added value to the systems being acquired. Endpoint is proposing an upgrade to the Technics SP-10R turntable motor that enables the use of a removeable spindle. This feature is essential for configuring a state-of-the-art commercial-grade turntable tailored to meet the Library’s preservation standards. Without a removable spindle, proper disc centering is not achievable. Many of the older discs in the Library’s collection require precise manual positioning on the platter, free of a fixed spindle, to allow for fine alignment using a microscope. This precision is critical to minimizing wow and distortion during playback, ensuring archival-quality results. A removeable spindle is a functional necessity for handling fragile, off-center, or rare discs with the precision required for archival-grade preservation. No other vendor or company, including the motor’s manufacture Technics, offers this spindle modification.

Plan ID Number:

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:

Only one responsible source and no other supplies or services will satisfy the Library’s requirements. The supplies and services are deemed available only from Endpoint Audio Labs in the case of a follow-on contract for the continued development of a major specialized system the Technics SP-10R turntable motor system. When it is likely that award to any other source would result in substantial duplication costs to the Government that is not expected to be recovered through competition.

Endpoint Audio is the only source for this contract because it represents a follow-on to the original award. Endpoint is directly involved in the continuing development and customization of the highly specialized Technics SP-10R turntable motor systems, and possesses the technical knowledge, design integration, and proprietary modification necessary to support the project.

No other vendor or company, including the motor’s manufacture Technics, the original manufacturer of the SP-10R motor, offers this specialized spindle modification. This spindle is customized and developed exclusively by Endpoint. The modification is customized and designed in direct response to the Library’s preservation needs and integrates seamlessly with the existing turntable system.

Because the original manufacturer does not produce this functionality, and no other vendors possess the specialized technical design, tooling, or experience to implement it, Endpoint is the sole source capable of developing and delivering this specialized spindle. This will void the Technics warranty on the SP10R system, and the Library is aware of this and accepts the risk.

Awarding this requirement to any other source would likely result in duplication of costs and effort because the specialized customized spindle (spinner) modification for the Technics SP-10R turntable motor system has already been developed, engineered, and tested by Endpoint. This modification was designed specifically to meet the Library’s archival preservation needs and is fully integrated with the existing SP-10R units that were previously procured under the original contract. If another vendor were to be awarded this effort, they would need to reverse engineer the existing modifications, develop new tooling and prototypes, and undergo a full cycle of testing, validation, and integration all of which would replicate work that has already been completed. Additionally, since Technics (the manufacture) does not offer a removable spindle modification, any new vendor would have to start from scratch without access to proprietary designs specifications, resulting in increased costs, longer lead times, and potential compatibility issues.

The rationale for noncompeting is that Endpoint Audio is the only source for this contract who offers the specialized spindle modification for the Technics SP-10R turntable motor systems designed specifically to meet the Library’s preservation needs. And awarding to any other vendor would replicate work that has already been completed leading to increased costs for the Library.

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:

The Audio Lab supervisor Robert Friedrich, and the COR continuously monitor the industry for advancements in archival turntable manufacturing and modifications. As new options become available, they will be considered for potential future upgrades, modifications or acquisitions. However, at this time the current solution represents the only viable path to achieving a state-of-the-art archival disc transfer system.

7. Program Office Certification

I certify that the description of the Government’s minimum needs, schedule requirements, and technical information that provide the basis for this justification are accurate and complete.

0BPART 3 – CONTRACTING OFFICER DETERMINATIONS & CERTIFICATION

8. Efforts to Solicit from As Many Potential Sources As Practicable Unless a justification is based on FAR 6.302-2, Unusual and compelling urgency, contracting officers shall post justifications for other than full and open competition, including brand name justifications, to the Contract Opportunities website on sam.gov (or eBuy for Brand Name Justifications under FAR Part 8) prior to requesting a proposal or otherwise entering into negotiations.

Advance notice will be published in sam.gov for 15 days before a contract is awarded. FAR 5.203(a).

Advance or concurrent notice will be published in sam.gov for a reasonable time for commercial items FAR 5.203(a) and 12.204(b).

Advance notice will not be published because the action meets the following FAR exception:

Notice would compromise national security. FAR 5.202(a)(1).

Unusual and compelling urgency; notice period would seriously injure Government. FAR 5.202(a)(2).

Expressly authorized or required to be made through another Government agency. FAR 5.202(a)(4).

Order will be placed against an IDIQ contract awarded under FAR 16.5. FAR 5.202(a)(6).

Order will be placed against GSA schedule or other competitively awarded contract. FAR 5.202(a)(11).

Other:

Advance notice will not be published per 41 U.S.C. § 6101; see attached deviation from the FAR per LCR 7-210 § 3.A.

We made the following efforts to interest potential sources in this award: None

9. Listing of Sources That Expressed Interest in Writing

The following sources expressed interest in this award: None

10. Additional Information

The following additional information is relevant to this justification and approval: N/A

11. Contracting Officer Determination that Price Is Fair and Reasonable As explained in detail below, I have determined that the prices for this contracting action are fair and reasonable based on comparison of the prices to the following (see FAR 15.404-1(b)(2)):

Historical prices paid by the Government Published competitive price lists Library’s Independent Government Estimate Prices obtained through market research Other: Prices obtained through competitive proposals

The following analysis (based on attached pricing information) supports my determination: A fair and reasonable pricing determination shall be made before an award is executed.

12. Contracting Officer Determination of Responsibility Checked System for Award Management (or will check in the case of competitive proposals for a brand name product)

13. Contracting Officer Determination of Best Value I have determined that this action represents the best value to the Government because: A best value determination shall be made before an award is executed.

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.

Name

Signature

Date

James R. Robinson 07/15/2025