JOFOC_1.pdf

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Justification for Other than Full and Open Competition Federal contract opportunity
Solicitation number
140G0125Q0175
Issued by
Department of the Interior US Geological Survey Office of Acquisitions and Grants

About this file

This is a Sole Source Justification and Approval document for a noncompetitive contract award by the Department of the Interior, United States Geological Survey (USGS), National Minerals Information Center (NMIC). The NMIC seeks center-wide access to CRU International Ltd subscriptions for ten critical mineral reports with a total estimated value of $502,068.82. The required reports cover aluminum, lead, zinc, molybdenum, fertilizer, copper, bauxite & alumina, tin, noble alloys & minor metals, and bulk ferroalloys, with three available report tiers (Premium or Classic levels). The contract will be firm-fixed price with an initial one-year period following purchase order receipt and three optional one-year renewal periods thereafter. The sole source award is justified under FAR 13.501(a) based on CRU's proprietary unique datasets containing global production, capacity, trade, consumption, and pricing data unavailable from other sources, particularly given China's export restrictions on critical minerals and the increasing need for supply chain risk assessment across U.S. Government agencies.

The justification emphasizes that CRU's technical coverage of mineral commodities and original research capabilities align with NMIC's statutory mandate under the National Materials and Minerals Policy, Research and Development Act of 1980 and the National Defense Stockpile Act, as well as multiple Executive Orders prioritizing critical mineral supply chain security and domestic production. Market research included an internet review of competing vendors and a sources sought notice that yielded three responses; however, none offered comparable data sets covering all required minerals. The Contracting Officer determined the anticipated cost to be fair and reasonable based on previous contract pricing comparisons. The acquisition was approved by Daniel Galvin (Contracting Officer), Stacey Diamond (Chief, Reston Acquisition Branch), and Douglas Hill (Bureau Competition Advocate, Acting), with the recommendation provided by Lee Bray (Acting Chief Mineral Commodities Section). Future competitions will be pursued if comparable alternatives become available in the market.

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PR# 0044023614

SOLE SOURCE JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Agency and Activity

The Department of the Interior, United States Geological Survey (USGS), National Minerals Information Center (NMIC), plans to contract on a sole source basis.

2. Nature of Action Being Approved

This requisition is for a new noncompetitive, firm-fixed price contract, to CRU International Ltd (CRU). The period is one year after receipt of purchase order with three one-year option periods thereafter.

3. Description of Supplies or Services

The NMIC requires center-wide access CRU subscriptions for ten reports on critical minerals. CRU’s services provide periodic reports and data on a broad range of mineral commodities that are updated throughout the year. Commodities specific for this acquisition are aluminum, lead, zinc, molybdenum, fertilizer, copper, bauxite & alumina, tin, noble alloys & minor metals, and bulk ferroalloys.

The following list of reports/services are required:

1. Aluminum Premium

2. Lead Premium

3. Zinc Premium

4. Molybdenum Classic

5. Fertilizer Classic

6. Copper Classic

7. Bauxite & Alumina Classic

8. Tin Classic

9. Noble Alloys & Minor Metals Classic

10. Bulk Ferroalloys Classic

4. Estimated Dollar Value

$502,068.82

5. Statutory Authority

The proposed action may be awarded on a sole source basis in accordance with FAR 13.501(a) Sole source (including brand name) acquisitions.

6. Rationale Supporting Use of Citation in No. 5

Market reports from CRU contain proprietary unique data sets that forecast and cover global production, production capacity, trade, consumption, demand drivers, and prices. The data is updated regularly throughout the year. CRU is the only source capable of supplying such data, which is used in support of the NMIC mission to provide comprehensive nonfuel minerals information necessary to assure adequate domestic military and civilian supply.

With increasingly fewer commodities being mined in the United States, and many foreign governments (e.g. China) refusing to share production or consumption information, market data from the CRU cannot be obtained otherwise. Given recent global trade sanctions, having access to market information is critical. Specifically, since China’s export ban on antimony, graphite, gallium and germanium in 2024 and, more recently, their export ban on several rare earth elements, the U.S.

Government at all levels has considerably increased its supply chain risk assessment and risk mitigation activities. Since NMIC is the “go to” expert science center for data and analysis on critical mineral supply chains, numerous government agencies have requested support on their own supply chain efforts.

CRU’s products and services also assist NMIC’s research activities directly. CRU provides original research on production, trade, consumption, and pricing of minerals and metals on a global scale. CRU’s technical coverage of the mineral commodities industry is not available elsewhere.

7. Other Information

The information to be obtained on these critical minerals through this vendor is important to the NMIC’s mission to analyze and disseminate minerals and mineral supply chain information as mandated in the National Materials and Minerals Policy, Research and Development Act of 1980 (30 U.S.C. 1601 et seq.) and the National Defense Stockpile Act (50 U.S.C.

§ 98 et seq.), the latter of which enables the Department of Defense to assess mineral supply chain risk and secure strategic materials for national defense.

CRU’s data aligns with several Executive Orders such as:

• Executive Order 13817, December 20th 2017 which emphasizes reducing foreign reliance on critical minerals, strengthening domestic supply chains, and ensuring economic and national stability.

• Executive Order 14156, January 20th 2025 which declares a national energy emergency, including critical minerals.

• Executive Order 14241, March 20th 2025 which directs the government to implement immediate measures to increase American mineral production.

• Executive Order 14285, April 24th 2025 which directs the government to research offshore critical minerals.

CRU’s data also aligns with the Section 232 investigation President Trump ordered on critical minerals’ impact on national security. While the Department of Commerce will lead the investigation, it will lean heavily on data, analysis and insight from NMIC.

8. The Efforts to Identify Additional Sources Including the Market Research Conducted

An internet review of vendors who provide similar services conducted as part of this procurement request determined that the offerings available from similar vendors did not have the same products and services that CRU provides. Consultation with the mineral commodity specialists confirmed that other vendors either do not cover the information needed in this contract or are insufficient to meet the requirements of NMIC.

The Contracting Officer (CO) posted a sources sought notice seeking sources for subscriptions offering the required minerals data sets and analysis. Three responses were received and assessed by the CO and requiring activity, however none offered the required data sets and analysis all on the minerals required by the NMIC.

9. Future Plans to Permit Competition

If another entity offers subscriptions to comparable minerals reports this requirement will be competed to the maximum extent practicable. However, until such time these become available this requirement will continue to be awarded noncompetitively.

10. Recommendation Program Office

Based on the above, I recommend this acquisition be conducted on a sole source basis and certify that the above statements are true and correct.

Lee Bray Acting Chief Mineral Commodities Section

11. Certifications from the Contracting Officer:

a. The contracting officer has determined that the anticipated cost to the Government will be fair and reasonable based on comparison to prices paid previously for the same subscription on previous contracts.

b. This justification is accurate and complete to the best of my knowledge and belief.

12. Approvals:

Daniel Galvin, Contracting Officer Date

Stacey Diamond, Chief, Reston Acquisition Branch Date

Douglas Hill, Bureau Competition Advocate (Acting) Date

2026-02-17T08:29:04-0500
DANIEL GALVIN
2026-02-18T15:54:24-0500
STACEY DIAMOND
2026-03-12T14:18:20-0400
DOUGLAS HILL

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