JOFOC 191T7026C0002.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SECTION 1: IDENTIFICATION OF THE AGENCY AND THE CONTRACTING ACTIVITY

Department of State Contracting Activity

☒ Overseas Post Rome, Italy

Requiring Activity Facility Section, Rome, Italy

SECTION 2: NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

Approval is requested to award on a sole-source basis to RADEA Stammhaus GmbH for the installation of radon mitigation systems at official residences of the Tri-Mission in Rome, Italy as described in Section 3 on behalf of the Requiring Activity.

The expiration date of this authority to act under a Class Justification and Approval (J&A) is January 31, 2026.

The result of this action shall be a Firm-Fixed-Price (FFP) contract.

SECTION 3: DESCRIPTION OF SUPPLIES/SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS

Background

Embassy Rome is addressing an urgent health and safety threat impacting Embassy families and empoyees. The embassy plans to mitigate high concentratos of radon gas by installing sub-slab depressurization (SSD) systems and exhaust fans to each of six official residences of the Tri-Mission.

The scope of work includes:

• Installation of SSD systems and exhaust fans

• Electrical and masonry work

• Radon testing and measurements

• Supervision of outsourced specialized masonry work

The estimated period of performance will begin immediately after the award.

The estimated value of this project is US dollars $438,264.12, VAT included.

SECTION 4: IDENTIFICATION OF THE STATUTORY AUTHORITY PERMITTING OTHER THAN

FULL AND OPEN COMPETITION

This acquisition is conducted under the authority of 41 USC 3304, as implemented by FAR 6.3 and substantiated by the following:

☒ FAR 6.103-2 – Unusual and compelling urgency.

SECTION 5: DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF THE AUTHORITY

CITED

The contractor’s unique qualifications are required because the project is exceptionally complex. The work is complex because radon is colorless and odorless radioactive gas that, when inhaled over prolonged periods, exposes the lungs to ionizing radiation from its decay products, leading to an increased risk of lung cancer.

The primary source of the gas is the soil under and around buildings. Radon mitigation is complex due to a combination of radon’s invisible physical properties and the variable and localized nature of its presence. It is impossible to detect without specialized equipment and specialized knowledge. Mitigation system must be placed in specific location based on an analysis of soil condition, sub-slab pressurization, building construction, and infrastructure capacity. The proposed contractor is based in Germany. The contractor specializes in radon analysis and remediation projects and has completed more than 850 projects in the last 24 years. The U.S. Army Corp of Engineers is a primary client of the contractor. The contractor has successfully completed work at numerous U.S. Depart of Defense facilities in Germany. The contractor has developed specialized techniques to measure and monitor radon and unique equipment to mitigare concentrations of radon.

SECTION 6. DESCRIPTION OF EFFORTS TO ENSURE THAT OFFERS WERE SOLICITED FROM AS

MANY POTENTIAL SOURCES AS IS PRACTICABLE, INCLUDING WHETHER A NOTICE WAS OR

WILL BE PUBLICIZED AS REQUIRED BY FAR SUBPART 5.1 AND, IF NOT, WHICH EXCEPTION

UNDER FAR 5.101 APPLIES

A synopsis of the proposed procurement was not published on SAM.gov because the contract action is being made under the conditions described in FAR 6.103-2, which allows for exceptions due to unusual and compelling urgency. Specifically, FAR 5.101 (b) (2) provides an exception to the requirement for publishing a synopsis using other than full and open competition. Given the critical nature of the work and its impact on official representational functions, this exception applies.

Preliminary market research was conducted in accordance with FAR Part 10 to identify potential sources capable of meeting the requirements. This research included reviewing past performance records, consulting with subject matter experts, and analyzing the availability of contractors with the necessary expertise, and extensive technical knowledge.

Further market research was deemed unnecessary due to the urgency of the requirement.

SECTION 7. DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED COST

TO THE GOVERNMENT IS FAIR AND REASONABLE

The Contracting Officer has anticipated the cost to be USD $438,264.12, which has been deemed fair and reasonable based on:

1. Post and OBO subject matter experts have reviewed the proposed work, quantities, and unit costs and confirmed that they are accurate and fair

2. The proposed cost is consistent with similar mechanical ventilation projects

3. An IGCE was developed based on the scope of work, including labor, material, equipment and project management.

4. Market research was conducted to assess prevailing rates for similar renovation services in the local area. The proposed cost is consistent with market prices for the complexity of the work further supporting its fairness.

By signing the justification, the Contracting Officer makes the determination that the USD $438,264.12 to the Government is expected to be fair and reasonable.

SECTION 8. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED (SEE PART 10) AND THE

RESULTS OR A STATEMENT OF THE REASON MARKET RESEARCH WAS NOT CONDUCTED

Market research was limited due to the compelling and unusual urgency of the requirement. The short notice, health and safety threat nature of the requirement have limited the ability to conduct full and open market research. This research included attendance at industry events, consulting with subject matter experts, and analyzing the availability of contractors with the necessary expertise, and extensive technical knowledge.

SECTION 9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN

COMPETITION

The required delivery schedule is immediate, with work beginning upon contract award

The project must be completed within 50 calendar months to not interfere with official events and activities at the three Chief of Mission Residences.

SECTION 10. LISTING OF THE SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST

IN THE ACQUISITION

None

SECTION 11. STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE OR

OVERCOME ANY BARRIERS TO COMPETITION BEFORE ANY SUBSEQUENT ACQUISITION FOR

THE SUPPLIES OR SERVICES REQUIRED

The Government recognizes the importance of fostering full and open competition for future acquisitions of similar supplies or services.

SECTION 12. CERTIFICATIONS

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein, are complete and accurate to the best of my knowledge and belief.

Technical Cognizance:

SIGNATURE:

Name: Mr. Michael Kerns, FM Director Title: Facility Manager

CERTIFICATIONS (Continued)

CONTRACTING OFFICER CERTIFICATION

I certify that this submission is accurate to the best of my knowledge, and that it contains complete information necessary to enable other officials to make an informed recommendation for approval or disapproval.

SIGNATURE:

Name: Crystal D. Sheridan Contracting Officer

01/28/2026 14:16 GMT

Kerns, Michael (KernsMF@state.gov)

01/28/2026 14:17 GMT

Sheridan, Crystal (SheridanCD@state.gov)

SECTION 13. APPROVALS

Name: Cynthia S. Richards

HCA

Name: David W. Simons Management Counselor

01/28/2026 14:41 GMT

Richards, Cynthia (RichardsCS@state.gov)

01/28/2026 15:38 GMT

Simons, David (SimonsDW@state.gov)