Just for Other than Full and Open Comp_Final_Redact.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(10 U.S.C. § 3204), Only One Responsible Source and

No Other Supplies or Services Will Satisfy Agency Requirements

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.3, the following facts and rationale justify the use of such authority:

1. Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Office of Contracting and Procurement Headquarters (CG-HCA) proposes to enter into a contract on a basis other than full and open competition.

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

(a) Nature of the action: The U.S. Coast Guard intends to procure Long Range

Identification and Tracking (LRIT) Data Services and to finish the user interface (UI) upgrade services on a sole source basis from Pole Star Space Applications Inc.

(b) Name and address of the contractor:

Pole Star Space Applications Inc. (Pole Star) 3201 34th Street South, A7 Saint Petersburg, FL 33711

(c) Type of action: Single Award Indefinite-Delivery, Indefinite-Quantity (IDIQ)

Contract, with Firm Fixed Price Delivery Orders.

(d) Estimated total value: (pricing retrieved from IGCE)

Period (yearly) Total

Base Ordering Period – 9/1/2025-8/31/2026 $11,395874.40 Ordering Period One – 9/1/2026-8/31/2027 $11,965,668.12 Option Ordering Period Two – 9/1/2027-8/31/2028 $12,535,461.84 Estimated Total Value $35,897,004.36

Table 1. Estimated Total Value

(e) Type of funding: Operations and Support Funds

(f) Year of funding: Fiscal Year 2025

(g) Solicitation Number: 70Z02325R76100025

(h) Background information about the requirement: The International Maritime Organization (IMO) Maritime Safety Committee (MSC), at its 81st session in May 2006, adopted amendments to Chapter V of the Safety of Life at Sea (SOLAS) convention in relation to LRIT. This LRIT regulation, which entered into force on January 1, 2008, requires all ships subject to SOLAS Chapter V/19-1 to transmit LRIT information on a phased-in schedule beginning December 31, 2008. Subject to any future changes in the regulation, all U.S. flagged vessels are required to transmit/provide LRIT position reports, at a minimum four (4) times daily, to the U.S. National Data Center (NDC) via a United States (U.S.) “recognized” Application Service Provider (ASP). Now, the U.S. estimates that there are approximately 850 U.S. Flag vessels subject to the LRIT regulations. The LRIT system with advanced vessel data services has allowed the U.S. to enhance its maritime security via improved Maritime Domain Awareness (MDA). The goal of LRIT is to implement a maritime security system that will enhance United States Government’s ability to track U.S. SOLAS Vessels, identify foreign vessels that are transiting within U.S. coastal waters and for vessels who have intended to enter U.S.

port.

3. Description of Supplies/Services.

USCG requires continued LRIT Data Services and User Interface upgrade to support its maritime security, safety, environmental response, and search and rescue missions. The contractor must operate as the U.S.-recognized Application Service Provider (ASP) and NDC, in accordance with IMO regulations.

Required services include the secure transmission, receipt, and management of LRIT position reports; 24/7 watch support; vessel conformance testing; integration of vessels into the U.S.

LRIT system; and maintenance of a secure, cloud-based geospatial data interface. The contractor must support related programs including Automated Mutual-Assistance Vessel Rescue System (AMVER), Nationwide Automatic Identification System (NAIS), Search and Rescue (SAR) and Optical Imagery, Vessel Sanctions and Port State Control Screening, while complying with cybersecurity standards and system authority to operate (ATO) requirements.

The contractor shall also manage all international data exchanges and billing agreements with foreign Data Centers (DCs) to enable access to foreign-flag vessel positions. These services include processing LRIT transactions, reconciling data, administering invoicing per IMO cost models, and supporting system audits and upgrades. All performance shall comply with U.S.

Coast Guard operational needs, DHS policies, and IMO LRIT technical requirements.

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(a)(1) (formerly 10 U.S.C. § 2304(c)(1)) implemented by the FAR Subpart 6.302-1 entitled, “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Identification of Exception to the Buy American Act.

Not Applicable as the Buy American Act does not cover services of the type being acquired under this effort.

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

The current situation stems from the need to continue services under contract with Pole Star beyond the existing ordering period, which ends on August 31, 2025. The proposed contractor, Pole Star is the only vendor currently certified by the IMO to serve as the United States’ ASP and NDC. Pole Star has successfully operated and maintained this system on behalf of USCG for over a decade, with a fully certified infrastructure that is seamlessly integrated into the global LRIT data network.

USCG requires uninterrupted LRIT Data Services to maintain compliance with IMO regulations. Due to the global, regulatory nature of LRIT operations, USCG relies on Pole Star -- as the U.S.-designated ASP/NDC1 -- to maintain over 90 data-sharing and billing agreements with foreign data centers. These agreements, along with Pole Star’s 24/7 watch center, support real-time vessel tracking, secure data transfers, and emergency maritime responses. While certain elements of the work such as data hosting or help desk support may seem separable in theory, in practice they are fully embedded within Pole Star’s proprietary, accredited system and cannot be segregated for separate award(s) without disrupting overall functionality and compliance for USCG.

Given the high complexity of this system and the real-time nature of the data flow, Pole Star is the only responsible source capable of meeting the full scope of this requirement without operational interruption. Transitioning to another vendor would require the government to replicate the entire ecosystem, including international certification, infrastructure development, software testing, and cybersecurity accreditation, which would result in a multi-year delay and duplicated costs estimated in the tens of millions of dollars.

Replicating the incumbent’s capabilities would cost the Government a substantial amount of money. This includes software redevelopment, re-obtaining IMO certification, cloud buildout/migration, re-establishing data-sharing agreements, and staffing a new 24/7 operations center. These costs would be duplicative as Pole Star currently possesses all required capabilities.

In summary, no other source can meet the Government’s requirements without incurring substantial duplication of cost and unacceptable mission delays. Pole Star is the only known source currently recognized by IMO to operate as the U.S.-designated ASP and NDC for LRIT services. Awarding to another source would result in substantial duplication of cost to

1 In 2009 USCG designated Pole Star to operate LRIT ASP. See Attachment 1. Pole Star further maintains its designation to operate the National LRIT Data Center for the United States. This was last renewed in 2019. See Attachment 2.

the Government that is not expected to be recovered through competition and would create unacceptable delays in fulfilling mission-critical maritime tracking and security requirements.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

As the sole IMO designated service provider for the United States, Pole Star is the only option to fulfill the requirement at present. Approval of another organization to this designation will require the application, review, and approval of the IMO governing body.

As required by 10 U.S.C. 3204(f), this justification shall be made publicly available within fourteen (14) days after contract award and remain posted for a minimum of thirty (30) days.

8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The Contracting Officer determined that the anticipated cost to the Government for the proposed sole source award to Pole Star will be fair and reasonable. This determination is based on several factors, including historical pricing under the current contract and technical validation of the proposed level of effort by the requiring activity.

Pole Star has been performing this work under an existing contract for several years. The prior award pricing will be used to ensure and the proposed pricing for this follow-on action is consistent with previous awards, with adjustments that are within an acceptable range based on inflation and additional scope. The requiring activity will also validate proposed labor categories, service levels, and deliverables, to confirm that the level of effort aligns with the expected work effort and market conditions for highly specialized maritime data services.

An Independent Government Cost Estimate (IGCE) was developed to support the acquisition and assess the reasonableness of anticipated costs for the required Long Range Identification and Tracking (LRIT) Data Services. The IGCE was based on historical pricing from previous awards to Pole Star Space Applications Inc., the level of effort outlined in the current Statement of Work (SOW), and current market indicators for comparable technical and support services. It accounted for key cost elements including labor categories, operational support requirements, 24/7 watch services, cloud hosting, software maintenance, international data exchange management, and system upgrades. Use of historical pricing, technical validation of proposed levels of effort, and the IGCE will ensure costs are fair and reasonable.

9. Description of Market Research.

USCG conducted market research to assess alternative sources, including a review of vendors currently recognized by IMO and an analysis of the technical, regulatory, and operational barriers to onboarding a new provider. Market research confirmed that no other contractor is authorized to provide the required services on behalf of the United States. The requirement was discussed with program stakeholders, technical experts, and the Contracting Officer’s Representative (COR), who validated that the services cannot be segmented or substituted without creating unacceptable mission risk.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

Failure to approve this J&A and continue services with Pole Star would result in an immediate loss of visibility on U.S.-flagged vessels and foreign vessels approaching U.S. waters. This would severely hinder the Coast Guard’s ability to conduct search and rescue operations, enforce maritime law, and monitor threats within our maritime borders. Additionally, it would place the United States in violation of international treaty obligations under SOLAS V/19-1, potentially resulting in loss of credibility and sanctions from the IMO. The cost, time, and complexity of standing up a new provider make sole source continuation with Pole Star not only the most logical path but the only responsible one to meet mission requirements.

11. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the Acquisition.

This requirement is a follow-on/bridge contract to the original awarded Contract No.

70Z02320DPR600200. The acquisition team reviewed the current and historical contract records for this requirement, and due to the unique requirement, that only the current contractor can satisfy, no additional public postings outside of the required were completed.

As such, no written inquiries, capability statements, or expressions of interest from other vendors were received. The only available documentation pertains to the incumbent contractor, Pole Star Space Applications Inc., under the current and previous contract awards.

As a result, there are no written expressions of interest to report on this action.

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any

Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

USCG does not anticipate removing the sole source basis for this requirement, the services must be performed by an entity recognized by IMO as the U.S-designated ASP and NDC.

Pole Star is the only provider certified to perform these roles. The technical requirements outlined in the SOW reflect essential regulatory, operational, and cybersecurity needs and are not considered overly restrictive.

The Government will continue to monitor changes in industry capability and the IMO-recognized provider landscape. If another qualified source becomes available in the future, the Coast Guard will reassess the opportunity for competition. Although a competitive procurement is not being pursued at this time, USCG will initiate early acquisition planning, including a review of specifications and certification timelines, to support a potential future competitive requirement.

13. Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

William E. Lewis Date Contracting Officer

14. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Bethany C. Casto Date Technical Representative/COR

Recommend for Approval

Maria L. Kersey-Robinson Date Procuring Activity Advocate for Competition (PAAC)

Approval

Shreena Morris Date Head of the Contracting Activity

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION