JUSTIFICATION AND APPROVAL SCT (Phase 1B) REDACTED - CPFD.pdf

Control Number: HQC002-26-09 Justification for Other than Full and Open Competition

A. Justification

1. Contracting Office:

Defense Commissary Agency (DeCA), Acquisition Management Directorate, Resale Division, 1300 Eisenhower Ave, Fort Lee, VA 23801

2. Type of Contracting Action:

This Justification and Approval (J&A) authorizes the award of a sole-source, single-award indefinite delivery, indefinite quantity (IDIQ) contract for the supply of brand-name commercial products for resale in DeCA commissaries listed in Attachment B and associated full-line distribution of such goods.

The intended awardee is Coastal Pacific Food Distributors (CPFD).

3. Description of the Supplies/Services:

DeCA requires contracts for the purchase of a broad range of resale goods for designated commissary locations. The principal purpose of this action is to furnish grocery and other resale items needed for commissary operations through a single contractor per commissary. The contract also includes incidental supply-chain functions necessary to support the furnishing of those goods. The recommended awardee will source the resale goods through DeCA’s traditional manufacturers, brokers, and suppliers. The estimated total value of this action is $6.7 Billion. The period of performance consists of a one-year base period and four (4), one-year option periods, for a total potential duration of 5 years if all options are exercised.

4. Authorities Cited:

(a) Pursuant to 10 U.S.C. § 2484(f), as implemented by FAR 6.103-5 under DoW Class Deviation DARS Tracking No. 2026-O0017 (Revolutionary FAR Overhaul Part 6, DFARS Part 206), DeCA may use other than full and open competition for the procurement of brand-name commercial products for authorized resale at DeCA commissaries.

(b) In addition, FAR 6.103-1 under DoW Class Deviation DARS Tracking No. 2026-O0017, and 10 U.S.C. § 3204(a)(1), supports this action because, for DoW, that authority extends to circumstances in which only a limited number of responsible sources can satisfy agency requirements. For the commissaries in Attachment B, CPFD is the only responsible source identified as capable of meeting the requirement within the required schedule and operational constraints.

5. Reasons for Authorities Cited:

Pursuant to the authority granted under 10 U.S.C. § 2484(f) and as justified under FAR 6.103-1, market research concluded that only CPFD possesses the requisite, pre-existing capabilities and infrastructure to supply brand-name products and provide the incidental delivery to the commissaries listed in Attachment B. While a small number of full-line distributors exist nationally, the substantial time and cost for any new entrant to replicate CPFD's unique qualifications would cause unacceptable schedule delays and a duplication of cost not expected to be recovered through competition. This finding, which validates the use of the cited authorities, is based on CPFD's unique qualifications as documented in the market research report.

1) Physical Infrastructure: The multimillion-dollar capital investment to build or retrofit a national distribution network of secure, multi-temperature warehouses that meet DeCA’s specific force protection and food handling standards.

2) Specialized Transportation Fleet: The need to acquire and maintain a dedicated fleet of multi-temperature trailers designed for the high-volume, long-haul, and delivery requirements specific to the covered commissaries in Attachment B.

Replicating this ecosystem would require an extensive implementation period. This delay is unacceptable as it would directly impede the fulfillment of DeCA’s statutory mission under 10 U.S.C. § 2484(a).

6. Efforts to Obtain Competition:

DeCA has conducted extensive market research as discussed in Paragraph 8. Through its extensive market research, DeCA took significant steps to solicit from as many potential sources as practicable.

Based on this research, DeCA concluded only CPFD has the necessary existing infrastructure, capability and readiness and network of commercial agreements required to fulfill this contract without unacceptable delays and duplication of costs.

7. Fair and Reasonable Cost Determination:

The Contracting Officer will ensure that contract terms, conditions and price are commensurate with the Government’s need. Price reasonableness will be established in accordance with DoD Deviation 2026- O0048 DFARS PGI 215.402-70(b). This action is exempt from the requirement for submission of certified cost or pricing data. The Government has information relevant to determining price reasonableness, including historical full-line distribution cost data for relevant brand-name commercial products for resale in, at, or by commissary stores. The Government may also consider current market information and obtain additional data from the offeror as necessary to support negotiations and the final price reasonableness determination. FAR 15.402 states that when certified cost or pricing data are not required, the contracting officer should use data available within the Government first and obtain additional data as necessary to establish a fair and reasonable price.

8. Market Research:

In accordance with FAR Part 10, the Government conducted extensive market research to determine the most suitable acquisition strategy to meet the agency’s needs. The objective of this research was to solicit information from as many potential sources as is practicable and to identify the full extent of commercial capabilities available in the marketplace. The multi-phased approach included a third-party analysis to define the Government’s minimum requirements, a broad market survey of all known industry participants via a Request for Information (RFI), and direct engagement with interested parties through multiple listening sessions. This market research concluded that the national grocery distribution market is highly consolidated, and while several sources expressed initial interest, it confirmed that only the proposed awardee possessed the existing infrastructure and specialized capabilities to meet the agency's full requirements without introducing unacceptable cost and schedule risk. Other potential sources were determined not to meet the Government’s minimum needs based on documented limitations.

9. Other Factors:

DeCA commissaries are statutorily required to operate similarly to a commercial grocery store. Market research confirmed that only a small number of companies in the grocery industry can provide the necessary full-line distribution capabilities. DeCA's unique requirements—including advanced electronic data interchange, mandated patron savings, and the geographic location of its commissaries— further narrow the pool of qualified contractors. The research also supported a two-region strategy as the most feasible approach identified to achieve scale, reduce complexity, and align with existing commercial distribution patterns.1 This approach avoids a "patchwork" of regional distribution patterns, which would prevent the use of large-scale commercial distribution centers, create disparate pricing models, and complicate administration. The contemplated regional division aligns with established commercial distribution patterns and geographical logistics realities.

For the commissaries in Attachment B, only CPFD was found to possess the requisite, pre-existing capabilities and infrastructure necessary to perform the contract successfully. The substantial time and cost for a new entrant to replicate this infrastructure would not be recovered through competition, validating the use of the cited authorities.

10. Interested Sources:

(a) C&S Wholesale Grocers, LLC (C&S) and SpartanNash Company (acquired by C&S)

(b) Coastal Pacific Food Distributors, Inc.

(c) United Natural Foods, Inc.

(d) Associated Wholesale Grocers, Inc.

(e) DHL Supply Chain

(f) KeHE Distributors, LLC

11. Actions to Increase/Foster Competition:

DeCA will periodically re-evaluate the marketplace through sources sought notices and other market research tools to assess if new vendors emerge who have developed the capabilities necessary to meet DeCA's stringent requirements. The defined contract structure, with a one-year base period and four (4), one-year option periods, for a total potential duration of 5 years if all options are exercised, provides future opportunities to recompete this requirement should the market evolve and other viable sources become available.

Approved by the Senior Procurement Executive on March 26, 2026.

1 A separate Justification for Other than Full and Open Competition has been issued by DeCA for the other region.

ATTACHMENT B

Zone Name Store

DoDAAC Store Name

JAPAN HQCWAC SASEBO

JAPAN HQCWAD KADENA AB

JAPAN HQCWG7 CAMP ZAMA

JAPAN HQCWHD ATSUGI NAF

JAPAN HQCWHE CAMP KURE

JAPAN HQCWHF MISAWA AB

JAPAN HQCWHH SAGAMIHARA

JAPAN HQCWHJ IWAKUNI MCAS

JAPAN HQCWHK YOKOSUKA NFA

JAPAN HQCWHL YOKOTA AB

JAPAN HQCWHM CAMP COURTNEY MCB

JAPAN HQCWHN CAMP FOSTER MCB

JAPAN HQCWHP CAMP KINSER MCB

JAPAN HQCWJ4 HARIO VILLAGE

KOREA HQCWG2 CHINHAE

KOREA HQCWG4 CAMP HUMPHREYS

KOREA HQCWG8 KUNSAN AB

KOREA HQCWG9 OSAN AB

KOREA HQCWGX CAMP CARROLL

KOREA HQCWGY CAMP CASEY

KOREA HQCWHB DAEGU

KOREA HQCWHY ANDERSEN AFB

KOREA HQCWHZ OROTE

KOREA HQCWJS K-16 AIR BASE

HAWAII HQCWHU HICKAM

HAWAII HQCWHV KANEOHE BAY MCBH

HAWAII HQCWHW PEARL HARBOR

HAWAII HQCWHX SCHOFIELD BARRACKS

ALASKA HQCWGC EIELSON AFB

ALASKA HQCWGD ANCHORAGE AREA

ALASKA HQCWGE FORT GREELY

ALASKA HQCWGG FORT WAINWRIGHT

ALASKA HQCWJ1 KODIAK

NORTHWEST HQCWGH MOUNTAIN HOME AFB

NORTHWEST HQCWGL MALMSTROM AFB

NORTHWEST HQCWGM BANGOR NBK

NORTHWEST HQCWGN BREMERTON NBK

NORTHWEST HQCWGP FAIRCHILD AFB

NORTHWEST HQCWGQ FORT LEWIS

NORTHWEST HQCWGR MCCHORD FIELD

NORTHWEST HQCWGU WHIDBEY ISLAND NAS

NORTHWEST HQCWJ3 SMOKEY POINT

NORTHERN CALIFORNIA HQCKL1 MCCLELLAN

NORTHERN CALIFORNIA HQCKL2 MOFFETT FIELD

NORTHERN CALIFORNIA HQCKLK BEALE AFB

NORTHERN CALIFORNIA HQCKLR ORD COMMUNITY

NORTHERN CALIFORNIA HQCKLV LEMOORE NAS

NORTHERN CALIFORNIA HQCKMC TRAVIS AFB

NORTHERN CALIFORNIA HQCKMF FALLON NAS

NORTHERN CALIFORNIA HQCKMJ FORT HUNTER LIGGETT

NORTHERN CALIFORNIA HQCKMU BRIDGEPORT MCMWTC

SOUTHERN CALIFORNIA HQCKL8 SAN DIEGO NB

SOUTHERN CALIFORNIA HQCKLH YUMA PG

SOUTHERN CALIFORNIA HQCKLM CAMP PENDLETON MCB

SOUTHERN CALIFORNIA HQCKLU IMPERIAL BEACH

SOUTHERN CALIFORNIA HQCKM5 YUMA MCAS

SOUTHERN CALIFORNIA HQCKMA SAN ONOFRE

SOUTHERN CALIFORNIA HQCKMP EL CENTRO NAF

SOUTHERN CALIFORNIA HQCKMQ MIRAMAR MCAS

SOUTHERN CALIFORNIA HQCKMR NORTH ISLAND NAS

ARIZONA NEW MEXICO HQCKLB DAVIS-MONTHAN AFB

ARIZONA NEW MEXICO HQCKLC FORT HUACHUCA

ARIZONA NEW MEXICO HQCKLF LUKE AFB

FRONT RANGE HQCKM7 HILL AFB

FRONT RANGE HQCKMH DUGWAY PG

CENTRAL CALIFORNIA HQCKL6 PORT HUENEME

CENTRAL CALIFORNIA HQCKLL BARSTOW MCLB

CENTRAL CALIFORNIA HQCKLP EDWARDS AFB

CENTRAL CALIFORNIA HQCKLQ FORT IRWIN

CENTRAL CALIFORNIA HQCKLW LOS ANGELES SFB

CENTRAL CALIFORNIA HQCKLY MARCH ARB

CENTRAL CALIFORNIA HQCKM6 CHINA LAKE NAWS

CENTRAL CALIFORNIA HQCKMD TWENTYNINE PALMS MCAGCC

CENTRAL CALIFORNIA HQCKME VANDENBERG SFB

CENTRAL CALIFORNIA HQCKMG NELLIS AFB