Justification FAR Part 13 Signed.pdf

CUI//SP-PROCURE//FEDCON

Control Number:

FAR Part 13 Justification and Approval Simplified Procedures for Certain Commercial Items

1. Requiring Activity: The Old Guard, Fort Myer

2. Contracting Activity: MICC Fort Belvoir

3. Description of Action: Request approval to award a new $256,000 noncompetitive Firm-Fixed-Price (FFP) purchase order to Live Oak Plantation Combined Driving, 7340 N US Highway 27 STE 201, Ocala FL 34482. The contract will be fully funded using Fiscal Year (FY) 26 Operations and Maintenance Army (OMA) funds.

4. Description of Supplies/Services: One Caisson Wagon IAW the Purchase Description

Item Quantity Delivery Date Estimated Unit Price

Estimated Value

Wagon 1 NLT 31 Jan 25 $256k $256k

5. Authority Cited: Title 41 U.S.C. §1901(e)(2) as implemented in FAR 13.501(b)(1),For purchases not exceeding the simplified acquisition threshold (SAT), contracting officers may solicit from one source if the contracting officer determines that the circumstances of the contract action deem only one source reasonably available (e.g. Urgency, exclusive licensing agreements, brand name, or industrial mobilization).

6. Reason for Authority Cited: Urgency: The Old Guard Caisson Detachment requires an additional wagon in January 2026 to meet their Congressionally mandated funeral support mission.

a. Background: NDAAs FY24 and FY25 requires the Old Guard Caisson Detachment to conduct 4 funerals per day in Arlington National Cemetery. By the end of FY 2026 the Caisson Detachment will be conducting 4 funerals per day which requires a minimum of 4 operational wagons. When accounting for training and spares, the Caisson Detachment requires 8 wagons total. Currently, the Caisson Detachment possesses one fully operational wagon and one other that can be used in emergencies.

In 2022 the Old Guard Caisson Detachment identified the need for additional caisson wagons to replace their 1917 versions which are old, heavy, and hard on the horses.

Since 2023 they have attempted to find a suitable replacement with no success.

In May 2025 MICC Fort Belvoir leadership realized that the acquisition strategy was not going to adequately address the need. In response, Mission Installation Contracting Command (MICC) tasked its Theater Support Center (TSC) to procure wagons via Other Transactional Authority (OTA) with an objective of procuring four wagons by

3QFY26. However, the government shutdown delayed the timeline by six weeks, putting the already aggressive timeline in jeopardy.

Simultaneously, market research by the Old Guard identified a Caisson wagon at Live Oak Plantation Combined Driving that meets all requirements for appearance, durability, and functionality.

b. Alternatives: The Caisson Detachment has tested wagons from Trial Rock Ordinance and the North Carolina Troopers Association but both wagons were found to be insufficient due to reliability standards. Neither wagon was capable of daily use as required by the Old Guard. DEVCOM designed and produced a prototype wagon that also suffers from reliability problems and will not improve the design.

c. Impact if not approved: If not approved, the Old Guard will not be able to complete their Congressionally mandated funeral support mission in Arlington National Cemetery.

7. Efforts to Obtain Competition: There has been extensive market research conducted, and multiple sources sought posted to industry to increase competition.

Mission Installation Contracting Command (MICC) tasked a group from the Theater Support Center (TSC) to procure wagons via Other Transactional Authority (OTA) which was stopped due to the government shutdown. The six-week delay has put their timeline at high risk.

a. Effective competition: There are a small number of wagon makers across the country that can produce wagons.

b. Subcontracting competition: N/A

8. Actions to Increase Competition: The TSC OTA is going to explore non-traditional methods and sources such as University Partnership in addition to more traditional vendors. The OTA will be used to compete the requirement to obtain the additional seven caisson wagons.

9. Market Research: Market research, including a sources sought that produced no responses, has shown that Live Oak Plantation Driving is a small business and the only source available to meet the urgent government need by 31 January 2026. Live Oak Plantation Driving has the specific wagon needed and is willing to sell it to the government. The MICC OTA will procure the balance of the requirement.

10. Interested Sources: Live Oak Plantation Combined Driving, Hanson Wheel and Wagon Shop

11. Other Facts:

a. Procurement history. Reasonable efforts have been made to determine the information behind previous procurements. No records of previous procurements exist in PCF and personnel from both the requiring activity and contracting office no longer work in their organizations.

Contract Number Contractor Procurement Method

Amount (est.) Period of Performance

N/A DEVCOM Sole Source $262k Delivered 2024 Unknown/Cashiers Check

Trial Rock Ordnance

Purchase Unknown 5 May 2023

Unknown North Carolina Troopers Association

Lease Unknown 2023

Unknown Unknown Purchase Unknown 1917

1) DEVCOM designed and built a prototype wagon in 2024 for the Old Guard.

This wagon is currently the primary wagon and this prototype suffers from durability problems. DEVCOM has no desire to continue work to correct deficiencies.

2) A wagons was purchased from Trial Rock Ordnance and leased from the North

Carolina Troopers Association in 2023 for testing. Though lighter than the 1917 wagon, they are not designed for daily use and were deemed insufficient. The Trial Rock Ordnance wagon is inoperable, and repair efforts are ongoing.

3) Caisson procured wagons in 1917 that have been modified in-house through the years, including replacing the original steel frame with aluminum. The 1917 wagons are at end of life and unusable.

b. Other facts. N/A

12. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price/cost to the Government for this contract action will be fair and reasonable. This determination will be made using comparison to the independent government estimate.

MAJ Paul Kilgore Contracting Officer

13. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

MAJ Paul Kilgore Contracting Officer