Justification FAR Part 6 - TFP26 (KO SIGNED) - v6.pdf

CUI//SP-PROCURE//FEDCON

Control Number: T-26-0003

CUI//SP-PROCURE//FEDCON

March 2026

JUSTIFICATION REVIEW DOCUMENT

FAR Part 6 Justification and Approval for Other than Full and Open Competition

Program/Equipment: Special Operations Command Europe (SOCEUR) will execute Trojan Footprint 2026, a biannual multinational exercise conducted across the U.S.

European Command (EUCOM) Area of Responsibility. To support personnel movement, logistics, and mission execution, SOCEUR requires a variety of leased non-tactical vehicles (NTVs).

Authority: FAR 6.103-6, National Security, implemented under 10 U.S.C. 3204(a)(6) and 41 U.S.C. 3304(a)(6), authorizes limiting competition when disclosure of agency needs would compromise national security.

Amount: Estimated $89,566

Prepared by: SSG Jay Pong Contracting Specialist E-mail: jay.t.pong.mil@army.mil

Contracting Officer: MSG Katharine Shockley Contracting Officer

DSN: 314-542-6853

Date:

DSN: 520-714-8413

Date:

E-mail: katharine.m.shockley.mil@army.mil

Technical: CPT Samuel B. Brunetta Phone:

415-385-9895 Date

Commander, Echo Company, 19th SFG E-mail: samuel.b.brunetta.mil@army.mil

SSG Justin Mclemore 20th SFG Representative Email: justin.j.mclemore.mil@army.mil

Requirements: LCDR Cesar Boulangger

SOCEUR J47

Phone: 205-746-3272 Date:

Phone: 0711-7073-4415 Date:

E-mail: cesar.a.boulangger.mil@socom.mil

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager/Program Executive Officer:

LCDR Cesar Boulangger

SOCEUR J47

Phone:

0711-7073-4415

Estimated $89,566E

SSG Jay Pong Contracting Specialist E-mail: jay.t.pong.mil@army.mil

SSG J P

C E

MSG Katharine Shockley Contracting Officer

DSN: 520-714-8413

Date:

E-mail: katharine.m.shockley.mil@army.mil

DSN: 314-542-6853DSN: 314-542-6853

: CPT Samuel B. Brunetta Commander, Echo Company, 19th SFG E-mail: samuel.b.brunetta.mil@army.mil

: Phone:

415-385-9895 Ph 415 385 9895

SSG Justin Mclemore 20th SFG Representative Email: justin.j.mclemore.mil@army.mil

Phone: 205-746-3272

LCDR Cesar Boulangger

SOCEUR J47

E-mail: cesar.a.boulangger.mil@s

LCDR C B l S gg @ ocom.milsos

0711-7073-44150

LCDR Cesar Boulangger

SOCEUR J47

LCDR C B l

Phone: 0Phone: 00

Phone:

0711-7073-44150711-7073-4415

Estimated $89,566EE

SSG Jay Pongg Contracting Specialist E-mail: jay.t.pong.mil@army.mil

SSGSSG JJJ PPP

C E j y p g @ y

SSG J P DSN: 314-542-6853DSN: 314-542-6853

MSG Katharine Shockley Contracting Officer

DSN: 520-714-8413

Date:

E-mail: katharine.m.shockley.mil@army.mil

S

: CPT Samuel B. Brunetta Commander, Echo Company, 19th SFG E-mail: samuel.b.brunetta.mil@army.mil

:: Phone:

415-385-9895 Pho 415 385 9895 Ph

SSG Justin Mclemore 20th SFG Representative Email: justin.j.mclemore.mil@army.mil

Phone: 205-746-327220 6 32 2

LCDR Cesar Boulangger

SOCEUR J47

E-mail: cesar.a.boulangger.mil@s

LCDR C B l ocom.milsos S E

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SOCEUR J47

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EEstimated $89,566EE

C E jay.t.pong.mil@army.mil C E

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MSG Katharine Shockley Contracting Officer

DDSN: 520-714-8413

DDate:

E-mail: katharine.m.shockley.mil@army.mil

SS

:: CPT Samuel B. Brunetta Commander, Echo Company, 19th SFG E-mail: samuel.b.brunetta.mil@army.mil

:::: Phone:

415-385-9895415 385 9895415 385 9895415 385 9895 PhoPho 415 385 9895

SSG Justin Mclemore 20th SFG Representative Email: justin.j.mclemore.mil@army.mil

Phone: 205-746-3272Phone: 205 746 327220 6 32 2

LCDR Cesar Boulangger

SOCEUR J47

E-m-mail: cesar.a.boulangger.mil@socom.misos S E

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SOCEUR J47

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EEstimated $89,566EE Estimated $89,566

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g Off MSG Katharine Shockley Contrtractting Officer

DSN: 520-714-8413

Date::

E-mail: katharine.m.shockley.mil@army.mil

:: CPPT Samuel B. Brunettta Commander, Echo Company, 19th SFG E-mail: samuel.b.brunetta.mil@army.mil

:::Technical: : Phone:

415-385-9895415 385 9895 Pho 415 385 9895 PhoPhPho 415 385 9895415 385 9895415 385 9895415 385 9895 PhoPho 415 385 9895

SSG Justin Mclemore 20th SFG Representativ Representative Email: justin.j.mclemore.mil@army.mil

Phone: 205--746-3272Phone: 205 746 327220 6 32 2

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LCDR Cesar Boulangger

SOCEUR J447

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CUI//SP-PROCURE//FEDCON

March 2026

Small Business: Not Applicable. This requirement will result in a contract awarded and performed OCONUS, therefore the contracting officer has determined not to apply FAR Part 19 to this procurement IAW the discretion afforded by FAR 19.000(b)(1)(ii), the contracting officer will not request review by the SBA procurement center representative IAW DFARS 219.402(c)(iii)(E).

Legal Counsel: Not Required. Only J&A valued at or greater than $250,000 will require a legal review.

FAR Part 6 Justification and Approval for Other than Full and Open Competition

1. Requiring Activity: Special Operations Command Europe (SOCEUR)

2. Contracting Activity: 409th Contracting Support Brigade, Unit 28231, APO, AE 09136-8231

3. Description of Action: The proposed action is to award a Firm Fixed Price (FFP) contract for the lease of Non-Tactical Vehicles (NTVs) in support of Trojan Footprint 2026. The requirement includes a mix of SUVs, pickup trucks, cargo vans, 9-passenger vans, and 12-passenger vans across North Macedonia, Georgia, Greece, and Poland.

The period of performance, including all options and potential extensions, is from May 4, 2026, to May 25, 2026.

This contract will support Special Operations Command Europe (SOCEUR) and its subordinate units by enabling troop movement, logistics support, and exercise execution across multiple host nations. The contractor will be selected based on their ability to meet location-specific delivery requirements identified during market research.

The use of an FFP contract is appropriate due to the commercial nature of the vehicles, well-defined specifications, and established market pricing.

4. Description of Supplies/Services: This requirement provides commercially available rental vehicles necessary to support SOCEUR�s execution of Trojan Footprint 26, a multinational exercise conducted across the European Command Area of Responsibility. The vehicles enable personnel transport, logistics movement, and mission support across dispersed training locations in North Macedonia, Georgia, Greece, and Poland. The Government requires a mix of SUVs, pickup trucks, cargo vans, and passenger vans to ensure mobility, flexibility, and operational reach for participating units. The requirement includes the following vehicles, quantities, and estimated values:

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March 2026

Item Quantity Delivery Date NTVs 33 04 MAY 2026

Items Quantity Location Period of Performance

(POP)

SUV 2

Krivolak Training

Area, North Macedonia

5�24 May 2026

Pickup Truck

Krivolak Training

Area, North Macedonia

5�24 May 2026

SUV 4 Tbilisi, Georgia 5�25 May 2026 Cargo Van 1 Tbilisi, Georgia 5�25 May 2026

SUV 3 Nea Peramos, Greece 5�25 May 2026

Pickup Truck

1 Nea Peramos, Greece 5�25 May 2026

9-Passenger Van

3 Nea Peramos, Greece 5�25 May 2026

Cargo Van 1 Nea Peramos, Greece 5�25 May 2026 12-Passenger

Van 16 Krakow, Poland 4�24 May 2026

FAR 52.217-8 XX Days

5. Authority Cited: FAR 6.103-6 � National Security, implemented under 10 U.S.C.

3204(a)(6) or 41 U.S.C. 3304(a)(6), permits contracting without providing for full and open competition when disclosing the agency�s needs would compromise national security.

6. Reason for Authority Cited: The authority allows the agency to solicit from a limited number of responsible sources who are already vetted under an existing Blanket Purchase Agreement (BPA) or contract vehicle that ensures controlled access. This satisfies the statutory requirement that the agency limit exposure while still obtaining competition to the extent practicable. Due to the nature of the Trojan Footprint exercise and SOCEUR�s participation with multinational partner countries, there are national security concerns if the locations of the exercise support are released by posting the solicitation on the GPE.

a. Background: Special Operations Command Europe (SOCEUR) is executing Trojan Footprint 26, a large-scale, multinational exercise conducted across multiple host nations within the U.S. European Command (EUCOM) Area of Responsibility. The exercise requires the movement of personnel, equipment, and mission-essential supplies across dispersed training locations in North Macedonia, Georgia, Greece, and

CUI//SP-PROCURE//FEDCON

March 2026

Poland. To support these operations, SOCEUR requires a fleet of commercially available Non-Tactical Vehicles (NTVs), including SUVs, pickup trucks, cargo vans, 9-passenger vans, and 12-passenger vans. These vehicles are necessary to ensure troop mobility, logistical support, and command-and-control functions throughout the exercise.

1) The market research confirms that all required vehicle types are commercial items widely available in the European rental market. However, the requirement is uniquely challenging due to the need for simultaneous delivery across four countries, varying vehicle quantities, and specific delivery timelines aligned with exercise execution. The market research identifies that while multiple vendors exist across Europe, only a limited number have demonstrated the capability to support multi-country, synchronized delivery for U.S. military exercises. Vendors listed in the 409th CSB NTV-BPA have prior experience supporting military exercises of similar nature, demonstrating proven capability to meet SOCEUR�s operational timelines and geographic dispersion.

2) The Government did not develop a technical data package or engineering specifications because the requirement is for commercial rental vehicles, and the commercial market already provides standardized vehicle descriptions, terms, and conditions. The market research confirms that the vehicles required�such as Chevrolet Tahoe equivalents, Toyota Hilux equivalents, Renault Trafic vans, and similar models� are readily available and do not require Government-unique specifications.

3) Failure to limit sources and secure these vehicles from a vendor with proven multinational delivery capability would result in unacceptable delays to exercise execution, disrupt troop movement, and degrade SOCEUR�s ability to meet established training objectives, which in turn would harm national security and the readiness of SOCEUR to meet their European mission. The exercise timeline is fixed and cannot be shifted without impacting partner-nation commitments and EUCOM-level planning.

These schedule constraints do not result from a lack of planning; they are inherent to multinational exercise coordination and host-nation training area availability.

b. Alternatives: Several alternatives were evaluated but determined not to be viable or in the Government�s best interest:

1) Use of organic military vehicles � Not feasible. SOCEUR does not possess sufficient organic NTVs in the required quantities, nor can military vehicles be repositioned across four countries without significant cost, diplomatic clearance, and operational disruption.

2) Conducting a full and open competition � Not feasible within the exercise timeline and national security considerations of identifying locations. If the requirement was published through the GPE, adversaries could potentially

CUI//SP-PROCURE//FEDCON

March 2026 extrapolate troop numbers and locations which would adversely impact national security. Furthermore, a competitive procurement would introduce delays incompatible with fixed exercise dates and host-nation training schedules. Additionally, many local vendors lack the ability to support multi-country delivery, reducing the likelihood of receiving viable competitive offers.

3) GSA Europe Fleet was evaluated as a potential alternative due to its established presence in the EUCOM AOR and its ability to support long-term leasing requirements. However, GSA�s European fleet program is optimized for long-duration leases, not short-term, exercise-specific rentals across multiple countries. GSA�s fleet support is geographically limited. Additionally, GSA does not maintain the required mix of passenger vans, cargo vans, and pickup trucks in the quantities needed for synchronized delivery. Utilizing GSA would result in unacceptable delays, fragmented support, and an inability to meet the exercise�s fixed schedule.

c. Impact if not approved:

1) If the J&A is not approved, it would directly jeopardize the Government�s ability to support Trojan Footprint, a multinational special operations exercise in Europe. Trojan Footprint is a time-sensitive, operationally critical SOF exercise involving multiple allied nations. Below are the outcomes if J&A is not approved:

i. Required non-tactical vehicles will not be available to support movement, logistics, and training events across dispersed European locations.

ii. Posting on GPE with full and open competition could risk exposing the unit�s by providing operational locations and troop formations in the European theater.

iii. Exercise timelines may slip or require cancellation of key events, degrading readiness and interoperability.

iv. Operational units may be forced to use suboptimal or ad-hoc transportation, increasing risk and reducing training value.

v. Host-nation coordination could be disrupted, harming U.S.

credibility in a multinational environment.

vi. The exercise depends on synchronized logistics; delays in vehicle support create cascading operational failures.

7. Efforts to Obtain Competition: The Contracting Officer will obtain competition by soliciting all eight (8) vendors on the 409th CSB NTV-BPA.

a. Effective competition: The Government anticipates receiving offers from eight

(8) vendors listed on our NTV-BPA. There is adequate competition.

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March 2026

b. Subcontracting competition: To the maximum extent practicable, the Government will encourage the selected prime contractor to obtain competition at the subcontract level. Vendors supporting previous SOCEUR exercises have historically used local subcontractors.

c. Actions to Increase Competition: The Government has taken several steps to increase competition for this and future acquisitions. Market research was conducted across multiple sources, including FPDS, SAM, commercial rental platforms, WEXMAC history, of GSA Europe Fleet, and 409th CSB procurement data. The Government also evaluated the feasibility of dividing the requirement by country to increase local vendor participation; however, this approach was rejected due to the risk of delivery misalignment and increased administrative burden.

The Government also assessed the use of GSA Europe Fleet, which provides long-term leasing support in Germany, Italy, and Belgium. However, GSA Fleet does not support short-term exercise requirements and likely does not operate in North Macedonia, Georgia, or Greece. As such, GSA Fleet cannot meet the requirement.

For future acquisitions, the Government will continue to expand vendor outreach, refine requirement descriptions in industry terms, and explore opportunities to break out components of the requirement where feasible. The Government will also continue to monitor the European rental market for emerging vendors capable of supporting multi-country delivery.

8. Market Research: Comprehensive market research was conducted on 20 January 2026 in accordance with FAR Part 10 and DFARS 210.001. The research included:

a. Review of commercial rental websites across Europe

b. Review of prior WEXMAC contracts for similar items

c. Analysis of 409th CSB procurement history for NTVs

d. Review of Trojan Footprint 24 contract performance

e. Defense Travel System

f. Assessment of NAICS 532111 and 532120 applicability

g. Evaluation of environmental conditions and rental market maturity in Greece, Georgia, North Macedonia, and Poland

h. Identification of potential offerors with prior SOCEUR support capability

i. Review of GSA Europe Fleet availability

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March 2026

The research confirmed that all required vehicle types are commercial items widely available in the European market. However, only a limited number of vendors demonstrated the ability to support multi-country, synchronized delivery required for Trojan Footprint 26.

9. Interested Sources: The government issued a pre-solicitation notice to all eight vendors on the 409th CSB NTV-BPA, and only SCA Group responded with available resources to support the requirement. Nevertheless, the government will still solicit all eight (8) vendors on the 409th CSB NTV-BPA for the Trojan Footprint requirement.

10.Other Facts:

a. Procurement History: Historically, SPD has awarded Orders for NTVs using the 409th CSB NTV-BPA under the Lowest Price Technically Acceptable criteria. No J&A were utilized for previous NTV-BPA Orders, as the orders we exempt from synopsis based on FAR 5.202(a)(12). However, with the FAR overhaul, the exemption at FAR 5.202(a)(12) no longer exists and thus the necessity to approve this justification and approval to restrict competition on the grounds of national security.

Contract Number Contractor Procurement Method

Amount (est.) Period of Performance

W564KV-25-F-A155 MONARCH

GLOBAL SP.

Z O.O

Local Sources $213,688.00

USD

30 Sep 2025 To 29 Sep 2026

W564KV-25-F-A184 MONARCH

GLOBAL SP.

Z 0.0.

Local Sources $84,178.85 USD 30 Sep 2025 to 29 Sep 2026

W564KV-25-C-A007 KVG LLC Local Sources $65,056.45 USD 10 Jan 2026 to 09 Jul 2026

W564KV-25-F-A026 S.C.A

Shipping

Consultants Associated

Local Sources $144,330.27

USD

30 Mar 2026 To 30 Sep 2026

1) These actions supported similar non-tactical vehicle (NTV) rental requirements in the EUCOM AOR and are consistent with the broader procurement history for rental vehicles described in the market research.

2) All listed prior actions were awarded by restricting competition to local sources IAW FAR 5.202(a)12: This aligns with the broader market research, which shows a robust commercial rental market and multiple vendors capable of providing NTVs across Europe via the 409th CSB NTV BPA.

3) No J&A was utilized, and the actions were not processed under �other than full and open competition� authorities. Instead, they were placed using existing vehicles

CUI//SP-PROCURE//FEDCON

March 2026 such as the 409th CSB NTV BPA, with the actions treated as competitive orders under the established BPA. Other NTV requirements were solicited to local sources outside the BPA under the synopsis exemption 5.202(a)(12), which provides that certain proposed contract actions are exempt from synopsis requirements.

4) The procurement history does not reveal unusual or problematic patterns such as repeated emergency or last-minute buys. Instead, history shows:

Recurring exercised-driven requirements (e.g., Trojan Footprint 24, Cold Response FTX) supported through planned rental contracts and BPAs. Normal competitive awards across multiple vendors and countries, with no indication of chronic urgency or sole-source dependence. The only �pattern� is that NTV rentals are a recurring, exercise-driven need across the EUCOM AOR, which is consistent with the mission profile of SOCEUR and other U.S. forces in Europe.

a. Other facts (additional justification for limiting competition):

1. Commerciality and availability: The report concludes that �the acquisition of rental vehicles for Trojanfoot Print 26 is a commercial product. There is significant procurement history showing that all vehicles required are available in the commercial market and can be supported through multiple contract means.

2. Established BPA structure and coverage: The 409th CSB NTV BPA already covers the EUCOM AOR with eight vendors and is specifically designed for NTV requirements, providing a ready pool of pre-vetted sources and streamlined ordering procedures.

3. Geographically dispersed, exercise-driven requirement: Trojan Footprint 26 requires SUVs, vans, and trucks in North Macedonia, Georgia, and Greece with overlapping periods of performance and tight timelines. The market research notes that rental markets in these countries are mature but fragmented, with IDP requirements, cross-border restrictions, and varying local conditions that complicate ad-hoc, open-market competition.

4. Government leverage and efficiency: The report emphasizes that the U.S.

Government is one of the largest rental customers worldwide and that leveraging existing contract vehicles (like the NTV BPA) allows the Government to obtain better pricing, terms, and service levels than isolated, one-off procurements.

5. Performance and risk considerations: Defined Key performance Indicators (KPIs): (vehicle availability rate, replacement vehicle delivery time, vehicle condition) and the need for rapid replacement in multiple countries favor

CUI//SP-PROCURE//FEDCON

March 2026 vendors already operating under the NTV BPA with demonstrated EUCOM experience and logistics networks.

6. Taken together, these facts support the conclusion that limiting competition to the NTV-BPA vendors�while still soliciting all eight BPA holders�is reasonable, necessary, and consistent with the Government�s need to ensure timely, reliable support to Trojan Footprint 26 while maintaining as much competition as practicable under the circumstances.

11. Technical Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

CPT Samuel B. Brunetta Commander, Echo Company

SSG Justin Mclemore 20th SFG Representative

12. Requirements Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

LCDR Cesar Boulangger

SOCEUR J47

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for each contract action will be fair and reasonable. A determination will be made using price analysis and evaluation of Independent Government Cost Estimates prepared by the Requiring Activity.

MSG Katharine Shockley Contracting Officer

CPT Samuel B. Brunetta Commander, Echo Company CPT S l B B tt

SSG Justin Mclemore 20th SFG Representative SSG J ti M l

0 SFG Representative

LCDR Cesar Boulangger

SOCEUR J47

LCDR Cesar Boulangger

MSG Katharine Shockley Contracting Officer MSG K th i Sh kl

SHOCKLEY.KATHA

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Digitally signed by

SHOCKLEY.KATHARINE.MORG

AN.1368426004

Date: 2026.03.09 15:56:31 +01'00'

CPT S l B B tt

SFG Representative

CPT Samuel B. Brunetta Commander, Echo Company CPT S l B B tt

SSG Justin Mclemore 20th SFG Representative SSG J ti M l

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SOCEUR J47

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MSG Katharine Shockley Contracting Officer MSG K th i Sh kl

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9 15:56:3103.09909Date: 2026.0Date: 2026Date: 2026 0Date: 2

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SSG Justin Mclemore 20thh SFG Representative SSG J ti M l

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LCDR Cesar Boulangger

AN.136

MSG Katharine Shockley Contracting Officer MSG K th i Sh kl

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9 15:56:31103.009Date: 2026.0Date: 2026Date: 2026 0Date: 2

+01 0001'00'01'00'+01'00' ________________________________________________________

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March 2026

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief. Approval may be made by the Contracting Officer for acquisitions valued up to $9M using their certification under FAR 6.303-2(b)(12).

MSG Katharine Shockley Contracting Officer MSG Katharine Shockley Contracting Officer MSG Katharine Shockley

SHOCKLEY.KATHA

RINE.MORGAN.136

8426004

Digitally signed by

SHOCKLEY.KATHARINE.MORG

AN.1368426004

Date: 2026.03.09 15:56:49 +01'00'________________________

MSG Katharine ShockleyMSG Katharine Shockley Contracting Officer MSG K th i Sh kl

SHOCKLEY.KATHAA

RINE.MORGAN.1366

8426004

Digitally signed by

SHOCKLEY.KATHARINE.MORG

AAN.1368426004

Date: 2026.03.09 15:56:49Date: 2 +01'00' __________________________ a a e oc e

RINE.MORGAN.136

MSG Katharine Shockley C MSG Katharine Shockley Contracting Officer MSG K th i Sh kl

SHOCKLEY.KATHAA

RINE.MORGAN.1366

8426004

Digitally signed by

SHOCKLEY.KATHARINE.MORG

AAN.1368426004

Date: 2026.03.09 15:56:49Date: 2 +01'00' __