Justification_for_Other_than_Full_and_Open_Competition_1.pdf

United States Department of the Interior

BUREAU OF LAND MANAGEMENT

https://www.blm.gov

SOLE SOURCE (INCLUDING BRAND NAME) JUSTIFICATION AND APPROVAL

FOR ACQUISITIONS UNDER THE SIMPLIFIED ACQUISITION PROCEDURES

This document sets forth the justification and approval as required by FAR Parts 6 and 12.

1. Contracting agency and activity.

The Department of the Interior, Bureau of Land Management (BLM), Arizona Strip District Office/Tim Pananos, requests the Arizona State Office (Procurement Office), to contract on a limited or sole source basis.

2. Nature and/or description of action being approved.

BLM Arizona intends to award a sole source, firm fixed price contract to Advanced Composting Systems (ACS) for the installation of a composting toilet at Vermillion Cliffs National Monument.

3. Description of supplies or services.

The Foundation for America's Public Lands (FAPL) has donated a composting toilet facility to BLM Arizona for use at Vermillion Cliffs National Monument. While FAPL has covered the cost of the facility itself, BLM Arizona is responsible for transportation and installation expenses. As BLM Arizona lacks the necessary resources to fully transport and install the facility, a qualified vendor is required to provide these services.

4. Estimated dollar value.

The estimated value of this service is $46,600.00.

5. Statutory authority.

6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements.

6. Rationale supporting use of the authority stated in paragraph 5.

a. MANUFACTURER (ACS) IS THE ONLY ONE THAT CAN INSTALL ITS OWN TOILET SUCCESSFULLY

WITHOUT DAMAGE TO COMPONENTS. AND ITS SPECIALIZED SKILLS ARE THE ASSEMBLY OF ITS

PREFABRICATED FACILITY THAT HAS THE COMPOSTING TOILET, SOLAR, AND WATER COLLECTION

INTEGRATED INTO THE BUILDING.

2. THERE ARE NO OTHER VENDORS. THE CONTRACTOR IS THE MANUFACTURER AND INSTALLER.

ACS HAS SPECIALIZED EQUIPMENT THAT IS USED TO INSTALL THE BUILDING. IT IS DESIGNED TO

BE TRANSPORTED TO THE SITE AND ASSEMBLED. IF A GENERAL CONTRACTOR WERE TO

DAMAGE ANY PART OF THE BUILDING, IT WOULD REQUIRE MATERIALS THAT ARE

MANUFACTURED AT ACS’S FACTORY TO BE SHIPPED TO THE SITE. ASSEMBLY AND CONFIGURING

ARE EXTREMELY COMPLICATED AND REQUIRES YEARS OF TRAINING TO BECOME PROFICIENT.

3. THE INSTALLATION INVOLVES ACS’S PROPRIETARY TECHNOLOGY, INCLUDING THE PHOENIX

COMPOSTING TOILET, PERMANENT WOOD FOUNDATION, ROOF GUTTER SYSTEM,

RAINWATERCATCHMENT SYSTEM, ELECTRICAL SYSTEM, SOLAR SYSTEM AND THE COMPUTER

SYSTEM THAT CONTROLS ALL ASPECTS OF THE COMPOSTING PROCESS.

4. INSTALLATION INSTRUCTIONS ON ACS’S WEBSITE ARE FOR INSTALLING THE PHOENIX

COMPOSTING TOILET INTO AN EXISTING STRUCTURE, RESIDENTIAL OR OFFICE. OUTSIDE

CONTRACTORS HAVE NEVER SUCCESFULLY ASSEMBLED THE PREFABRICATED STRUCTURE

WITHOUT DAMAGE OR FUNCTIONALITY ISSUES. DAMAGE OR IMPROPER INSTALLATION VOIDS

ALL WARRANTIES, AND CORRECTION OR REPAIR CAN COST AS MUCH AS INITIAL INSTALLATION.

7. Other information.

Although there are likely other vendors willing to install the composting system manufactured by Advanced Composting Systems, the potential for damage or improper installation significantly increases the risk of unsuccessful completion of this project and added costs for repair and/or correction.

8. The efforts to identify additional sources including the market research conducted.

Marker research was conducted in order to determine the method of solicitation and cost of similar requirements. This requirement is unique in the sense that the facility itself has already been purchased by FAPL. Similar requirements included the purchase and installation of a composting toilet facility, therefore the method of solicitation and cost of requirement differ significantly from BLM Arizona’s need.

9. Future plans to permit competition.

This is a one-time requirement, and there are no planned acquisitions for or related to this requirement, therefore, no actions to increase future competition are required.

10. The ordering activity Contracting Officer’s certification that the justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief and evidence that the supporting data that form a basis for the justification have been certified as complete and accurate by technical/program personnel.

I certify that the facts and representations under my cognizance, which are included in this justification and which form a basis for this justification, are complete and accurate.

(Signature)____________________________ (Date) ____07/23/2026_________

(Type or Print Name): _____Timothy Pananos_______________________________________

Contracting Officer’s Representative

11. I certify that the justification is accurate and complete to the best of my knowledge and belief:

(Signature) _______________________________________ (Date) _______________________

(Type or Print Name): ___________________________________________________________ Contracting Officer