Legal Review - Justification and Approval FAR Part 12 (JA) CARC 15 Oct Redaction PCO_Redacted2.pdf

JUSTIFICATION REVIEW DOCUMENT

FAR Part 12 Justification for Other than Full and Open Competition

Program/Equipment: Chemical Agent Resistant Coating (CARC) painting, in pattern, for 215 Light Armored Vehicles (LAVs) at west coast Marine Corps

Installations.

Authority: The statutory authority to restrict competition is Title 41 United States Code (U.S.C.) §1901 as implemented by Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) 12.201-1 and 10 U.S.C. §3204 as implemented by FAR 6.103- 1(c)(2)(ii) Unacceptable delays in fulfilling the agency's requirements.

Amount: $4.8M

Prepared by: Drew Pearson Phone: 520-692-8431 Contract Specialist Date: 07 Aug 2026 E-mail: drew.j.pearson2.civ@army.mil

Contracting Officer: John Sarti Phone: 571-588-9233 Contracting Officer Date: 07 Aug 2026 E-mail: John.M.Sarti2.civ@army.mil

Technical: Julia Mao Phone: 571-588-7439 Engineer Date: 07 Aug 2026 E-mail: wenjie.mao.civ@army.mil

Requirements: Kevin Horn Phone: 586-282-9147 Supervisor/Logistics Lead Date: 07 Aug 2026 E-mail: kevin.m.horn2.civ@army.mil

Impact if not approved: If the Justification is disapproved, the Government would be forced to incur the delay as described above.

7. Efforts to Obtain Competition: The Government will not pursue competition for this effort for the reasons stated above in Section 6. The Contracting Officer will publish the notices required by FAR 5.101 and any bids or proposals received will be considered. Competition among subcontractors is a possibility for sourcing labor and material and publishing provides an opportunity to source from prime vendor.

8. Actions to Increase Competition: The Government intends to solicit future requirements for these services on a competitive basis when the timeline will allow other businesses the potential opportunity to develop the knowledge to perform the required work as the timeline will not be as critical.

9. Market Research: Market research was conducted IAW FAR 10 for this acquisition.

ACC-DTA and PM LAV issued a Request for Information (RFI) (Sources Sought notice) to industry that included questions related to application of these CARC compounds in a pattern to tactical vehicles and the ability to perform on site. The Market Survey closed on 16 June 2026, with a total of nine responses received.

Company Small Under

NAICS 811121

Capable of Performing

BHPE, LLC. Yes No

Enterprise Ventures Corporation (EVC)

Unknown No

Hentzen Coatings Unknown No

Lakeside Meridian

Unknown No

MILSPRAY

No Yes

RV Global Solutions

Yes No

San Diego Powder & Protective Coatings

Unknown No

Sundial Powder Coating

Team Auto Collision

Of the nine responses, only MILSPRAY had the capability to perform this effort within the timeframe required.

10. Interested Sources: To date no other sources other than those described above have written to express interest.

11. Other Facts: There are no other facts necessary to justify limiting competition that were not previously stated.

a. Procurement History: none. This was previously done by Government personnel at the different Depots.

b. Other Facts: n/a

12. 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.

Digitally signed 07 Aug 2026 Julia Mao Engineer

13. 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.

Digitally signed 07 Aug 2026 Kevin Horn Supervisor/Logistics Lead

14. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable. This determination will be made using price analysis techniques. As part of the basis, certified cost or pricing data will not be required IAW exception 15.403(b)(3).

Signed/js/ 07 Aug 2026

JOHN SARTI

CONTRACTING OFFICER

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

Signed/js/ 07 Aug 2026

JOHN SARTI

CONTRACTING OFFICER

CAI MEMORY…