E2FOM_RCC_1N_Approved_Redacted.pdf

Exception to Fair Opportunity Template Update DEC 2025

Critical Fleet Deficit: On May 1, 2026, NSWCDIV PHL PA identified an acute readiness risk: the active Freedom-class LCS fleet has . The GTE currently inside the USS FORT WORTH is a newly installed, unused, pristine engine.

The Threat: If this engine is not extracted in before the ship sails, the Navy faces a severe operational gap. A failure on any active Freedom-class hull would result in due to the lack of standby spares.

Failing to perform this removal in under the current contract, and instead delaying the removal until the ship arrives at the Deactivation Facility in guarantees severe negative consequences:

1. Immediate Duplicative Costs: Executing this work in will result in at least in immediate, unnecessary duplicative costs for temporary services, crane support, rigging, and logistical setup that have already been established by the incumbent contractor in San Diego.

2. Guaranteed Schedule Slippage & Mission Failure: Attempting to compete this requirement or coordinate a new contractor in will cause massive logistical delays. The transit and subsequent layup schedule would be entirely derailed, causing a cascading failure of the ship’s deactivation timeline.

3. Unacceptable Taxpayer Risk: Moving an un-extracted, valuable, unused engine away—only to pay higher, non-mobilized rates to extract it at a non-homeport facility—is an irresponsible and highly inefficient use of government funds.

The incumbent contractor already possesses the necessary access, specialized shipboard familiarity, setup, and temporary services on-site at Introducing a new contractor at this late stage (less than before sail-away) would introduce severe integration risks, require costly duplication of staging and safety certifications, and make meeting the deadline physically impossible.

The Contracting Officer will evaluate the incumbent’s proposal using historical cost data, established labor rates under the existing SWRMC vehicle, and independent government estimates (IGE) to ensure that the final price for Work Item 234-11-001 (RCC 1N) is fair, reasonable, and highly advantageous to the government.

If this sole-source action is not approved immediately:

The USS FORT WORTH will fail to meet its sail-away milestone.

The Navy will incur a minimum of $ in wasted, duplicative expenditures.

The active-duty LCS fleet will remain critically vulnerable to extended operational failure due to a

b. Only one such awardee is capable of providing such services required at the level of quality required because the services ordered are unique or highly specialized.

c. The order must be issued on a sole-source basis in the interest of economy and efficiency as a logical follow-on to an order already issued under the MAC, provided that all the awardees were given fair opportunity to be considered for the original order.

Exception to Fair Opportunity Template Update DEC 2025

d. It is necessary to place an order to satisfy a minimum guarantee.

e. For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.

5. Determination of Fair and Reasonable Cost.

The original delivery order was awarded competitively in which three (3) of the six (6) LOT 1 MAC- IDIQ Contract Holders submitted a proposal. Epsilon Solutions was awarded the contract for the Continuous Maintenance availability based on Lowest Price Technically Acceptable (LPTA) criteria.

A thorough review and analysis, with regard to price and scope, of the pricing information provided by Epsilon Solutions will be conducted by the Project Team (PT) and verified by the Contracting Officer.

Determination of fair and reasonable costs will primarily be accomplished by use of parametric methods used to determine reasonableness of labor hours, materials, and times proposed by Epsilon, in accordance with FAR 15.404-1(b)(2)(iii). Furthermore, application of rough yardsticks will be utilized for significant inconsistencies that warrant additional pricing inquiries in addition to review of any historical pricing information for Epsilon Solutions that is available, as well as similar work accomplished by other contractors. The PT with verification by the Contracting Officer will accomplish this analysis in conjunction with comparison of all proposed labor hours and material.

The Contracting Officer has determined that to the Government for this Acquisition will be fair and reasonable based on FAR 15.404-1(e)(1), technical analysis from the PM, FAR 15.404-1(b)(2)(i) – comparison of proposed prices of labor and material burden rates received in response to the solicitation, and FAR 15.404-1(b)(2)(v), comparison with the IGE.

6. Description of Efforts Made to Solicit Offers From as Many Offerors as Practicable:

All offerors under the LCS SEC WEST PT. III MAC were given fair opportunity to submit a proposal in response to the solicitation of the availability basic work package. As this is new work there would be unrealistic contractual expectations to overcome barriers that have led to this exception. Furthermore, if the work is not performed during this window of availability, the USS FORT WORTH (LCS-3) will not fulfill its current operational obligations and would thus incur mission risk to the Government.

7. Actions Taken to Remove or Overcome Barriers that Led to the Exception to Fair Opportunity:

As noted above, this work item could not have been identified earlier as it was not identified that SWRMC Planning of the ICMAV would need to be able to remove MT-30 Gas Turbine Engine (GTE) under this current availability. The issue was not identified during prior inspections. While standard procedures would follow the typical solicitation process providing fair opportunity to the LCS SEC WEST PT. III MAC IDIQ contract holders, it is in the Government’s best interest to incorporate this critical work in order to meet and support the USS FORT WORTH (LCS-3) operational readiness. This is an atypical event and could not be planned or forecasted, accordingly, the ACO determined that this course of action is the most prudent way forward in this unique instance.