OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3006.301-90

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 USC 3304 (A): USE OF NONCOMPETITIVE PROCEDURES

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0F 1J&A-26-0333

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-111F

2) and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), U.S. Immigration and Customs Enforcement (ICE), Office of Acquisition Management (OAQ) proposes to enter into a contract on behalf of the Homeland Security Investigation (HSI) on a basis of other than full and open competition.

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

(a) Nature of action: DHS ICE intends to procure VIKEN Detection RAVEN-PPAK handheld X-ray imager systems on a sole source basis.

(b) Name and address of the Contractor

Viken Detection 21 North Avenue Burlington, MA 01803

(617) 467-5526

(c) Contract Type: Firm Fixed Priced

(d) Estimated Total Value (including options):

Product Code Description Qty Unit Price Extended

Price

RAVEN-PPAK,

RAVEN160

RAVEN

UPGRADE:

MatID

1 If applicable, the Acquisition Plan ( AP) must be finalized and signed prior to submitting the Justification to OCPO.

2 FAR Class Deviation 25-11 is implemented as a result of Revolutionary FAR Overhaul, referred as RFO, following Executive Order 14275, Restoring Common Sense to Federal Procurement. All citations in this document follow applicable DHS RFO Deviations therefore are referred as RFO.

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RFO 6.103-3: Industrial mobilization; engineering, development, or research capability; or expert services.

RFO 6.103-4: International agreement.

RFO 6.103-5: Authorized or required by statute.

RFO 6.103-6: National security.

RFO 6.103-7: Public interest.

5. Identification of Exception to the Buy American Statute

The item is a Commercially Available Off-the-Shelf (COTS) item manufactured in the United States. Pursuant to FAR 25.101(a)(2), the domestic component test is waived for COTS items, and the item qualifies as a domestic end product.

6. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The proposed acquisition is restricted to the VIKEN Detection RAVEN-PPAK system because the Government’s minimum mission requirements necessitate an integrated, proprietary platform. The RAVEN-PPAK configuration is not a collection of standalone commodities, but a unified ecosystem comprising a RAVEN160 handheld X-ray imager, PNL1417a transmission panel, and highly specialized, software-enabled upgrades

These integrated components are proprietary to the VIKEN Detection RAVEN platform;

they are specifically engineered to communicate with the RAVEN scanner’s architecture and must be activated at the time of manufacture. Utilizing an alternative manufacturer’s device or attempting to integrate disparate components would result in critical failures regarding compatibility, performance, and software support. Furthermore, procuring individual elements from multiple sources would void the manufacturer’s warranty, render proprietary software upgrades unusable, and preclude the delivery of necessary platform-specific operator training. Because the required capabilities imaging, material discrimination, and advanced AI detection must function as a single, manufacturer-certified system, VIKEN Detection is the only source able to provide all the required functionalities via one platform.

7. Description of efforts made to ensure that offers are solicited from as many potential sources as is practicable.

To ensure that all potential sources were considered, HSI conducted comprehensive market research to evaluate the current landscape for this requirement. While current market analysis confirms that the proprietary capabilities of the required platform remain uniquely suited to our specific mission needs, we have taken active steps to maintain visibility in the broader

Page - 4 - of 6 market. HSI remains committed to fostering competition by conducting annual market research to identify and evaluate emerging alternatives. Through this ongoing evaluation process, HSI ensures that our acquisition strategy remains adaptive and that we are continuously surveying the marketplace for viable new sources.

8. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer has determined that the anticipated cost to the Government for the VIKEN Detection RAVEN-PPAK systems is fair and reasonable. This determination is based on comparison of the proposed price against the Independent Government Cost Estimate (IGCE), and comparison with historical pricing for similar systems. The proposed pricing reflects a comprehensive, integrated package that includes proprietary hardware, specialized software upgrades, warranty coverage, and training. Given that these components are essential to maintaining an integrated, mission-capable platform and that competitive alternatives cannot provide the required system compatibility, the price is considered fair and reasonable.

9. Description of Market Research.

A market analysis was conducted in May 2026, to evaluate potential acquisition strategies.

The following alternatives were assessed against the Government’s specific operational requirements:

Full and Open Competition: Market surveys indicate that a generic competitive procurement would not yield the required RAVEN-PPAK configuration. Alternative handheld X-ray systems lack the proprietary platform-specific capabilities essential to current mission requirements.

Base Configuration Procurement: The acquisition of base-level handheld scanners excluding integrated specialized modules such as fails to meet the validated performance threshold required by end-users.

Componentized/Modular Procurement: Disaggregated procurement of hardware components and software modules was evaluated and rejected. This approach introduces significant technical risks, including interoperability challenges, licensing fragmentation, complex integration, and the potential voiding of manufacturer warranties. These critical features are inherently tied to the RAVEN platform architecture and require cohesive acquisition.

Conclusion: Market research confirms that the requested solution is the only product that meets all identified technical and performance requirements. Other potential alternatives were evaluated and found unable to meet the RAVEN-PPAK configuration requirement, rendering them unsuitable for this application.

10. Any other facts supporting the use of other than full and open competition.

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