5.1.1-LSJ-P00009-Flight Coordinator SAM Posting).pdf

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3008.405-6

Sole Source Justification RFO 8.401(b) (Class Deviation 25-08)

J&A-26-0195

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, 40 U.S.C. 501, Services for Executive Agencies, and

Revolutionary FAR Overhaul (RFO) 8.401(b) (Class Deviation 25-081) which follows the ordering procedures established by the General Services Administration (GSA) at GSAR 538.7104-3.

1. Agency and Contracting Activity.

The Department of Homeland Security, Immigration and Customs Enforcement (ICE), Office of Acquisition Management (OAQ) proposes to modify a Blanket Purchase Agreement (BPA) on a basis of other than full and open competition that supports ICE Enforcement and Removal Operations (ERO).

2. Nature and/or Description of the Action being Approved.

(a) Name and address of the contractor:

CSI Aviation, Inc.

3700 Rio Grande Blvd NW, Ste. 1 Albuquerque, NM 87102-2876

(b) Type of action: BPA Modification

(c) Estimated total value (including options): $305,741,520.00

Period Unit Unit Price Total

Option Period 2: 07/17/2026-03/08/2027 8 mo. $9,554,422.50 $76,435,380.00

Option Period 3: 03/07/2027-03/08/2028 12 mo. $9,554,422.50 $114,653,070.00

Option Period 4: 03/07/2028-03/08/2029 12 mo. $9,554,422.50 $114,653,070.00

Total $305,741,520.00

3. Description of Supplies/Services.

This requirement is for logistical support staff up to 140 dedicated flight coordinators stationed at ICE field offices nationwide and at the ICE Air Operations (IAO) hubs. These

1 FAR Class Deviation 25-08 is implemented as a result of Revolutionary FAR Overhaul, referred to 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 to as RFO.

Sole Source Justification RFO 8.401(b) (Class Deviation 25-08) coordinators will prepare and manage lists of individuals for scheduled domestic and removal flights, providing logistical support for flight scheduling, coordinating with transportation providers, ensuring compliance with legal, operational, and safety requirements, maintaining flight manifests and documentation, assisting with pre-flight preparations, and resolving logistical challenges to ensure seamless operations on real-time for 18 hours a day, 7 days a week.

4. Identification of Regulatory Exception and Rationale.

The regulatory exception is pursuant to RFO FAR 8.401(b) and GSAR 538.7104- 3(b)(1)(ii) Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized.

5. Identification of Exception to the Buy American Statute: N/A

6. Demonstration of the Proposed Contractor’s Unique Qualifications to Provide the Requirement.

(a) The services needed by the Government are unique or highly specialized.

The Government requires highly specialized logistical support for mass air transportation of individuals in custody, including the preparation and management of flight manifests, coordination with transportation providers, compliance with legal and safety requirements, and real-time resolution of logistical challenges. These services demand personnel with deep expertise in secure air operations, familiarity with ICE’s protocols, and the ability to operate seamlessly across multiple field offices and hubs nationwide.

(b) CSI is the only source capable of providing the servicers required at the level of quality required.

CSI Aviation is the only source capable of meeting these requirements due to its established track record and proprietary systems tailored specifically for ICE Air Operations. CSI’s flight coordinators possess unique qualifications, including:

Extensive experience in secure, large-scale air transportation for government agencies.

Access to specialized, integrated flight tracking and manifest management systems that are interoperable with ICE’s operational platforms.

Personnel trained in ICE-specific security protocols, chain-of-custody procedures, and compliance with sensitive law enforcement requirements.

Ability to deploy dedicated teams nationwide, ensuring continuity and consistency in operations across all ICE field offices and hubs.

Sole Source Justification RFO 8.401(b) (Class Deviation 25-08)

Market research confirms that no other vendor can perform the unique or highly specialized flight coordination requirements with this combination of expertise, systems integration, and operational readiness at this time. Attempting to separate the requirement or introduce a new vendor would compromise the integrity of ICE’s flight operations, introduce unacceptable security risks, and disrupt established processes that are critical to mission success.

Moreover, CSI Aviation is uniquely qualified and prepared to immediately provide the highly specialized logistical support services required under the BPA. The need for dedicated logistical support staff was not originally anticipated; however, increased operational demands now require these services. CSI’s specialized systems and processes are tailored to ICE’s mission requirements and systems for secure and efficient mass air transportation. Deploying CSI teams to ICE field offices and hubs will enhance operational efficiency, leverage existing resources, and reduce administrative burdens on ICE personnel. The requirement aligns with the BPA’s scope, which mandates that CSI provisions all necessary personnel, materials, and services for reliable, safe, and secure transportation.

(c) Details covering what events lead to the situation requiring use of other than full and open competition procedures including whether any portion of the work can be segregated to allow for competition;

ICE Air Operations (IAO) is critical to enforcement and removal operations. The logistical complexity of scheduling flights for individuals in custody requires significant coordination and resources. ICE field offices face challenges due to competing priorities and limited staffing. Adding these services under the existing BPA enables ICE to address operational challenges, streamline processes, and maintain mission effectiveness. No other vendor can provide the highly specialized services at the level of quality required with this combination of expertise, systems integration, and operational readiness.

Separating the work for competition is not feasible, as it could compromise security and disrupt the established flight tracking systems and processes.

(d) Summarize alternatives considered and why they will not work;

No alternative vendor possesses the capability to provide these services with the combination of specialized knowledge and experience that adheres to the security system requirements.

Introducing another vendor at this stage would result in mission delays and increase performance and security risks. Additionally, operational effectiveness and mission readiness would be compromised, and the overall contract costs would increase. No other sources can meet the required level of services at this time. Transitioning to another vendor would require intensive onboarding to obtain the operational capability, knowledge and expertise that CSI already employs.

(e) Impact to the mission that would result if the J&A is not approved and, Sole Source Justification RFO 8.401(b) (Class Deviation 25-08) consequently, the product or service not provided.

Failure to approve this J&A would severely impact ICE’s ability to conduct timely and secure removal operations, increase workload for ICE personnel, and introduce unacceptable risks to mission effectiveness. Only CSI’s specialized flight coordinators can ensure seamless, secure, and efficient operations across all ICE locations.

Transitioning to another vendor would require significant onboarding and knowledge transfer resulting in operational delays and disruption to the continuity of operations.

7. DHS intends to post this requirement on sam.gov in accordance with RFO FAR 8.401(b) and the procedures at GSAR 538.7104-3(b)(3).

Sole Source Justification

RFO FAR 8.401(b) (Class Deviation 25-20)

10. Approval

ALBERT J DAINTON

Digitally signed by ALBERT J DAINTON Date: 2026.07.16 10:03:58 -04'00'

Procuring Activity Advocate for Competition Date

Digitally signed by ALBERT J

ALBERT J DAINTON DAINTON

Date: 2026.07.1610:04:52-04'00'

Head of Contracting Activity Date

U.S. Immigration and Customs Enforcement