REDACT_E2FOM_RCC 1N_APPROVED_Redacted.pdf

Exception to Fair Opportunity Template Update MAY 2026

JUSTIFICATION for an EXCEPTION to FAIR OPPORTUNITY for the placement of an order over the micro purchase threshold (MPT) under a Multiple Award Contract (MAC)

Upon the basis of the following justification, as a Contracting Officer of Southwest Regional Maintenance Center (SWRMC), I hereby approve the Justification for an Exception to Fair Opportunity Pursuant to RFO FAR 16.507-6.

JUSTIFICATION

l. Agency and Contracting Activity. Department of the Navy, Southwest Regional Maintenance Center.

2. Nature/Description of Action. This is a fair opportunity exception to place an order with prospective Multiple Award Contract (MAC) holder under LCS SEC WEST PT. III MAC number N00024-25-D-4219, Standard Ship Repair (Standard). The Delivery Order Number is N5523626F8061 for the USS

CHARLESTON (LCS-18) FY26 CONTINUOUS MAINTENANCE AVAILABILITY (CMAV) A6A1;

SSP: TPPC-LCS18-SWRMC26-S001.

3. Description of Supplies/Services. Work Item #573-11-001 RCC 1N has been created to fix and repair the Platform Lift Assembly. The estimated value of this work is based on the Independent Government Estimate (IGE) from the SWRMC Project Manager. Funding will be FY26 OM&N D8 in support of the Category 3 Casualty Report (CAT 3 CASREP) repairs. The availability schedule is

. The Government's minimum needs have been verified by the certifying technical and requirements personnel.

4. Identification of the Exception to Fair Opportunity. (RFO FAR 16.507-6(a))

Identification/Justification for Exception:

a. The agency need for services is of such urgency that providing fair opportunity would result in unacceptable delays.

The emergent requirement to fix and repair the Platform Lift Assembly (Work Item 573-11-001; RCC 1N) represents a critical and time-sensitive need that directly impacts the fundamental operational capabilities and safety of the USS CHARLESTON (LCS-18). This deficiency involves severe mechanical and structural degradation of the platform lift, signaling an imminent failure of the hoist, guide, and safety locking mechanisms. This is not a minor discrepancy; it is a critical material failure that compromises the ship's internal material handling, aviation support, and mission package deployment systems, presenting an untenable risk to both the crew and the vessel itself. Without immediate intervention, the ship's force cannot safely operate the lift, effectively halting the movement of critical cargo, ordnance, and support equipment between decks.

The loss of the Platform Lift Assembly catastrophically degrades the vessel's multi-mission execution capabilities, a core design attribute of the Independence-class (Independence-variant) Littoral Combat Ship platform. The ship's ability to rapidly load, stow, and deploy mission packages, transit ordnance to the flight deck or mission bay, and conduct sustained aviation or surface warfare operations would be severely impeded. This degradation places the ship well below its minimum operational "redlines" for cargo handling and combat systems readiness. Operating in such a compromised state, particularly during underway exercises and certification events, would violate established safety protocols and introduce an unacceptable level of risk to personnel working on or near the lift. Furthermore, the mechanical instability of the lift platform presents a significant secondary hazard, creating a dangerous crush and fall environment for crew members, which mandates immediate corrective action.

This mechanical failure creates a direct and immediate negative impact on the ship's demanding operational and training schedule. The vessel's ability to get underway is entirely jeopardized by this deficiency. This is not a simple scheduling inconvenience; the upcoming availability window and subsequent underway periods are critical gateways for pre-deployment certifications. Failure to execute this training means the crew cannot be certified in essential mission areas, directly rendering the ship not mission-ready for its scheduled deployment. The cascading effect of this single material failure is immense, threatening a significant gap in fleet operational availability and undermining the Navy's strategic force posture during its upcoming deployment cycle.

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.

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.

A thorough review and analysis, with regard to price and scope, of the pricing information provided by Standard 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 Standard, in accordance with RFO FAR 15.404-1(b)(3). 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 Standard that is available, as well as similar work accomplished by other contractors. This analysis will be accomplished in conjunction with comparison of all proposed labor hours and material by the PT with verification by the Contracting Officer.

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 CHARLESTON (LCS-18) 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 a Category 3 CASREP. The issue was not identified during prior inspections and only came to light when the ship's crew uncovered the deficiencies immediately after the Systems Operational Test (SOT) III concluded on . 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 critical maintenance work in order to meet and support the USS CHARLESTON (LCS-18) 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.