Redacted Justification and Approval FAR 6.103_WRAM.pdf

System (MTS) components. This effort will incorporate all major strategic ports and waterways, leveraging machine learning techniques to scale the existing model to encompass the wider MTS. The work will also include the development of extensible, repeatable risk-reduction prototypes, accompanied by a user-friendly visualization platform and interface for end users.

3. Description of Supplies/Services.

The requirement is for technical and analytical support to expand the Waterways Risk

Assessment Model (WRAM) analysis methodology and codebase from a proof of concept to a full prototype that will include all major strategic ports and waterways of the

MTS. This includes data integration, training of machine learning models and submodels, output validation, risk model refinement, documentation updates, stakeholder engagement, and support for tool use during the initial pilot period.

4. Identification of Statutory Authority Permitting Other Than Full and Open

Competition.

(a) The statutory authority permitting other than full and open competition is 10

U.S.C. 3204(a)(1) as implemented by FAR Subpart 6.103-1 (FAR Class

Deviation 25-11) entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Identification of Exception to the Buy American Act.

(a) Not Applicable: This J&A does not include the exception listed under FAR

25.103(b)(2) or FAR 25.202(a)(2) as the procurement will utilize only domestic end products and/or construction materials in compliance with the Buy American

Statute.

6. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Require Use of the Authority Cited.

The proposed sole-source contract with MITRE Corporation is justified under the authority of 10 U.S.C. 3204(a)(1) as implemented by FAR 6.103-1 ("Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements") because MITRE possesses unique qualifications and capabilities that are essential for maintaining the continuity and effectiveness of the WRAM.

(a) Rationale for using the authority cited in section 4 of the J&A:

a. This authority is invoked because MITRE is the only source capable of providing the required support services without incurring unacceptable risks and delays.

This prototyping involves training and customizing a machine learning model and code base which requires understanding of the subject matter expert input, the analysis methodology, and the underlying information technology framework from a strict USCG perspective. MITRE is not just familiar with WRAM; they are currently developing it. Shifting to a second contractor would cause significant delays in attaining the same level of understanding necessary for a swift execution.

(b) 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:

a. This requirement stems from the USCG's ongoing need to respond efficiently to evolving threats, increasing vessel traffic, and emerging technologies present in the

MTS. The U.S. Coast Guard NAVCEN require the use of other than full and open competition due to the expiration of the DHS S&T FFRDC Single Award IDIQ and MITRE identified as the only source capable of meeting the requirement.

b. The USCG has determined that no portion of the required work can be segregated into separate contracts to allow for competition. Fragmenting these tasks would lead to inefficiencies, communication breakdowns, and a loss of overall system coherence. The specialized knowledge of the WRAM system and relationships within the USCG also makes it impossible to have multiple contractors work on different aspects of the requirement.

(c) Summarize alternatives considered and why they will not work: N/A

(d) Impact to the mission that would result if the J&A is not approved and, consequently, the product or service not provided:

a. Disruption of Critical Risk Assessment Capabilities: The USCG would lose an asset, the need for which is supported by the efforts of the Board of Inquiry into the Francis Scott Keyes Bridge incident, to effectively assess and mitigate risks within the MTS, potentially leading to increased marine casualties, injury to persons, and economic loss throughout the MTS.

b. Increased Risk to Maritime Safety and Security: Without the WRAM, the

USCG would be less able to follow the intent behind Presidential Executive Order

Restoring America’s Maritime Dominance to proactively identify and address emerging threats, putting maritime safety and security at risk.

c. Delayed Implementation of Key USCG Initiatives: The WRAM is essential for supporting several key USCG initiatives, waterway management planning and resource allocation decisions.

(e) Not Applicable: This J&A does not include the exception listed under FAR 25.103(b)(2) or FAR 25.202(a)(2).

(f) Additional Details for "Only One Responsible Source":

a. Why Only MITRE is Capable: Only MITRE, possesses the combination of specialized subject matter expertise in science and technology development, an in-depth knowledge of WRAM architecture, modeling tools, access and understanding of the historical data, and established relationships with USCG stakeholders necessary to meet these requirements effectively.

b. Unique Capabilities/Qualifications of MITRE: MITRE's unique qualifications include: (1) its role as the original developer of the WRAM proof of concept and analytic methodology; (2) its possession of specialized modeling experts and data scientists as a 501(c)3 specializing in science and technology; (3) its deep understanding of the USCG's operational environment; and (4) its established relationships with USCG analysts and decision-makers.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential

Sources as is Practicable.

Presolicitation Notice 70Z02325RNAV10001 has been published on SAM.gov on August 14, 2025, to ensure offers are solicited from as many potential sources as practicable.

8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The Contracting Officer determines that the anticipated price(s) will be fair and reasonable based on a comparison of proposed prices to the current Task Order 70Z02325F9124000 and comparison of proposed prices with the Independent Government Cost Estimate

(IGCE) which leverages validated labor rates from Homeland Security Systems Engineering and Development Institute (HSSEDI) Indefinite Delivery/ Indefinite Quantity (IDIQ) contract

70RSAT20D00000001.

9. Description of Market Research.

Market research as prescribed in FAR Part 10 was conducted from May 2025 through August

2025, to identify contractors with the requisite expertise in and familiarity with USCG mission, systems and databases. Mandatory search of the USCG/DHS Strategic Sourcing

Vehicle(s) and GSA Federal Supply Schedule(s) did not yield any sources capable of meeting the requirement. Furthermore, market research was conducted through other means, including the review of historical contract data, Dynamic Small Business Search

(DSBS), reviewing industry databases, relevant past performance records, and Sam.gov interested vendors list, which did not produce any sources. The Contracting Officer determined that sufficient information was obtained and therefore a separate Sources Sought Notice was not published. However, a presolicitation notice was published to allow industry to provide their capabilities for meeting the requirement. The results concluded that the incumbent MITRE is the only source uniquely positioned to fulfill this requirement.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

(a) Unsuitability of Technical Data Packages, Specifications, or Statements of Work for Full and Open Competition:

a. A full technical data package cannot be assembled until the current development efforts in DHS’s Technical Execution Plan TEP 43-24-0272 and Task Order

70Z02325F9124000 are concluded September 30, 2025, respectively, meaning other contractors would not be able to provide an accurate estimate. Furthermore, even with a comprehensive data package, a new contractor would still face a significant learning curve to fully understand the WRAM analysis methodology, the many datasets involved, the necessary next steps, and the government perspective on maritime waterways risk. This would inevitably lead to increased costs, delays, and a higher risk of errors.

(b) Inability to Modify Requirement to Enhance Competition:

a. The requirement cannot be modified to enhance competition without fundamentally altering the nature of the task and accepting unacceptable risks.

Dividing the work into smaller, more easily competed tasks is not feasible. The tasks of data integration, model refinement, documentation updates, and stakeholder engagement are all tightly intertwined and require a holistic understanding of the WRAM.

11. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the

Acquisition.

(a) Presolicitation notice was released on SAM.gov August 14, 2025, requesting that parties express their interest in writing to the contracting officer. The incumbent, The MITRE Corporation, is the only entity that expressed interest in the acquisition. No other sources have expressed any interest in the proposed acquisition, despite this outreach effort.

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome

Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or

Services Required.

(a) Data Rights Assessment: The USCG will conduct a thorough review of existing data rights associated with WRAM, specifically focusing on the potential for acquiring or negotiating broader rights to emphasize open-source solutions and enable future competitive opportunities for future expansions.

This will include identifying any data or algorithms that are essential to

WRAM’s functionality and exploring options for developing alternative solutions.

(b) Market Research and Outreach: The USCG will conduct ongoing market research to identify potential new vendors with expertise in maritime risk assessment, data analytics, and machine learning. This will include attending industry conferences, review vendor capabilities statements, and engaging with potential suppliers through Small Business events. The USCG will also actively communicate its future requirements to the industry to encourage new entrants.