Redacted Signed Justification and Approval for Korea Final.pdf

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

FAR 6.103-1(a) (GSA Class Deviation RFO 2025-06)

OCONUS LOGISTICS SUPPORT SERVICES

INDO-PACOM KOREA

1. AGENCY AND CONTRACTING ACTIVITY:

General Services Administration (GSA) Federal Acquisition Service (FAS) General Supplies and Services (GSS) 1800 F St NW Washington, DC 20405

2. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED:

The statutory authority allowing other than full and open competition is Federal Acquisition Regulation (FAR) 6.103-1(a) (GSA Class Deviation RFO 2025-06), Only one responsible source and no other supplies or services will satisfy agency requirements.

Current Contract: 47QSCC20D0010

Contractor:

LC Industries Inc 4500 Emperor Blvd Durham, NC 27703

As further described below, the action being approved for a single award,sole source, Indefinite- Delivery Indefinite-Quantity (IDIQ) contract that is the follow-on to IDIQ contract 47QSCC20D0010.

47QSCC20D0010 was awarded in August 2020, with a one-year base ordering period and four one-year optional ordering periods. The fourth optional ordering period end date was August 10, 2025. The contract includes clause 52.217-8 which allows for an additional contract extension of up to 6 months.

This optional period of performance has been exercised, and so the current period of performance is now through February 11, 2026. There are no remaining optional periods of performance under this contract.

Under 47QSCC20D0010, LC Industries (“LCI”) is required to provide a total supply chain solution from sourcing, procuring, warehousing, transporting or arranging for transportation and delivery to the customer in the Republic of Korea (ROK). LC Industries is responsible for sourcing and delivering products within 3 business days after receipt of order. LCI is responsible for providing items that conform to the specifications of 829 National Stock Number (NSN) or or Local Stock Number (LSN) items.

The purpose of this J&A is to document justification and gain approval for a follow-on contract with LC Industries. The follow-on contract will have a six-month base period and two three-month options.

The six-month base period of performance is from February 12, 2026, to August 11, 2026. The first three-month optional period of performance would be from August 12, 2026, to November 11, 2026.

The second three-month optional period of performance would be from November 12, 2026, to February 11, 2027 and a 6 month extension period of performance would be August 11, 2027.

3. DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED TO MEET

AGENCY’S NEEDS:

GSA requires LC Industries to provide a total supply chain solution from sourcing, procuring, warehousing, transporting or arranging for transportation and delivery to the customer in the Republic of Korea (ROK) identified in each delivery order (DO) that is placed under the IDIQ. LC Industries is currently performing this requirement under contract 47QSCC20D0010. As stated above, performance under this contract ends on February 11, 2026.

The specific tasks involved in the delivery of supply chain services, which would be required for six months with additional optional performance periods, include the following:

1) Procurement

● a. The procurement of commercially available items, including office supplies, janitorial and sanitation supplies and tools. The contractor shall be responsible for providing items that conform to the specifications of each National Stock Number (NSN). The actual list of products will be dynamic during the life of the contract with additions, modifications and deletions identified by the government that are within the scope of this solicitation. The contractor as well as the government will be allowed to suggest these types of changes, but approval rests with the government.

b. The contractor shall be responsible for sourcing all products so long as the products meet the following requirements:

• Pursuant to the provisions of the Javits-Wagner-O’Day Act, production facilities of the NIB and NISH items marked as AbilityOne are mandatory sources, and the contractor must procure those items from AbilityOne distributors. Pursuant to Federal Acquisition Regulation (FAR) 8.3 (GSA Class Deviation RFO 2025-08), items marked as UNICOR are mandatory sources for the contractor and must procure those items from

UNICOR.

• All other items not identified as AbilityOne must be TAA compliant per Federal Acquisition Regulation (FAR) subpart 25.4. A list of countries with Trade Agreements with the United States is located at: https://ustr.gov/trade-agreements.

2) Transportation

a. Upon the receipt of the DO from GSA, within 3 business days the contractor will deliver all items to the destination identified in the DO. Attachment 1 - NSN List, identifies forecasted volumes in the INDO-PACOM Korean theatre.

b. The contractor must meet the installation security requirements listed as Security Considerations in this solicitation.

c. The contractor will be responsible for fulfilling the DO generated by the GSA Order Management Services system (OMS). All proposals must show that the contractor is compliant with the Electronic Data Interchange (EDI) requirements of GSA. Each DO will show the specific item, quantity, and delivery requirements for that order.

d. Consolidation of orders is allowed as long as the delivery time standard for all items in the shipment will be met. Additionally, consolidated shipments must only be consolidated to the end user customer as identified in the “Mark For” data field of the DO.

e. Packaging, Packing, Marking, and Labeling. The contractor shall be responsible for the creation and application of supply and shipping documentation, shipping labels, and package markings meeting customer requirements. The Contracting Officer Representative (COR) will ensure that all goods received conform to applicable regulations as well as agency requirements related to documentation, packaging, packing, marking and labeling. The primary references for this are:

• Defense Standard Practice for Military Packaging (MIL- STD-2073)

• Department of Defense Standard for Military Marking for Shipment and Storage (MIL-STD-129).

f. Dangerous Goods/Hazardous Materials. The contractor shall be responsible for compliance with all dangerous goods/hazardous materials regulations. This will include certification, documentation, packing, packaging, marking and labeling.

g. Customs. All customs processes will be the responsibility of the contractor.

h. Vendor Portal (VP) and Electronic Data Interchange (EDI) Requirements The contractor will be responsible for establishing EDI interfaces with GSA as the primary method for transmission of data associated with conducting business with GSA. The ability to provide order tracking that includes in-transit visibility up to the point of delivery is the desired end-state.

The Government is in the process of recompeting this requirement using full-and-open competition. As of the date of this J&A, the Request for Proposal for the competition has been published on SAM.gov, under solicitation number 47QSCC25R0023. The RFP had a proposal submission deadline of 16 September. However, due to negotiations and amendments issued after the initial solicitation period, the submission deadline was extended to December 8, 2025.

The follow-on contract for which this J&A is seeking approval will allow for an uninterrupted continuation of the services provided under this contract while the recompete is ongoing. It is anticipated that additional time will be needed to complete the award process, but also because the awardee needs 120 days to ramp up for performance. Therefore, the contract must be awarded at least 120 days before the end of the current period of contract performance. Based on the current end date of February 11, 2026, the competition would have needed to be awarded by October 14, 2025. The RFP states that the contractor will have 120 days from notice by the Government that ordering will be available. The additional six months will allow sufficient time for a potentially new contractor to complete its ramp up, thus leveling the playing field, as opposed to changing the requirement to allow less ramp up time, which could mean that only the current contractor would be able to compete. In addition to FAR 52.217-9, Option to Extend the Term of the Contract, this contract will also include FAR 52.217-8, Option to Extend Services. The purpose of including this clause is in case there are unforeseen delays in awarding the competitive contract, such as lengthy protests, then the Government would have the option to extend services under this contract to avoid a break in service.

If a follow-on contract is not awarded, then there is a risk of interruption of supply chain services to our customers. The ROK AOR requirement has proven to be an important supply chain option for federal and DoD customers overseas, and an interruption would mean that customers would no longer have this supply source and would significantly increase customers’ wait and delivery times which could lead to delays impacting missions. Currently supplies are delivered within 3 business days.

Customers have steadily come to rely on the ROK AOR option for their supply needs. The sales so far under the contract are as follows (purchase order total):

8/1/2020-7/31/2021

Purchase Order Total: 2,948,002.03

Number of Orders: 9,732

8/1/2021-7/31/2022

Purchase Order Total: 6,670,861.56

Number of Orders: 15,990

8/1/2022-7/31/2023

Purchase Order Total: 6,957,917.26

Number of Orders: 14,357

8/1/2023-7/31/2024

Purchase Order Total: 8,553,496

Number of Orders: 14,132

8/1/2024-7/31/2025

Purchase Order Total: 7,173,799.03

Number of Orders: 10,230

Loss of this support will severely impact GSA’s ability to successfully deliver supplies to the customer in 3 business days per the contract's requirements. Any interruption of service would negatively impact the ability of customers to purchase key items to support their military operations and supply chains.

4. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION:

The statutory authority permitting other than full and open competition is FAR 6.103-1(a) (GSA Class Deviation RFO 2025-06). GSA has determined there is only one responsible source and no other source will satisfy agency requirements. Specifically, the basis for other than full and open competition is that the minimum need can only be satisfied by one supplier with unique capabilities in accordance with FAR 6.103-1(a) (GSA Class Deviation RFO 2025-06).

5. SUPPORTING INFORMATION THAT THE CONTRACTOR’S UNIQUE

QUALIFICATIONS REQUIRES THE USE OF ONLY ONE RESPONSIBLE

SOURCE AUTHORITY:

LC Industries (LCI) represents the sole responsible source currently capable of providing critical supply chain support for the Republic of Korea (ROK) Area of Responsibility (AOR) during the upcoming contract transition period. With an established and comprehensive infrastructure spanning the Korean peninsula, LCI possesses unparalleled institutional knowledge and operational capabilities that make them uniquely qualified to meet the complex logistical requirements of the U.S. military's regional supply chain.

The company's deep-rooted expertise is evident in its current full operational capability within the ROK AOR, maintaining a sophisticated supply network that encompasses approximately 829 National Stock Number (NSN) items, with nearly half sourced from mandatory suppliers like AbilityOne and UNICOR.

LCI has meticulously developed delivery logistics for hundreds of military and federal installations across the region, navigating the intricate challenges of cross-border supply management and demonstrating an exceptional understanding of location-specific delivery requirements.

LCI's logistical prowess extends beyond mere inventory management. The company has strategically positioned warehousing, established robust import/export capabilities, and developed comprehensive systems for managing overseas shipments while strictly adhering to MARAD regulations. This level of operational sophistication ensures seamless, uninterrupted supply chain support during the critical six-month bridge period, mitigating potential risks associated with contract transition.

The complexity of supporting military logistics in the ROK AOR cannot be overstated. LCI has proven its ability to immediately respond to increased governmental supply demands, maintaining a flexible and responsive supply chain that can adapt to rapidly changing operational needs. Their preexisting infrastructure, combined with deep regional expertise, positions them as the only contractor capable of providing the specialized, comprehensive support required during this transitional period.

By selecting LC Industries as the sole source, the Government can ensure continuous, reliable, and efficient supply chain management without disrupting critical military logistics. LCI's unique combination of regional knowledge, established infrastructure, and operational flexibility makes them the most appropriate and responsible choice for maintaining uninterrupted support to U.S. military operations in the Republic of Korea.

6. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE

SOLICITED FROM AS MANY SOURCES AS PRACTICABLE:

As mentioned, GSA is actively working to compete this requirement. Interest received from industry for this requirement appears to be high. However, successfully competing this new requirement and ramping up a new contract with full 120-day notice would not be possible within this time frame.

Additionally, customer orders could be placed at risk if the new competed requirement goes live at the end of the fiscal year, due to systems concerns. However, ample competition is expected during the new requirement currently being solicited under 47QSCC25R0023, and a competitive award is anticipated to be made.

7. DETERMINATION THAT THE ANTICIPATED COST TO THE

GOVERNMENT WILL BE FAIR AND REASONABLE:

An Independent Government Cost Estimate (IGCE) was developed for this requirement. Market research was performed using market pricing found on GSA Advantage and in the open market for CONUS delivery. Markup was then added to account for overseas warehousing, logistics, and delivery to bases overseas. The estimated price was then multiplied by the average demand under the current INDO-PACOM Korea contract for Fiscal Years (FYs) 2025 and 2026. The IGCE breakdown for this requirement is as follows:

Base Period (6 months): $3,758,315.03 Option Period (OP) 1 (3 months): $1,916,740.67 OP2 (3 months): $1,955,075.48 6 month extension under FAR 52.217-8: $3,910,150.96 Total anticipated value: $11,540,282.14 Requested Contract Ceiling: $15,000,000.00

The current Independent Government Cost Estimate (IGCE) is $11.5M, which is based on market information including GSA Advantage and knowledge of additional costs required for OCONUS warehousing and other associated expenses. This IGCE has been validated through comparison with current pricing under the LCI contract, confirming alignment with expected negotiation outcomes.

However, this justification requests approval for a ceiling value of $15M. This higher ceiling amount provides necessary flexibility to accommodate potential surges in requirements that may arise during the period of performance. By establishing a $15M ceiling at this stage, we can avoid the need for subsequent amendments to the justification or Acquisition Plan should requirements exceed the baseline IGCE of $11.5M. This approach ensures operational continuity and reduces administrative burden while maintaining appropriate oversight and control mechanisms. Prior to award, the Contracting Officer will evaluate the proposed pricing and will ensure that the contract being awarded under this justification is fair and reasonable.

8. DESCRIPTION OF MARKET RESEARCH CONDUCTED:

Market research for the new requirement was conducted, including Sources Sought notice 47QSCC240023. The Government received multiple responses to the Sources Sought notice and determined that ample competition is expected under 47QSCC25R0023. The competition is full-and-open. The requirement under 47QSCC25R0023 is very similar to the requirement currently in place in ROK AOR as well as in the Pacific region, including Japan, Korea, Guam, and Hawaii, and other locations. Based on other forms of market research related to those requirements currently in place (i.e. technical knowledge of individuals within the Government regarding similar requirements that have recently been implemented), it has been determined that a new contractor who is not currently performing the contract would need approximately 120 days to fully ramp up after a new follow-on contract is awarded.

9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND

OPEN COMPETITION:

None.

10. LIST OF SOURCES EXPRESSING WRITTEN INTEREST IN THIS

ACQUISITION, IF ANY:

No other known sources are available or have expressed written interest that can immediately meet this requirement.

11. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO

REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE

MAKING ANY SUBSEQUENT ACQUISITION FOR THE SUPPLIES OR

SERVICES REQUIRED:

As described above GSA is actively recompeting this requirement. Ample competition is expected.

12. APPROVALS

WRITTEN BY:

Ghulam Khan Contract Specialist (QA1HA)

Valeriya Orlova Date Contracting Officer Internal Acquisitions Branch (QSCBB)

TECHNICAL REQUIREMENTS PERSONNEL CERTIFICATION:

I hereby certify that any supporting data (e.g. verifying the Government’s minimum needs or scheduled requirements or other rationale for other than full and open competition), which form a basis for this justification, are complete and accurate.

Roger Nioko Date Program Manager Office of Supply Chain Management (SCM) GSA FAS General Supplies and Services (GSS)

CONTRACTING OFFICER CERTIFICATION:

By signing this justification the Contracting Officer certifies that the facts and statements made are accurate and complete.

Katie Champion Date Contracting Officer Special Contracting Branch B/Internal Acquisitions Branch (QSCBB) Special and Assisted Contracting Division (QSCB) Office of Contract Operations (QSC) GSA FAS Office of General Supplies & Services (GSS)

APPROVALS:

Andres Almazan Date Branch Chief, Special Contracting Branch B (QSCBB) Special and Assisted Contracting Division (QSCB)

Douglas Schmidt Date Operational Guidance Branch SME

Stephen Smith Date Director, Special and Assisted Contracting Division (QSCB)

Ryan Schrank Date Contracting Executive

COMPETITION ADVOCATE

Janet Schweer Date Competition Advocate

APPROVAL AUTHORITY CERTIFICATION

I, the approving authority, determine that the circumstances identified in this document are accurate; therefore, limiting competition under FAR 6.103-1(a) (GSA Class Deviation RFO 2025-06) is justified. The signature below also represents approval of this Justification and Approval.

I certify to the accuracy and completeness of this justification to the best of my knowledge.

Ryan Schrank Date Acting Contracting Executive (QSC), Delegated HCA Authority