(SAP) Justification for Other than Full and Open Competition 071223 signed.pdf

March 8, 2023 Version

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIMPLIFIED ACQUISITION PROCEDURES (SAP) FAR 13.106-1(b)

SOLICITATIONS MAY BE LIMITED TO ONE SOURCE ONLY IF THE CONTRACTING OFFICER DETERMINES THAT ONLY ONE SOURCE IS REASONABLY AVAILABLE. THIS DETERMINATION MUST BE SUPPORTED WITH FULL JUSTIFICATION FOR SOLE SOURCE FROM THE CUSTOMER. WHEN THE CUSTOMER DESCRIBES AN ITEM WITH A PURCHASE DESCRIPTION WHICH LIMITS THE AVAILABILITY TO ONE SOURCE, THE JUSTIFICATION MUST EXPLAIN WHY THE ITEM IS THE ONLY ONE THAT WILL MEET THE GOVERNMENT’S REQUIREMENT. STATEMENTS SUCH AS "ONLY KNOWN SOURCE" OR "ONLY SOURCE WHICH CAN MEET THE REQUIRED DELIVERY DATE" ARE INADEQUATE TO

SUPPORT A SOLE SOURCE PURCHASE.

PURCHASE REQUEST OR REQUISITION

NUMBER

20150PR230025712

PROJECT/TASK

NUMBER

ESTIMATED AMOUNT (Over Micro- Purchase Threshold, but up to the SAT)

239,986.00

CITE AUTHORITY & JUSTIFICATION TYPE – READ FAR 6.302 TO DETERMINE APPROPRIATE TYPE

10 U.S.C. § 3204(a)(1)

ONLY ONE RESPONSIBLE SOURCE AND NO OTHER SUPPLIES OR SERVICES WILL SATISFY

AGENCY REQUIREMENTS.

☐ 10 U.S.C. § 3204(a)(2) UNUSUAL AND COMPELLING URGENCY

10 U.S.C. § 3204(a)(3)

INDUSTRIAL MOBILIZATION; ENGINEERING, DEVELOPMENTAL, OR RESEARCH CAPABILITY; OR

EXPERT SERVICES

☐ 10 U.S.C. § 3204(a)(4) INTERNATIONAL AGREEMENT

☐ 10 U.S.C. § 3204(a)(5) AUTHORIZED OR REQUIRED BY STATUTE

☐ 10 U.S.C. § 3204(a)(6) NATIONAL SECURITY

☐ 10 U.S.C. § 3204(a)(7) PUBLIC INTEREST [SECRETARY OF HOMELAND SECURITY NEEDS TO APPROVE THIS DOC]

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE. The Contractor shall provide aviation grade fuels, JP-5, JP-4, JP-8 (MIL-T-5624), or commercial equivalents. Jet A, Jet A-1, and Jet B (ASTM D-1655) shall be the primary type of aviation fuel provided under this contract. JET A: Jet A is a commercial grade of fuel that meets the specifications of ASTM-D1655. It is very similar to JP-5, except that it has a lower flash point of approximately 100 °F compared to the 140 °F flash point for JP-5. Jet A can be used as a replacement when JP-5 is not readily available. JET A-1: Jet A-1 is a commercial grade of fuel that meets the requirements of ASTMD1655. It is very similar to JP-8 and has the same flash point and freezing point. Its NATO code is F-35. Jet A-1 can be used as a replacement when JP-8 is not readily available. JET B: Jet B is a commercial grade of fuel that meets the requirements of ASTM-D6615. It is very similar to JP-4 and has the same flash point and freezing point. Jet B can be used as a replacement when JP-4 is not readily available. It does not have a NATO code number. The Contractor shall also provide Low Sulfur Diesel Fuel (<500PPM or better) and 87 Octane gasoline for vehicles.

UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON NO OTHER

SUPPLIES OR SERVICES CAN BE USED.

Morton Bahamas Limited located in Matthew Town is the only known contractor that has the capabilities to barge and store bulk amounts of aviation fuel, diesel fuel and gasoline on the island. These fuels are needed to sustain their fleet while maintaining day-to-day operational functions. Strategic Sources were checked to determine if there was a vehicle in place for the procurement of these fuels, however, although there are vehicles for these fuel procurements for other locations, there are none available for Great Inagua, Bahamas. As a result of both location and storage issues, the strategic sourcing vehicles do not apply.

A DESCRIPTION OF EFFORTS MADE TO ENSURE THAT QUOTATIONS OR OFFERS ARE SOLICITED FROM AS MANY

POTENTIAL SOURCES AS PRACTICABLE (INCLUDE YOUR MARKET RESEARCH EFFORTS HERE).

A Sources Sought Notice was posted to Contract Opportunities on https://www.SAM.gov with only one (1) vendor providing inquiry, Lucayan Technology Solutions, LLC. After additional research was conducted into the responding vendor, it was found that the responsive vendor had no previous experience providing the fuel required in this procurement nor did they have the means or access to the USCG location to deliver the fuel to the Air Station. As a result, the vendor, Lucayan Technology Solutions, LLC was disqualified as a potential source of supply, leaving only Morton Bahamas Limited as the only source of supply for the fuel required for this contract. Given the lack of other responses to the Sources Sought Notice, inability of any other vendors to provide the fuel or have access to deliver the fuel in this remote location in Great Inagua Island, Bahamas, no portion of the work may be segregated to allow for competition. Morton Bahamas Limited is the only source of supply capable of providing and delivering the fuel at this remote location.

REASON THAT SUGGESTED SOURCE IS THE ONLY SOURCE WHICH CAN PROVIDE THE SUPPLIES OR SERVICES.

Because Great Inagua, Bahamas is located in a remote area, only Morton Bahamas Limited has the capabilities available to barge in Jet A aviation, diesel and gasoline fuels. Morton Bahamas Limited is the only known contractor on the island that can supply the demand of fuel required by the FOB on a daily basis.

https://www.acquisition.gov/far/part-6#FAR_6_302 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204

March 8, 2023 Version

EXPLAIN WHY AN ADEQUATE PURCHASE DESCRIPTION OR OTHER INFORMATION SUITABLE TO SOLICIT BY FULL AND OPEN COMPETITION HAS NOT BEEN DEVELOPED OR ARE NOT AVAILABLE. Air Station Clearwater operates two (2) aviation facilities in the Bahamas, one (1) at Great Inagua and the other at the U.S. Navy’s Autec installation at Andros Island. Morton Bahamas Limited is the only known source available at Matthew Town, Inagua. Should Air Station Clearwater be unable to obtain fuel via Morton Bahamas Limited, the next nearest location to obtain fuel would be the Island of Providenciales, which is 92 miles away and takes approximately 1.5 hours per round trip. In order to access this location, Air Station Clearwater would require the use of an HH-60 aircraft. This trip alone would cost roughly $18,000.00 ($12k/hour X 1.5 hours). Another alternative would be to fly an AC-130 from Clearwater, Florida to the Great Inagua Island. An AC-130 costs approximately $15k/hour to operate at 6 hours per round trip, which equates to approximately $90k/trip. While this is another option, it would be counterproductive. Additionally, Great Inagua Island does not have any landing signal lights, so a fixed-wing aircraft (like a C-130) cannot land there without sunlight. Operations run 24/7/365 out of Great Inagua Island, consequently, neither of the two (2) options would be considered cost effective; rather, the USCG would waste a significant amount of resources, hours and money. Additionally, considering the current economy and inflation these prices would be substantially more dependent upon the actual days and times that the flights were taking place. Considering both of these scenarios, there are no economically responsible alternatives that may be considered at this time since Morton Bahamas Limited is the only available source located in Matthew Town, Great Inagua, Bahamas

PROVIDE A STATEMENT OF ACTIONS, IF ANY, THE GOVERNMENT MAY TAKE TO REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED. COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED.

Morton Bahamas Limited is currently the only available source of supply capable of providing the various types of fuel outlined in this justification. Every reasonable effort will be made to remove barriers to competition for future requirements. These efforts will include continuing to identify additional sources that may be capable of providing these types of fuel or alternative methods of delivering these types of fuel to Great Inagua Island, Bahamas. Additionally, the USCG will continue to conduct research into Strategic Sourcing vehicles as well as to determine if the DLA MOA becomes available in more remote locations, to include the Bahamas.

SIGNATURE AND TITLE OF CUSTOMER

CODE

TELEPHONE

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE

SK1 727-535-1507 12JUL2023