Simplified Acquisition Procedures (SAP) JA_Approved_1-27-2023.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

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

PURCHASE REQUEST OR REQUISITION NUMBER

Request for Proposal (RFP) No. 70Z02323Q73110001

PROJECT/TASK

NUMBER

Flood Response Training Services

ESTIMATED AMOUNT (Over Micro-Purchase Threshold, but up to the SAT) $571,806.82

IDENTIFICATION OF THE AGENCY AND THE CONTRACTING OFFICE, AND SPECIFIC

IDENTIFICATION OF THE DOCUMENT AS A “JUSTIFICATION FOR OTHER THAN FULL AND OPEN

COMPETITION.” PLEASE CITE THE AUTHORITY AND TYPE OF JUSTIFICATION.

The Department of Homeland Security, United States Coast Guard (USCG), Office of Contract Operations (CG-912) and Office of Boat Forces (CG-731) prepared this justification for other than full and open competition. Authority: FAR 13.106- 1(b) (Soliciting from a single source).

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE.

The USCG requires contractor technical and administrative support services for a firm fixed price to provide four (4) convenings of a five-day course on flood response in the urban environment. The course objective is to prepare students to utilize response platforms and specialized equipment in the flooded urban environment, flooded waterways and bays, enclosed ports, and any other flood effected area. The vendor must address Awareness, Operations, and technical level job performance requirements in National Fire Protection Association (NFPA) 1006 Chapter 16, 17, and 22. The vendor need not meet the swift-water requirements for Technician Level but should address swift-water awareness to students. Swift -water-rescue is not a USCG mission. Therefore, the Coast Guard generally refrains from training USCG personnel in swift-water rescue except to identify and safely remove themselves from it. (The Coast Guard defines Swift-water as water over two feet in depth, moving through a defined channel that is flowing at a minimum rate of greater than three knots.)

UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON

NO OTHER SUPPLIES OR SERVICES CAN BE USED.

Unique characteristics and circumstances, based on programmatic, curriculum, and training requirements for the Flood Response Course confine supplier availability to one (1) vendor are. Time constraints also function as additional factor.

Although the Coast Guard maintains a designated curriculum outline (which identifies learning objectives to meet program requirements), the service or program lacks established or actual training material itself. Moreover, the Coast Guard lacks designated trainers to deliver this form of instruction. A majority of the providers teach swift-water training. however, this type of training is outside of the Coast Guard’s mission scope and policy. This requirement is unique because the USCG is a Critical Incident Response Rescue Asset and requires training that is specific to their mission. Currently only Spec Rescue International has the capability and is the only known source with established curriculum, training material, and instructional staff to meet Coast Guard programmatic, curriculum, and training requirements.

Furthermore, the USCG must complete this training well before the onset of hurricane season in May 2023. The Coast Guard must also coordinate with the National Guard for the use of the urban training facility on March 26, 2023. The Coast Guard established a formal curriculum outline that is in accordance with the Service’s training system. There is a total of five (5) units of instructions, twenty (20) terminal performance objectives, and one-hundred and twenty-nine (129) enabling objectives to meet Coast Guard program requirements and no other source has those materials.

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).

The USCG issued a Request for Information (RFI) No. 70Z02323I912300002 which was posted on Sam and GSA e-Buy on 11/9/2022 and closed on 12/9/2022. The RFI received only one response from a vendor named Spec Rescue International. In addition, the Coast Guard issued the RFI to 41 Small businesses on GSA e-Buy and received no potential interest.

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

SERVICES.

Based on USCG market research, the Coast Guard intends to issue a sole source contract to Spec Rescue International due to their established curriculum design, development, and implementation of Coast Guard tailored training. Based on the limited responses in engaging industry, there are no other services offering Coast Guard tailored Flood Response Training.

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.

The statutory authority permitting other than full and open competition is 10 U.S.C. § 3204(a)(1) implemented by the FAR 13.106-1(b) entitled “Soliciting from a single source.” This is applicable due to the time sensitive nature of the training needed as well as the reliability of the vendor providing continuity to the USCG Flood Response Program.

PROVIDE A STATEMENT OF ACTIONS, IF ANY, THE GOVERNMENT MAY TAKE TO REMOVE OR

OVERCOME ANY BARRIERS TO COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED.

The USCG intends on developing organic in-house training capabilities prior to this contract’s completion. Under ideal circumstances, this contract will enable the Coast Guard to become self-sufficient, thus obviating the need to contract for these services and reducing USCG costs.

SIGNATURE AND TITLE OF CUSTOMER

Joshua Janney, LT, Contracting Officer's Representative

OFFICE CODE

CG-7312

TELEPHONE NO.

202-372-2458

DATE

SIGNATURE OF CONTRACTING OFFICER

William E. Lewis, Contracting Officer

OFFICE CODE

CG-9123

TELEPHONE NO.

703-850-4153

DATE