Simplified Acquisition Procedures (SAP) Justification for Other than Full and Open Competition Template for FAR 12.102(a) Commer.pdf

Last Updated 03/03/2026

U.S. COAST GUARD JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

COMMERCIAL PRODUCTS AND SERVICES AT OR BELOW THE SAT

FAR 12.102(a), FAR Class Deviation 25-21 Rev. 1 for FAR Part 12 PURCHASE REQUEST OR REQUISITION NUMBER: ESTIMATED TOTAL VALUE, INCLUDING OPTIONS:

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

AUTHORITY JUSTIFICATION TYPE

Restricting Competition FAR 12.102(a), FAR Class Deviation 25-21 Rev. 1 for FAR Part 12

☐ Only One Source Is Available (e.g., urgency, exclusive licensing agreements, or industrial mobilization).

☐ Brand Name - Items peculiar to one manufacturer: The particular brand name, product, or feature is essential to the Government’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s needs

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED AND THE INTENDED USE:

SUGGESTED SOURCE NAME, ADDRESS, & UNIQUE ENTITY IDENTIFIER (UEI):

RATIONALE FOR JUSTIFICATION TYPE SELECTED ABOVE TO INCLUDE RELEVANT INFORMATION GAINED

THROUGH YOUR MARKET RESEARCH TO SUPPORT THE JUSTIFICATION TYPE:

CONTRACTING OFFICER - FAIR AND REASONABLE PRICE DETERMINATION METHODS:

☐ MARKET RESEARCH

☐ COMPARISON OF PROPOSED PRICE WITH PRICES FOUND REASONABLE ON PREVIOUS PURCHASES

☐ CURRENT PRICE LIST

☐ COMPARISON WITH SIMILAR ITEMS IN A RELATED INDUSTRY

☐ COMPARISON TO IGCE

☐ CONTRACTING OFFICER’S PERSONAL KNOWLEDGE (EXPLAIN)

☐ OTHER (EXPLAIN)

SIGNATURE AND TITLE OF TECHNICAL AND REQUIREMENTS POC DATE

SIGNATURE OF CONTRACTING OFFICER DATE

https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-12#FAR_12_102 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-12#FAR_12_102 Bryan Duffey Highlight

Bryan Duffey Highlight

Bryan Duffey Highlight

Bryan Duffey Highlight

Bryan Duffey Highlight

Bryan Duffey Highlight

Bryan Duffey Highlight

TGonzalez2 Underline

TGonzalez2 Cross-Out

EIN: 98-0581542; DUNS:

RATIONALE FOR JUSTIFICATION TYPE SELECTED ABOVE TO INCLUDE RELEVANT INFORMATION GAINED THROUGH YOUR MARKET RESEARCH TO SUPPORT THE JUSTIFICATION TYPE Statements like Only known source or Only source which can meet the required delivery date are inadequate and marketing language like This company has made its mark This company is recognized as industrys best and This company is the leader in is unacceptable: MARIN has developed the HSM system installed, and the associated data analysis process, on the BERTHOLF and STRATTON used by the USCG for hull structural evaluations including structural fatigue budget; therefore, MARIN is uniquely qualified to support quality assurance visits, maintenance, and data analysis for the WMSL cutters needed to fulfill the objectives of the project. No other source has the knowledge to reproduce or conduct the required services; furthermore identifying, qualifying, and implementing a new system creates an undue cost burden on the Coast Guard, cutter schedules and would result in the incompatibility with historical data compiled using proprietary analysis.

MARIN still has the specific knowledge, validated fatigue life analysis tools, and Finite Element Models of the WMSLs required to continue support on project for the USCG as required by the SOW. It would take another company significant time and expense to duplicate the five-year FLAP effort.; therefore, a purchase description cannot be written to overcome this for this effort.