Sole Source Justification.pdf

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Attached to
Rubb Shelter Inspections
Solicitation number
W50S77-26-Q-0001
Issued by

About this file

This is a Memorandum for Record documenting an absence of competition determination for a sole-source contract award. The Texas Air National Guard's 147th Attack Wing, through its 147th Aircraft Maintenance Squadron (AMXS), intends to sole-source aircraft shelter inspection services to Rubb Inc. at an estimated contract value of $18,242. The requirement is for bi-annual inspections of aircraft shelters located on the Ellington Field flight line, with inspections also required after exposure to high winds or snow loads approaching design limits. The contractor must provide all necessary management, tools, supplies, equipment, and labor to perform and maintain inspections. The contract will be structured as a new firm fixed-price agreement funded under O&M (Operations and Maintenance) appropriations.

The contracting officer, BUDDY L. CIEMIENGO, MSgt, TXANG, justifies the sole-source determination under 41 USC 1901 as implemented in FAR 13.106-1(b)(1), citing that Rubb Inc. is the sole source producer and service vendor for the installed aircraft shelters. The justification emphasizes that the equipment and technical information are proprietary to the OEM, Rubb only sells directly to end users without authorized resellers, and warranty protection requires that repairs, inspections, and maintenance be performed exclusively by Rubb or warranty coverage will be voided. Market research confirmed that no competing manufacturers can satisfy this requirement, and increasing competition would require installing entirely new aircraft shelters throughout the installation, which the government determined to be unreasonable. No prior procurement history exists for this requirement, and no posting requirements are mandated for this sole-source award. The point of contact is Miguel Jimenez.

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TEXAS AIR NATIONAL GUARD

HEADQUARTERS 147TH ATTACK WING (ACC)

Houston, Texas 77034

11 Feb 2026

MEMORANDUM FOR RECORD

SUBJECT: ABSENCE OF COMPETITION

1. Contracting Information:

A. Contracting Office: 147th Attack Wing

B. Requiring Activity: 147th AMXS

C. POC: Miguel Jimenez

2. Action:

A. Nature of Action: Only one source.

B. Contract Action: New Contract

C. Contract Type: Firm Fixed Price

D. Fund Type: O&M

3. Estimated total price of request: $18,242

4. Name of Requirement

A. Aircraft Shelter Inspection

B. Description of Requirement:

The 147th ATKW, Texas Air National Guard, intends to sole source the services to inspect the Aircraft Shelters located on the Ellington Field flight line. The contractor shall provide all management, tools, supplies, equipment, and labor necessary to operate and maintain the required inspections. Structures are designed to require a minimal amount of maintenance over the life of the structures. The inspection should be performed bi-annually or after the structures are exposed to high winds or snow loads close to the designed limit of the structure.

C. Demonstrate, in detail, why this specific item or service is the only one that meets your requirement:

The 147th ATKW, Texas Air National Guard, intends to sole source the inspections as the current assets were purchased from Rubb Inc. and must be repaired, inspected, and maintained by the company to ensure the warranty for the shelters stays intact. Work by any other vendor would void any warranty for the shelters. FAR 13.106-1(b)(1) soliciting from one responsible source.

5. Has this been previously procured?

NO

6. Authority Cited:

41 USC 1901 as implemented in FAR 13.106-1(b)(1) Soliciting from a single source.

A. Reason for Authority Cited:

Rubb Inc. is the sole source producer and service vendor for the current aircraft shelters in place.

The equipment and technical information in proprietary in nature and specific only to the OEM.

Rubb only sells to direct end users and does not sell their products through distribution channels.

Additionally, Rubb is the only aircraft shelter installed at the 147th ATKW. As such competing this requirement on the open market is not reasonable.

7. Posting Requirements:

None

8. Contracting Requirements

A. Efforts to Obtain Competition

Market research confirmed the result of the proprietary nature, only Rubb can inspect the existing aircraft shelter system. This equipment has unique and complimentary capabilities that cannot be satisfied by other manufacturers. There are zero authorized resellers for Rubb.

B. Actions to Increase Competition

In order to increase competition, the government would have to install an entire new aircraft shelters throughout the installation, which would not be reasonable to the government.

BUDDY L. CIEMIENGO, MSgt, TXANG Contracting Officer

2026-02-18T10:11:05-0600
CIEMIENGO.BUDDY.LEE.1383947711

File details come from the government source that posted it. Updated .