Sole Source Justification - NVDC - FE_Redacted.pdf

international trade and may be subject to detention by foreign Port State Control authorities or refusal of entry into port.

4. Identification of Statutory Exception and Rationale.

The statutory exception is GSAR 538.7104-3(b) The circumstances of the acquisition deems only one source reasonably capable of providing the products, services, or solutions.

The National Vessel Documentation Center (NVDC) requires continued administrative support services for the processing of U.S. Flag Vessel . circumstances of this acquisition deem the incumbent contractor as the only source reasonably capable of providing these services without causing an unacceptable disruption to the U.S. commercial shipping industry. The current Task Order expires on September 26, 2026, and the NVDC is currently in the process of redefining the requirements for this program, including better aligning with Mission Management System (MMS) documentation updates, Government Furnished Property (GFP) constraints, and certifications for security compliance. It is currently anticipated that the requirements will be updated on or around August-September 2026.

During this critical transition period, uninterrupted CSR processing is vital. The execution of this effort relies heavily on institutional knowledge of the underlying maritime ss processes. The incumbent contractor possesses this unique historical continuity and operational expertise, which is required to maintain the current high level of efficiency and effectiveness while the Government finalizes the redefined requirements.

Attempting to transition these services to a new contractor at this juncture is impractical.

Any other contractor would be forced to undergo a steep learning curve to acquire the necessary institutional knowledge and gain a thorough understanding of the CSR workflows within a compressed timeframe. Furthermore, it is not in the Government's best interest to subject a new vendor to this process, only to immediately disrupt their operations with the changes resulting from the requirements being redefined.

A gap in service or a degradation in processing efficiency would be extremely detrimental.

Because CSRs are internationally mandated and vital to the operational legality of the U.S.

commercial shipping industry, any delay or failure in processing directly impacts the global supply chain and maritime commerce. Utilizing a source other than the incumbent during this transition would result in an unacceptable gap in service, a severe loss of processing efficiency during the learning phase, and an unjustifiable duplication of time and administrative costs associated with onboarding a new Contractor. Said start-up costs, transition costs, and developmental and training costs if a new Contractor were brought on board would be cost prohibitive and would result in substantial duplication of cost to the Government that is not expected to be recovered through competition via a short-term Task Order as the requirements are subject to change soon. Furthermore, it would introduce an unacceptable risk of not providing adequate services to the commercial shipping industry during the interim period. DWBH, LLC is the only vendor capable of providing these services during this transition period.

To ensure that the follow-on Contract will have as many potential sources as possible, an APFS record will be generated for the 2027 competitive recompete to ensure the contractor industry has the most up-to-date information available. The Government intends the follow-on Contract to be solicited as competitively as possible.

5. Demonstration of the to Provide the Requirement.

The current Task Order supporting the National Vessel Documentation Center (NVDC) Continuous Synopsis Record (CSR) program expires on September 26, 2026. The unforeseen circumstances beyond our control that created the need for an extension of services are two-fold: (1)

(2) delays as a result of the unprecedented and historic Government shutdowns in FY2026.

The current Task Order expires on September 26, 2026, and the NVDC is currently in the process of redefining the requirements for this program. Additionally, the unprecedented Government shutdown resulted in suspension of critical operations and communications within the program office, delays in approvals and reviews, and significant disruption of the scheduled procurement timeline. This additional time will provide Contracting with ample time to redefine their requirements, mitigate risks associated with the procurement, and properly issue a competitive solicitation and execute an award.