Starboard_Sole Source Justification_ss redacted (26-446).pdf

Version 2.0 19Aug2020

SINGLE SOURCE DETERMINATION USING

SIMPLIFIED ACQUISITION PROCEDURES (SAP)

FOR AN ACTION NOT EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: 12.102(a) and 41 USC 1901)

PR# 143011-26-0164

1. Agency and contracting activity. Department of Commerce, Fisheries OMB Field Delegates and

National Marine Fisheries Service (NMFS), Office of Law Enforcement (OLE), Pacific Islands Division (PID)

2. Description of supplies or services required to meet agency needs (including the estimated value).

The NOAA OLE Pacific Islands Division (PID) requires a web-based, satellite and terrestrial Automatic Identification System (AIS) data analysis application service. This subscription will provide three (3) concurrent-user accounts with uncompromised, wide-breadth satellite AIS data showing real-time and historical positions of U.S. and foreign commercial fishing vessels.

• Intended Use: This application is mission-critical for remote tracking, compliance analysis, and detecting illicit maritime activity, such as dark-vessel behaviors, illegal transshipments, and Exclusive Economic Zone (EEZ) boundary incursions, to detect, investigate, and counter Illegal, Unreported, and Unregulated (IUU) fishing.

• Period of Performance / Delivery: Access must be active within one (1) calendar week of contract award. The service must include access to not less than 3 years of historical vessel position data.

• Estimated Value: $75,000

• Contract Type: Firm-Fixed-Price (Subscription Service)

3. Identification of the single source or the brand name to be solicited.

Vendor Name: Starboard Maritime Intelligence Limited c/o NORTHWEST REGISTERED AGENT SERVICE 8 The Green Suite Suite A Dover, DE 19901 Unique Entity Identifier (UEI): ZA59BMNSBL29 Contact Info: Mat Brown (mat.brown@starboardintelligence.com)

4. Supporting rationale. Only one source or brand name is reasonably available as detailed below:

□ Exclusive Licensing Agreement/Restrictive Rights/Authorized Reseller - The source has one or more of the following: an established exclusive licensing agreement, proprietary data, limited rights in data, patent rights, OEM required certifications or OEM authorized reseller, copyrights or secret processes with regard to the supplies or services required.

Only the Starboard Maritime Intelligence web application is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

Supporting Narrative & Unique Qualifications: While multiple commercial vendors provide general-purpose maritime AIS tracking data, Starboard Maritime Intelligence is the only specialized web-based platform built from the ground up to support the international, multilateral counter-IUU fishing (IUUF) in the Pacific.

• Mandated International Interoperability: Under the SAFE Act and the U.S.

Interagency Working Group on IUU Fishing 5-Year Strategy, OLE PID is required to execute a whole-of-government approach and coordinate enforcement with regional partners. Starboard is uniquely designed to integrate directly with the systems used by major regional fisheries management bodies, specifically the Western and Central Pacific Fisheries Commission (WCPFC) and the Pacific Islands Forum Fisheries Agency

(FFA).

• Alignment with Regional Joint Operations: Starboard is the designated AIS analyst tool of the FFA. It utilizes exact data formatting, standards, and export functionalities that seamlessly cross-verify against the FFA's Regional Surveillance Picture (RSP) and registry compliance tracking datasets. No other software natively aligns with these regional threat vectors.

• Actionable Mission Collaboration: PID analysts routinely support and collaborate with the FFA’s Regional Fisheries Surveillance Center (RFSC) and joint U.S. Coast Guard/Shiprider missions. Because Starboard is already utilized by the USCG, JIATF- West, and the FFA, it provides a common IUUF operating picture across the Pacific.

This allows PID to seamlessly generate and share actionable intelligence regarding high-risk "dark" vessel behavior and unsanctioned high-seas transshipments.

Mission Impact if Not Approved: If forced to procure a standard, general-purpose commercial maritime tool, NOAA OLE PID will lose its technical compatibility with key international defense and enforcement partners. Technicians will be unable to readily export or correlate data within multinational joint operations windows, creating critical blind spots during high-seas enforcement operations and directly degrading the agency's ability to successfully investigate and prosecute sensitive international fisheries cases.

5. Market Research.

Market research was conducted by PID personnel who have actively tested, demoed, or utilized all primary maritime surveillance tools in this space. Three major U.S. Small Business schedule holders were evaluated:

1. Kpler Inc. (Marine Traffic Enterprise): Evaluated at ~$25,000/year for 5 licenses. While cost-effective, it is a general-purpose tool that lacks native integrations (such as EO/IR or RF overlays) and features no tailoring for the counter-IUUF mission or regional partner frameworks.

It cannot meet the international interoperability requirements of the PID.

2. Windward US Inc.: Evaluated as an excellent AI-driven maritime analysis tool containing the required AIS feeds. However, it is not tailored to regional partner frameworks or joint Pacific operations. Furthermore, it is cost-prohibitive at approximately $90,000 per single license (~$270,000 for the required three concurrent-user seats), making it financially unviable.

3. Starboard Maritime Intelligence: Priced at $75,000 for three licenses. It possesses identical core AIS tracking data as competitors but stands alone as a highly specialized, mission-tailored platform that natively meets all international interoperability, Class B priority filters, and partner-sharing capabilities required by the government.

6. Technical/Requirements Representative Certification

I certify that this requirement constitutes the Government’s minimum needs and the supporting data provided herein is accurate and complete to the best of my knowledge and belief.

_____________________________________ __6/25/2026_________ Sylvia Scott Date Budget Analyst, NOAA OLE

7. Determination I hereby determine that the circumstances of this action deem only one source is reasonably available. This determination is accurate and complete to the best of my knowledge and belief.

Heather Mahle Date Contracting Officer