USCG JEFO 31574568 APPLEDORE MARINE 70Z04721DAPLEDO00 redacted.pdf

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Justification for Exception to Fair Opportunity (JEFO), Waterfront Design Services for USCG AIRSTA/SECTOR Port Angeles, WA
Solicitation number
31574568
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This is a Justification for an Exception to Fair Opportunity for a task order under an indefinite-delivery indefinite-quantity (IDIQ) contract. The U.S. Coast Guard (USCG), Program Executive Office Shore (CG-SHORE) Office of Contracting (CG-SHORE-C) seeks to award a task order to Appledore Marine Engineering (AME) without considering other awardees under USCG OCEAN A/E IDIQ MATOC contract number 70Z04721DAPLEDO00 for design services related to waterfront facility repairs at Air Station Port Angeles, Washington (PSN 30610173). The task order encompasses Architect-Engineer (A/E) design services including detailed design plans, material specifications, and construction cost estimates for repairs to the pier (RPUID 18018) and Stations Floating Docks 1, 2, and 3, addressing deficiencies identified in inspection reports dated September 2025 and August 2025. The work may be executed as design-build or design-bid-build depending on scope requirements. Services also include environmental regulatory permitting support.

The justification for sole-sourcing to AME is based on FAR 16.505(b)(2)(i)(C) as a logical follow-on to the original task order 70Z08825FESDV0004 awarded January 31, 2025. Key rationales include continuity of expertise (AME conducted the design-level inspection and produced the foundational assessment reports), reduced risk and improved efficiency through avoiding duplication of inspection efforts, and an expedited schedule requirement with funding expiring September 30, 2026. The contracting officer certifies that anticipated costs will be fair and reasonable based on established ceiling rates within the IDIQ contract and sound engineering cost estimating practices. The document is signed by Contracting Officer Guiljohn Alcantara, Technical Representative Rob Tyzzer, and Senior Field Contracting Officer Samantha Watts, all dated November 18-19, 2025.

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2 | P a g e already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

Business Case and Rationale:

Continuity of Expertise: Appledore Marine Engineering (AME) was awarded Task Order 70Z08825FESDV0004 on January 31, 2025, under the USCG OCEAN A/E IDIQ MATOC. A critical component of that task order was a "design level inspection" of the pier, intended to gather sufficient information to produce a repair design. AME has already conducted Repair Design Level Inspection of the pier at Air Station Port Angeles (RPUID 18018) and produced a report entitled Design-Level Inspection & Assessment at USCG Air Station Port Angeles Pier.

Report September 2025. They also conducted Routine Level Inspections of Station Floating Docks 1, 2, and 3, and provided lists of deficiencies and recommended repairs in their report entitled Waterfront Facilities Inspection & Assessment at USCG Air Station Port Angeles August 2025.

AME possesses a deep understanding of the specific deficiencies, challenges, and site conditions at Air Station Port Angeles as a direct result of their prior work. They have already invested time and resources in familiarizing themselves with the infrastructure.

Reduced Risk and Improved Efficiency: Using AME for the follow-on design work significantly reduces the risk of errors, omissions, and delays. A new A/E firm would need to replicate the initial inspection effort, leading to redundant costs and a potential loss of critical information gained during the original inspection. The existing knowledge base allows AME to proceed directly with the design phase, streamlining the process and minimizing potential disruptions.

Expedited Schedule: Funds for the repair of the Pier and floating docks at Station Port Angeles expire on 30 September 2026, allowing very little time for an A/E to perform design of repairs and produce the construction package required to award construction contract. The remaining time before funds expire does not allow for solicitation for A/E services. Should such solicitation occur, Appledore Marine Engineering would likely rate highest amongst respondents, but not enough time would remain to develop construction package and funds would expire, leaving the assets unrepaired and missions impacted due to failing infrastructure.

Logical Extension of Scope: The original task order specifically contemplated future design services as a logical follow-on. The SOW for Task Order 70Z08825FESDV0004 explicitly stated that "Produce plans, material specifications, and detailed construction estimates for repairs to various waterfront facilities. Repair projects may be executed as design-build or design-bid-build, to be determined by the scope of repairs needed. This possible future task is considered logical follow-on work subject to fair opportunity exemption. Such work will be negotiated and awarded as a separate task."

5. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The contracting officer determines that the anticipated price(s) will be fair and reasonable based on the following: Contract No. 70Z04721DAPLEDO00 Appledore Marine Engineering, LLC is an IDIQ Contract under USCG OCEAN A/E IDIQ MATOC all labor rates an fees have ceilings rates that have been determined to be fair and reasonable. The IGE was developed using sound engineering principles and incorporates industry-standard cost estimating practices. Prior to award, a detailed cost analysis will

3 | P a g e be performed to ensure that the proposed costs are within the established ceiling rates and are fair and reasonable in relation to the scope of work.

6. Any other facts supporting the justification.

Awarding this task order to any other contractor would necessitate the duplication of the initial design level inspection, resulting in increased costs, schedule delays, and a potential compromise in the accuracy and completeness of the design. The continuity of expertise provided by AME is essential to ensuring the timely and cost-effective completion of these critical repair projects. AME is uniquely situated to conduct follow-on design due to their knowledge of deficiencies resulting from their inspection, their experience at the project site performing similar repair designs, their knowledge of the project location and experience conducting similar designs and producing construction packages (plans and specifications) for repair of aged wooden piers at multiple locations.

7. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

Future actions will be competed on the USCG OCEAN A/E IDIQ MATOC. The USCG will periodically evaluate its requirements and market conditions to determine if adjustments to the acquisition strategy are necessary to promote greater competition in future procurements. This includes exploring opportunities to break down larger projects into smaller, more manageable task orders that may be more accessible to a wider range of contractors.

8. Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Guiljohn Alcantara Date Contracting Officer

9. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Date

Technical Representative/COR

10. A written determination by the approving official that one of the circumstances in paragraphs FAR 16.505 (b)(2)(1)(A) through (E) applies to the order.

I have reviewed this Justification for an Exception to Fair Opportunity and find it to be accurate and complete to the best of my knowledge and belief.

ALCANTARA.GUILJ

OHN.ANOC.118790

Digitally signed by

ALCANTARA.GUILJOHN.ANOC.

1187903722 Date: 2025.11.19 08:50:05 -08'00'

TYZZER.ROBERT.

ELLIS.1241939797

Digitally signed by

TYZZER.ROBERT.ELLIS.124193

Date: 2025.11.18 15:05:41 -08'00' 11/18/25

11/19/25

4 | P a g e

Samantha Watts Date Senior Field Contracting Officer

WATTS.SAMANTH

A.CHRISTINA.1238

041780

Digitally signed by

WATTS.SAMANTHA.CHRISTINA

.1238041780 Date: 2025.11.19 10:15:34 -08'00' 11/19/25

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