Limited Competition - Brand Name Justification.pdf

Justification for Other Than Full and Open Competition

Justification for Other Than Full and Open Competition (JOFOC) - Brand Name Justification drafted in accordance with RFO FAR 6.104, RFO FAR 12.102(c), and DFARS 206.104-70.

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

BRAND NAME JUSTIFICATION

Pursuant to 10 U.S.C. 3204(a)(1) as implemented by RFO FAR 6.104 — Brand Name

Descriptions

1.0 IDENTIFICATION OF THE AGENCY AND CONTRACTING ACTIVITY

• Requiring Activity: Arkansas Army National Guard (AR ARNG) Marksmanship Training

Unit

• Contracting Activity: United States Property and Fiscal Officer Arkansas Purchasing and

Contracting Division

• Document Identifier: W912JF26QA012

2.0 NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

This action is a new Firm-Fixed-Price (FFP) contract action for the acquisition of commercial off-the-shelf (COTS) Heckler & Koch Defense No. 50253805 H&K upper receiver kit and

51000150 handguard sets. Contracting on a brand-name-restricted basis is necessary to satisfy the Government’s minimum operational requirements.

3.0 DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED

The Government requires ten (10) Heckler & Koch Defense No. 50253805 H&K upper receiver kit and 51000150 handguard sets. Estimated Total Value: $40,000.00

Period of Performance / Delivery: Within 180 Days After Receipt of Order (ARO)

Funding Type: Operations & Maintenance (O&M)

4.0 STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION

• Statutory Authority: 10 U.S.C. 3204(a)(1) (formerly 10 U.S.C. 2304(c)(1)), implemented by RFO FAR 6.103-1— "Only One Responsible Source and No Other Supplies or

Services Will Satisfy Agency Requirements — Brand Name Descriptions."

5.0 DEMONSTRATION THAT THE PROPOSED CONTRACTOR'S UNIQUE

QUALIFICATIONS OR NATURE OF THE ACQUISITION REQUIRES USE OF THE

AUTHORITY CITED

Market research indicates that only Heckler & Koch Defense Inc. possesses the unique engineering architecture, patented mechanisms, and physical form factors required to satisfy the operational mission profile.

Specifically: Heckler & Koch Defense Inc. is the sole manufacturer of the proprietary SDMR parts; however, they sell these military components through authorized defense distributors.

Platform Compatibility:

The AR-ARNG actively operates the H&K M110A1 Squad Designated Marksman Rifle

(SDMR) system. The upper receiver and handguard assemblies are critical spare parts required to maintain operational readiness at the National Guard Marksmanship Training Center at Camp

Robinson. Attempting to utilize third-party, commercial-off-the-shelf AR-10 upper receivers or non-OEM handguards will result in a complete mechanical mismatch. The HK417 upper receiver has proprietary pin dimensions and bolt carrier group travel channels that are incompatible with standard mil-spec M4 or commercial AR-10 lower receivers.

Gas System Tolerances

The M110A1 SDMR utilizes a proprietary short-stroke gas piston system. The tolerances of the gas block seating and piston alignment are specifically milled into the H&K upper receiver barrel interface. Non-OEM components will cause incorrect gas-port alignment, resulting in gas blowback, cycling failures, accelerated parts wear, or catastrophic receiver failure during live-fire operations.

Accuracy Standard Preservation

The M110A1 SDMR is designed to maintain a 1.5 MOA (Minute of Angle) accuracy standard

[12]. The handguard complete with proprietary mounting screws (Ident-No. 51000150) is specifically designed to float the barrel and maintain harmonic stability. Alternate commercial handguards do not utilize the proprietary barrel-nut mounting geometry of the HK417, which would degrade the rifle's precision-fire capability at combat distances (300 to 600+ meters).

Technical Data Rights

Heckler & Koch Defense Inc. maintains exclusive proprietary data rights for the

HK417/M110A1 design, technical drawings, and manufacturing tolerances. No commercial competitor possesses the Technical Data Package (TDP). The Government does not own the technical data rights. Re-engineering or testing alternative designs would require extensive, cost-prohibitive laboratory validation and safety certifications.

6.0 EFFORTS TO OBTAIN COMPETITION & MARKET RESEARCH SUMMARY

Pursuant to FAR Part 10, the Government conducted extensive market research in September

2026, which included:

1. Direct inquiry with the OEM: Heckler & Koch Defense Inc.

2. Web searches and historical contracting databases (SAM.gov).

Heckler & Koch Defense Inc. is the sole manufacturer of the proprietary SDMR parts; however, they sell these military components through authorized defense distributors. Multiple authorized defense distributors possess active dealer agreements with H&K Defense. Brand-name limited competition is achievable among these authorized small business vendors.

7.0 DETERMINATION OF FAIR AND REASONABLE COST

In accordance with RFO FAR 12.204(a), the Contracting Officer will ensure that the final price paid by the Government is fair and reasonable. Price reasonableness will be established via:

1. Competition among authorized Contractors.

8.0 ACTIONS TO OVERCOME COMPETITION BARRIERS FOR FUTURE

PROCUREMENTS

The Government will continue to monitor the market for compatible open-architecture small arms systems; however, as long as the proprietary M110A1 SDMR remains the primary fielded marksman platform, the purchase of OEM parts remains a technical necessity.

9.0 TECHNICAL AND REQUIREMENTS PERSONNEL CERTIFICATION

I certify that the supporting data under my cognizance which forms the basis for this justification is complete and accurate to the best of my knowledge and belief.

Technical / Operational Point of Contact:

Mackenzie Smith, CPT, Logistics Management Specialist

ARARNG NGMTC

Signature: _Mackenzie Smith__________________________ Date: ______________

10.0 CONTRACTING OFFICER CERTIFICATION

In accordance with RFO FAR 6.104-2, I certify that this justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer:

Ralph Grinnell

USPFO-AR P&C

Signature: _Ralph Grinnell__________________________ Date: ______________

10.0 CHIEF OF CONTRACTING OFFICE CERTIFICATION

In accordance with RFO FAR 6.104-2, I certify that this justification is accurate and complete to the best of my knowledge and belief.

Chief of the Contracting Office:

Mark White

USPFO-AR P&C

Signature: _Mark White__________________________ Date: ______________