A02 JA for K-ROC_Redacted_SAM.pdf

Control Number: 26-025

JUNE 2025

JUSTIFICATION REVIEW DOCUMENT

FAR Part 12 Justification and Approval

Simplified Procedures for Certain Commercial Items

Program/Equipment: Lodging and Meal Services for the Korea Readiness Orientation Course (K-ROC), Eighth Army G-3 Engineer, at Yongsan Garrison, Seoul.

Authority: Title 41 United States Code (U.S.C.) §1901(e)(2) as implemented in Federal Acquisition Regulation (FAR) 12.102 Restricting competition & SAP FAR 13.501(A)(2) under the authority of the simplified procedures for certain commercial items.

Amount: $6.5 million.

Prepared by: CPT YE SUK KIM

G3 EN Plans Officer Date: 14 APR 26

Contracting Officer: MICHAEL West Contracting Officer Date: 27 APR 26 michael.l.west8.civ@army.mil

Technical / CPT YE SUK KIM Requirements: G3 EN Plans Officer Date: 14 APR 26

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Legal Counsel:

SCOTT A. LILLIE

Attorney Advisor (Civilian) Date reviewed: 27 APR 26

b. Market research has determined that no other commercial lodging provider can offer the necessary combination of a secure, access-controlled perimeter and close proximity to key mission activities, such as the War Memorial of Korea. Off-post providers are unable to meet these essential security and logistical needs. Awarding this requirement to any other source would result in unacceptable operational delays and potential security vulnerabilities. Therefore, the use of sole-source procedures is justified to ensure uninterrupted support for the K-ROC mission.

c. Alternatives:

1) Use of Off-Post Commercial Hotels: This was deemed unacceptable. It would introduce significant security risks by dispersing personnel and would make timely group transportation logistically unfeasible due to traffic and installation gate procedures.

2) Use of In-House Resources (Barracks): Existing barracks have been uninhabitable and unmaintained. They are uninhabitable and require significant renovation. There are also no dining facilities located on USAG- Yongsan other than Dragon Hill Lodge.

3) Conducting a Competitive Acquisition: This is not viable, as market research conclusively shows only one source can meet the mandatory on-installation performance location.

d. Impact if not approved: Disapproval would force the program to rely on ad-hoc, inefficient methods, place an undue administrative and financial burden on individual Service Members via the DTS system, and introduce significant logistical and security risks that would jeopardize the program's mission and schedule.

7. Efforts to Obtain Competition: Efforts to obtain competition for this requirement were limited due to the unique and restrictive need for secure, on-installation lodging and meal services at Yongsan Garrison. Market research confirmed that Dragon Hill Lodge (DHL) is the only source capable of meeting the Government’s minimum needs.

No other commercial lodging provider in the area can offer the required combination of secure, access-controlled accommodation and proximity to mission activities.

Given the unique location and mission requirements, no action can be taken to increase competition for this specific acquisition. Should circumstances change in the future, the Government will reevaluate the market to identify any new potential sources.

8. Actions to Increase Competition: The primary barrier to competition is the unalterable geographical requirement for performance on Yongsan Garrison. This barrier cannot be overcome unless another commercial entity is permitted to operate a hotel on the installation, which is not feasible. No actions can be taken to increase competition for this specific requirement in the future. However, the Government will continue to monitor the local market to see if other secure on-post facilities are built.

9. Market Research: In accordance with FAR Part 10, market research consisted of a comprehensive review of the local commercial market to determine the availability of services that could meet the Government’s mandatory minimum requirements. We checked websites such as Agoda, Expedia, etc. This included a geographical, logistical, and security-based screening of commercial lodging facilities in the greater Seoul area in proximity to Yongsan Garrison. The market intelligence confirmed that DHL is the only facility physically located within the secure, access-controlled perimeter of the military installation. Because strict adherence to Force Protection protocols, physical security, and personnel accountability are unalterable minimum requirements for the K- ROC mission, no off-post commercial hotel can safely or logistically satisfy the agency's needs. Therefore, this physical security constraint is the single most critical and restrictive factor, definitively concluding that DHL is the only responsible source capable of fulfilling this requirement.

10. Interested Sources: This requirement was not publicized due to the sole source determination. As a result, no other sources have expressed interest or submitted capability statements for this acquisition.

11. Other Facts: This is a new requirement; therefore, there is no procurement history.

A key fact supporting this justification is that the Dragon Hill Lodge is a Non- Appropriated Fund Instrumentality (NAFI) of the U.S. Army, created to support U.S.

personnel in Korea. Its inherent experience with military group reservations and on-post operations further mitigates performance risk and makes it uniquely qualified.

12. Technical/Requirements Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

CPT YE SUK KIM

G3 EN Plans Officer

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price/cost to the Government for this contract action is fair and reasonable.

This determination is based on a comprehensive price analysis of Dragon Hill Lodge’s (DHL) proposal, which includes significant discounts for food services, particularly breakfast and lunch. The current commercial rate for breakfast at DHL is $23.59 per person for a buffet-style meal, which does not include coffee. For this requirement, DHL has agreed to a discounted rate of $10.00 per person for soldiers, with coffee and water

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer