Description
The Department of Homeland Security, United States Coast Guard (USCG), Office of Contract Operations (CG-912) proposes to enter into a contract on a basis other than full and open competition. (a) Nature of the action: Installed Fire Fighting Regulation 4 Certification (b) Name of vendor: Cass Fire Protection LLC. (c) Type of action: Fixed Price Service (d) Estimated total value (including options): $99,900.00USD Identification of Statutory Authority Permitting Other Than Full and Open Competition. (a) This justification authorizes and approves the use of other than full and open competition to issue a firm-fixed-price purchase order to Cass Fire Protection for the comprehensive inspection, testing, and certification of fire alarm and suppression systems. This action is critical to ensure compliance with state law and to protect life and property at Coast Guard Base Los Angeles Long Beach. (b) The services required include a complete, end-to-end inspection and functional test of all fire alarm, detection, and suppression systems across the base (c) The scope of work has the following critical and non-negotiable requirements: i. The inspection and testing must be performed in direct coordination with the Los Angeles Fire Department (LAFD), as mandated by California State Law. ii. The outcome must be a full certification demonstrating the systems are compliant with all applicable state and federal regulations for the 2026 operational year. iii. Work must commence immediately upon award to ensure completion and fund obligation before the expiration of the current Continuing Resolution (CR) on January 31, 2026. Statutory Authority Permitting Other Than Full and Open Competition: 10 U.S.C. 2304(c)(2) as implemented by Federal Acquisition Regulation (FAR) 6.302-2, Unusual and Compelling Urgency. (e) This J&A also presents facts and rationale that align with the circumstances described in FAR 6.302-1 , Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements, which further solidifies the case for a sole-source award. (f) Demonstration that the Use of the Cited Authority is Required: The use of other than full and open competition is essential, as the U.S. Government would be exposed to serious injury—both in terms of safety and legal compliance—if this requirement is not executed immediately. A standard competitive procurement process is not feasible. (g) Unusual and Compelling Urgency (Primary Justification per FAR 6.302-2): Unacceptable Safety and Legal Risk: The fire systems at Coast Guard Base Los Angeles Long Beach are not yet certified for 2026. This is a violation of California state statute, which legally mandates this inspection be performed in conjunction with the LAFD. A lapse in certification creates an unacceptable risk to the lives of Coast Guard personnel, civilian employees, and visitors, and exposes mission-critical federal property to catastrophic damage in the event of a fire. (h) Impending and Unavoidable Deadlines: The current Continuing Resolution (CR) and its associated funding for this critical safety requirement will expire on Saturday, January 31, 2026. Furthermore, the threat of a government shutdown requires an award to be made before this date. The time required to prepare a competitive solicitation, allow for proposal submission, conduct evaluations, and make an award would far exceed the time available, leading to the loss of critical funds and a failure to meet the legally mandated safety compliance. The urgency is a direct result of these external circumstances, not a lack of advance planning. (i) Only One Responsible Source (Supporting Justification per FAR 6.302-1): Unique In-Depth Knowledge: The proposed contractor Cass Fire Protection possesses extensive and highly specialized knowledge of the fire systems at Base LA LB. They have performed previous maintenance and inspections, granting them an unparalleled understanding of the system's unique architecture, complexities, and interdependencies. (j) Elimination of Unacceptable Delays: A new contractor would face a significant and time-consuming learning curve to familiarize themselves with the base's intricate systems. This would involve extensive site discovery and documentation review, introducing delays that are unacceptable given the imminent CR expiration. Cass Fire Protection can begin substantive work immediately, which is crucial for meeting the deadline. (k) Required LAFD Coordination: The mandatory coordination with the LA Fire Department is complex. Cass Fire Protection has experience navigating this specific inter-agency process for this specific location, which is critical to achieving a timely and successful certification. A new vendor would struggle to establish this rapport and workflow under extreme pressure. (l) Description of Efforts Made to Solicit Offers from as Many Sources as Practicable: Due to the unusual and compelling urgency described in Section 5, there was no time to solicit offers from other sources. A public synopsis of this requirement under FAR 5.202(a)(2) was deemed infeasible as it would prevent the agency from meeting the critical deadlines, resulting in serious injury to the Government. (m) Determination by the Contracting Officer that the Anticipated Cost will be Fair and Reasonable: The Contracting Officer will determine that the anticipated cost is fair and reasonable. This determination will be made by comparing the proposed price with the Independent Government Cost Estimate (IGCE) and analyzing the historical pricing for similar services provided to the government. (n) Description of the Market Research Conducted: Market research was limited due to the extreme urgency. However, past experience and knowledge of the marketplace confirm that very few vendors, if any, could mobilize and execute this specific, complex requirement in coordination with the LAFD within the severely compressed timeframe. Research confirms that Cass Fire Protection as the requisite unique knowledge and immediate capability. The confluence of three distinct factors makes this situation unique: (1) a non-negotiable legal requirement for safety compliance, (2) an absolute deadline for the expiration of funds under a CR, and (3) an impending potential government shutdown. The combination of these factors creates an unprecedented level of urgency that necessitates a sole-source award to the only vendor capable of mitigating these risks simultaneously. A Statement of the Actions the Agency May Take to Remove or Overcome any Barriers to Competition: This J&A is for a one-time, urgent requirement. The underlying cause of the compressed timeline is the timing of the CR. For future requirements of this nature, the requiring activity will ensure that procurement planning begins with sufficient lead time to permit full and open competition. Future routine maintenance and inspection services will be competed.