Most of the poorly written J&As I've seen in contract file audits have been those written and approved solely by a lazy contracting officer, and often they also fail to publicize the J&A. J&As that are reviewed and approved by multiple higher-graded contracting/legal personnel (in this case, two GS-14s and a GS-15) are typically not so poorly written and justified. You have to keep in mind, too, that this probably went through some kind of policy review prior to the CoCO or competition advocate reviews. It reflects poorly on an entire contracting organization as opposed to one CO.