A05_Sole_Source_Determination.pdf

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ASU E3 Night Vision Goggles
Solicitation number
1240LP26Q0095
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Sole Source Justification Summary

This is a Sole Source Justification document from the USDA Forest Service, Pacific Southwest Region, for the procurement of four (4) aviation night vision goggles (NVGs) certified to FAA TSO-C164a standards. The requirement specifies goggles with a 40-degree field of view, tilt and interpupillary adjustment, an objective lens focus range of 15 centimeters to infinity, and green or white phosphor imagery operating from an external battery pack. The critical distinguishing feature is that the goggles must preserve the wearer's unaided peripheral vision with a front-mounted diopter adjustment that does not obstruct the peripheral field—a safety-of-flight requirement for low-level night operations near towers, wires, and other aircraft. The suggested source is Aviation Specialties Unlimited Inc. (HYJBYG322PJ9, Small Business/Woman-Owned Small Business), offering the Element 3 (E3) Lightweight Aviation Night Vision Goggle, part number E31001W-1T. The requisition number is 1171441, PSC 5855, and Solicitation Number 1240LP26Q0095. The estimated value does not exceed the simplified acquisition threshold, and no written justification approval under FAR 6.104 is required.

The justification identifies two mandatory safety-of-flight requirements that eliminate competition: (1) retained unaided peripheral field of view, since LED obstruction and position lighting cannot be detected through NVG optical filters and must be seen via peripheral vision, and (2) compatibility with the fielded battery pack and mount inventory to enable in-flight goggle exchanges during failures. Market research conducted April 6, 2026, by technical staff including the Region's Helicopter Inspector Pilot found that all competing products, including those from L3Harris Technologies, utilize the ANVIS-9 configuration with the diopter focus ring located at the rear of the assembly, obstructing approximately 20 percent of the peripheral field. The E3 uniquely relocates the diopter ring to the front, preserving the peripheral field, and this physical design cannot be remedied through modification or alternate sourcing. The manufacturer confirmed exclusive manufacture, sale, and distribution domestically by letter dated April 3, 2026, and no U.S. distributor or reseller exists. A Notice of Intent to Award will be published at the Governmentwide Point of Entry for 15 days before award, with capability statements subject to evaluation and potential reconsideration of this determination.

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PUBLIC POSTING COPY — estimated value removed Page 1 of 3 Rev. 07/29/26

United States Department of Agriculture Sole Source Justification

In accordance with Federal Acquisition Regulation (FAR) 12.102(a), this document records the Contracting Officer’s determination that only one source is available to satisfy this requirement, and the basis for that determination. The acquisition is for commercial products valued above the micro-purchase threshold and at or below the simplified acquisition threshold established at FAR 2.101; a written justification approved under FAR

6.104 is not required.

(1) Mission Area and Contracting Activity.

Requesting Activity: USDA Forest Service, Pacific Southwest Region • Contracting Activity: PAST C4 Requisition Number: 1171441 • PSC: 5855 Solicitation Number: 1240LP26Q0095

(2) Estimated Value

Withheld from public posting. The estimated value is documented in the contract file and does not exceed the simplified acquisition threshold established at FAR 2.101.

(3) Brief Description of Supplies or Services

Four (4) aviation night vision goggles certified to FAA TSO-C164a, with a 40-degree field of view, tilt and interpupillary adjustment, an objective lens focus range of 15 cm to infinity, a green or white phosphor image, and operation from an external battery pack.

The goggle must also preserve the wearer’s unaided peripheral vision. Given the Program’s low-level night operations near towers, wires, and other aircraft, maximum retained peripheral vision around the goggle is a mission-essential safety characteristic, and a front-mounted diopter adjustment that does not obstruct the wearer’s peripheral field is required.

(4) Suggested Source

Aviation Specialties Unlimited Inc., 4632 West Aeronca St., Boise, Idaho 83705 Element 3 (E3) Lightweight Aviation Night Vision Goggle, part number E31001W-1T Small Business, Woman-Owned Small Business • UEI: HYJBYG322PJ9

(5) Justification for Restricting Competition and the Basis for that Decision.

A. Why no other product or source meets the Government's need.

The Program has two minimum requirements that any offered goggle must meet. Both are safety-of-flight requirements, not preferences or enhancements.

Requirement 1 — Retained unaided peripheral field of view. The optical filters required on all aviation night vision goggles to prevent gain-down and shutdown eliminate the goggle's ability to display LED light sources.

Obstruction lighting on towers and aircraft position lighting have both transitioned to LED. Those hazards cannot be seen through the goggle and can only be detected by the pilot's unaided peripheral vision around it. Unaided peripheral vision is therefore the Program's sole means of detecting that entire class of hazard, and any obstruction of that field constitutes a direct flight hazard.

Requirement 2 — Compatibility with the fielded battery pack and mount inventory. Program aircrew must be able to perform an in-flight goggle exchange in the event of a goggle failure, which requires that the replacement goggle operate on the battery pack and mount already installed on the aircrew helmet. A goggle requiring a separate battery pack or mount cannot be exchanged in flight and leaves the crew unaided for the remainder of the flight. This capability is a mandatory salient characteristic of the requirement.

Why the ANVIS-9 configuration cannot meet Requirement 1. Every goggle built in the ANVIS-9 configuration

— regardless of manufacturer or vendor — locates the diopter focus ring at the rear of the assembly, adjacent to the wearer's face, where it obstructs approximately 20 percent of the unaided peripheral field. The E3 relocates

Page 2 of 3 Rev. 07/29/26 the diopter ring to the front of the assembly, leaving the peripheral field unobstructed. This is a function of the physical design of the configuration and cannot be remedied through modification, alternate sourcing, or a different production lot. Market research confirms no other goggle available to the Government provides an unobstructed unaided peripheral field while meeting the Program's remaining requirements.

Scope of this determination. The determination rests solely on the two requirements stated above. The E3 and the currently fielded Gen 3 AN/AVS-9 use the same image intensifier tube, and the Government does not assert that the E3 is technically superior in image performance or any other respect. Continued standardization with the Program's existing helmet mounts, battery packs, and 180-day contracted maintenance plan supports this determination and avoids additional costs in mount acquisition and installation costs, but is not an independent basis for it. This determination does not rest on a lack of advance planning or on the absence of adequate specifications.

B. Market research conducted and the results.

Market research was conducted on 4/6/2026 by program and technical staff, principally the Region’s Helicopter Inspector Pilot, an NVG Certified Flight Instructor and the Region’s principal NVG flight evaluation pilot. CalFire aviation personnel were interviewed in March 2026.

Mandatory and priority sources were searched with negative results: USDA inventory, agency excess property, Federal Prison Industries, the AbilityOne Procurement List, USDA-wide contracts, and GSA Advantage!/eLibrary.

The suggested source holds no Federal Supply Schedule contract covering the item; this is an open-market acquisition.

Market research identified no aviation night vision goggle other than the E3 that preserves the wearer’s unaided peripheral field. All other products identified, including certified goggles offered by L3Harris Technologies, retain the ANVIS-9 frame configuration with the diopter focus ring at the rear of the assembly. Each was evaluated against the requirement described in paragraph A and found technically unacceptable. No modification would relocate the diopter assembly without redesigning the goggle.

The Government separately determined that the required item has no United States distributor or reseller. The Helicopter Inspector Pilot found on 6/10/2026 that it is available domestically only from the manufacturer, the manufacturer confirmed exclusive manufacture, sale, and distribution by letter dated 4/3/2026. Because a single domestic source exists, an acquisition permitting competition among resellers of the same product is not available.

A Notice of Intent to Award a Sole Source will be published at the Governmentwide Point of Entry for 15 days before award. Any capability statement received in response will be evaluated, and this determination revisited if warranted.

(6) Supporting Documentation in the Contract File

The findings above are supported by the following, retained in the contract file and not reproduced here:

● Technical justifications of the Helicopter Inspector Pilot and the Helicopter Program Manager, addressing the independent technical assessment, evaluation of alternatives, and specifications.

● Streamlined Market Research / Acquisition Plan, Requisition 1171441.

● Manufacturer exclusive distribution letter dated 4/3/2026 and product datasheets.

● Contracting Officer correspondence with the manufacturer dated 6/17/2026 establishing current unit and kit pricing and confirming domestic manufacture, supporting the separate price reasonableness determination under FAR 12.204(a).

Page 3 of 3 Rev. 07/29/26

Certifications & Approvals

(1) Technical / Requirements Personnel Certification

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

Josh Hutchison, Helicopter Program Manager Date

(2) Contracting Officer’s Certification

I certify that the data supporting the decision to restrict competition is accurate and complete to the best of my knowledge and belief. I have determined that only one source is reasonably available to meet the Government’s minimum need. I hereby approve this determination.

Westley Bisson, Contracting Officer Date

2026-08-03T09:18:49-0700
JOSHUA HUTCHISON
2026-08-03T10:28:55-0600
WESTLEY BISSON

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