Brand_Name_Justification_Redacted.pdf

Version 1.0

Source Selection Information – see FAR 2.101 and 3.104

BRAND NAME JUSTIFICATION

FOR AN ACTION EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

USING SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS

(AUTHORITY: FAR 13.501(a), 41 U.S.C. 1901)

NMAN6000-19-00818

1. Agency and contracting activity.

Department of Commerce, NOAA Acquisition and Grants Office (AGO), Eastern Acquisition Division (EAD) and the NOAA Office of Marine and Aviation Operations (OMAO) Aircraft Operations Center (AOC).

2. Nature and/or description of the action being approved.

This is a brand name justification for a new, 4-year indefinite delivery, indefinite quantity (IDIQ) contract. A firm fixed price contract is contemplated for award with a brand name restriction only for the purchase of two (2) new PT6A-27 aircraft engines, which are manufactured by Pratt & Whitney.

3. Description of supplies or services required to meet the agency’s needs (including the total estimated value).

This acquisition is to provide “full-service” maintenance and repair for the Pratt & Whitney engines utilized by the NOAA’s light aircraft fleet at a total estimated cost of over the four-year ordering period. “Full-service” includes inspection, overhaul, repair, rental engines and upgrade of NOAA’s current Pratt & Whitney engines. In addition, this requirement will include the purchase of two (2) new Pratt & Whitney engines to replace end-of-life and/or damaged engines to allow the AOC to meet operational and safety requirements.

The otherwise competitive solicitation will include a brand name restriction, as documented in this justification, which covers the purchase of the aforementioned two (2) new Pratt & Whitney PT6A- 27 engines, not the “full service” of the NOAA’s Pratt & Whitney engines. New Pratt & Whitney engines have an estimated cost of

4. Statutory authority permitting the sole source (including brand name) acquisition.

41 U.S.C. 1901, using SAP up to $7M as authorized by FAR 13.500(a) and implemented by FAR 13.501(a).

5. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The Contracting Officer has determined the following circumstances justify the use of a brand name as supported below:

Brand Name: The brand name restriction for this otherwise competitive requirement is for the purchase of two (2) Pratt & Whitney PT6A-27 engines for NOAA’s Twin Otter aircrafts. Supporting and operating an aircraft requires specialized tools, spare parts, and training that is specific to the type of aircraft. As such, uniformity of parts for like and/or similar aircraft allows for significant flexibility concerning resources and costs. NOAA AOC owns and operates the following light aircraft:

NMAN6000-19-00818

Source Selection Information – see FAR 2.101 and 3.104

Aircraft Type Registration Number

Serial Number Pratt & Whitney Model

DHC-6-300 Twin Otter N46RF 824 PT6A-27

DHC-6-300 Twin Otter N48RF 740 PT6A-27

DHC-6-300 Twin Otter N56RF 788 PT6A-27

DHC-6-300 Twin Otter N57RF 688 PT6A-27

B300C King Air N68RF FM-21 PT6A-60A

To Be Acquired King Air 350 TBD` TBD PT6A-60A

The main goal of an aircraft overhaul is safety. Third party parts makers need to meet a certain standard set by the federal Government to ensure the safety of the parts when they are installed on the aircraft, but the original manufacturer of the Twin Otter aircraft, Viking Air Ltd (Viking), are the people that know the exact fit and finish of every part. On occasion, a manufacturer teams up with a third-party part manufacturer to provide parts for their aircraft. Pratt & Whitney PT6A-27 engines are the original equipment provided by Viking for NOAA’s Twin Otter aircrafts. In doing so, Viking approved the PT6A-27 engines for the Twin Otter aircraft and have validated that the PT6A-27 engines have the exact form, fit and function required to operate safely in the Twin Otter aircraft.

A “brand name or equal” description cannot be used, as the utilization of a different brand would not have the same form, fit and function as the original engines (PT6A-27), which could affect the safety of flight. While similar engines may function in the Twin Otter aircraft, other manufactures are not aware of Viking’s fit and finish when it comes to making similar engines for the Twin Otter;

thus, the similar engines may take longer to install and will not fit exactly, which would compromise performance and safety. For example, as described in the Air Facts Journal (https://airfactsjournal.com/2012/04/considering-a-twin/) if one of the engines on the Twin Otter quits, “the aircraft will immediately and dramatically begin to diverge from controlled flight in all three axes. It takes prompt, correct and in some situations aggressive pilot action to prevent the airplane from going out of control. The slower the airplane is at the time of failure, the more aggressive the pilot must be. Under some circumstances it will become completely uncontrollable well before the wing stalls, because of insufficient airflow over the control surfaces to counter asymmetric thrust.” Consequently, the use of an unknown engine is a safety concern, which would require additional training and pilot flight hours for familiarity with performance and functionality.

In addition, the use of other company’s engines would require additional costs for NOAA AOC to operate the Twin Otter aircraft. Examples of the additional costs are as follows:

Certification: All aircraft not using the original manufacturer’s parts require additional certification for safety of flight. This would require additional flight hours and maintenance to ensure safety and performance.

Additional Purchases: The Twin Otter is a dual engine aircraft; however, AOC switches out individual engines from both of their Twin Otter aircrafts regularly for repair and overhaul.

Operationally, both engines on a twin-engine aircraft need to match (identical engines) for performance and safety of flight considerations; consequently, if an engine other than the Pratt & Whitney PT6A-27 engine is purchased, AOC will need to purchase four engines, vice two, to allow for identical engines for both Twin Otter aircraft.

Source Selection Information – see FAR 2.101 and 3.104

The utilization of an engine other than the Pratt & Whitney PT6A-27 would prevent commonality and standardization of engines used in NOAA’s fleet. As shown in the table above, all of NOAA’s light aircraft utilize Pratt & Whitney model engines, to include the King Air 350. Extensive aircraft fleet commonality and standardization research has shown that vast improvements exist with respect to compliance-based safety culture, economical and logistical benefits from shared common parts, training requirements, and aircrew efficiencies. Safety is vastly improved through aircraft fleet standardization efforts by utilizing the same brand engines for all aircraft types within NOAA’s fleet.

Finally, as demonstrated, the use of engines other than the Pratt & Whitney PT6A-27 could have an adverse effect on the Twin Otter's mission for NOAA AOC. NOAA’s Twin Otter aircraft remain very busy year round supporting airborne marine mammal, hydrological, remote sensing, air chemistry and emergency response programs. The use of engines other than the Pratt & Whitney PT6A-27 for NOAA’s Twin Otters is unknown. As similar engines do not have the same form, fit and function as the Viking approved PT6A-27 engines, performance and safety could be compromised. Moreover, additional maintenance would be required to ensure proper form, fit and function, which would require extended downtime for the NOAA’s Twin Otters, which would affect NOAA’s wide-ranging mission requirements.

Due to AOC’s stringent aircraft safety requirements and the current established maintenance programs for NOAA’s aircraft, Pratt & Whitney engines are the only viable option for this procurement. Therefore, the purchase of the two (2) new engines should be restricted to the Pratt & Whitney PT6A-27 engines, as using other brands’ engines would be harmful to the Government if NOAA’s Twin Otter are unable to meet mission requirements. Furthermore, using other brands’ engines would be harmful to NOAA AOC’s financial well-being (through the purchase of additional engines and maintenance requirements) and NOAA AOC’s safety and standardization objectives by diminishing fleet commonality.

6. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies.

In accordance with FAR 5.102(a)(6), the Request for Quotation (RFQ), inclusive of this brand name justification for the PT6A-27 Pratt & Whitney engines, will be posted on the Governmentwide Point of Entry, FedBizOpps (FBO), for all interested and capable sources.

7. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will determine anticipated cost to the Government as fair and reasonable based upon competitive quotations, market research, current published price lists and the independent Government cost estimate (IGCE).

8. Description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted.

Due to the safety and standardizations concerns detailed in Section 5 of this document, further market research concerning the brand name restriction for the PT6A-27 Pratt & Whitney engines was not conducted.

9. Any other facts supporting the use of a sole source (including brand name), such as:

None.

Source Selection Information – see FAR 2.101 and 3.104

10. List of the sources that expressed a written interest in the acquisition.

None.

11. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

The Government will continue to gauge the aviation industry and marketplace capabilities for future requirements as the aviation industry evolves.