1. IDENTIFICATION OF THE AGENCY AND CONTRACTING ACTIVITY

Contracting Activity: General Services Administration (GSA) Federal Acquisition Service (FAS) General Supplies and Services (GSS), Assisted Contracting Branch B 819 Taylor St., Fort Worth, TX 76102

Requiring Activity: United States Naval Air Systems Command (NAVAIR) –

PMA 290 (NAVAIR)

Description of Requirement: P-8A Antenna Gasket Kit

Manufacturer: Aviation Devices and Electronic Components, LLC (AvDEC)

GSA’s Acquisition PIID # 47QSWC26K0003 Period of Performance (POP): 12 weeks

Contract Value:

2. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

This action is to request the approval of a sole source Purchase Order for the supply of Av-DEC’s antenna gaskets to support the production of the P-8A Poseidon aircraft.

This Justification and Approval serves to support the procurement as a sole source award for deliverables manufactured by Av-DEC in accordance with FAR 12.102(b) (GSA Class Deviation RFO-2025-12), Restricting competition.

3. A DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS

(INCLUDING THE ESTIMATED VALUE)

General Services Administration

JUSTIFICATION AND APPROVAL FOR RESTRICTING COMPETITION (J&A)

FAR 12.102(b)(GSA Class Deviation RFO-2025-12)

Description Part # Quantity Price Each Total Price P-8A Antenna Gasket (USN) 140 P-8A Antenna Gasket (AUS) 14 P-8A Antenna Gasket (UK) 9 P-8A Antenna Gasket (NO) 5 P-8A Antenna Gasket (NZ) 4 P-8A Antenna Gasket (KS) 6 P-8A Antenna Gasket (GY) 8 P-8A Antenna Gasket (CN) 14 Total:

The total estimated value of this requirement is (for spare parts).

4. AN IDENTIFICATION OF THE STATUTORY AUTHORITY PERMITTING OTHER THAN FULL

AND OPEN COMPETITION

This acquisition will be conducted under 10 U.S.C. 3204(a)(4) and the authority of FAR 12.102(b)(2) (GSA Class Deviation RFO-2025-12), restricting competition and in accordance with FAR 12.201-1 Simplified procedures (GSA Class Deviation RFO- 2025-12), which allows restricting competition for the purchase of the P-8A spare part components in amounts greater than the simplified acquisition threshold but not exceeding $9,000,000.00. Each spare part component meets the definition of a commercial product in accordance with FAR 2.101 (GSA Class Deviation RFO-2025-02) as these items are generally available for public use with a minor modification not customarily available in the commercial marketplace made to meet Federal Government requirements.

For restricting competition exceeding the simplified acquisition threshold, the requirements at FAR 12.201-1 (GSA Class Deviation RFO-2025-12) apply. The need to restrict competition is justified in writing utilizing the format at FAR 6.104-1 (GSA Class Deviation RFO-2025-06) in accordance with 41 U.S.C. 1901. This justification will be approved at the levels specified in accordance with FAR 6.104-2(a) (GSA Class Deviation RFO-2025-06) and posted to SAM.gov within fourteen (14) days of contract award in accordance with FAR 6.301(b) (GSA Class Deviation RFO-2025-06).

5. A DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR THE

NATURE OF THE ACQUISITION REQUIRES USE OF THE AUTHORITY CITED

NAVAIR has a need for the procurement of antenna gaskets for the P-8A Poseidon aircraft, modified from the commercial aircraft Boeing 737-800ERX. The P-8A Poseidon is the latest maritime, patrol and reconnaissance aircraft designed to secure the Navy’s future in long-range maritime patrol capability. NAVAIR’s PMA 290 holds the responsibility of maintaining, repairing, and implementing new aircraft capabilities to the P-8A aircraft fleet for operational use. The P-8A aircraft antenna gasket was developed for, integrated into, and tested on the P-8A during an extensive, competitively awarded P- 8A system development and demonstration phase. AvDEC is the sole designer, developer, and manufacturer of the aircraft antenna gasket for use in the P-8A. AvDEC’s design is proprietary and not based on any generic specification design. Av-DEC is the only known source with the requisite knowledge of the design, technical data, instruction manuals, installation procedures, and maintenance data necessary to support/sustain the whole system, fabrication, performance, and operational characteristics of the antenna gasket capable of meeting the P-8A requirements, and is therefore uniquely qualified to perform the efforts contemplated under this J&A. Any other supplier would need to have their parts certified, which requires testing and analysis.

Awarding to any other source would disrupt on-going P-8A production and maintenance by delaying the delivery of qualified and properly integrated antenna gaskets to the P-8A line. The timeline to compete and qualify a second source to fulfill the P- 8A production weapon system requirements is estimated to be approximately four years.

The Department of the Navy issued ‘Authorization of AvDEC Polyurethane Conductive Gaskets on Aircraft Communication /

Navigation Antennas and Static Wick Mounting Bases to Aircraft Aluminum Surfaces to Eliminate Corrosion and Related Precipitation Static Issues’ dated December 18, 2003, authorizing the use of AvDEC’s antenna gaskets for installation on Navy and Marine Corps aircraft antenna and static dischargers located on aluminum substrates. The authorization letter further states the antenna gasket that AvDEC provides is a polyurethane conductive gasket that provides electrical bonding between aircraft aluminum substrate and the mounting base of aircraft antenna and static discharge mounting bases. This technology is used to seal and protect components against moisture and subsequent corrosion while at the same time providing a mechanism for bonding and grounding, eliminating airborne communication precipitation static (P-static) discrepancies caused by corrosion.

6. A DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED FROM AS MANY

POTENTIAL SOURCES AS IS PRACTICABLE, INCLUDING WHETHER A NOTICE WAS OR WILL BE

PUBLICIZED AS REQUIRED BY SUBPART 5.2 AND, IF NOT, WHICH EXCEPTION UNDER 5.202

APPLIES DESCRIPTION OF EFFORTS TO ENSURE THAT OFFERS ARE SOLICITED FROM AS MANY

POTENTIAL SOURCES AS PRACTICABLE, INCLUDING IF A NOTICE WILL BE PUBLICIZED AS

REQUIRED BY SUBPART 5.2

The market research conducted by the Contracting Officer and information submitted by the customer for review indicates that only one (1) source is available. Additionally, the Contracting Officer posted a notice of proposed contract action on December 8, 2025, to SAM.gov, in which the Government intends to solicit and negotiate with only one (1) source; and no responses were received.

The notice was open for two (2) weeks and closed on December 22, 2025. Also, an email was sent to AvDEC on November 20, 2025, to see if they had any authorized distributors for the P-8A antenna gaskets. On the same day, AvDEC responded that it does not have any authorized distributors for direct U.S. military sales.

7. A DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED COST TO THE

GOVERNMENT WILL BE FAIR AND REASONABLE

Because this requirement is being restricted, the Government will be utilizing at least two (2) price analysis techniques outlined in FAR 15.404-1(b) (GSA Class Deviation RFO-2025-15) by which to determine pricing submitted by AvDEC to be fair and reasonable. These techniques include, but are not limited to the following:

8. A DESCRIPTION OF THE MARKET RESEARCH CONDUCTED (SEE PART 10) AND THE RESULTS OR A

STATEMENT OF THE REASON MARKET RESEARCH WAS NOT CONDUCTED

In accordance with FAR Part 10 (GSA Class Deviation RFO-2025-10), Market research was conducted to evaluate the availability of AvDEC gaskets in meeting the Government’s need. Based on the NAVAIR’s input, a Notice of Intent (NOI) to negotiate on a sole-source basis was published to SAM.gov on December 8, 2025, for fourteen (14) days to solicit industry feedback regarding the gasket requirement. The NOI closed on December 22, 2025, with no responses received. The Contracting Officer also contacted AvDEC, through email on November 20, 2025, to inquire whether authorized distributors were available for the gaskets.

AvDEC confirmed that it does not have any authorized distributors and that they will quote directly.

9. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN COMPETITION

All facts supporting this justification have been provided above.

10. A LISTING OF THE SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN INTEREST IN THE

ACQUISITION

The AvDEC antenna gasket is the only product that has been rigorously tested and determined to meet the Government's needs.

There were no responses to the NOI that was posted or inquiries submitted by industry concerning the Government’s intent to sole source this requirement to AvDEC.

11. STATEMENT OF ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE BARRIERS TO

COMPETITION

Increasing concerns have emerged regarding potential barriers to competition when access to design, knowledge, and technical data is required. However, AvDEC is currently the only source capable of meeting the Government’s needs. Prior to any subsequent procurement, the Government will once again review the market using various methods to assess whether any other qualified sources are available and are able to meet the Government's requirements.

TECHNICAL REQUIREMENTS CERTIFICATION

I certify that this support data under my cognizance, which forms a basis for this justification, are accurate and complete to the best of my knowledge.

Date

CONTRACTING OFFICER CERTIFICATION AND APPROVAL

The Contracting Officer has determined this procurement meets the circumstances described in FAR 12.102(b) (GSA Class Deviation RFO-2025-12), restricting competition for purchases exceeding the simplified acquisition threshold and that the appropriate actions were taken under this acquisition to meet the conditions described in FAR 12102(b) (GSA Class Deviation RFO-2025-12) and FAR 12.201-1 (GSA Class Deviation RFO-2025-12), Simplified procedures. The information contained in this justification is accurate and complete to the best of the Contracting Officer's knowledge and belief.

COMPETITION ADVOCATE’S CERTIFICATION:

I, the approving authority, determine that the circumstances identified in this document are accurate; therefore, restricting competition under FAR 12.102(b) (GSA Class Deviation RFO-2025-12) is justified. The signature below also represents approval of this Justification and Approval for restricting competition.

er Date