4d_Limited Source Justification Redacted.pdf

Limited-Sources Justification

Pursuant to the Multiple Award Schedule Program (as authorized by 40 U.S.C. § 501), this justification is prepared in accordance with the requirements of Federal Acquisition Regulation (FAR) 8.405-6(c) for the use of sources limited to fewer than those required in FAR 8.405-1, FAR 8.405-2, and FAR 8.405-3. The circumstance justifying restriction is FAR 8.405- 6(a)(1)(i)(B) through the following facts and rationale:

(1) Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG) proposes to enter an order on the basis of a limited-sources justification.

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

(a) Nature of action: USCG intends to limit competition to Spika Manufacturing

(b) Name and address of the contractor: Spika Mfg., 254 Cottonwood Creek Rd, Lewistown, MT 59457

(c) Contract type: Firm-Fixed-Price

(d) Estimated total value (including options): $224,143.47

(e) Type of funding: Air Operations PPA

(f) Year of funding: Fiscal Year 2024

(g) Solicitation number: 61300PR240000029

(h) Background information about the requirement: See SOW

(3) Description of Supplies/Services.

Provide aircraft maintenance stands to for MH-60T Maintenance Training Unit. These stands will be used to train USCG Aviation personal the various tasks required to perform schedule and unscheduled aircraft maintenance.

(4) Identification of the justification and the rationale.

FAR 8.405-6(a)(1)(i)(B) Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized are not prevalent elsewhere on the schedules are represented by the historical procurements by the

USCG of these components. Being the OEM/designer of the applicable stands eliminates rework and or repair due to unsatisfactory workmanship.

(5) Determination by the ordering activity Contracting Officer that the anticipated order represents the best value consistent with 8.404(d).

The Contracting Officer has determined that issuing the proposed task order to Spika Manufacturing represents the best value and will result in the lowest overall cost alternative, considering price and administrative costs, to meet including the Defense Logistics Agency (DLA) Federal Logistics Information Service (FLIS); Department of

GSA Advantage;

only entity with access to, the technical data, specifications, and drawings required to manufacture this item. Spika has not licensed the rights to the technical data required to manufacture this item to any other manufacturers, leaving no other sources of supply. The item to be purchased must meet critical safety, durability, and reliability requirements, which necessitate extensive and sophisticated testing. The Government does not own or possess the relevant technical data, specifications, and drawings required to develop an adequate purchase description and has not developed the technical data required to reverse engineer this item, nor does it plan to do so. It has been determined that it would be uneconomical for the Government to either purchase the data rights or develop the technical data necessary to develop an adequate purchase description for the manufacture of this item. Therefore, issuing the proposed task order to Spika Manufacturing is the most advantageous option and represents the best value for the Government.

(6) A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

The United States Coast Guard (USCG) intends to purchase three (3) Maintenance Check Stands (Part Number:

1101106) and (Part Number: 110105) on a sole source basis directly from the Original Equipment Manufacturer (OEM) Spika Design & Manufacturing, Inc. These Maintenance Check Stands and Staircase are specifically designed for performing maintenance on MH-60T aircraft, enabling personnel to access areas of the aircraft undergoing maintenance and repair safely and efficiently. Originally, these Maintenance Stands and Staircase were designed and manufactured by the OEM under a competitive contract with the USCG. The design process involved a thorough review of all MH-60T maintenance procedure cards, with a strong emphasis on human factor engineering, safety, and service life. However, the USCG did not purchase the data rights and does not possess the technical specifications required for manufacturing these items by any entity other than the OEM. Spika Manufacturing is the sole vendor capable of producing height-adjustable check stands that meet the specific needs of the USCG MH-60T model helicopter fleet. The precise height adjustability specifications are critical for both the tail inspection stand and main airframe inspection stands. These specifications are necessary to accommodate the turning of the MH-60T tail rotor blades during inspection and maintenance, and to ensure adequate clearance of the Auxiliary Fuel Tank during main airframe maintenance operations. Given the unique and exacting requirements for these maintenance stands and staircase, Spika Manufacturing remains the only viable source for these items, as no other manufacturers have the technical capability or data rights to produce them to the required specifications.

(7) Any other facts supporting the justification.

No additional facts.

(8) A statement of actions, if any, the agency may take to remove or overcome any barriers that preclude the agency from meeting the requirements of 8.405-1 and 8.405-2 before any subsequent acquisition for the supplies or services is made.

As previously stated, the Government does not own or possess any rights to the technical data, specifications, and drawings required to manufacture this item which has prevented the USCG from being able to provide an adequate technical description to potential new sources. Therefore, it is difficult to take steps to foster competition when the manufacturing, performance, and acceptance data are proprietary to the OEM.

(9) Technical/Requirements Personnel Certification.

data, which forms a basis for the justification, is accurate and complete.

Name Date Technical Representative

(10 I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Name Date Contracting Officer

7 19 2024