Redacted_J&A_J0000186.pdf

Justification for Other Then Full and Open Competition Under 4l U.S.C. t90l Only One Responsible Sourc,e and No (Xher Supplies Will Satisfy Agency Requirements

Overhaul of Rescue Hoist Assembty Solicitation Num ber: 70203818QJ0000186

Pursuant to the requirements of the Competition in Contacting Act and in accordance with the requirements of Fedoral Acguisition Regulation (FAR) 13.5, this justification is preparrd under the authorityof FAR l3.50l.Useof FAR 13.501 isjustifiedbythefollowingfactsandrationaleusingthe format at FAR 6.303-2, modified to reflect an acquisition under the authority of Simplified Acquisition Procedures at 4 I U.S.C. 190 I :

(1) Agency and Contrecting Activity.

The Department of Homeland Security (DHS), United Sates Coast Guard (USCG), Aviation Logistics Center (ALC), Medium Range Recovery (MRR) Product Line Division, proposes to enter into a purchase order on a basis ofother than full and open competition.

(2) Nature end/or description oftbe action beiag approved.

The MRR Procurement Branch requests approval to solicit and award, on a sole source basis, an overhaul order for the componen(s) specified herein. A firm fixed price purchase order will be placed to overhaul these components. The components are required for outfitting USCG MH{0T aircraft with the latest designed/drawing revision authorized and are essential to avoid grounding of the aircraft. Alt specifications, manufacturing drawings, dat4 test equipmsnt, and tooling required to overhaul these Gomponents are proprietary to Goodrich Corporation (known as Goodrich hereafter). Stakeholders include the MRR Product Line and supported USCG Air Stations. This requirement will be solicited utilizing FAR Part l2 Acquisition of Commercial ltems and FAR Subpart I3.5 Simplified procedures for Certain Commercial Items. The approximate total dollar value is $870K.

The United States Naval Supply Weapons Systems Support (NAVSUP WSS) is the Primary Inventory Control Agency and has sole authority and responsibility for certiffing souroes of support for H-60 components. Certification of sources of support was executed in accordance with Public ["aw 108-135 Section 802 of the Defense Appropriations Act of 2004 and Naval Air Systems Command lnstruction (NAVAIRINST) 4200'56. However, USCG ALC MRR Engineering is ttre responsible authority for unique parts used on the H-60 aircraft. Responsible Contractors are limited to USCG ALC MRit Engineeringapproved soutces and Goodrich isthe only approved source. Goodrich's contact information is as follows:

Goodrich Corporation 2727lmpenal Hwy Brea, CA 928214713 Cage Code:3HRL,4

(3) Description of Supplkxlservices.

The USCG currently operates a fleet of forty-five (45) MH-50T rotary wing aircraft. This specialized, high demand, aircraft cunently enables the USCG to perform missions *u"I'ar search and rescue, law enforcemen! international ice patrol, marine environmental prctection, and marine r€souree conservation.

With such a demanding operational tempo, aircraft condition and availability are essential to mission success. The components are interchangeable throughout the H-60 fleet. Tile basic objective of this requirement is to preserve service life, reduce life cycle cos! and increase mission capabilities. This overhaul requirement will provide replacement Ready for Issue spares for the fleet and programmed depot maintenance. Goodrich is the original equipment manufacturer orthese components.

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Justificrtion for Other Than Full end Open Competition Under 4l U.S.C. 1901 Only One Responsiblo Source and No Other Supplirs Will Satisfy Agency Requirements

Overhaul of Rescue Eoist Assembly Solicitetion Number: 70203818Q,.I0000f 86

(4) Identification of the justlfcstion rnd the rationale.

The statutory authority permitting otherthan full and open competition is 4l U.S.C. l90l(c), as implemented in FAR 13.501(a), "Sote source (including brand name) acquisitions." Responsible sources are limited to USCG ALC MRR Engineering approved sources. There are no other supply sources or alternate part numbers available to meet the Govemment's roquirements.

(5) Demonstretion thet the nlture of the ecquisition requires use of tbe authority clted.

The specifications, manufacturing drawings, data, test equipment, and tooling required to overhaul these comPonents are proprietary to Goodrich. The USCG did not purchase rights to the proprietary data required to foster a competitive environment as part of any original provisioning for use on the MH-607 rotary wing aircraft and thc costs to procure this data would be cost prohibitive. Goodrich has been confacted in the past to inquire about thc releasc of any proprictary technology to the USCG or any distributors. Goodrich has responded that their technology is proprietary and resale of their proprietary technology is prohibited.

In addition, NAVSUP WSS is the Primary Inventory Control Agency and has sole authority and responsibility for certiffing sources of supply and support for MH-60T components. Certification of sources of supply was executed in accordance with Public law 108-136 Section 802 of the Defense Appropriations Act of 2004 and Naval Air Systems Command Instruction (NAVAIRINST) 4200.56. The statutory authority permitting other than firll and open competition is I 0 U.S.C. 2304 (c)( I ) as implemented by FAR 6.302-l (bxlxii). However, USCG ALC MRR Engineering is responsible for unique parts used on the MH-60T aircraft. Responsible sources are limited to USCG ALC MRR Engineering approved souroes. Goodrich is the only approved source for this component. There were no other overhauling sources or alternate part numbers available to m€et the Government's requirements.

Failurc to approve this sole source Justification for Other Than Full and Open Competition (J&A) will jeopardize performance of MRR's mission due to grounding of the aircraft as a result of no stock being available as required.

(6) A description of the ellorts made lo ensure thet ofrers are solicited fium as many potertial rnurcer es is practicable.

This procurement forecast is posted as DHS - Acquisition Planning Forecast System (APFS) No:

F20 I 804 I I 5l on http:llapfs.dhs.gov and was included in the DHS Forecast of Small Business Opportunities. Market research confirmed Goodrich is the only approved overhaul source for the components specified horcin. Prior to award, a combined synopsis to solicit on a sole source basis and award a contract fulfilling the notice requirements of FAR 5.201 will be posted to the GPE via I$p:llwv{vq.'Hbizopps,Bor. A copy of the approved J&A on a sole source basis will be uploaded after the award. Any capability statement, proposal, or quotation received in response to the noiice will be considered prior to award.

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Justificetion forOther Then Full and Open Competition Under 41U.S.C. 1901

Only One Responsible Source and No Other Supplies Will Satisfy Agency Requirtmeuts Overheul of Rescue Hoist Assembly

Solicitation Number: 702038f 8ql00001t6

(7) Determinetion by the Contrecting Officer that tbe anticipated cost to the government will be fair and reasonable.

Pricing iriformation collected from market research and the previous paid prices was used in the development of the Independent Govemment Cost Estimate (ICCE) for tlis requirement. The current Producer Price Index escalation rate based on the Final Demand-lntermediate Demand aggregation system was applied. The Contracting Officer may request other than certified cost and pricing daa. The Contracting Officer anticipates comparison of prices proposed with historical pricing and the IGCE will establish price reasonableness.

(8) Description of market research.

Market research was conducted in accordance with FAR Part l0 from February 201 8 to April 201 8.

Market Researeh confirmed Goodrich is the only approved overhaul source for the components specified herein. The components are not commercial in nature and not prevalent in private aviation and commercial aviation but arp uscd on other military aviation aircraft Navy H60 models. All terms and sonditions are not expected to differ from customary tsrms and conditions in the marketplace or standard

Covemment practices. Contract financing is not applicable to this requirement. There are no laws or regulations unique to this requirement. No environmentally preferable services were identified during market research and Buy American/Trade Agreements Acts/Section 508 regulations/Safety Act is not applicable to this requirement.

(9) Any other facts supporting the use of other than full end open competition.

Goodrich is the only approved source to overhaul this component. Failure to approve this sole source

J&A will jeopardize performance of MRR's mission due to grounding of the aircraft as a result of no stock being available as components are required.

(10) A listing of the sourrcs, if any, that exprcssed, in writing, an interest in the acquisition.

A review of Federal Logistics Data on Mobile Mediq Department of Defense - Fed Mall, and/or General Services Administration Advantage confirmed Goodrich is the actual manufacturer and the only approved source of supply at this time.

(f l) A ststcment of the actiom, if any, the ageacy may take to rcmove or overcome any barriers to competition beforc any subsequeot acquisition for reguired sopplies or selvices.

There is only one (l ) responsible source approved by USCC ALC MRR Engineering to perform the overhaul requirements. The USCG did not purchase rights to the proprictary technolory required to foster a competitive environment as part of any original provisioning for use on the H{0 aircraft. Every reasonable effort will be made to rernove barricrs to competition for frrture requirements. These efforts will include continuing to identiff additional sourc€s that may evenhrally become approved by USCG ALC MRR Engineering to perform the overhaul requirrments.

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Attorncy Allco Loe USCO Acquisitinrs Lau snd Claims (LSC AtX)

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Supcrvirory G{ncdngOfEocr, US6, ALC. MRS

Chicf of thc Coruacting Offre, USCG, ALC

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