J&A.pdf

December 2015

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIMPLIFIED ACQUISITION PROCEDURES (SAP)

SOLICITATIONS MAY BE LIMITED TO ONE SOURCE ONLY IF THE CONTRACTING OFFICER DETERMINES THAT ONLY ONE SOURCE IS REASONABLY AVAILABLE. THIS DETERMINATION MUST BE SUPPORTED WITH FULL JUSTIFICATION FOR SOLE SOURCE FROM THE CUSTOMER. WHEN THE CUSTOMER DESCRIBES AN ITEM WITH A PURCHASE DESCRIPTION WHICH LIMITS THE AVAILABILITY TO ONE SOURCE, THE JUSTIFICATION MUST EXPLAIN WHY THE ITEM IS THE ONLY ONE THAT WILL MEET THE GOVERNMENT’S REQUIREMENT.

STATEMENTS SUCH AS "ONLY KNOWN SOURCE" OR "ONLY SOURCE WHICH CAN MEET THE REQUIRED DELIVERY DATE" ARE INADEQUATE

TO SUPPORT A SOLE SOURCE PURCHASE.

PURCHASE REQUEST OR REQUISITION NUMBER

PROJECT/TASK NUMBER

ESTIMATED AMOUNT (Over Micro-Purchase Threshold, but up to the SAT

IDENTIFICATION OF THE AGENCY AND THE CONTRACTING OFFICE, AND SPECIFIC IDENTIFICATION OF THE DOCUMENT AS A “JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION.” PLEASE CITE THE AUTHORITY AND TYPE OF JUSTIFICATION. The United States Coast Guard (USCG), Aviation Logistics Center (ALC), Short Range Recovery (SRR) Division has a requirement to purchase spare parts on a sole source basis utilized on the MH-65 helicopter. The statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c)(1); FAR 6.302-1.

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE. This procurement is for the following spare parts to be utilized on the MH65 helicopter: Thirteen (13) LH Funnel Assy (P/N: 366A61-2075-01 NSN: 1560-14-447-2648), Five (5) Hose (P/N: 366A76-1021-1402 NSN: 4720-14-464-0969), Eleven (11) Valve (P/N: 704A34-635-037 NSN: 4820-14-390-0141), One Hundred and Sixty (160) Bolt,Close Toleranc (P/N: 365A23-4111-21 NSN: 5306-14-484-1479), One Hundred and Eighty Five

(185) Damper Housing (P/N: 365A34-6225-20 NSN: 5330-14-396-6049), and Thirty (30) Hinge,FWD,R/H (P/N: 365A24-1176-01

NSN: 1560-14-386-1457).

UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON NO OTHER SUPPLIES OR SERVICES CAN BE USED. These parts are utilized on the MH65 helicopter and are the Original Equipment Manufacturer (OEM)’s part number.

No alternate part number is provided per the IPC. No alternate parts are authorized for use on the MH65 per the OEM’s maintenance manuals or SRR Engineering and Tech Services. Accepting alternate part numbers at this time could cause a malfunction in the aircraft causing a hazardous outcome.

A DESCRIPTION OF EFFORTS MADE TO ENSURE THAT QUOTATIONS OR OFFERS ARE SOLICITED FROM AS MANY POTENTIAL SOURCES AS PRACTICABLE (INCLUDE YOUR MARKET RESEARCH EFFORTS HERE). The spare parts to be procured under this acquisition are highly specialized parts, designed and manufactured by a non-Government activity and the technical data required for acquisition by other than the OEM or an OEM approved source is not available. Airbus Helicopters France (F0210) is the OEM for the H-65 helicopter. Airbus Helicopter France does not sell directly to the USCG and have stated that “Airbus Helicopters, Inc. (3GSZ1) is the only approved source of supply for Airbus Helicopter France products for the MH-65 aircraft.” Therefore, procurement of any parts from other than the OEM or an OEM approved source will compromise the safety of the aircraft and the crew. The solicitation and resulting purchase order will require all materials delivered to have clear, documented traceability to the OEM and a completed Certificate of Conformance, certifying compliance with this contract condition, in accordance with FAR clause 52.246-15, Certificate of Conformance, which will be incorporated.

REASON THAT SUGGESTED SOURCE IS THE ONLY SOURCE WHICH CAN PROVIDE THE SUPPLIES OR SERVICES. The parts on the schedule must be manufactured by the OEM in order to maintain structural integrity of the aircraft and ensure complete compatibility of replacement parts; The USCG neither compromises nor makes exceptions in matters of human’s safety and protection of Government property and does not accept lower standards in these matters. All parts must be new and must be traceable to the OEM. Use of OEM parts will ensure the parts are manufactured in accordance with OEM specifications and standards, conform to original form, fit and function, and are compatible and interchangeable with existing components.

EXPLAIN WHY AN ADEQUATE PURCHASE DESCRIPTION OR OTHER INFORMATION SUITABLE TO SOLICIT BY FULL AND OPEN COMPETITION HAS NOT BEEN DEVELOPED OR ARE NOT AVAILABLE. The required specifications of suitable alternate spare parts would not be sufficient for equipment selection. After receiving responses from the solicitation, an initial test and evaluation would have to be completed on the aircraft to ensure compatibility. It would not be cost or time effective to test multiple spare parts from manufacturers due to time restraints of Coast Guard Air Stations testing procedures.

PROVIDE A STATEMENT OF ACTIONS, IF ANY, THE GOVERNMENT MAY TAKE TO REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED. The OEM owns the proprietary data rights, specifications and drawings to these items which have limited the USCG’s ability to provide adequate technical descriptions to potential new manufacturers.

Therefore, it is difficult to take steps to foster competition as the manufacturing, performance, and acceptance data are proprietary to the OEM.