J&A_new.docx

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIMPLIFIED ACQUISITION PROCEDURES (SAP) FAR 13.106-1(b)

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

2019224-DB03

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 repair 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 parts to be repaired and utilized on the MH65 helicopter: Eighteen (18) Processor, TCAS 1 (P/N: 805-10001-026, NSN: 6340-01-HS1-2507).

UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON NO OTHER SUPPLIES OR SERVICES CAN BE USED.

This acquisition is restricted to the only source known to have the capability of repairing the scheduled parts back to original equipment manufacturer (OEM) specification. The USCG has determined that these parts can only be repaired directly from the OEM. Furthermore, the Government does not have the adequate data or lacks right to the data and it is not economical to buy the data or rights to the data.

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 parts to be repaired 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 sources are not available. The USCG uses past performance history and Inventory Locator Service (ILS) Mart to seek available sources. Soliciting to other than the OEM will compromise the safety of the aircraft and crew

REASON THAT SUGGESTED SOURCE IS THE ONLY SOURCE WHICH CAN PROVIDE THE SUPPLIES OR SERVICES.

Market research has determined that the item OEM, L-3 Aviation Products, Inc. (CAGE 25583), has maintained their status as the only source qualified to fulfill this requirement, in that they own the proprietary data required to perform the work, the technical expertise to interpret the data, and the ability to solve technical problems, all of which are vital for the continued operational readiness of the aircraft. However, USCG will accept quotes for these items from the OEM or any OEM approved repair facility.

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.

USCG did not purchase data rights as part of the initial system acquisition of the H-65 aircraft. The required specifications of suitable alternate repair sources would not be sufficient for 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 repair procedures from multiple sources 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.

L-3 Aviation Products, Inc. owns the proprietary data rights, specifications and repair procedures to these items which have limited the USCG’s ability to provide adequate alternate repair sources. Therefore, it is difficult to take steps to foster competition as the repair data is proprietary to the OEM.

SIGNATURE AND TITLE OF CUSTOMER

CODE

DB

TELEPHONE NUMBER

252-335-6672

DATE

08/12/2019

SIGNATURE OF CONTRACTING OFFICER

DATE

April 2019