J&A_Signed_Redacted.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

8290-GN01

PROJECT/TASK NUMBER

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

$67,600.00

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), Engineering Services Division

(ESD), Policy and Logistics Branch (PLB) anticipates the award of a firm-fixed price purchase order on a sole source basis. This justification for other than full and open competition is submitted for approval in accordance with (IAW) Federal Acquisition Regulation (FAR) 6.303-1(a) using the authority in FAR 6.302-1(b) – only one responsible source and no other supplies or services will satisfy agency requirements.

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE.

ESD intends to purchase the Cowling Parts Racks shown in the table below, on a sole source basis, directly from the Original Equipment Manufacturer (OEM) – All Metal MS Inc. (CAGE Code: 3Y6K7), hereinafter referred to as All Metal. These Racks are used to store the cowlings for the MH-65 helicopter when they must be removed in order to perform aircraft maintenance and repair.

Quantity

Optional Quantity

Part Number (PN)

Nomenclature

2 each Up to 6 each CR 120 Cowling Parts Rack

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

CAN BE USED.

The Racks to be purchased under this acquisition are highly specialized and have been specifically designed and manufactured by All Metal for the storage of USCG MH-65 helicopter cowlings. USCG Engineering has evaluated these Racks and have submitted a CG-22, Aeronautical Publication Change Recommendation, for these Racks to be incorporated into Coast Guard Technical Order (CGTO) 32A38-AGSE-1 (Tool and

Equipment Aeronautical Ground Support Equipment Program) as the only Cowling Parts Rack to be used with

USCG MH-65 helicopters.

As the OEM, All Metal owns all rights to the technical data, specifications, and drawings required for the manufacture of these Racks. The rights to the required technical data to acquire these items from sources other than the OEM are not owned by the Government nor have they been licensed to any other sources.

December 2015

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).

Extensive market research was conducted using both Government and commercial sources. This included querying the following information systems and web sites: Defense Logistics Agency (DLA) Federal Logistics

Information Service (FLIS); Department of Defense Electronic Mall (DoD EMall); the General Services

Administration’s (GSA) on-line purchasing service – GSA Advantage!®; Inventory Locator Service e-marketplace (ILSmart); internet search engines; and the OEM’s web site. This item is not available from any mandatory Government source IAW FAR 8.002 or from any non-mandatory source IAW 8.004. All Metal does not sell this Rack through any authorized distributors.

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

As the OEM, All Metal owns all rights to the technical data, specifications, and drawings required to manufacture this Rack. All Metal has not licensed the rights to the technical data required to manufacture this

Rack to any other commercial vendors. Therefore, there are no other sources capable of manufacture.

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 Government does not own or possess any rights to the technical data, specifications, and drawings required to manufacture this Rack. In addition, the Government has not developed the technical data required to reverse engineer this Rack and has no plans to do so. It has been determined that it would be uneconomical for the

Government to either purchase the data rights or to develop the technical data necessary to manufacture this

Rack.

PROVIDE A STATEMENT OF ACTIONS, IF ANY, THE GOVERNMENT MAY TAKE TO REMOVE OR OVERCOME ANY BARRIERS TO

COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED.

As previously stated, the Government does not own or possess any rights to the technical data, specifications and drawings required to manufacture these items. This 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.

SIGNATURE AND TITLE OF CUSTOMER

XXXXXXXXXXXXXXXXXXXX

Steve DurhamXXXXXXXX

Item Manager – ESD, PLB

CODE

TELEPHONE NUMBER

(252) 335-6571

DATE

2 November 2018

SIGNATURE OF CONTRACTING OFFICER

XXXXXXXXXXXXXXXXXXXXXXXX

Kathrine R. LeachXXXXXXXX

Contracting Officer – ESD/IODX

CODE

TELEPHONE NUMBER

(252) 335-6834

DATE

10 November 2018