Redacted__J&A_GG_Rotor_Stator_Overhaul.pdf

Justification for Other Than Full and Open Competition

Under 41 U.S.C. 1901

Only One Responsible Source and No Other Supplies or Services Will Satisfy

Agency Requirements

Solicitation No. 70Z03819QL0000086

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by Federal

Acquisition Regulation (FAR) Subpart 13.5 and in accordance with the requirements of FAR 13.501, the justification for the use of the statutory authority under FAR Subpart 13.5 is justified by the following facts and rationale required under FAR 6.303-2 as follows:

(1) Agency and Contracting Activity.

The United States Coast Guard (USCG), Aviation Logistics Center (ALC), Medium Range

Surveillance (MRS) Division, Elizabeth City, NC proposes to enter into a contract on the basis of other than full and open competition.

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

The USCG, ALC, MRS Division seeks approval to award a firm fixed price purchase order on a sole source basis for the overhaul of three (3) Gas Generator Rotor and Stator Assemblies, P/N:

5175T01G01, to support the HC-144 Maritime Patrol Aircraft (MPA) CT7-PC3 turboprop engine. The

Original Equipment Manufacturer (OEM) is General Electric Company, doing business as GE

Aviation.

(a) Nature of action: The USCG intends to procure overhaul services for the Gas Generator

Rotor and Stator Assemblies.

(b) Name and address of the contractor:

General Electric Company

Doing Business As: GE Aviation

Military Systems Operation

1 Neumann Way

Cincinnati, OH. 45215

Cage Code: 07482

(c) Contract type: Firm Fixed-Price Purchase Order

(d) The estimated total cost of this requirement is $891,627

(e) Type of funding: Operations & Support (O&S)

(f) Year of funding: 2019

(g) Background: The HC-144 MPA is a medium range, twin engine turboprop aircraft used in search and rescue and maritime patrol missions. The rotor and stator assemblies are needed to support the USCG missions.

This requirement will be awarded in accordance with FAR Part 12, Acquisition of Commercial Items in conjunction with FAR Part 13.5, Simplified Acquisition Procedures for Certain Commercial Items.

(3) Description of Supplies/Services.

The proposed purchase order is for the overhaul of three (3) Gas Generator Rotor and Stator

Assemblies in support of the HC-144 MPA flight operations and missions.

The anticipated contract action will have an estimated total contract value of $891,627 to be funded with O&S funds. This requirement is a firm-fixed price purchase order in accordance with FAR part 12

Acquisition of Commercial Items and FAR Part 13.5 Simplified Procedures for Certain Commercial items. The item which comprises this requirement is listed below:

NSN Part Number Nomenclature QTY

2835-01-HS2-7638 5175T01G01 GG Rotor & Stator 3

(4) Identification of the Statutory Authority Permitting Other Than Full and Open

Competition.

The statutory authority permitting other than full and open competition is 41 U.S.C. 1901(c), as implemented in FAR 13.501 (a) “Sole source acquisition.”

(5) Demonstration that the proposed contractor’s unique qualification or the nature of the Acquisition Requires use of the authority cited.

In order to maintain structural integrity of the aircraft and ensure complete compatibility, the overhaul of the Gas Generator Rotor & Stator Assemblies listed in this requirement must be obtained from the

OEM or an OEM approved source. Use of OEM parts will ensure the Gas Generator Rotor & Stator

Assemblies are manufactured in accordance with OEM specifications and standards, conform to original form, fit, and function, and are compatible and interchangeable with existing components. For these reasons, it is in the USCG’s best interest and in the interest of the safety of our flight crews to procure only GE Aviation authorized services and parts.

(6) Description of Efforts made to Ensure that Offers are Solicited from as Many Potential

Sources as is Practicable.

This Justification for Other Than Full and Open Competition (J&A) will be posted on Federal Business

Opportunities (FBO.gov). Any responsible vendor may submit a quotation; all responsible offers will be considered. If any responses are received as a result of this solicitation, the file will be documented accordingly and the requirement competed among all eligible offerors.

This acquisition is forecasted in the Department of Homeland Security (DHS) Acquisition Planning

Forecast System (APFS), number F2019046434 published June 14, 2019 and can be found at www.apfs.gov.

http://www.apfs.gov/

(7) Determination by the Contracting Officer that the Anticipated Cost will be Fair and

Reasonable.

The Contracting Officer will determine the prices to be fair and reasonable based on prior acquisition history and from current published price lists.

(8) Description of Market Research.

Market research indicates the overhaul of the Gas Generator Rotor & Stator Assemblies is not listed on a General Services Administration (GSA) contract or available through GSA Advantage. Market research also consisted of querying the Industry Base System, Inventory Locator System (ILS), and previous procurement history. The marketplace search reveals only one vendor capable of providing the required overhaul. Market research shows that GE Aviation OEM is the only capable vendor to provide the required overhaul. Additional offerors must be authorized by the OEM, having access to current

OEM overhaul and repair manuals, and must be FAA Part 145 certified.

(9) Any other Facts Supporting the Use of Other Than Full and Open Competition.

The overhaul to be procured under this acquisition is highly specialized in nature, developed by a non-

Government activity and the technical data required for acquisition by other than the OEM is not available. The MRS Engineering Officer has determined that the required assemblies are critical for flight and has assigned an Acquisition Method Code (AMC) of 3 and Acquisition Method Suffix Code

(AMSC) of C. In accordance with DoD 4100.39 (series) Volume 10, Table 71, an AMC of 3 or 5 requires the purchases from the actual manufacturer or prime contractor only. An AMSC of C, Q, or R stipulates engineering source approval by the design control activity in order to maintain the quality of the parts.

(10) A Listing of Sources, if Any That Expressed, in Writing, an Interest in the

Acquisition.

A notice of intent will be submitted to FBO.gov upon approval of this document. Any responsible offeror capable of providing the overhaul for the Gas Generator Rotor & Stator Assemblies with parts traceability back to the OEM will be considered. If responses to the solicitation indicate additional sources are available, the file will be documented accordingly and the requirement competed among all eligible offerors.

(11) A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any

Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services.

The overhauls to be procured are complex and must meet critical operational and reliability requirements, the achievement of which require unique production techniques and extensive and/or sophisticated testing, and the Government has not yet acquired or developed the technical data. The

USCG will continuously conduct market research to ensure that companies interested in doing business with the USCG are given every opportunity to compete for future USCG requirements. In an effort to increase competition, HC-144 MPA program members intend to conduct internet database research and ensure procurements are advertised in FBO. In, addition, the USCG will investigate the feasibility of purchasing technical data from the OEM. If another potential source emerges, and the USCG is able to obtain the required technical data, the USCG will assess whether competition for any future requirements are feasible.