Attachment 5 - JA.pdf

August 2020

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

Offline / 2021314-PM01

PROJECT/TASK

NUMBER

IOD

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

$138,802.62

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), Industrial Operations Division (IOD) anticipates the award of a firm-fixed price contract 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)(2) – 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.

The USCG, ALC, IOD has a requirement on a sole source basis for the annual maintenance of the Pauli Blast Booth and Blast Cabinet Systems utilized in the ALC stripping shop.

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

SUPPLIES OR SERVICES CAN BE USED.

The Pauli Blast Booth System and Blast Cabinet can only be maintained, calibrated, and repaired by a company that has access to the Original Equipment Manufacturer (OEM)’s maintenance manuals and is an approved source to complete the maintenance. At this time, the only company capable of completing the aforementioned tasks on the Pauli Blast Booth System and Blast Cabinet is the OEM, Pauli Systems Inc. (CAGE Code: 06UZ8).

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 (WebFLIS); 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.

These services are not available from any mandatory Government source IAW FAR 8.002 or from any non-mandatory source IAW FAR 8.004.

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

Pauli Systems Inc. possesses the proprietary rights to the drawings and specifications needed to perform the required maintenance. Pauli Systems Inc. is the OEM and the only source with the necessary proprietary data, 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 stripping shop which supports the aircraft at ALC.

August 2020

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 USCG did not purchase data rights as part of the initial system acquisition of the blast booth system. The USCG does not possess adequate technical descriptions to provide to potential new sources and is unable to provide proprietary information to outside vendors. This information must be obtained directly from the OEM, Pauli Systems Inc. The cost to procure data rights, presuming they would be made available, would be cost prohibitive.

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 stated above, the OEM, Pauli Systems Inc., possesses the proprietary rights to the blast booth system which has limited the USCG’s ability to provide adequate technical descriptions to potential new sources. Therefore, it is difficult to take steps to foster competition as the manufacturing, repair, performance and acceptance data are proprietary to the OEM, Pauli Systems Inc. A solicitation will be posted to the Federal Business Opportunities website in order to solicit potential sources as a means of providing the service.

SIGNATURE AND TITLE OF CUSTOMER

Peter W. Murray

Inventory Management Specialist

CODE

TELEPHONE

NUMBER

(252) 334-5194

DATE

11/10/2021

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

NUMBER

DATE