Redacted J and A - 70Z03824QB0000125.pdf

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MH-65 RETREAD
Solicitation number
70Z03824QB0000125
Issued by

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This document is a Justification for Other Than Full and Open Competition under Simplified Acquisition Procedures, supporting a restricted solicitation for the repair (retread) of 52 MH-65 helicopter Main Landing Gear (MLG) Tubeless Tires, with an option for up to 250 additional tires. The requirement can only be met by Wilkerson Company, Inc. (CAGE: 61135), as they are the only known source with the necessary technical drawings, specifications, and OEM-approved repair capabilities. The USCG does not possess the data rights to provide to potential new sources, and the cost to procure them would be prohibitive. The estimated value of the contract is $51,340. The solicitation, 70Z03824QB0000125, will be issued as a Request for Quotation with a closing date of April 1, 2024. The USCG Ombudsman Program is available for filing agency protests.

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Text version

March 8, 2023 Version

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. Do not use marketing language in this document. Language such as “This company has made its mark,” “This company is recognized as industry’s best,” and “This company is the leader in…” is unacceptable.

PURCHASE REQUEST OR REQUISITION

NUMBER

2024078-DD03

PROJECT/TASK

NUMBER

H65

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

$51,340.00

CITE AUTHORITY & JUSTIFICATION TYPE – READ FAR 6.302 TO DETERMINE APPROPRIATE TYPE

10 U.S.C. § 3204(a)(1)

ONLY ONE RESPONSIBLE SOURCE AND NO OTHER SUPPLIES OR SERVICES WILL SATISFY

AGENCY REQUIREMENTS.

☐ 10 U.S.C. § 3204(a)(2) UNUSUAL AND COMPELLING URGENCY

10 U.S.C. § 3204(a)(3)

INDUSTRIAL MOBILIZATION; ENGINEERING, DEVELOPMENTAL, OR RESEARCH CAPABILITY; OR

EXPERT SERVICES

☐ 10 U.S.C. § 3204(a)(4) INTERNATIONAL AGREEMENT

☐ 10 U.S.C. § 3204(a)(5) AUTHORIZED OR REQUIRED BY STATUTE – MUST PROVIDE IT

☐ 10 U.S.C. § 3204(a)(6) NATIONAL SECURITY

☐ 10 U.S.C. § 3204(a)(7) PUBLIC INTEREST [SECRETARY OF HOMELAND SECURITY NEEDS TO APPROVE THIS DOC]

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

This procurement is for the repair (retread) services of Fifty-Two (52) [with an option for additional quantity of Two Hundred and Fifty (250)] MLG Tubeless Tires (P/N: DR30020T, NSN: 2620-01-HS1-

3610) to be used on the MH65 helicopters.

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

SUPPLIES OR SERVICES CAN BE USED.

The items to be repaired under this solicitation can only be completed by a company with access to all applicable maintenance manuals and has been approved by the Original Equipment Manufacturer (OEM) and USCG SRR Engineering. At this time, the only known repair facility capable of repairing these MLG

Tubeless Tires is Wilkerson Company, Inc. (Cage: 61135).

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).

Historical data shows Wilkerson Company, Inc. is the suggested source of supply for the repair of the parts on this requirement and the only known source authorized to repair the parts in accordance with

OEM specifications. Wilkerson Company, Inc. has designed drawings and specifications that have been approved by SRR Engineering. Wilkerson Company Inc. has maintained their status as the only source qualified to fulfill this requirement in that they are the only known contractor with proprietary data required to perform the work, which is vital for the continued operational readiness of the aircraft. If any other potential sources are found, they will be evaluated by SRR Engineering to whether or not they can repair these MLG Tubeless Tires as per SRR Engineering approved drawings and specifications.

https://www.acquisition.gov/far/part-6#FAR_6_302 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204

March 8, 2023 Version

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

The USCG did not purchase data rights as part of the initial system acquisition of the MH-65 helicopter.

The USCG does not possess adequate technical drawings and specifications to provide to potential new sources and is unable to provide proprietary repair information to outside vendors. Due to the maturity of the MH-65 platform, the cost to procure data rights, presuming they would be made available, would be cost prohibitive.

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.

As stated above, the USCG did not purchase data rights as part of the initial system acquisition of the MH-

65 helicopter. The USCG does not possess adequate technical drawings and specifications to provide to potential new sources and is unable to provide proprietary repair information to outside vendors. Due to the maturity of the MH-65 platform, 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.

The USCG does not possess adequate technical drawings and specifications to provide to potential new repair sources and is unable to provide proprietary information to outside vendors. Therefore, it is difficult to take steps to foster competition.

SIGNATURE AND TITLE OF CUSTOMER

Robert E. Askew Jr.

CODE

IM DD/DV

TELEPHONE

NUMBER

(252) 334-5406

DATE

19 Mar 2024

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

NUMBER

DATE

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