Redacted J and A - 70Z03824QB0000183.pdf

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

2024191-DC01

PROJECT/TASK

NUMBER

SRR

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

$35,251.04

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 following spare parts to be utilized on the MH-65 helicopters:

NIIN P/N Nomenclature Qty Opt. Qty

14-404-8831 366A68-1311-00 MRK.BEC.ANT.MOUNT 2 2

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 of supply known to have the capability of furnishing the required supplies. The USCG has determined that these parts can only be acquired from Airbus Helicopters, Inc.

Furthermore, the Government does not have adequate data or lacks rights to 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 spare parts to be procured 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 Original Equipment

Manufacturer (OEM) is not available. Airbus Helicopters France (F0210) is the OEM for the requested parts.

Therefore, procurement of any parts from other than the OEM or their authorized distributor, Airbus Helicopters, Inc. (3GSZ1), will compromise the safety of the aircraft and the crew. The solicitation and resulting purchase order will require all materials delivered to have clear, documented traceability to the OEM and a completed Certificate of

Conformance, certifying compliance with this contract condition, in accordance with FAR clause 52.246-15, Certificate of Conformance, which will be incorporated.

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 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.

These parts are proprietary to the OEM, Airbus Helicopters, Inc., and maintenance procedures were written specifically to interact with these parts. Based upon the technical certification on file, technical data is not available and cannot be developed to permit full and open competition.

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 required specifications of suitable alternate spare parts would not be sufficient for equipment 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 spare parts from manufacturers 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.

The OEM owns the proprietary data rights, specifications and drawings to these items which have limited the USCG’s ability to provide adequate technical descriptions to potential new manufacturers. Therefore, it is difficult to take steps to foster competition as the manufacturing, performance, and acceptance data are proprietary to the OEM.

SIGNATURE AND TITLE OF CUSTOMER

Carlton Colson

CODE

DC

TELEPHONE

335-6672

DATE

07/09/24

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE