Attachment 3 - Redacted J and A - 70Z03826QB0000050.pdf

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JUSTIFICATION AND APPROVAL FOR

OTHER THAN FULL AND OPEN COMPETITION

10 U.S.C. § 3205

SOLICITATION NO. 70Z03826QB0000050

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by Federal Acquisition Regulation (FAR) 12.102(b), FAR Class Deviation 25-21 Rev. 1 for

FAR Part 121, FAR 6.103, FAR Class Deviation 25-11 for FAR Part 6 and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under

RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Aviation Logistics Center (ALC), Short Range Recovery (SRR) Product Line Division prepared this justification for other than full and open competition.

2. Nature and/or Description of the Action being Approved.

(a) Nature of the action: The USCG, ALC, SRR Product Line Division intends to procure on a sole source basis various spare parts used on the

USCG MH-65E aircraft.

(b) Name and address of the contractor:

Airbus Helicopters, Inc. (AHI)

2701 N. Forum Drive

Grand Prairie, TX 75052-7099

Cage Code: 3GSZ1

(c) Contract Type: Firm Fixed-Price Indefinite Delivery Requirements Type

1 In this document, citations to RFO Parts 12, 6, 10, 15, and 25 are citations specifically to Federal Acquisition

Regulation (FAR) Class Deviation 25-21 Rev. 1 for FAR Part 12, FAR Class Deviation 25-11 for FAR Part 6, FAR

Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 Rev. 1 for FAR Part 15, and FAR Class

Deviation 26-09, Rev. 1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), which was implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

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(d) Estimated total value (including options):

Period Duration Total

Base Year 4 mo. $780,444

Option Year 1 12 mo. $842,879

Option Year 2 12 mo. $910,310

Option Year 3 12 mo. $983,134

Option Year 4 12 mo. $1,061,785

Total $4,578,552

(e) Type of funding: Operations and support funds

(f) Year of funding: Fiscal Year 2026 through 2030 funds will be used as appropriate.

(g) Solicitation number: 70Z03826QB0000050

(h) Background information about the requirement: The items in this requirement are various spare parts which provide effective supply support for the MH-65E

Aircraft.

3. Description of Supplies/Services. As the Aviation Inventory Control Point (AICP), ALC must provide effective supply support for all USCG aviation units and for the Programmed Depot Maintenance (PDM) Program. This requirement is to be awarded to AHI, the OEM’s only authorized distributor, that has access to the original OEM parts and can provide traceability. These various aircraft spare parts are crucial to meet the USCG’s many missions. The material and estimated quantities to be procured are based on current and past usage data. Projected stocking levels are based on failure and corrosion trends; current upgrades and modifications in process; experience and project scrap rates; and procurement lead times. Stock level recommendations are also obtained from the USCG’s forecasting tool to help ensure ALC can support all mission requirements. The part numbers for this requirement are listed in Attachment 1.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition. The statutory authority permitting other than full and open competition is 10 U.S.C. § 3205 as implemented by RFO Subpart 12.102(b) and RFO 6.103-1 entitled "Only one responsible source and no other supplies or services will satisfy the agency requirements" and in accordance with (IAW) the requirements of RFO 6.104.

5. Identification of Exception to the Buy American Statute.

This J&A requirement does not include the exception at RFO 25.103(b)(2) or RFO 25.202(a)(2) for the Buy American Act, due to the fact these parts are manufactured by a foreign entity.

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6. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited. ALC has a requirement to purchase, on a recurring basis, spare parts manufactured or supplied by the OEM, AHF.

AHF has one (1) authorized distributor for North American customers, their affiliates, AHI, located in Grand Prairie, TX (See Attachment 2). Additionally, it has all been identified through their Acquisition Method Code (AMC) and their Acquisition

Method Suffix Code (AMSC) as being sole source to the OEMs sole authorized distributor, Airbus Helicopters, Inc.

(a) The USCG self-certifies its’ aircraft in IAW standards established by the Code of

Federal Regulations (CFR) and the Federal Aviation Administration (FAA). The

CFR Title 14, Aeronautics and Space, Part 21, Certification Procedures for

Products and Articles, governs the procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificates, and airworthiness approval. 14 CFR 21 defines airworthiness approval as a document issued by the FAA for an aircraft, aircraft engine, propeller, or article which certifies that the aircraft, aircraft engine, propeller, or article conforms to its approved design and is in a condition for safe operation.

The USCG will only procure parts which have airworthiness approval. IAW 14

CFR 21.9, with limited exceptions, only a replacement or modification article produced under a type certificate or produced under an FAA production approval is suitable for installation on a type-certified product. The CFR Title 14, Subpart K, covers the procedures for the FAA Parts Manufacturer Approval (PMA). The FAA

PMA process is acceptable for an alternate manufacturer for the parts listed in this requirement, provided that the vendor submits a complete data package ensuring that the parts meets or exceed OEM specifications and subsequently, passes the

USCG form, fit, and function requirements. To date, there are no known approved

FAA PMA’s for the parts listed in this requirement.

Parts provided that do not meet the CFR and FAA requirements could compromise structural and system integrity of the aircraft, putting aircrew personnel and

Government property at risk. The USCG neither compromises nor makes exceptions in matter of human safety and protection of Government property and does not accept standards in these manners.

Use of OEM parts will ensure the parts are manufactured IAW OEM specifications and standards, conform to original form, fit, and function, and are compatible and interchangeable with existing components.

AHI is the only known vendor that can provide the traceability to the OEM as required by the CFR and FAA.

(b) The use of 10 U.S.C. 3205 implemented by the RFO 12.102(b), and RFO 6.103 entitled “Only One Responsible Source and No Other Supplies or Services Will

Satisfy Agency Requirements.” is necessary because AHI is the only OEM

Last Updated 07/09/26 4 authorized distributor in North America.

(c) In an attempt to promote competition, extensive market research was conducted.

However, because of the OEM having only one (1) authorized distributor, the probability of any distributors obtaining prices for the cage code(s) and part numbers in the requirement are unlikely.

(d) Alternate sources could not be considered due to the fact that there are no known approved FAA PMA for the parts in the solicitation that meet or exceed OEM specifications and subsequently, pass the USCG form, fit, and function requirements. In addition, there is only one (1) North American OEM authorized distributor. In order to maintain structural integrity of the aircraft and ensure complete compatibility of replacement parts, the parts listed in this requirement must be obtained from the OEM or an OEM approved source. Parts produced by another manufacturer will compromise structural and system integrity of the aircraft, putting aircrew personnel and Government property at a safety of flight risk. The USCG neither compromises nor makes exceptions in matter of human safety and protection of Government property and does not accept lower standards in these matters. Therefore, the mission will be impacted as a result of this J&A not being approved as stated above and not having these parts will negatively impact flight operations of the SRR aircraft and progress of PDM. In a fiscal and stockage environment requiring minimal investment in inventory, it is critically important to secure a reliable supplier that can satisfy the contract requirements needed to react to every-changing mission requirements.

(e) This J&A requirement does not include the exceptions at FAR 25.103(b)(2) for

FAR 25.202(a)(2) for the Buy American Act.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

(a) This procurement forecast was posted on the DHS-Acquisition Planning Forecast System (APFS), APFS No. F2025072100 at http://apfs.dhs.gov, originally published November 19, 2025, revised and published on March 11, 2026, and included in the DHS Forecast of Small Business Opportunities. There were no inquiries received in response to the published APFS.

(b) Announcement has not been posted to SAM.gov.

(c) The estimated date of publication is June 10, 2026.

(d) Not applicable. The exceptions under RFO 5.302 do not apply to this requirement.

8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable. The contracting officer determines that the anticipated price(s) will be fair and reasonable based on comparison to historical http://apfs.dhs.gov/

Last Updated 07/09/26 5 prices paid or similar items in a related industry.

9. Description of Market Research. IAW RFO Part 10, various methods of market research were launched for this requirement:

(a) Market research was conducted during January 2026. During this time extensive research was conducted through reviewing previous procurement history, internet searches, and discussions with the OEM. The USCG conducted a Program

Management Review (PMR) with AHI where it was determined there are no authorized distributors of these parts. Based on historical data and the OEM Letter, it has been determined that it is in the best interest of the Government to solicit this requirement on an other than full and open, sole source basis. The USCG will maintain open communications with the OEM and will continually conduct market surveys to identify possible additional sources that may eventually receive OEM authorization to sell Airbus Helicopter, France products to North American customers.

(b) This J&A requirement does not include the exceptions at RFO 25.103(b)(2) or RFO

25.202(a)(2) for the Buy American Act.

(c) Market Research was conducted.

(d) This requirement does not have or require patents, copyrights, and/or intellectual property.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

(a) The USCG does not own the necessary technical data required to support the manufacture of the required supplies. The drawings and technical data are proprietary and available only from the OEM. Due to proprietary rights, it will be difficult to take steps to foster competition.

(b) The parts in the schedule cannot be reversed engineered and/or modified by other sources, because in order to maintain structural integrity of the aircraft and ensure complete compatibility of replacement supplies, the parts listed in this requirement must be obtained from the OEM and their authorized distributors.

(c) This requirement is not a follow-on for the continued provision of highly specialized services pursuant to RFO 6.103-1(c)(2)(i).

(d) Not applicable to RFO 6.302-2(d) or HSAR 3006.302-270, this is not an unusual and compelling urgency.

11. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the

Acquisition. No other sources have expressed interest in this acquisition.

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12. 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 Required.

(a) Extensive internet database research was conducted, and requirements were advertised on Contract Opportunities (SAM.Gov). In support of the Competition in

Contracting Act, ALC established the New Product Development Branch (NPD), and a representative of the NPD Branch is assigned to the SRR Product Line. This representative has the responsibility to search for alternate sources of supply/services and alternate acceptable products. Engineering, Contracting, and NPD representatives continuously conduct market research to ensure that vendors interested in doing business with the USCG are given every opportunity to compete for requirements. NPD is exploring avenues of reverse engineering for some of the hard to find or expensive to repair items, which should further encourage competition, however, this process is lengthy, costly, and labor intensive.

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13. Technical/Requirements Personnel Certification.

I certify this requirement meets the Government's minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

Cox MAGGIE DAVIS 1598918410 Digitally signed byCOX.MAGGIE.DAVIS.1598918410

• • • Date: 2026.07.21 15:15:15 -04'00'

Maggie D. Cox Date Item Manager, USCG, ALC, SRR

14. Contracting Officer's Certification.

I certify this requirement meets the Government's minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

MOJICA.LUIS.NM Digitallysignedby

MOJICA.LUIS.NMN.1060994494

N .1 060994494 Date: 2026.07.21 15:19:18-04'00'

Luis Mojica Date

Contracting Officer, USCG, ALC, SRR

15. APPROVAL

Shreena L. Morris Date

Procuring Activity Advocate for Competition (P AAC)

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Solicitation No. 70Z03826QB0000050 Attachment 1

Part Number Nomenclature

704A34635034 CHECK VALVE

366D18707 CONNECTING LINK RIG

366-D-187-05 CONNECTING LINK RIG

A0212CD20E2AS ROD,BALL BEARING

121FS2917 ELECTRO VALVE

360A32-1657-01 BEARING,REAR TR TAK

TS13600 THERMO SENSOR

704A43211007 BOX,REGULATOR

704A34-121-003 PULL KNOB

360A32-1135-04 PAD,RTOR BRAKE

366A68-1311-00 MRK.BEC.ANT.MOUNT

704A43-211-013 PCB CONTROL

365A96-3160-00 STORAGE CONTAINER

704A34-635-037 VALVE

67-905-102-28 SELF SEALING COUPL

360A32-3656-22 WASHER,BEVEL WHEEL

365A32-5425-20 SPACER

DHS613-626-01 UNION

DHS613-626-22 UNION

366A25-1291-21 WINDOW GRIP

365A32-2046.Y1 BUSH,REPAIR

365A33-3548-20 PLATE

ECS2290BH100N NUT,HEXAGONAL

721D10-10S PLUG IN UNION

366A21-1100-2701 BASE PLATE LOWER LH

365A11-5088-23 SCREW,SPECIAL

366A25-4520-06 BACK PLATE ASSY,AFT

PS701-5059-001 PIN,SPECIAL

M1282-320-320L3 BALL JOINT

22731TK060040X PIN,THREADED

RA20A BALL

WC23 GASKET

ENM325701A HEAT SHIELD

SCU0172.3,5X6 HOSE

22719BC040010L PIN,STRAIGHT HEADED

19387 PIN

19010 BOLT

P1D0460210 PROBE,TEMP,HYDRAULI

Aéroport International Marseille-Provence, 13725 Marignane Cedex, France www.airbushelicopters.com

Airbus Helicopters, société par actions simplifiée au capital de

586 212 416,10 Euros – R.C.S. Aix-en-Provence 352 383 715

Aéroport International Marseille-Provence 13725 Marignane Cedex Commercial Operation Distribution & Services Network

Our Ref: EBONL 0032-2026

Subject: Airbus Helicopters Products for H-65 and Drawing Design Rights.

Airbus Helicopters has authorized our U.S. affiliate, Airbus Helicopters, Inc., in Grand Prairie, Texas, to be the only approved source of supply in North America for parts and products for the H-65 aircraft. AH and AHI, as the OEM of the H-65 aircraft, cannot be held liable, provide part certification or warranty protection on parts purchased from brokers, vendors, or any third parties.

AH and AHI will not release drawings or data rights to any outside third party for the purpose of reverse engineering or re-manufacturing under a different part number.

If you have any questions, please do not hesitate to contact us.

Thank you again for the opportunity to support the Coast Guard mission.

Sincerely yours, Valery DELISLE Airbus Helicopters Commercial Operations Partners Network Animation Head of North & South America, Africa & Middle East Mobile : 33 6 71 36 08 41 Email : valery.delisle@airbus.com

Marignane, January 15th 2026

Mr Kristen R. Copeland Supervisory Contracting Officer US Coast Guard Aviation Logistics Center Short-Range Recovery Division Elizabeth City, North Carolina 27909

Attachment 2