70Z03826QW0000109 - Attachment 3 -Redacted J and A.pdf

SOLE SOURCE ACQUISITION

Field Service Representative and Technical Services to support the C-27J aircraft

Solicitation 70Z03826QW0000109

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In compliance with Federal Acquisition Regulation (FAR) 12.102(b) (FAR Class Deviation 25-21), the written justification and approval, in accordance with FAR 6.104-1 (FAR Class Deviation 25- 11), is provided as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security, 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 other than full and open competition.

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

(a) Nature of the action: The USCG intends to procure on a sole source basis Field Service Representative (FSR) and Technical Services to support the C-27J aircraft.

(b) Name and address of the contractor:

Leonardo Spa (Leonardo) Piazza Monte Grappa Rome Italy 00195 Cage Code: A1512

(c) Type of action: Firm Fixed Price, Indefinite Delivery Requirement Contract

(d) Estimated total value (including options) $4,112,159 broken down as follows:

Period Yearly Total Base Year 12 months $1,435,455 Option Year 1 12 months $1,464,164 Option Year 2 12 months $1,212,540

Services are currently provided under USCG contract 70Z03821DW0000001 with a period of performance end date of April 30, 2026.

(e) Type of funding: Operations and Support funds

(f) Year of funding: Fiscal Year 2026

(g) Solicitation number: 70Z03826QW0000109

(h) Background information about the requirement: The USCG currently operates a fleet of ten (10) C-27J fixed wing aircraft. The operational position of these aircraft is expected to decrease over the next three years. These specialized, high demand, aircraft currently enable the USCG to perform missions such as search and rescue, law

Last Updated 11/21/25 2 enforcement, international ice patrol, marine environmental protection, and marine resource conservation. This requirement is critical to have all C-27J aircraft operational and continuing their operational capability. The services under this justification were previously awarded as a Requirement type contract under contract 70Z03821DW0000001 that expires on April 30, 2026.

3. Description of Supplies/Services.

The contractor will provide services for FSR and Technical Services to support the C-27J aircraft fleet maintenance and operational requirements.

4. Identification of 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 as implemented in Federal Acquisition Regulation (FAR) 12.102, “Sole Source Acquisitions”.

5. Identification of Exception to the Buy American Act.

The Buy American Act is not applicable.

6. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Require Use of the Authority Cited.

(a) Rationale for using the authority cited in section 4 of the J&A;

The C-27J was designed, manufactured, and integrated exclusively by Leonardo, a multinational company specializing in aerospace, defense and security. The C-27J structural design, electrical architecture, and overall system build is a product of Leonardo, and as such, only Leonardo has the technical expertise to troubleshoot, repair and direct USCG personnel on conditions exclusive to the USCG C-27J aircraft.

(b) Details covering what events lead to the situation requiring use of other than full and open competition procedures including whether any portion of the work can be segregated to allow for competition.

Due to the critical and proprietary nature of the C-27J Engineering Services and Field Service Representative (FSR) support, only a contractor with direct access to proprietary manufacturer drawings, information, and Original Equipment Manufacturer (OEM) can fulfill the Government’s needs. These circumstances have resulted in Leonardo being the only contractor capable of providing the necessary sustaining engineering and FSR support for technical questions and engineering service requests. The unique access and expertise required for this work prevents the requirement from being segregated or competed among other vendors.

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(c) Summarize alternatives considered and why they will not work.

This requirement is for Technical Services and FSR support for the C-27J aircraft. This requirement is restricted to the OEM; there are no alternatives to acquire these services from other than the OEM due to the proprietary data and maintaining airworthy condition of the aircraft.

(d) Impact to the mission that would result if the J&A is not approved and, consequently, the product or service not provided.

Failure to approve this sole source Justification for Other Than Full and Open Competition will jeopardize the performance of the USCG’s mission due to grounding of aircraft. Grounding the C-27J aircraft would severely limit the USCG’s ability to perform its core missions, particularly search and rescue operations. Without access to necessary engineering services and technical support, the aircraft could not be maintained in an airworthy condition, resulting in reduced operational fleet availability. This would directly hinder the USCG’s capacity to respond quickly to emergencies, locate and rescue individuals in distress, and provide critical support during natural disasters or maritime incidents. Ultimately, grounding these aircraft would compromise the safety of the public and diminish the USCG’s effectiveness in fulfilling its mission requirements.

(e) Section is required to be completed when the J&A includes the exception listed under FAR 25.103(b)(2) or FAR 25.202(a)(2)).

Not applicable

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

(a) If an entry was made in APFS, provide the publication date.

This acquisition is forecasted in the Department of Homeland Security (DHS) Acquisition Planning Forecast System (APFS), number F2025070488 published on July 23, 2025, and revised on August 20, 2025, and can be found at https://www.apfs.gov. There were no responses received as a result of the APFS posting.

(b) If an announcement has already been made in SAM.gov, provide the publication date.

Not Applicable.

(c) If an announcement is being planned for posting in SAM.gov, provide the estimated publication date.

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The Justification for Other than Full and Open Competition (J&A) will be posted to the Government-wide Point of Entry (GPE), via https://www.sam.gov under solicitation 70Z03825QW0000109 with an estimated publication date of February 2, 2026.

(d) If an announcement will not be published, identify the applicable exception under FAR Part 5.

Not Applicable.

8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The prices will be determined fair and reasonable based on comparison with prior contract pricing and the Independent Government Cost Estimate (IGCE).

9. Description of Market Research.

(a) Describe the market research techniques used, results, date(s) when the market research was conducted, and how the Contracting Officer used it to determine price reasonableness.

The USCG posted a Sources Sought Notice (SSN) to identify potential offerors for C-27J Engineering and Field Service Representative (FSR) support. Of the three offerors who responded, only Leonardo Spa, the aircraft’s OEM, met the requirements. Other offerors provided incomplete responses and could not provide the technical support and FSR services needed for this requirement due to the proprietary data. Market research, including reviews of similar contracts and industry practices, confirmed that only the OEM can provide the necessary proprietary technical services to maintain airworthiness and ensure safety. No alternatives are available due to the proprietary nature of the required data and support.

(b) Describe the market research results that support the determination that the items are

Not applicable.

(c) If market research was not conducted, state why.

Not applicable.

(d) If patents, copyrights, and/or intellectual property are applicable to the acquisition, describe the circumstances for acquiring a patented or copyrighted product on the representation of the intellectual property holder that has not been licensed for resale and consult with the Coast Guard IP attorney.

Not Applicable

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

(a) An explanation why technical data packages, specifications, statement of work, or purchase descriptions are not suitable for full and open competition.

Leonardo Spa is the only approved source that can provide the FSR and Technical services needed for the C-27J aircraft. The technical data, engineering specifications, and technical drawings are primarily proprietary to the OEM, Leonardo. This contract requires access to the technical data to maintain and support the C-27J aircraft and its operational missions. The USCG did not purchase and was not provided with the opportunity to purchase full data usage rights as part of the acquisition of the C-27J aircraft. As a result, the USCG cannot foster full and open competition for this effort, as the manufacturing, operational, technical data are proprietary, and the USCG does not possess adequate and appropriate technical data to provide to potential offerors. The services to be provided under this acquisition are highly specialized and are only available from the OEM Leonardo. Therefore, this requirement is not suitable for full and open competition. The technical data package, including drawings, specifications, manuals, and publications required to develop additional sources to provide these services were not procured by the government and are proprietary to the OEM.

(b) Discuss why your requirement cannot be modified to enhance competition.

This requirement cannot be modified to enhance competition because data rights and technical data are not available from anyone other than the OEM, or an OEM authorized distributor.

(c) For a proposed contract subject to the restrictions of FAR 6.103-1 (FAR Class Deviation 25-

11) for follow-on acquisitions as described in 6.103-1(c)(2)(i) (FAR Class Deviation 25-11), provide an estimate of the cost to the Government that would be duplicated and detailed information on how the estimate was derived.

(d) For a proposed contract subject to the restrictions of FAR 6.103-2(c) (FAR Class Deviation 25-

11) or HSAR 3006.103-2(c)(70) (HSAR Class Deviation 25-01) and where FAR 6.103-2 (FAR Class Deviation 25-11) is cited as the authority, describe the exceptional circumstances allowing for an award for a period of performance in excess of the one-year limitation (applicable to all federal agencies) or the DHS-specific statutory 150-day limitation.

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

SSN 70Z03825IL0000005 was posted on SAM.gov on July 25, 2025, with a response date of August 06, 2025. The USCG received three (3) responses from BHPE, LLC, NAAS, LLC and Leonardo Spa. However, only one (1) source is able to provide the FSR and Technical Services needed for this requirement. An email from the OEM Leonardo Spa dated November 20, 2025, stated that only Leonardo Spa can provide the services needed.

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) Will the Government revise overly technical specifications, acquire data rights, etc.?

The USCG does not possess the technical data or expertise required to perform or compete the FSR and Technical Services pertinent to this J&A. 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. To increase competition, C-27J Engineering Division members intend to annually attend aviation trade show, conduct internet research, and ensure procurement requirements are published on SAM.gov. If other potential sources emerge, and the required technical data becomes obtainable, the USCG will assess whether competition for any future requirements are feasible.

(b) When a J&A is issued for the purposes of acquiring goods or services while a competitive procurement is being conducted, the justification should include a detailed timeline for completion of the competitive procurement. The period of performance for the sole source action should fairly balance the time needed to complete the competitive procurement.

The focus should be on minimizing the need for additional sole source awards.