Redacted Justification for Other Than Full and Open Competition.pdf

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JUSTIFICATION AND APPROVAL FOR

OTHER THAN FULL AND OPEN COMPETITION

70Z03827QH0000001 Purchase of Gear Boxes

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 6.104, FAR Class Deviation 25-11 for FAR Part 6, the following facts and rationale are presented in accordance with Revolutionary FAR Overhaul (RFO) 6.104 requirements:

1. Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Aviation Logistics Center (ALC), Long Range Surveillance (LRS) Product Line (PL), proposes to enter into a contract on a basis other than full and open competition.

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

(a) Nature of the action: The USCG, ALC, LRS PL requests approval to solicit and award on a sole source basis, a Firm-Fixed Price contract for the procurement of Gear Box Assembly, Main Landing Gear (MLG) (P/N 8521) and Gearbox, Landing (PN: 8348M1) used on the HC-130J aircraft.

(b) Name and address of the contractor:

CEF Industries LLC.

320 Church St., Addison, IL 60101

Cage Code: 00268

(c) Contract Type: Firm Fixed-Price Contract

(d) Estimated total value (including options):

(e) Type of funding: Procurement, Construction, and Improvements (PC&I) funds

(f) Year of funding: Fiscal Year 2027

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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(g) Solicitation number: 70Z03827QH0000001

(h) Background information about the requirement: The USCG, ALC, LRS PL supports the HC-130J aircraft by providing logistics, inventory management and sustainment support for the USCG aviation assets utilized by Air Stations geographically located in and outside the continental United States. As part of this responsibility, the LRS PL has a requirement for sustainment of numerous components used on the aircraft, which includes Gear Box, MLG and Gearbox, Landing. The requirements under this justification were previously satisfied through individual purchase orders.

3. Description of Supplies/Services.

This requirement is for the procurement of Gear Box Assembly, MLG and Gearbox, Landing used on the HC-130J aircraft. Gear Box Assembly, MLG and Gearbox, Landing are integral to the landing gear system on the HC-130J.

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. § 3204(a)(1) implemented by the RFO Subpart 6.103-1 entitled One Responsible Source and No Other Supplies or Services Will Satisfy Agency

5. Identification of Exception to the Buy American Statute.

This requirement for the procurement of Gear Box Assembly, MLG and Gearbox, Landing does not take exception listed under FAR 25.103 (b) or FAR 25.202(a)(2). Therefore, the Buy American Act will be included in terms and conditions of this requirement.

6.

the acquisition requires use of the authority cited.

(a) Rationale for using the authority cited in section 4 of the J&A. Do not duplicate language already used.

CEF Industries, LLC is the Original Equipment Manufacturer (OEM) for the actuators, gear boxes and ball screws utilized on the HC-130J. All specifications, manufacturing drawings, test equipment, and tooling required to manufacturer this item are proprietary to CEF Industries, LLC. The USCG did not purchase the rights to the proprietary data required to foster a competitive environment as part of any original provisioning for use on the HC-130J aircraft. To maintain integrity of the system, ensure compatibility of the replacement components and safe operations of the aircraft, this item must be procured by the OEM, CEF Industries, LLC or their authorized distributors.

(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;

LRS Engineering Officers have determined that interested parties must have continuous access to OEM manuals, specifications, and data to provide the factory new, gear boxes in this requirement. The USCG is prohibited from

Last Updated 09/01/26 3 disclosing any technical documents in their possession as these were developed at private expense by CEF Industries, LLC and are proprietary. For these reasons, other than full and open competition procedures are necessary for this requirement, and no portion of this procurement can be segregated to allow for competition.

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

The use of alternate parts from third-party suppliers or alternate manufacturers was deemed unacceptable due to not meeting required specifications and certifications for use on the HC-130J. The OEM, CEF Industries, LLC as well as three (3) authorized distributors: Dyess Aviation, Inc.; All Clear Aerospace & Defense, Inc.;

and Satair USA Inc. are the only sources to provide this requirement.

(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 grounding of aircraft as a result of insufficient stock being available as Gear Box, MLG and Gearbox, Landing are required for the HC-130J.

(e) (Section is required to be completed when the J&A includes the exception listed under RFO 25.103(b)(2) or RFO 25.202(a)(2)) Rationale for use of the nonavailability exception to the Buy American statute, including detailed information explaining why the particular articles, materials, or supplies of the class or kind to be acquired, either as end items or components, are not mined, produced, or manufactured in the United States in sufficient and reasonably available commercial quantities and of a satisfactory quality.

The exceptions under RFO 25.103(b)(2) or RFO 25.202(a)(2) do not apply to this requirement.

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.

P2027075999 was entered 10/19/2026

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

Sources Sought Notice 70Z03826IH0000021 was posted to SAM.gov on 05/06/2026 and closed on 05/20/2026

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

It is anticipated that a solicitation will be posted to the GPE via SAM.gov on approximately 10/28/2026. Any capability statement or quote received in response to the combined synopsis/solicitation will be considered prior to award.

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

The exceptions under RFO Part 5 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 prices will be fair and reasonable based on comparison of proposed prices that were found fair and reasonable on previous purchases in accordance with (IAW) FAR 15.404-1(b)(2)(ii), as well as in comparison to the IGCE IAW FAR 15.404-1(b)(2)(v), and pricing obtained through market research for the same items IAW FAR 15.404-1(b)(2)(vi).

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 the market research to determine price reasonableness.

Market research was conducted IAW FAR Part 10 (FAR Class Deviation 25-06) from February through March 2026. Market research indicates that the procurement of the Gear Box Assembly, MLG and Gearbox, Landing identified in this requirement is not listed on a General Services Administration (GSA) contract or available through GSA Advantage. Market research also consisted of querying the Acquisition history, Internet Search, Inventory Locator System (ILS), Catalog and product literature, DHS-Wide and Multi-Components Contract Vehicles, Excess from Other Agencies, AbilityOne, and Contracting Opportunities. These searches revealed no alternate supply sources. The OEM and authorized distributors are the only approved source to provide the Gear Box Assembly, MLG and Gearbox, Landing. The procurement of this requirement for the HC-130J aircraft is commercial in nature and is prevalent in private aviation and commercial aviation.

All terms and conditions are not expected to differ from customary terms and conditions in the marketplace or standard Government practices.

Sources sought notice 70Z03826IH0000021 was posted to SAM.gov on 05/06/2026 and closed on 05/20/2026. The sources sought notice received two (2) timely responses. None of the responses were determined capable. CEF Industries, LLC, Dyess Aviation, Satair USA or All Clear Aerospace and Defense did not respond to the Sources Sought Notice. Through email correspondence with CEF Industries, LLC., it was confirmed that they are the OEM and that the technical data for the required components is proprietary. There are three (3) authorized distributors:

Dyess Aviation, Inc.; All Clear Aerospace & Defense, Inc.; and Satair USA Inc.

These are the only approved sources for the components.

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(b) (Section is required to be completed when the J&A includes the exception listed under RFO 25.103(b)(2) or RFO 25.202(a)(2)). Describe the market research results that support the determination that the items are nonavailable.

The exceptions under RFO 25.103(b)(2) or RFO 25.202(a)(2) do not apply to this requirement.

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

Not applicable. Market research was conducted IAW FAR Part 10 from February through March 2026 and again October 2026.

(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.

This requirement does not have patents, copyrights, and/or intellectual property.

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.

The gear boxes to be procured under this acquisition is highly specialized in nature and developed by a non-Government activity. The technical data required to procure new, manufactured items from sources other than the OEM is not available. Through email correspondence with CEF Industries, LLC., it was confirmed that they are the OEM and that the technical data for the required components is proprietary. There are three (3) authorized distributors: Dyess Aviation, Inc.; All Clear Aerospace & Defense, Inc.; and Satair USA Inc. These are the only approved sources for the components. CEF Industries LLC has not shown an interest in selling or providing the proprietary data rights to the Government or any other entity. It is not economically feasible for the USCG to purchase these proprietary rights.

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

The Gear Box Assembly, MLG and Gearbox, Landing to be procured is complex and must meet critical operational and reliability requirements, the achievement of which requires unique production techniques and extensive and/or sophisticated testing. The Government has not yet acquired or developed the technical data. If another potential source emerges, and the USCG is able to obtain the required technical data, the USCG will assess whether competition for any future requirement is feasible.

(c) For a proposed contract subject to the restrictions of RFO 6.103-for follow-on acquisitions as described in 6.103-1(c)(2)(i), all components must provide an estimate of the cost to the Government that would be duplicated and detailed information on how the estimate was derived.

This requirement is not subject to the restrictions of RFO 6.103-1 as described in 6.103-1(c)(2)(i).

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(d) For a proposed contract subject to the restrictions of RFO 6.103-2(c) or HSAR 3006.103- 2(c)(70), HSAR Class Deviation 25-01 and where RFO 6.103-2 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.

This requirement is not subject to the restrictions of RFO 6.103-2(c) or Homeland Security Acquisition Regulations (HSAR) 3006.103-2(c)(70), HSAR Class Deviation 25-01.

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

A sources sought notice was issues in Contract Opportunities on SAM.gov on 05/06/2025 and closed on 05/20/2026 requesting that parties expressed their interest in writing to the Contracting Officer. Two (2) timely responses were received during the duration of the Sources Sought Notice. CEF Industries, LLC or the three (3) authorized distributors did not respond to the Sources Sought Notice, but it was previously confirmed through email correspondence with CEF Industries, LLC., that they are the OEM and that the technical data for the required components is proprietary. The three (3) authorized distributors include: Dyess Aviation, Inc.; All Clear Aerospace & Defense, Inc.; and Satair USA Inc.

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 required to foster full and open competition for the procurement of the Gear Box Assembly, MLG and Gearbox, Landing covered under this justification and approval. 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, program members conduct internet database research and ensure procurements are advertised in SAM.gov.

If another potential source emerges and the USCG is able to obtain the required technical data. The USCG will assess whether competition for any future requirements is 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.

Not applicable to this requirement.

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13. Technical/Requirements Personnel Certification.

which forms a basis for this justification, is complete and accurate.

14. and Approval

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.