JOTFOC_STRATTON_P45449.DOCX

Justification for Other than Full and Open Competition Simplified Acquisition Threshold

1. Vessel: CGC STRATTON(WMSL-752)

2. PR# 2118858P45449

3. Description of Supplies or Services:

This work item describes the requirements for the Contractor to perform DEI (Diesel Engine Inspection) on both Main Propulsion Diesel Engines (BMPDE). Main Propulsion Diesel Engine, Injector, Renewal, Main Propulsion Diesel Engine, High Pressure Intercoolers, Air Side, Chemical Cleaning & Inspection, and Main Propulsion Diesel Engine, Low Pressure, Intercooler, Air Side, Chemical Cleaning & Inspection

4. Estimated Value of Procurement: $

5. Sources Available: MTU America Name: MTU America

6. Pursuant to FAR Subpart 13.106-1 (b), the Contracting Officer may solicit from one source if they determine that the circumstances of contract action deem only one source reasonably available:

Check the appropriate reason below:

7. Impact Statement (describe the impact on the mission or property)

The USCG and non-original equipment manufacturer (OEM) contractors do not have the technical expertise to conduct the maintenance required on these engines. Attempting to complete this work without OEM proprietary data or using other than OEM parts could cause failure to occur; degradation to the vessel's primary mission could result in a failure to meet USCG operational commitments.

8. Explain why an adequate purchase description or other information suitable to solicit by Full and Open Competition has not been developed or are not suitable.

Extensive market research has been conducted. MTU is the OEM for these engines as well as required parts for this maintenance.

9. Provide a Statement of Actions, if any, the government may take to remove or overcome any barriers to competition before future acquisitions are required.

MTU America was the designer and integrator of the WMSL Main Propulsion system. Because of the complexity and extensive amount of work, MTU America is the only source who can complete the required work within the designated performance period safely, proficiently, and with an acceptable risk to USCG's financial and operational readiness.