Attachment 1 - Redacted JandA - 70Z03826RJ0000006.pdf

Last Updated 07/23/26 1

JUSTIFICATION AND APPROVAL FOR

OTHER THAN FULL AND OPEN COMPETITION

10 U.S.C. § 3204(a)(1) Procurement of T700-401D Engines

70Z03824DJ0000013

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-111) 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.

Department of Homeland Security, United States Coast Guard (USCG), Aviation Logistics Center (ALC), Medium Range Recovery (MRR) Product Line Division.

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

(a) Nature of the action: The USCG, ALC, MRR Product Line intends to modify contract 70Z03824DJ0000013 to increase the contract ceiling for the procurement of T700-401D Engines manufactured by General Electric Corporation (GE) for the current Indefinite Delivery Requirements type contract. GE is the only source capable of providing the required engines utilized on the USCG MH-60T aircraft.

The USCG awarded this contract (70Z03824DJ0000013) that consisted of a one

(1) year Base Period and four (4) one (1) year Option Periods. ALC has a need for the ceiling increase due to an unanticipated need for an additional one hundred and sixteen (116) engines. The first fifty-six (56) engines are needed due to the unanticipated requirement to support the MH-60R/CG program by providing Government Furnished Equipment (GFE) engines for production of the MH- 60R/CG aircrafts. The remaining sixty (60) engines would fully cover the recapitalization efforts to align the entire MH-60T fleet, mitigate constraints with the T700-401C engines, and provide sufficient inventory support.

This proposed increase to the contract will not result in any extension to the remaining periods of performance and all other terms and conditions shall remain unchanged. The changes made to this J&A are to update the estimated contract ceiling amount.

(b) Name and address of the contractor:

1 In this document, citations to RFO Parts 6, 10, 15, 25 are citations specifically to 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 25-09 Rev.1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

Attachment 1 - Redacted J&A - 70Z03826RJ0000006

Last Updated 07/23/26 3

This J&A makes no changes to the original description of supplies/services as outlined in the previous J&A that were approved on 04/22/2024 and 01/16/2026, which states that this requirement is for the purchase of T700-401D engines including shipping/storage containers. The engines are required for outfitting the USCG aircraft with the latest design/drawing revision authorized on the USCG MH-60T model.

The proposed increase to the current contract will support the unplanned order to deliver engines needed for the USCG’s growth of the MH-60R/CG aircraft, as well as upgrading the current fleet of MH-60T aircraft.

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 RFO Subpart 6.103-1 entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Identification of Exception to the Buy American Statute.

Not applicable.

6. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

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

GE is the sole design authority and the Original Equipment Manufacturer (OEM) of the T700-401D engines. The specifications, manufacturing drawing, data, test equipment, and tooling are proprietary to the OEM, GE. The USCG has contacted the OEM previously to inquire about the release of any proprietary technology to the USCG or any distributors. The OEM stated their technology is proprietary, and resale of the proprietary technology is prohibited to maintain integrity of the system, ensure compatibility of the replacement components and safe operation of the aircraft. No other part number can be utilized.

(b) Details covering what events lead to the situation requiring use of other than full and open competition procedures.

As stated below in section 6c, GE is the OEM and only Naval Supply Systems Command Weapon Systems Support (NAVSUP WSS) approved source. GE is the only source capable of providing the required engines. Therefore, no purchase can be segregated to allow for competition.

(c) Summary of Alternatives considered and why they will not work.

The engines are utilized throughout the MH-60T fleet and considered a flight Critical Safety Item (CSI) part. To successfully maintain airworthiness of the aircraft and aircraft systems, protect personnel safety, and perform the USCG’s mission, the acquisition of CSIs is restricted to the OEM. GE is the only NAVSUP WSS

Last Updated 07/23/26 4 approved source and there are no authorized distributors. Due to the critical state of the component and lack of data, GE is the only known source from which the Government can procure the engines. Therefore, no purchase can be segregated to allow for competition.

(d) Impact to the mission that would result if the J&A is not approved.

Failure to approve this justification will jeopardize the performance of the USCG’s H60 Program and the MRR Product Line’s mission to provide engines to the production of the MH-60R/CG aircraft and upgrade the entire fleet of MH-60T aircraft.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many

Potential Sources as is Practicable.

(a) The original APFS, F2023062885 for contract, 70Z03824DJ0000013, was published on 03/12/2024.

(b) This justification will be made publicly available on SAM.gov as required by 10 U.S.C.

3204(f). A notice of intent for the proposed action will be posted on SAM.gov informing industry of the Government’s intent to increase the contract ceiling... The USCG will make publicly available the justification required by RFO 6.305(a)(FAR Class Deviation 25-11).

8. Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable.

This J&A makes no changes to the original fair and reasonable justification on the previously approved J&A as it pertains to fair and reasonable costs which are as follows:

The Contracting Officer determines that the anticipated prices for this procurement will be fair and reasonable based on comparison of proposed prices to historical prices paid (RFO 15.404-1(b)(2)), comparison of proposed prices to the Independent Government Cost Estimate (IGCE) (RFO 15.404-1 (b)(5)), and analysis of other than certified cost and pricing data (RFO 15.404-1 (b)(7)).

9. Description of Market Research.

(a) This J&A makes no changes to the original Market Research of the previously approved

J&A. Market Research is still valid and hasn’t changed since 2024. GE is the only known source for the procurement of T700-401D engines. GE does not grant any proprietary data to any business, organization, person or commercial interest. To ensure the information from the Sources Sought Notice was still accurate, Asset Maintenance Management Information System (AMMIS), General Services Administration (GSA), Webflis vice FEDLOG, and FEDMALL were searched and no additional information was obtained regarding the procurement of T700-401D engines.

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

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(a) The MH-60T aircraft, including its engines, were procured and provisioned by USCG;

however, this procurement did not include the technical data packages, specifications, and documentation necessary to enable full and open competition. Therefore, it would be difficult to take steps to foster competition as the manufacturing performance and acceptance data are proprietary, as USCG does not have adequate technical data to provide to potential offerors.

(b) Any new engine must conform to the design data and quality requirements, or an unsafe condition could result which may cause damage to, or loss of, assets and significant injury or loss of life. The engines must meet all form, fit, and function requirements specified in the OEM manuals. Therefore, this requirement cannot be modified to enhance competition, as a risk to flight safety is never acceptable.

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

To date, there have been no inquiries regarding this procurement.

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.

The USCG does not possess the technical data required to foster full and open competition for the engines 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. In an effort to increase competition, MH-60T 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 are feasible.

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