Attachment 2 - Redacted J and A - 70Z03823QJ0000277.pdf

August 2020

ATTACHMENT 2 - REDACTED J&A - 70Z03823QJ0000277

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIMPLIFIED ACQUISITION PROCEDURES (SAP) FAR 13.106-1(b)

SOLICITATIONS MAY BE LIMITED TO ONE SOURCE ONLY IF THE CONTRACTING OFFICER DETERMINES THAT ONLY ONE SOURCE IS REASONABLY AVAILABLE. THIS DETERMINATION MUST BE SUPPORTED WITH FULL JUSTIFICATION FOR SOLE SOURCE FROM THE CUSTOMER. WHEN THE CUSTOMER DESCRIBES AN ITEM WITH A PURCHASE DESCRIPTION WHICH LIMITS THE AVAILABILITY TO ONE SOURCE, THE JUSTIFICATION MUST EXPLAIN WHY THE ITEM IS THE ONLY ONE THAT WILL MEET THE GOVERNMENT’S REQUIREMENT. STATEMENTS SUCH AS "ONLY KNOWN SOURCE" OR "ONLY SOURCE WHICH CAN MEET THE REQUIRED DELIVERY

DATE" ARE INADEQUATE TO SUPPORT A SOLE SOURCE PURCHASE.

PURCHASE REQUEST OR REQUISITION NUMBER

PROJECT/TASK

NUMBER

ESTIMATED AMOUNT (Over Micro-Purchase Threshold, but up to the SAT)

IDENTIFICATION OF THE AGENCY AND THE CONTRACTING OFFICE, AND SPECIFIC IDENTIFICATION OF THE DOCUMENT AS A “JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION.” PLEASE CITE THE

AUTHORITY AND TYPE OF JUSTIFICATION.

Commanding Officer, USCG Aviation Logistics Center (ALC), Medium Range Recovery (MRR) Procurement Branch, intends to award a firm-fixed price purchase order on a sole source basis. The statutory authority permitting other than full and open competition is 41 U.S.C. 1901(c), as implemented in FAR 13.106-1(b) (1).

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE.

ALC MRR intends to procure these item(s) on a sole source basis. This requirement is for item(s) used on the MH-60T aircraft. The item(s) are required for replacement during routine maintenance because of failures/corrosion/damage.

QTY Ordered Option Qty Increase Description NSN Part Number

5 EA 5 EA DOOR MOD. WEATHER RA 1560-01-HS1-3807 27426/5790066-501

UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON NO OTHER

SUPPLIES OR SERVICES CAN BE USED.

These item(s) that are to be procured under this acquisition are highly specialized item(s) which have been designed and manufactured by Helicomb International Inc. (Cage Code 6W159). As the Original Equipment Manufacturers (OEM) of these item(s) Helicomb International Inc., owns all rights to the technical data, specifications, and drawings required for their manufacture. The rights to the technical data necessary to have these item(s) manufactured by Helicomb International Inc. are not owned by the Government and it has been determined that it is uneconomical to purchase these rights. These item(s) are the only ones approved by the USCG’s Aircraft Configuration Control Board for use on the MH-60T helicopter.

A DESCRIPTION OF EFFORTS MADE TO ENSURE THAT QUOTATIONS OR OFFERS ARE SOLICITED FROM AS MANY

POTENTIAL SOURCES AS PRACTICABLE (INCLUDE YOUR MARKET RESEARCH EFFORTS HERE).

Extensive market research was conducted using both Government and commercial sources. This included querying the following information systems and web sites: Defense Logistics Agency (DLA) Federal Logistics Data; DLA FedMall; the General Services Administration’s (GSA) online purchasing service – GSA Advantage®;

Inventory Locator Service e-marketplace (ILSmart); internet search engines; and the OEM’s web site. A combined synopsis/solicitation will be posted to the Sam website at www.Sam.gov IAW FAR 5.101(a)(1). The OEM will be notified of this posting to www.SAM.gov via email.

REASON THAT SUGGESTED SOURCE IS THE ONLY SOURCE WHICH CAN PROVIDE THE SUPPLIES OR SERVICES.

Helicomb International Inc. is the OEM, and they own the rights to the technical data, specifications, and drawings required to manufacture these item(s). USCG Aviation Engineering has assigned these item(s) an Acquisition Method Code (AMC) of 3. IAW Volume 10, Table 71 of DoD 4100.39 (series), an AMC of 3 indicates to be procured from the actual manufacturer including a prime contract who is the actual manufacturer.

The USCG is conducting a sole source acquisition.

http://www.sam.gov/

August 2020

EXPLAIN WHY AN ADEQUATE PURCHASE DESCRIPTION OR OTHER INFORMATION SUITABLE TO SOLICIT BY

FULL AND OPEN COMPETITION HAS NOT BEEN DEVELOPED OR ARE NOT AVAILABLE.

These item(s) that are to be manufactured are complex and must meet critical operational and reliability requirements, the achievement of which require unique production techniques and extensive and/or sophisticated testing. The Government does not own or possess any rights to the technical data, specifications, and drawings required to manufacture these item(s) and it has been determined that it is uneconomical to purchase them. In addition, the Government has not developed the technical data required to manufacture these item(s) and has no plans to do so.

PROVIDE A STATEMENT OF ACTIONS, IF ANY, THE GOVERNMENT MAY TAKE TO REMOVE OR OVERCOME ANY

BARRIERS TO COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED.

As previously stated, the Government does not own or possess any rights to the technical data, specifications and drawings required to manufacture these item(s) which have prevented the USCG from being able to provide an adequate technical description to potential new sources. Therefore, it is difficult to take steps to overcome the limited source barrier to foster competition when the manufacturing, performance, and acceptance data are proprietary to the OEM.