ATTACHMENT 2 - Redacted Justification and Approval For Other Than Full and Open Competition 70Z03823QJ0000339.pdf
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- Housing, Mech Drive
- Solicitation number
- 70Z03823QJ0000339
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This document is a justification for other than full and open competition for a sole source procurement. The United States Coast Guard Aviation Logistics Center intends to award a firm-fixed price purchase order to Goodrich Corporation for 10 each housing, mechanical drive units and an additional optional quantity of 20 units. The total estimated amount is $32,380.50. Goodrich Corporation is identified as the original equipment manufacturer of these items, which are used on the MH-60T Coast Guard aircraft. As the OEM, Goodrich Corporation owns the technical data, specifications, and drawings required for manufacture of these complex items, which have been designed to meet critical operational and reliability requirements. The government does not own rights to this data and it was determined to be uneconomical to purchase them. Market research confirmed these items are not available from any other source.
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August 2020
ATTACHMENT 2 – REDACTED J & A - 70Z03823QJ0000339
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. Do not use marketing language in this document. Language such as “This company has made its mark,” “This company is recognized as industry’s best,” and “This company is the leader in…” is unacceptable.
PURCHASE REQUEST OR REQUISITION
NUMBER
2023160-JP01
PROJECT/TASK
NUMBER
MH-60T
ESTIMATED AMOUNT (Over Micro- Purchase Threshold, but up to the SAT) $ 32,380.50
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.
The United States Coast Guard (USCG), Aviation Logistics Center (ALC), Medium Range Recovery (MRR) Product Line 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.
MRR intends to purchase the item(s) shown in the table below on a sole source basis.
Quantity
Additional Optional Quantity
NSN
Part Number
(P/N)
Nomenclature
10 each 20 1650-01-394-7584 42315-127
HOUSING, MECH.
DRIVE
These item(s) are used on the MH-60T USCG aircraft.
UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON NO OTHER
SUPPLIES OR SERVICES CAN BE USED.
The item(s) that are to be procured under this acquisition are highly specialized item(s) which have been designed and manufactured by GOODRICH Corporation (Cage Code 3HRL4). As the Original Equipment Manufacturer (OEM) of these item(s), GOODRICH Corporation owns all rights to the technical data, specifications, and drawings required for its manufacture. The rights to the technical data necessary to acquire these item(s) from other than the OEM are not owned by the Government and it has been determined that it is uneconomical to purchase these rights. The item(s) in the table are the only ones approved by the USCG’s Aircraft Configuration Control Board (ACCB) 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 Information Service (WebFLIS); FedMall; and the OEM’s web site. The item(s) is not available from any required or optional source of supply in accordance with (IAW) FAR 8.002. A notice of intent will be posted to the Sam.gov web site at www.sam.gov IAW FAR 5.101(a)(1). The OEM will be notified of this posting to www.sam.gov.
August 2020
REASON THAT SUGGESTED SOURCE IS THE ONLY SOURCE WHICH CAN PROVIDE THE SUPPLIES OR SERVICES.
GOODRICH Corporation is the OEM and they own the rights to the technical data, specifications, and drawings required to manufacture the item(s). USCG Aviation Engineering has assigned the item(s) an Acquisition Method Code (AMC) of 3. IAW Volume 10, Table 71 of DoD 4100.39 (series), an AMC of 3 indicates that this item is required to be purchased from the actual manufacturer, regardless of whether the prime contractor is the actual manufacturer. The USCG is conducting a sole source acquisition.
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.
The item(s) that are to be procured 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 the 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 the 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 the item(s) which has prevented the USCG from being able to provide an adequate technical description to potential new sources. Therefore, it is difficult to take steps to foster competition when the manufacturing, performance, and acceptance data are proprietary to the OEM.
SIGNATURE AND TITLE OF CUSTOMER
Ashley J. Hankinson, Item Manager MRR
CODE
JP
TELEPHONE
NUMBER
252-384-7152
DATE
06/09/2023
SIGNATURE OF CONTRACTING OFFICER
Contracting Officer MRR
CODE TELEPHONE
NUMBER
DATE
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