Attachment 3-Redacted J A - 70Z03825QB0000001.pdf

March 8, 2023 Version

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

70Z03825QB0000001

PROJECT/TASK

NUMBER

SRR-S

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

$70,326.60

CITE AUTHORITY & JUSTIFICATION TYPE – READ FAR 6.302 TO DETERMINE APPROPRIATE TYPE

10 U.S.C. § 3204(a)(1)

ONLY ONE RESPONSIBLE SOURCE AND NO OTHER SUPPLIES OR SERVICES WILL SATISFY

AGENCY REQUIREMENTS.

☐ 10 U.S.C. § 3204(a)(2) UNUSUAL AND COMPELLING URGENCY

10 U.S.C. § 3204(a)(3)

INDUSTRIAL MOBILIZATION; ENGINEERING, DEVELOPMENTAL, OR RESEARCH CAPABILITY; OR

EXPERT SERVICES

☐ 10 U.S.C. § 3204(a)(4) INTERNATIONAL AGREEMENT

☐ 10 U.S.C. § 3204(a)(5) AUTHORIZED OR REQUIRED BY STATUTE – MUST PROVIDE IT

☐ 10 U.S.C. § 3204(a)(6) NATIONAL SECURITY

☐ 10 U.S.C. § 3204(a)(7) PUBLIC INTEREST [SECRETARY OF HOMELAND SECURITY NEEDS TO APPROVE THIS DOC]

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE. This procurement is for a base plus four option year requirement for the following spare part to be utilized on the MH65 helicopter:

BATTERY (NSN: 6140-01-HS1-2852 PN: MRB-10-600).

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

SUPPLIES OR SERVICES CAN BE USED. This acquisition is restricted to the only source(s) of supply known to have the capability of furnishing the required supplies. The piece parts referenced is manufactured by

United Batteries & Accessories (Cage Code 3EFG4). The USCG has determined that since the original equipment manufacturer (OEM) is the sole distributor of the piece parts referenced in the schedule can only be procured from the OEM. Furthermore, the Government does not have the adequate data or lacks the rights to data, and it is not economical to buy the data or the rights to the data.

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).

). The spare parts to be procured under this acquisition are highly specialized parts, designed and manufactured by a non-Government activity. These parts are specifically designed for the USCG G366 platform cabin lighting system as the backup power supply source. The cabin lighting back up battery is a rechargeable power system and is designed to provide emergency power to the aircraft cabin should the aircrafts generator power system fail. The technical data required for acquisition by other than the OEM or an OEM approved source is not available. The only manufacture of this part is United Batteries &

Accessories. Since the backup emergency power source is a key component to the aircrafts primary generator electrical system, procurement of any parts from other than the OEM or an OEM approved source will compromise the safety of flight for the aircraft and the crew. The solicitation and resulting contract award will require all materials delivered to have clear, documented traceability to the OEM and a completed Certificate of Conformance, certifying compliance with this contract condition, in accordance with FAR clause 52.246-15, Certificate of Conformance, which will be incorporated.

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

. The item listed in the schedule requires specific form, fit, and electrical function specifications allowing the aircrafts computer module to directly interface with the aircraft generators. Although not deemed as flight critical the referenced part is a vital component should the aircrafts generator power system fail. Due to these circumstances the USCG has limited the source of supply to United Batteries & Accessories. Additionally, all maintenance procedures https://www.acquisition.gov/far/part-6#FAR_6_302 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204

March 8, 2023 Version have been tested and written specifically to interact with the aircrafts electrical system. Based upon the technical certification on file, technical data is not available and cannot be developed to permit full and open competition.

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 required specifications of suitable alternate piece parts would not be sufficient for source selection. After receiving responses from the solicitation, an initial exclusive testing and evaluation involving interaction with the aircrafts electrical system would have to be completed to ensure compatibility. It would not be cost or time effective to test multiple services from sources due to time restraints of Coast Guard Air Stations testing procedures.

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

BARRIERS TO COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED.

The OEM owns the proprietary data rights, specifications and drawings to these items which have limited the USCG’s ability to provide adequate technical descriptions to potential new manufacturers. Therefore, it is difficult to take steps to foster competition as the manufacturing, performance, and acceptance data are proprietary to the OEM.

SIGNATURE AND TITLE OF CUSTOMER

Tre’Von Lamb

CODE

DO

TELEPHONE

NUMBER

571-614-2881

DATE

10/07/2024

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

NUMBER

DATE