Attachment 3 - Redacted J and A - 70Z03826QJ0000007

(c) Contract Type: The USCG intends to award a Firm-Fixed Price (FFP) Indefinite Delivery Requirements type contract consisting of a one (I) one

(I) year Base Period plus four ( 4) one ( 1) year Option Periods. The Structural Components will be purchased through individually funded FFP delivery orders.

(d) Estimated total value (including options):

Broken down as follows (*Rounded to the nearest dollar)

Period

Base Period Option Period 1 Option Period 2 Option Period 3 tion Period 4

Total Estimated Value

12 mo.

12 mo.

12 mo.

12mo.

l 2mo.

(e) Type of funding: Operations and Support (O&S) funds

Total*

( t) Year of funding: Fiscal Year 2026 - 203 I funds will be used as applicable to the period of performance of each individually funded delivery order.

(g) Solicitation number: 70Z03826QJ0000007

(h) Background infonnation about the requirement: This requirement is to procure Structural Components to be utilized on the MH-60T aircraft. Nine (9) Structural Components under this justification were previously awarded under contract, 70Z0382 l DJ0000004, with a period of performance (POP) of 05/14/2025 to 05/13/2026, for a total of$) ,4 01,749, to the OEM, SAC. Four ( 4) Structural Components under this justification were previously awarded under contract, 70Z0382 I DJ0000008, with a POP of 07/26/2021 to 07/25/2026, for a total of $271,91 4, to the OEM, SAC. Four (4) Structural Components under this justification were previously awarded on contract, 70203821 DJOOOOO 1 1, with a POP of 07/09/2021 to 07/08/2026, for a total of $244,54 7, to an OEM authorized manufacturer and MRR Engineering approved source, Fraccaro.

3. Description of Supplies/Services.

The cabin floor consists of three (3) sections constructed of aluminum honeycomb core sandwiched between laminated glass fabric skins, with edges reinforced by graphite laminate. Each section has fittings and inserts to secure various types of airborne equipment, seats, and cargo. When the floor sections are bolted in place, they receive additional strength and support from the lower cabin section skeleton. The engine support structure struts are attached to the engine assembly aft mount links to the aft mount flange, and on the engine compartment deck. Damage to the struts, fittings or links is considered

Last Updated 03/05/26 2 critical when greater than minor damage limits or requires replacement of the member.

Fittings are considered critical primary strucrure and are limited to nicks, scratches, or corrosion no deeper than five (5%) percent of material thickness at point of damage.

The Structural Components are part of the structural system that are required to be replaced during each overhaul induction for regularly scheduled Programmed Depot Maintenance (PDM).

Nomenclature National Stock Part Number Associated Contract Unit Number (NSN) (PIN) of

Issue

(U/1)

Fitting RH-4102 1560-01-161-4220 70209-23004S 103 70Z0382IDJ0000004 EA

Fitting LH 1560-01-348-7345 70209-82437-107 70Z03821DJ0000004 EA

FittinR LH-354 1560-01-HS 1-5509 70209-22215S 108 70203821DJ0000004 EA

Fitting 1560-01-HSl-55 I 7 70209-82448-112 70203821DJ0000004 EA

Fitting RH-354 1560-01-HSI-5528 70209-22315-105 70203821DJ0000004 EA

Fitting Assy I 560-01-HSl-5532 70209-22311-046 70Z03821DJ0000004 EA

Fitting Assv 1560-01-HS 1-5539 70209-81 l 02-049 70Z03821DJ0000004 EA

Fitting RH-308 1560-01-HS3-7454 70209-22206S I 08 70Z03821DJ0000004 EA

Fitting LH-295 1560-0 l-HS2-8480 70209-22205S t 11 70Z03821DJ0000004 EA

FWD Spar 1560-01-338-956 l 70209-82543-041 70Z03821DJ000001 l EA

Fitting Structural Fitting 1560-0 l-437-8909 70850-82015-128 70Z03821DJ000001 l EA

Bracket 5340-0 l-509-2115 70209-24205-101 70203821DJ0O000I l EA

AFT Cargo 1560-0J-HS 1-0825 70209-22311-045 70203821 DJ000O0 11 EA

Hook Fitting Fitting 1560-01-HS 1-5282 70209-22312-106 70203821DJ0000008 EA

FTGMLGRHS 1560-01-HS 1-9244 7 l 209-82221-042 70Z03821DJ0000008 EA

(No Pilot Holes) FTGMLGLHS 1560-01-HS 1-9245 7 l 209-82221-041 70203821DJ0000008 EA

Fitting Assembly 1560-0 l-HS 1-9406 70209-82213-112 70Z0382IDJ0000008 EA

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 FAR 6.103-1 entitled "Only one responsible source and no other supplies or services will satisfy agency requirements".

Estimated Total

Contract Quantity

2 Flight Critical Item. Due to the flight critical nature of the Structural Component, the Fitting RH-410 must be accompanied with a Certificate of Airworthiness (COA) as required in accordance with (IA W) Federal Aviation Administration (FAA) procedures.

Last Updated 03/05/26 3

5. Identification of Exception to the Buy American Statute.

The nonavailability to the Buy American Act does not apply to this requirement.

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. Do not duplicate language already used.

The specifications, manufacturing, drawings, data, test equipment, and tooling required for the manufacture of the Structural Components are proprietary to the OEM, SAC. Email correspondence with MRR Engineering revealed that Fraccaro has manufactured the Structural Components for SAC and the USCG in the past.

The USCG did not purchase rights to the proprietary data required to foster a competitive environment as part of any original provisioning for use on the MH-60T aircraft and it would be cost prohibitive to procure this data. Per MRR Engineering via email correspondence, responsible sources are limited to the OEM, OEM approved manufacturer or distributor, and MRR Engineering approved source.

(b) Details covering what events lead to the situation requiring use of other than full and open competition procedures including whether any portion of the work can be segregated to allow for competition;

Three (3) Sources Sought Notices (SSN) were posted at SAM.gov from 07/18/2024 to 08/07/2025, in efforts to identify potential vendors for the Structural Components.

Five (5) responses were received in response to the SSNs.

Three (3) responses were received from BHPE LLC (BHPE). Email correspondence with BHPE confinned that they do not have the capability to manufacture or distribute the Structural Components.

One (1) response was received from Tens Machine Company Inc. (Tens Machine).

Email correspondence with Tens Machine con finned that they have the capability to manufacture one ( l) Structural Component.

One (l) response was received from Priority Resources & Solutions LLC (PRS).

PRS did not include the North American Industry Classification System (NAICS) code 336413 - Other Aircraft Parts and Auxiliary Equipment Manufacturing in their capability statement. Therefore, PRS does not have the capability to manufacture or distribute the Structural Components.

Email correspondence with SAC confirmed that they are the OEM of the Structural Components and all technical data is proprietary to them. Per MRR Engineering, the Structural Components are designed to carry the stress load of flights. Therefore, responsible sources are limited to the OEM, OEM approved manufacturer or distributor, and MRR Engineering approved source.

Last Updated 03/05/26 4

(c) Summarize alternatives considered and why they will not work;

The USCG is not seeking alternatives as this requirement is for Structural Components designed to carry the stress load of flights. Correspondence with MRR Engineering confirmed that these are the only Strucrural Components qualified for use on the MH-60T aircraft and there are no other alternatives as the USCG does not possess the technical data to qualify other Structural Components. Therefore, only the OEM, OEM approved manufacturer or distributor, and MRR Engineering approved source will be considered.

(d) Impact to the mission that would result if the J&A is not approved and, consequently, the product or service not provided.

If this Justification for Other than Full and Open Competition (J&A) is not approved, the lack of Structural Components would cause a severe degradation in the USCG's ability to conduct search and rescue, law enforcement, international ice patrol, marine environmental protection, and marine resource conservation, and various other missions.

(e) Rationale for use of the nonavailability exception to the Buy American statute, including detailed information explaining why the particular articles, materials, or supplies of the class or kind to be acquired, either as end items or components, are not mined, produced, or manufactured in the United States in sufficient and reasonably available commercial quantities and of a satisfactory quality.

The nonavailability exception to the Buy American Statute does not apply to this requirement. Therefore, the Buy American Statute will be included in both the solicitation and terms and conditions of this contract.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

(a) [fan entry was made in APFS, provide the publication date.

This procurement forecast is posted as DHS - Acquisition Planning Forecast System (APFS) No. F2025068460 published on 07/28/2025 at http://apfs.dhs.gov and was included in the OHS forecast of small business opportunities.

(b) If an announcement has already been made in SAM.gov, provide the publication date.

Not applicable.

(c) If an announcement is being planned for posting in SAM.gov, provide the estimated publication date.

This J&A will be posted to the GPE website, SAM.gov, with an estimated posting date of 05/09/2026. Any capability statement, proposal or quotation received in response will be considered prior to award.

(d) If an announcement will not be published, identify the applicable exception under RFO Part 5.

Not applicable.

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8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The Contracting Officer anticipates that prices for this requirement will be detennined fair and reasonable. This will be based on competitive quotations, comparison to the Independent Government Cost Estimate, and by comparison to similar items in related industries.

9. Description of Market Research.

(a) Describe the market research techniques used, results, date(s) when the market research was conducted, and how the contracting officer used the market research to detennine price reasonableness.

Market research was conducted IA W FAR Part 10 from March 2024 through March 2026. OHS APFS entries were reviewed and there were no previous entries.

This procurement forecast is posted as DHS - APFS No. F2025068460 and was published on 07/28/2025 at http://apfs.dhs.gov. SSN, 70Z038241J0000053, was posted at SAM.gov on 07/18/2024 with a closing date of 07/25/2024 in efforts to identify potential vendors. Two (2) responses were received from BHPE and Tens Machine as a result of this posting. SSN, 70Z03824IJ0000054, was posted at SAM.gov on 07/22/2024 with a closing date of08/05/2024. One (1) response was received from BHPE as a result of this posting. SSN, 70Z03825IJ0000060, was posted at SAM.gov on 07/30/2025 with a closing date of 08/07/2025 in efforts to confinn previously gathered information and identify potential vendors. A review of the Asset Maintenance Management lnfonnation System (AMMIS) database was conducted and reviewed recent procurement history.

Government databases such as General Services Administration (GSA) and Federal Logistics lnfonnation System Web Search (WebFLIS) were reviewed. Reviewed commercial sites such as Inventory Locator Service (ILS) to identify other potential sources. Existing OHS-wide and multi-component contract vehicles with DHS Strategic Sourcing Program Office and/or on DHS Enterprise-wide Contract Vehicle Portal were reviewed and were determined out of scope for this requirement. Communication with SAC confirmed they are the OEM, all information regarding specifications, drawings, data, test equipment and tooling are proprietary to them. Communication with MRR Engineering confirmed Fraccaro is an approved source to provide the Structural Components. Communication with MRR Engineering confirmed that qualified sources to provide the Structural Components are limited to the OEM, OEM approved manufacturer or distributor, and MRR Engineering approved source.

(b) Describe the market research results that support the determination that the items are nonavailable.

This requirement does not include the exception listed at FAR 25. l 03(b )(2) or FAR 25.202(a)(2) for the Buy American Act.

(c) If market research was not conducted, state why.

Not applicable; market research was conducted from March 2024 - March 2026.

Last Updated 03/05/26 6

(d) If patents, copyrights, and/or intellectual property are applicable to the acquisition, describe the circumstances for acquiring a patented or copyrighted product on the representation of the intellectual property holder that has not been licensed for resale and consult with the Coast Guard IP attorney.

Patents, copyrights, and/or intellectual property are not applicable to this requirement.

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

(a) An explanation why technical data packages, specifications, statement of work, or purchase descriptions are not suitable for full and open competition.

The specifications, manufacturing, drawings, data, test equipment, and tooling required for the manufacture of the Structural Components are proprietary to the OEM, SAC. The USCG does not have rights to the proprietary data required to foster a competitive environment, and it is cost prohibitive to obtain. Therefore, as stated in 6(a), responsible sources are limited to the OEM, OEM approved manufacturer or distributor, and MRR Engineering approved source.

(b) Discuss why your requirement cannot be modified to enhance competition.

This requirement cannot be modified to enhance competition because the Structural Components and subsequent technological data are proprietary to the OEM, SAC.

Responsible sources are limited to the OEM, OEM approved manufacturer or distributor, and MRR Engineer approved source. Therefore, this requirement cannot be modified.

(c) For a proposed contract subject to the restrictions of RFO 6.103-for follow-on acquisitions as described in 6.103-l (c)(2)(i), all components must provide an estimate of the cost to the Government that would be duplicated and detailed information on how the estimate was derived.

This requirement is not subject to the restrictions of FAR 6. l 03-1 (FAR Class Deviation 25-11) as described in FAR 6.103- l (c)(2)(i) (FAR Class Deviation 25-11).

( d) For a proposed contract subject to the restrictions of RFO 6.103-2( c) or HSAR 3006.103- 2{ c )(70), HSAR Class Deviation 25-0 I and where RFO 6.103-2 is cited as the authority, describe the exceptional circumstances allowing for an award for a period of performance in excess of the one-year limitation (applicable to all federal agencies) or the DHS specific statutory 150-day limitation.

This requirement is not subject to the restrictions of FAR 6.103-2( c) (FAR Class Deviation 25-11) or Homeland Security Acquisition Regulation (HSAR) 3006. l 03- 2( c)(70) (HSAR Class Deviation 25-01) where FAR 6.103-2 (FAR Class Deviation 25-

11) is cited as the authority.

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

To date, there have been no other sources that have expressed interest in this requirement.

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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.

(a) Will the Government revise overly technical specifications, acquire data rights, etc.?

The USCG did not purchase rights to the proprietary data required to foster a competitive environment as part of any original provisioning for use on the MH- 60T aircraft. 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. To increase competition, MH-60T program members conduct internet database research and ensure procurements are advertised on SAM.gov. If another potential source emerges, and the USCG can obtain the required technical data, the USCG will assess whether competition for any future requirements is feasible.

(b) When a J&A is issued for the purposes of acquiring goods or services while a competitive procurement is being conducted, the justification should include a detailed timeline for completion of the competitive procurement. The period of perfonnance for the sole source action should fairly balance the time needed to complete the competitive procurement. The focus should be on minimizing the need for additional sole source awards.

Not applicable.

(Remainder of Page Intentionally left Blank)

Last Updated 03/05/26 8

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