Attachment 3 - Redacted J and A - 70Z03826QJ0000299.pdf

Attachment 3 - Redacted J and A - 70Z03826QJ0000299

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

(f) Year of funding: Fiscal Year 2026 and 2027

(g) Solicitation number: 70Z03826QJ0000299

(h) Background information about the requirement: The USCG previously awarded PO, 702038 I 9PR0000433, on 09/16/2019, to AAI Corporation doing business as Textron Systems, for the procurement of the ABE Model 31 0A, Adapter Set, and ABE Model 31 OA training. This was an FFP PO valued at $739,617 and was completed on 12114/2020.

3. Description of Supplies/Services.

The ABE Model 31 0A and Adapter Set enables critical boresighting required to align the Embedded Global Positioning System/Inertial Navigation Systems (EGis) to the center point of the aircraft. Unlike other military H-60 variants that rely on external, temporary alignment fixtures, the USCG MH-60T aircraft's mounting system is permanently fixed to the 3-axis main beams within the aircraft structure. Boresighting is used to create a baseline that harmonizes critical mission systems and is required for each overhaul induction during regularly scheduled Programmed Depot Maintenance (PDM), Navy conversion aircraft, and green hulls. Because primary flight mission displays rely on the accurate baseline, proper alignment is critical to the integration and reliability of the MH-60T's avionics suite.

Nomenclature Part Number Unit of Quantity Optional Issue Quantity

ABE Model 310A 40262-44000-40 EA 1 Adapter Set 78003-40000-10 EA 1

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)( I) implemented by the RFO Subpart 6.103-1 entitled "Only One Responsible Source and No Other Supplies Will Satisfy Agency Requirements"

5. Identification of Exception to the Buy American Statute.

Not applicable.

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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.

The specifications, manufacturing, drawings, data, test equipment, and tooling required for the manufacture of the ABE Model 31 0A and Adapter Set are proprietary to the Original Equipment Manufacturer (OEM), Textron Systems. The ABE Model 31 0A and Adapter Set manufactured by Textron Systems is the only one with fixtures that are able to attach to the MH-60T airframe and is qualified for boresighting on the USCG MH-60T aircraft. 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 and it would be cost prohibitive to procure this data.

(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;

Correspondence with Textron Systems dated 06/10/2026, confirmed that they are the 0 EM of the ABE Model 31 0A and Adapter Set, and there are no authorized distributors. Given this information, Textron Systems is the only source capable of providing the required ABE Model 31 0A and Adapter Set. No other part numbers or acceptable alternate vendors have been identified. Correspondence with MRR Engineering dated 06/04/2026 confirmed that only the ABE Model 31 0A and Adapter Set are qualified for use on the MH-60T aircraft as a result of the unique mounting system. Procuring the required ABE Model 31 0A and Adapter Set from the OEM will ensure the specified requirements are met. Therefore, due to the unavailability of the proprietary data and no authorized sources, no portion of the requirement can be segregated to allow for competition.

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

There are no authorized distributors and the OEM holds all specifications, manufacturing, drawings, data, test equipment, and tooling required for the manufacture of the ABE Model 31 0A and Adapter Set.

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

Failure to approve this J&A will jeopardize the performance of the USCG's mission due to grounding of the aircraft as a result of the inability to perform mandatory routine and post-maintenance boresighting required for the USCG MH-60T aircraft.

(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.

Not applicable.

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

(a) If an entry was made in APFS, provide the publication date.

APFS No. F2026074220 was published on 06/23/2026 and revised on 07/30/2026, at http://apfs.dhs.gov, and was included in the OHS Forecast of Small Business Opportunities. There were no responses received as a result of the APFS posting.

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

Sources Sought Notice (SSN), 70Z03826IJ000003 l, was posted at www.SAM.gov on 06/09/2026 and expired on 06/29/2026. No responses were received in response to this posting.

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

This J&A will be posted at SAM.gov, with an estimated posting date of 08/24/2026. 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.

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

The contracting officer determines that the anticipated prices will be detem1ined fair and reasonable based on comparison with 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 detem1ine price reasonableness.

Market research was conducted in accordance with (IA W) FAR Part l O from June 2026 - August 2026. A review of the Asset Maintenance Management Information System (AMMIS) database was conducted and recent procurement history was reviewed. In addition, Government databases such as Federal Logistics Information System Web Search (WebFLIS), SAM.gov, and USASpending.gov were all reviewed as part of market research. Commercial databases such as Inventory Locator Service (ILS) were reviewed and returned no alternative suppliers. Existing OHS-wide and multi-component Contract Vehicles with OHS Strategic Sourcing Program Office and/or on OHS Enterprise-side Contract Vehicle Portal were reviewed and were determined out of scope of this requirement.

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

Not applicable.

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

Not applicable.

( 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.

Not applicable.

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 ABE Model 310A and Adapter Set are proprietary to the OEM, Textron Systems. Correspondence with Textron Systems dated 06/10/2026 confirmed that the proprietary data cannot be shared. Therefore, the only capable source qualified by MRR Engineering to provide the ABE Model 31 0A and Adapter Set is Textron Systems.

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

Correspondence with Textron Systems confirmed that the technological data is proprietary. This requirement will ensure the ABE Model 310A and Adapter Set are manufactured to the OEM's specifications, maintaining quality and integrity and minimizing flight risk. Given this information, this requirement cannot be modified to enhance competition.

(c) For a proposed contract subject to the restrictions of RFO 6.103-for follow-on acquisitions as described in 6.l03-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.

Not applicable.

( 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 25-01 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 OHS specific statutory 150-day limitation.

Not applicable.

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

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

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 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 ensure competition, MH-60T program members will 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 performance 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.

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13. Technical/Requirements Personnel Certification.

I certify this requirement meets the Government's minimum need and that the supporting data, which forms a basis for this ·ustification. is com lete and accurate.

14. Contracting Officer's Certification

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

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