Attachment 3 - Redacted JA.pdf

Attachment 3

SOLE SOURCE ACQUISITION

Procurement of Main Landing Gear (MLG) and Nose Landing Gear (NLG) Tires in Support of the

HC-144 Aircraft

Last Updated 10/15/25

In compliance with Federal Acquisition Regulation (FAR) 13.501(a)(1)(ii), this justification uses the format at FAR 6.104-1 and is modified to state that the procedures in FAR subpart

13.5 are used.

1. Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Aviation Logistics

Center (ALC), proposes to enter into a contract on a basis other than full and open competition.

2. Nature and/or Description of the Action being Approved.

(a) Nature of the action: USCG intends to procure on a sole source basis Main Landing

Gear (MLG) and Nose Landing Gear (NLG) tires in support of the HC-144 Aircraft.

(b) Name and address of the contractor:

Wilkerson Company Incorporated

1033 Church Street

Blackstone VA, 23824-2837

Cage Code 61135

(c) Type of action: Firm Fixed-Price Contract

(d) Estimated total value (including options): $2,389,202 broken down as follows:

PERIOD TOTAL

Base Year 12 mo. $415,460

Option Year 1 12 mo. $444,542

Option Year 2 12 mo. $475,660

Option Year 3 12 mo. $508,956

Option Year 4 12 mo. $544,584

Total $2,389,202

The products under this justification were not previously awarded under another contract.

(e) Type of funding: Operations and Support funds

(f) Year of funding: Fiscal Year 2026

(g) Solicitation number: 70Z03826QL0000003

(h) Background information about the requirement: The HC-144 Maritime Patrol

Aircraft (MPA) is a medium range, twin engine turboprop aircraft used in search and rescue and maritime patrol missions. The procurement of NLG and MLG Tires are required to support USCG missions.

3. Description of Supplies/Services

The contractor will provide MLG and NLG tires to support the HC-144 aircraft. These supplies are essential to avoid grounding the aircraft.

4. Identification of Statutory Authority Permitting Other Than Full and Open

Competition.

The statutory authority permitting other than full and open competition is Section 3205 of

Title 10, U.S. Code, as implemented in the Federal Acquisition Regulation (FAR) 13.501

(a), “Sole Source Acquisitions”.

5. Identification of Exception to the Buy American Act.

The Buy American Act is not applicable.

6. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Require Use of the Authority Cited.

(a) Rationale for using the authority cited in section 4 of the J&A

The NLG and MLG tires have been assigned an Acquisition Method Code (AMC)

Code of 3 which requires they be procured from the actual manufacturer or prime contractor. The Original Equipment Manufacturer (OEM) of both the MLG and NLG tires is Dunlop Aircraft Tyres Limited. Using the OEM, or an OEM authorized source, will ensure the MLG and NLG tires are manufactured in accordance with

OEM specifications and standards, conform to original form, fit, and function, and are compatible with preexisting aircraft components. Procuring the requirements from an unauthorized source could result in part failure or other unsafe conditions.

Wilkerson Company Incorporated has been authorized by the OEM to distribute these requirements and has a history of providing the USCG with reliable availability at fair market value. The USCG does not have adequate technical data to provide to potential offerors to promote competition.

(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:

The MLG and NLG tires specified in this requirement are considered Critical Safety

Items (CSIs). A CSI is a part with one or more critical characteristics that, if not conforming to the design data or quality requirements, would result in an unsafe condition. Unsafe conditions relate to mishap severity categories I (Catastrophic), an

II (Critical) of Military Standards MIL-STD 882 and MIL-STD-100, System Safety

Program Requirements. USCG Engineering has determined that in order to ensure safety of flight, procuring these tires must come from the OEM or an OEM authorized distributor. In an email dated April 02, 2025, the OEM stated that there is only one authorized distributor for Dunlop Tyres which is Wilkerson Company

Incorporated.

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

SSN 70Z03825IL0000006 was posted on SAM.gov on April 21, 2025, with a response date of May 05, 2025. The USCG received four (4) timely responses to the

SSN: BHPE, LLC, Quality Aeroparts, Inc., Pyramis Aerospace, LLC, and Kijero, LLC. However, only one (1) source is able to provide the MLG and NLG tires for this requirement based on the email from the OEM, Dunlop Aircraft Tyres Limited, dated April 02, 2025, that stated only Wilkerson Company Incorporated is the only authorized distributor. The MLG and NLG tires are to be utilized on the USCG HC-

144 aircraft and must maintain an airworthy condition, which restricts the requirement to the OEM or an OEM authorized distributor. There are no alternatives to acquire these supplies from other than the OEM due to the critical safety, proprietary data and maintaining airworthy condition of the aircraft.

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

This procurement will provide MLG and NLG tires required to support operational maintenance as well as scheduled Programmed Depot Maintenance (PDM) of the

HC-144 aircraft. Without these tires, aircraft will be grounded for extensive periods of time until the OEM tires can be procured. Failure to approve this J&A will jeopardize the performance of the USCG’s mission due to insufficient stock availability for operational aircraft.

(e) Section is required to be completed when the J&A includes the exception listed under FAR 25.103(b)(2) or FAR 25.202(a)(2). Not Applicable.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many

Potential Sources as is Practicable.

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

This acquisition is forecasted in the Department of Homeland Security (DHS)

Acquisition Planning Forecast System (APFS), number F2025069591 published on

March 12, 2025, revised on April 15, 2025, and can be found at https://www.apfs.gov. There were no responses received as a result of the APFS posting.

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

This Justification for Other Than Full and Open Competition will be posted to the

Government-wide Point of Entry (GPE), via https://www.sam.gov under Solicitation

70Z03826QL0000003 with an estimated publication date of November 19, 2025.

(c) If an announcement will not be published, identify the applicable exception under

FAR 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 fair and reasonable in accordance with FAR 15.404-1. The prices will be determined fair and reasonable based on a comparison of proposed pricing with prior Asset Maintenance Management

Information System (AMMIS) history, current published price lists, and the IGCE.

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 it to determine price reasonableness.

Market research techniques used consisted of reviewing the AMMIS history database and Government databases such as General Services Administration (GSA), Federal

Logistics repository (FEDLOG) and FEDMALL. Review of these government databases determined they were outside the scope of this requirement Wilkerson

Company Incorporated is the only approved source to distribute Dunlop tires. All terms and conditions are not expected to differ from customary terms and conditions in the marketplace or standard Government practices.

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

The J&A requirement does not include the exceptions at FAR 25.103(b)(2) for FAR

25.002(a)(2) for the Buy American Act.

https://www.apfs.gov/

(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.

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.

Dunlop Aircraft Tyres Limited, the OEM, and Wilkerson Company Incorporated, the authorized distributor, are the only approved sources for the procurement of the MLG and NLG tires. Therefore, this requirement is not suitable for full and open competition. The technical data package, including drawings, specifications, manuals, and publications required to develop additional sources to procure these parts were not procured by the government and are proprietary to the OEM.

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

This requirement cannot be modified to enhance competition because the components and the subsequent technical data are not available from any distributor other than the OEM, or an OEM authorized distributor.

(c) For a proposed contract subject to the restrictions of FAR 6.103-1 (FAR Class

Deviation 25-11) for follow-on acquisitions as described in 6.103-1(c)(2)(i) (FAR

Class Deviation 25-11), provide an estimate of the cost to the Government that would be duplicated and detailed information on how the estimate was derived.

(d) For a proposed contract subject to the restrictions of FAR 6.103-2(c) (FAR Class

Deviation 25-11) or HSAR 3006.103-2(c)(70) (HSAR Class Deviation 25-01) and where FAR 6.103-2 (FAR Class Deviation 25-11) 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.

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

Acquisition.

SSN 70Z03825IL0000006 was posted on SAM.gov on April 21, 2025, with a response date of May 05, 2025. The USCG received four (4) timely responses to the

SSN: BHPE, LLC, Quality Aeroparts, Inc., Pyramis Aerospace, LLC, and Kijero, LLC. However, only one (1) source is able to provide the MLG and NLG tires for this requirement based on the email from the OEM, Dunlop Aircraft Tyres Limited, dated April 02, 2025, that stated only Wilkerson Company Incorporated is the only authorized distributor.

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.?

At this time, for reasons set forth in this document, the USCG does not possess the technical data required to foster a full and open competition. The USCG will continually conduct market research to ensure that companies interested in doing business with the USCG are given every opportunity to compete for future USCG requirements.

(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.

All Signatures can be found in the contract file.