Attachment 4 - Redacted JA 70Z03825RB0000003.pdf

Justification for Other Than Full and Open Competition 10 U.S.C. § 3204

Repair of Main Rotor Blade and Tip Cap Solicitation No. 70Z03825RB0000003

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Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.3, the following facts and rationale justify the use of such authority.

1. Agency and Contracting Activity. The United States Coast Guard (USCG), Aviation

Logistics Center (ALC), Short Range Recovery (SRR) Division, Elizabeth City, North Carolina prepared this justification for other than full and open competition.

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

(a) Nature of the action: This is a sole source acquisition. The USCG, ALC, SRR Division intends to procure repair services on a sole source basis, for the Main Rotor Blade and Tip Cap utilized on the USCG MH-65E aircraft.

The parts are manufactured by Airbus Helicopters France (AHF) (Cage Code F0210), the Original Equipment Manufacturer (OEM). The only approved maintenance repair/overhaul (MRO) facility in North America is Airbus Helicopters, Inc. in Grand Prairie, TX (Hereby referred to as AHI) (See Attachment 1).

(b) Name and address of the contractor:

Airbus Helicopters, Inc. (AHI) 2701 Forum Drive Grand Prairie, TX 75052 Cage Code: 3GSZ1

(c) Type of action: The USCG intends to award a Firm Fixed-Price

Indefinite Delivery Requirements type contract consisting of a one-year Base Period and up to four (4) one-year Option Periods, if exercised.

The items to be repaired will be procured using individually funded firm fixed-price task orders.

(d) Estimated total value (including options): $13,271,968 broken down as follows:

Period Length of Period Total

Base 12 Months $2,307,871 Option One 12 Months $2,469,423 Option Two 12 Months $2,642,283 Option three 12 Months $2,827,242 Option Four 12 Months $3,025,149

Total $13,271,968

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Note: This requirement was previously awarded under 70Z03821DB2000003. The period of performance for this contract ends on 02/28/2026.

(e) Type of funding: Operations and Support funds

(f) Year of funding: Fiscal Year 2026 through 2031 will be used as appropriate.

(g) Solicitation number: 70Z03825RB0000003

(h) Background information about the requirement: As the Aviation Inventory Control

Point (AICP), ALC is required to provide effective supply support for all USCG Aviation Units and for Program Depot Maintenance (PDM) support. The Main Rotor Blade and Tip Cap are required for outfitting the USCG aircraft with the latest designed/drawing revision authorized on the MH-65E model and are essential to avoid grounding of the aircraft. The vendor will provide all specifications, manufacturing drawings, data, test equipment, and tooling required to perform repairs to these components, which is proprietary to AHF, the OEM. Extensive market research has determined that AHI is the only North American vendor capable of providing the required repair of the Main Rotor Blade and the Tip Cap.

This has been verified via correspondence with the OEM and is provided in the attached documentation labeled “Attachment 1.”

3. Description of Supplies/Services.

The MH-65E employs a main gearbox rotor head assembly that requires four individual Main Rotor Blades with individual Tip Caps. Each blade is constructed from composite materials designed with a high-efficiency, low noise profile that must be weighted, balanced and synchronized to the aircraft’s main gearbox rotor head. They also generate aerodynamic lift force to support the weight of the helicopter, while providing the thrust needed in counteracting the aerodynamic drag of the aircraft when hovering or when the rotor head is pitched in forward flight.

The USCG currently operates a fleet of MH-65E aircraft. This specialized, high demand aircraft currently enables the USCG to perform missions such as search and rescue, law enforcement, international ice patrol, marine environmental protection, and marine resource conservation. With a demanding operational tempo, aircraft condition and availability are essential to mission success.

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This requirement is for the repair services of Main Rotor Blade and Tip Cap completed by the OEM approved North American MRO facility, AHI, for use on the MH-65E aircraft.

This requirement will provide replacement ready for issue spares for the fleet and programmed depot maintenance program. AHF is the OEM of this components and AHI is the only OEM approved MRO facility in North America.

The following are part numbers included in this J&A:

Nomenclature Part Number (PN) Main Rotor Blade 366A11-0010-03 through -07 Tip Cap 366A11-5030-03

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 Subpart 6.302-1 entitled Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

5. Identification of Exception to the Buy American Act: This requirement is for the repair services for the Main Rotor Blade and Tip Cap where 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) AHI is the only known vendor that can provide the European Union Aviation Safety Agency (EASA) Form 1 and traceability to the OEM required by Code of Federal Regulations (CFR) and FAA. The use of 10 U.S.C. 3204 (a) (1) is necessary because AHI is the OEM’s only approved distributor in North America.

(b) In an attempt to promote competition, extensive market research was conducted.

The USCG contacted the AHI on March 11, 2025, to determine whether approved distributors were available. In response, AHI provided a statement letter dated 24 March 2025 (Attachment 1) stating that AHI is the only approved MRO for the services in this requirement.

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(c) In order to maintain structural integrity of the aircraft and ensure complete compatibility of replacement parts, the parts listed in this requirement must be repaired by the OEM or an OEM approved source. Components repaired by an unapproved OEM supported facility will compromise structural and system integrity of the aircraft putting aircrew personnel and aircraft at a safety of flight risk. The USCG neither compromises nor makes exceptions in matters of human safety and protection of Government property and does not accept lower standards in these matters.

(d) Therefore, 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 sole source J&A will jeopardize performance of the USCG’s mission due to grounding of the aircraft because of no stock being available as components are required in the maintenance, repair and overhaul of the MH-65E Aircraft. Additionally, in a fiscal and stock environment requiring minimal investment in inventory, it is critically important to secure sources that can satisfy the contractual requirements needed to react to ever-changing mission requirements.

(e) This exemption to FAR 25.103(b)(2) is not taken. This requirement is for the repair of the main rotor blade and tip cap. As per attachment 1, the OEM for these components has only one authorized repair facility, which is AHI. As stated above, failure to approve this sole source J&A will jeopardize performance of the USCG’s mission due to grounding of the aircraft because of no stock being available.

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

(a) This procurement was forecasted in the Department of Homeland Security (DHS)

Acquisition Planning Forecast System (APFS) No. F2025069082 on March 12, 2025, and included in the DHS Forecast of Small Business Opportunities. There were no inquiries received in response to the published APFS.

A Sources Sought Notice 70Z03825BI0000020 was posted on the SAM.Gov website on February 6, 2025, with a closing date of February 28, 2025. No additional vendors were identified as to being able to provide the services in this requirement.

A second Sources Sought Notice 70Z03825IB0000007 was posted on the SAM.Gov website on April 17, 2025, with a closing date of May 1, 2025. One response was received from Begini Howard Private Equity (BHPE), however, this vendor is not technically acceptable due to the sole source nature of this requirement.

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(b) In accordance with FAR 5.203(a)(2) and FAR 12.603, the proposed contract action will be advertised on the Contract Opportunities website at SAM.Gov as a combined sole source synopsis solicitation. The estimated date of publication is June 16, 2025.

(c) The exceptions under FAR 5.202 do not apply to this requirement.

(d) The exceptions under FAR 6.305 do not apply to this requirement.

8. Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable.

The Contracting Officer anticipates that the prices for this procurement will be fair and reasonable. This is based on comparison of proposed prices with prices found reasonable on previous purchases (FAR Subpart 15.404-1 (b)(2)(ii)), comparison with the Independent Government Cost Estimate (IGCE) (FAR Subpart 15.404-1(b)(2)(v)), and comparison with similar items in a related industry (FAR Subpart 15.404-1 (b)(2)(vi)).

9. Description of Market Research: IAW FAR Part 10, various methods of market research were launched for this requirement.

(a) Market research was conducted between February 2024 to October 2024 and a refresher was conducted on February 2025 and consisted of internet searches utilizing Federal Logistics (FEDLOG), General Services Administration (GSA) Advantage, Defense Logistics Agency’s Federal Mall (FEDMALL). A review was conducted of the Asset Maintenance Management Information System (AMMIS) database history. Existing DHS-wide and multi-component contract vehicles with DHS Strategic Sourcing Program Officer and/or on DHS Enterprise-Wide Contract Vehicle Portal were reviewed and were determined out of scope of this procurement. A Sources Sought Notice 70Z03825IB0000020 was posted on the SAM.Gov website on February 6, 2025, with a closing date of February 28, 2025. No additional vendors were identified as to being able to provide the services in this requirement. A second Sources Sought Notice 70Z03825IB0000007 was posted on the SAM.Gov website on April 17, 2025, with a closing date of May 1, 2025. One response was received from Begini Howard Private Equity (BHPE), however, this vendor is not technically acceptable due to the sole source nature of this requirement.

(b) This J&A requirement does not include the exceptions at FAR 25.103(b)(2) or FAR 25.202(a)(2) for the Buy American Act.

(c) Market research has been conducted.

(d) This requirement does not have or require patents, copyrights and/or intellectual property.

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

(a) The USCG does not own the necessary technical data required to support the repair of the required parts. The drawings and technical data are proprietary and available only from the OEM. The USCG did not purchase the rights as parts of the original acquisition.

Due to the proprietary rights, it will be difficult to take steps to foster competition.

(b) The parts in this requirement cannot be reverse engineered and/or modified by other sources because this requirement is for the repair of existing parts. In order to maintain structural integrity of the aircraft and ensure complete compatibility of the repaired parts, the parts listed in this requirement must be repaired by the OEM approved MRO facility.

(c) This requirement is not a follow-on for a continued provision of highly specialized services pursuant to FAR Subpart 6.302-1(a)(2)(iii).

(d) Not applicable to FAR 6.302-2(d) or HSAR 3006.3020270. This is not considered unusual and completing urgency.

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

Acquisition: No other sources have expressed interest in this acquisition.

12. 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) Complete specifications and drawings for the components are proprietary to the OEM and therefore not available to the USCG. The USCG does not possess the technical expertise nor the software data rights for the components. It is difficult to take steps to foster competition as the manufacturing, performance, and acceptance data are proprietary to the OEM. As the Aviation Inventory Control Point (AICP), ALC is tasked with supporting systems that have been deployed for use in the aviation community. In an effort to increase competition among manufacturers, affiliates, and distributors, SRR Product Line members attend annual aviation trade shows and host industry days at the ALC.

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(b) Extensive internet database research was conducted, and requirements are advertised on Contract Opportunities. In support of the Competition in Contracting Act, ALC established the New Product Development Branch (NPD) and a representative of the NPD Branch is assigned to the SRR Product Line. This representative has the responsibility to search for alternate sources of supply/services and alternate acceptable products. Engineering, Contracting and NPD representatives continuously conduct market research to ensure that companies interested in doing business with the USCG are given every opportunity to compete for requirements. NPD is exploring avenues of reverse engineering for some of the hard to find or expensive to repair items, which should further encourage competition; however, this process is lengthy, costly and labor intensive.

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13. 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.

Terrie L. Pickard Date Contracting Officer, USCG, ALC, SRR

14. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Vernon L. Clark Date Item Manger, USCG, ALC, SRR

RECOMMENDED FOR APPROVAL:

Kristen R. Copeland Date Level Above Supervisory Contracting Officer, USCG, ALC, SRR

David S. Burgess Date Chief of the Contracting Office, USCG, ALC

APPROVAL:

Frederick Steward - ALC, CG-914, SILC-CON Date Procuring Activity Advocate for Competition (PAAC)