Attachment J- Justification for Other than Full and Open Competition (Work Item D-10) Redacted.pdf

Last Updated 11/01/24

U.S. COAST GUARD JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIMPLIFIED ACQUISITION PROCEDURES (SAP) FOR FAR 13.106-1(b)

PURCHASE REQUEST OR REQUISITION

NUMBER:

ESTIMATED TOTAL VALUE, INCLUDING OPTIONS:

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

AUTHORITY JUSTIFICATION TYPE

☒ 13.106-1(b)(1) ONLY ONE SOURCE REASONABLY AVAILABLE (e.g., urgency, exclusive licensing agreements, or industrial mobilization).

☐ FAR 5.102(a)(6), FAR

11.105, FAR 13.106-1

(b) (1)

BRAND NAME – Items peculiar to one manufacturer: The particular brand name, product, or feature is essential to the Government’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s needs.

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED AND THE INTENDED USE:

In accordance with FAR 13.106-1(b)(1)(i) and in alignment with the Hamilton FQ4 FY25 DS availability, the SFLC SES has outlined the requirement for a licensed technical representative from Appleton Marine Inc. to accomplish the following tasks to the Model FB90-28 cranes onboard the USCGC Hamilton.

Appleton Marine is the only company with the proprietary data needed to complete work item D-10, Folding Boom Cranes, Biennial Maintenance, Perform.

Provide manufacturer's proprietary system/equipment information, software and tools.

Assist with and ensure compliance with manufacturer's procedures and standards during disassembly, inspection, repair, modification, calibration, and reassembly of the equipment/system.

Oversee operational and load testing

SUGGESTED SOURCE NAME, ADDRESS, & UNIQUE ENTITY IDENTIFIER (UEI):

Name: Appleton Marine Inc

Address: 3030 E. Pershing St. Appleton, WI 54911 USA

Phone: (920) 738-5432

UEI: HWLGUR28KMS6

RATIONALE FOR JUSTIFICATION TYPE SELECTED ABOVE TO INCLUDE RELEVANT INFORMATION GAINED

THROUGH YOUR MARKET RESEARCH TO SUPPORT THE JUSTIFICATION TYPE:

In accordance with the Hamilton FQ4 FY25 DS availability, the SFLC SES has identified the necessity for a licensed technical representative from Appleton Marine Inc. to oversee the maintenance and servicing of critical systems aboard U.S. Coast Guard cutters. The specialized knowledge provided by the manufacturer's representative is essential to ensuring the safe and successful completion of this project, as their expertise is required to mitigate potential risks associated with the specified system.

The scope of services to be provided by the technical representative is outlined in TECH Pub 7903, which details the specific tasks and objectives the contractor must achieve with the presence of the

Last Updated 11/01/24 technical representative. The tasks cover essential maintenance and troubleshooting procedures to ensure optimal system performance.

These systems are integral to the cutters' boat launch and recovery operations, which are tasked with the crane and traversal of 5-ton boats on a moving ship, often under challenging weather conditions.

Given the critical nature of these systems, it is important to note that previous incidents involving the Coast Guard have resulted in the loss of crew members due to mishaps related to these systems.

Out of an abundance of caution and a commitment to safety, the U.S. Coast Guard is mandating the presence of a licensed technical representative from Appleton Marine Inc. to supervise and guide the maintenance process. This oversight is crucial to ensuring that all maintenance procedures are conducted in accordance with manufacturer specifications, industry standards, and the highest safety protocols.

This proactive approach will help minimize any risks and ensure the continued safety and reliability of the boat launch and recovery systems aboard the cutters.

On 12 March 2025 an email communication was sent to Appleton regarding availability of Licensed Technical Representatives and data rights to proprietary information. Appleton responded advising that the company does employ Licensed Technical Representatives and declined to share or sell the data rights to the crane systems to the USCG. Appleton also confirmed that there are no third-party vendors with access to the proprietary data held by the company, thus precluding competition for this work item.

CONTRACTING OFFICER - FAIR AND REASONABLE PRICE DETERMINATION METHODS:

☐ MARKET RESEARCH

☒ COMPARISON OF PROPOSED PRICE WITH PRICES FOUND REASONABLE ON PREVIOUS PURCHASES

☐ CURRENT PRICE LIST

☐ COMPARISON WITH SIMILAR ITEMS IN A RELATED INDUSTRY

☒ COMPARISON TO IGCE

CONTRACTING OFFICER’S PERSONAL KNOWLEDGE (EXPLAIN)

☐ OTHER (EXPLAIN)

SIGNATURE AND TITLE OF TECHNICAL AND REQUIREMENTS POC

DATE

SIGNATURE OF CONTRACTING OFFICER

DATE