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Justification for Other than Full and Open Competition Under 10 U.S.C. 2304 (c)(1)

Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by FAR 6.3 and in accordance with the requirements of FAR 6.303-1, the justification for the use of the statutory authority under FAR 6.3 is justified by the following facts and rationale required under FAR 6.303-2 as follows:

(1) Agency and Contracting Activity.

The Office of Contract Operations (CG-9127), the United States Coast Guard (USCG) Headquarters, Department of Homeland Security (DHS), Washington, DC, 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.

The United States Coast Guard has a requirement for a stand-alone temporary Gulfstream G-V lease contract to Flight Support Incorporated (FSI), 120 Newsome Dr., STE J, Yorktown, VA 23692-5011, Cage Code: 38BM6, for continued Long Range Command and Control Aircraft (LRCCA) in order to accomplish the transition between a new competitively selected G550 lease contract vendor and the incumbent contractor.

(3) Description of Supplies/Services.

The requirement is to provide a Gulfstream G-V lease. Two Gulfstream G-V aircraft based at Air Station Washington (ASW) are used to conduct the LRCCA mission; one G-V that is owned by USCG, and the current G-V operating on a lease with FSI. The existing G-V aircraft lease expires on September 15, 2016. Additionally, all options have been exercised under the incumbent lease contract and there are no mechanisms under that contract that will enable an extension. As such, a new G-V lease must be executed in order to satisfy mission requirements until the new G550 leased aircraft is delivered to ASW.

Period Government Estimate

Base Month $ x Option Month $ x Option Month $ x Option Month $ x Option Month $ x Option Month $ x Aircraft Deconfiguration $ x

Total 2016 OE funds: $ x

(4) Identification of the justification and the rationale.

The statutory authority permitting other than full and open competition is Under 10 U.S.C. 2304 (c)(1), FAR 6.302-1(2)(iii)(B), Unacceptable delays in fulfilling the agency’s requirements. Two Gulfstream G-V aircraft based at ASW are used to conduct the LRCCA mission; one G-V that is owned by USCG, and the current G-V operating on a lease with FSI. The existing G-V aircraft lease expires on September 15, 2016. An existing G-V aircraft under lease to USCG is already configured to provide unrestricted secure command and control communication capabilities and the ability to perform normal duties while en route. Based on market research, FSI is the only source able to provide the short term lease necessary until the transition to the new contract G550 leased aircraft is complete.

(5) Demonstration that the nature of the acquisition requires use of the authority cited.

The current G-V aircraft USCG contract expires on September 15, 2016. Although the new five-year LRCCA has just been competitively awarded, the selected G550 aircraft must be provisioned for Secure Internet Protocol Router Network (SIPRnet) functionality as well as the installation of standard administrative office capabilities (ie. secure fax, telephone, etc.); the installation of this equipment must be completed prior to delivery of the aircraft to ASW for USCG operational use. There is a high risk that the required installation and aircraft testing for the G550 will not be completed prior to the end of the lease period for the existing G-V aircraft.

If a lease is not executed prior to delivery of the G550 aircraft under the new lease contract, the existing G-V aircraft under lease will depart ASW and USCG will be left with a single USCG-owned G-V aircraft to perform the mission. With USCG averaging approximately 1,000 flight hours per year for LRCCA requirements and the USCG-owned G-V being fifteen years old and in increasing need of depot maintenance, DHS Secretary, USCG Commandant, and other qualified users would not have use of the G-V, resulting in ASW mission failure.

As this is a commercial acquisition, FAR Subpart 13.5—Simplified Procedures for Certain Commercial Items will be utilized.

(6) A description of the efforts made to ensure that offers are solicited from as many potential sources as is practicable.

A FedBizOpps notice will be publicized as required by FAR 5.102(a)(6) and FAR Subpart 5.2 upon approval of this J&A.

(7) Determination by the Contracting Officer that the anticipated cost to the government will be fair and reasonable.

The Contracting Officer anticipates that the proposed prices will be fair and reasonable. The current contract with FSI provides five years of pricing history related to this requirement. The Contracting Officer will use price analysis IAW 13.106-3 as this is a commercial procurement.

(8) Description of market research.

Market research was conducted based on prior leased aircraft procurement as well as current lease procurement. APFS P2015030645 was posted on 8 December 2015 and P2016033175 updated on 6 July 2016 was posted. Request for Information HSCG23-16-I-2DA001 was posted on 22 October 2015 and updated 21 November 2015. An industry day at USCGHQ, Washington DC was conducted on 1 March 2016. Market research efforts resulted in the following vendors listed in section (10) below that expressed interest.

(9) Any other facts supporting the use of other than full and open competition.

N/A

(10) A listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

xxxx responded to the RFI.

(11) A statement of actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for supplies or services.

At this time, for reasons as set forth previously in sections (2) and (5), the USCG is unable to conduct a full and open competition for this short-term effort. However, in order to foster full and open competition for any future requirements, the USCG will continuously conduct market research to ensure that companies interested in doing business with USCG are given every opportunity to compete for future requirements. In an effort to increase competition the program office will attend aviation trade shows, conduct internet database research, and ensure requirements are advertised in the Government Point of Entry (FEDBIZOPPS).

(12) 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.

Contracting Officer Date

(13) 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.

Technical Representative/COTR Date

(14) Legal Review and Concurrence:

I have reviewed this justification and deemed it legally sufficient.

Attorney Date

(15) CPACA Review and Concurrence:

APPROVAL:

Over $650k but not exceeding $12.5mil Date

CPACA