HSCG38-08-Q-200084 J A fedbizopps.doc

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION HSCG38-08-Q-200084

Pursuant to the requirements of the test program for commercial items as implemented by Section 4202 of the Clinger-Cohen Act of 1996 as implemented by FAR 13.501(a)(ii), this justification for other than full and open competition is supported by the following facts and rationale in the format described at FAR 6.303-2:

(1) Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for other than full and open competition.”

U.S. Coast Guard, Aircraft Repair and Supply Center (ARSC), HH-65 Contract Section, Elizabeth City, North Carolina, proposes to issue a purchase order on a basis other than full and open competition.

(2) Nature and/or description of the action being approved.

Approval is requested to purchase, on a sole source basis, a quantity of eighteen (18) ballistic blanket sets for the HH65 and an option to increase the quantity if the AUF Mission becomes fleet operational.

This item is manufactured for the USCG by Armour of America. The initial purchase was procured using full and open competition. The prototype was developed and then tested and approved by USCG's Engineering. This purchase is for additional production quantities of the ballistic blanket sets.

The proposed contract type is a firm-fixed price purchase order and the vendor is Armour of America, 308 Alabama St, Auburn, Al. 36832-4343.

3. A description of the supplies or services required to meet the agency’s needs (including the estimated value).

As the Aviation Inventory Control Point (AICP), ARSC must provide effective supply support for all Coast Guard aviation units and for the Programmed Depot Maintenance Program. This requirement is to be awarded to the OEM or a responsible source that has access to original OEM parts and can provide traceability. Failure to purchase the ballistic blanket sets will leave the aircraft without full force protection capability and adversely impact the Coast Guard‘s law enforcement mission. The material and estimated quantities to be procured are based on current mission requirements. In anticipation of future mission requirements, included is an option to outfit the remaining HH65 fleet. These are intended for the current fiscal year; one set per aircraft.

(4) An identification of the statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c)(1) as implemented by the Federal Acquisition Regulation (FAR) 6.302-1 entitled “Only one responsible source or a limited number of responsible sources and no other type of supplies or services will satisfy agency requirements”.

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

The item to be procured is manufactured for the USCG by Armour of America. The initial purchase was procured using full and open competition. The prototype was developed and approved by USCG's Engineering. This new purchase is for additional quantities of the ballistic blanket sets.

Furthermore, this is a small business and as such has no resellers and distributors who may be able to propose on one or more of the parts to be procured.

(6) Description of efforts made to ensure that offers are solicited from as many potential sources as is practicable. - The proposed contract action is for the amount not expected to exceed the simplified acquisition test program threshold. A combined synopsis/solicitation for commercial items prepared in accordance with the format in FAR Subpart 12.603 will be issued. This procedure combines the synopsis required by 5.102 (a)(6) and 5.2 and the issuance of the solicitation into a single document.

(7) Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable. – It is the Contracting Officer’s opinion that price ultimately negotiated for this procurement will be determined fair and reasonable based on comparison with historical pricing, and the Government's estimate.

(8) Description of the market research. When conducting market research, the Coast Guard's Aviation Maintenance Management Information System (AMMIS) is checked. This is a database that provides historical data for all parts purchased by ARSC. This database includes, but is not limited to, part number, nomenclature, purchase/delivery order number and historical pricing data. As part of the requirements package, a copy of all AMMIS data is included to support the independent Government estimate. Federal Logistics (FEDLOG) is a federally supported program which lists all manufacturers/suppliers by cage code. This program provides a valuable tool for supplier information and is utilized by requirements personnel to determine if alternate sources of supply exist. Information is accessed by National Stock Number, Nomenclature, item name, supplier name, and cage code. Another source is Inventory Locator mart (ILS). This website is used to locate hard to find parts. - Market surveys are continually conducted to identify new sources of supply for the HH65 components and spare parts.

(9) Any other facts supporting the use of other than full and open competition, i.e., proprietary data packages, etc.

This requirement is for additional quantity of the ballistic blanket set. Initially on 9/27/07, the USCG issued an unrestricted combined synopsis/solicitation for a prototype and limited amount of productions sets. The solicitation was posted for 21 days including questions and answers and a response extension. Ample opportunity was given for vendors to submit a proposal that met the USCG's requirement. There were two vendors that responded timely; two other vendors responded late and another two expressed interest but never submitted a proposal. Armour of America was selected based upon best value. Because of USCG’s mission requirements, high priority demands, and inventory levels, ARSC HH-65 cannot delay this procurement to facilitate development of these ballistic blankets by other vendors. The vendor must be capable in performing and delivering in the required timeframes.

(10) Listing of the sources, if any that expressed in writing, an interest in the acquisition. – In accordance with FAR 5.102 and 5.201, the intent to contract for this product will be posted to FEBizOpps.

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required. – Although the USCG does own the drawings, patterns, at this time to give other vendors this information, would require the USCG go through the first article approval again. The initial procurement was done via full and open competition and the vendor was selected based upon best value. The selected vendor has proven to be capable in performing in the required timeframe based on previous history. Because of its mission requirements, high priority demands, and inventory levels, USCG ARSC HH-65 cannot delay this procurement to facilitate development of these ballistic blankets by other vendors.

As the Aircraft Inventory Control Point (AICP), ARSC is tasked with supporting systems that have been deployed for use in the aviation community. However, in an effort to increase competition among affiliates and distributors, HH65 Product Line members annually attend aviation trade shows, extensive Internet database research is conducted and procurements are advertised in FedBizOpps. In support of the Competition in Contracting Act, ARSC established the New Product Development Branch (NPD). The NPD representative assigned to the HH-65 Product Line has the responsibility to locate new sources of supply/services and alternate acceptable products New Product Development representative with Engineering, and contracting continuously conduct market research through sources sought notices, posting RFQs and RFPs in FedBizOpps, attendance of trade shows and networking to ensure that companies interested in doing business with the USCG are given every opportunity to compete for our requirements. Each year, NPD attends the annual Helicopter Assoc. Int'l, a major industry trade show – in 3/08 Houston, 3/07 Aneheim, CA, 3/06 Orlando, FL. NPD identifies and visits those companies that offer similar parts to the ones used on the aircraft or have manufacturing capabilities of similar items.

(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; and

Cynthia D. Soules

DATE

Contracting Officer

(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 justification, is complete and accurate.

Patricia M. Rozanski

Technical Representative

APPROVAL:

Keith O’Neill

Assistant Competition Advocate