JOTFOC-08Q200090.doc

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION HSCG38-08-Q-200090

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) Agency and the contracting activity. 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 limited sources basis, servos for use on the HH65 aircraft. These servos are manufactured by Goodrich Actuation Systems. The proposed contract type is a firm-fixed price purchase order. Market research reveals that the following vendors are capable of providing these servos to the U.S. Coast Guard: Sey Tec, Hurst, TX; Boone Air Parts, Valencia, CA; Defense Technology Equipment, Sterling VA; HK Aerospace, Burbank, CA; B&B Marketing Enterprises, Deerfield Beach, Fl; American Eurocopter, Grand Prairie, TX; Goodrich Control Systems, Montreal, QC; Alpine Air Support, Brutten, Switzerland.

(3) 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 anticipated to be awarded to responsible sources with traceability to the Original Equipment Manufacturer (OEM) of the items solicited. Failure to purchase these parts may cause aircraft to be grounded. The material and estimated quantities to be procured are based on current and past usage. Projected stocking levels are based on: experienced mean time between failure rates; failure and corrosion trends; experienced and projected scrap rates and procurement lead times. The period of performance is 365 days from time of award.

(4) Identification of the statutory authority permitting other than full and open competition.10 U.S.C. 2304(c)(1), as implemented by 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 requires use of the authority cited. The components/parts to be procured are manufactured by Goodrich Actuation Systems, who owns all rights to proprietary data, specifications and drawings. There are no domestic manufacturers for these parts. There are, however, U.S. affiliates and distributors who may be able to propose on one or more of the parts to be procured. The part number listed in the requirement is the only one approved for use on the HH65 aircraft. This would prohibit consideration of a part number manufactured by other companies; therefore, limiting the number of firms who can submit an offer for the parts listed in the requirement.

(6) Description of efforts made to ensure that offers are solicited from as many potential sources as is practicable. This action was solicited utilizing the streamlined synopsis/solicitation procedures for commercial items authorized in FAR 12.603; therefore, a pre-solicitation synopsis was not issued. If any responses are received as a result of this solicitation, the file will be documented accordingly and the requirement competed among all eligible offerors.

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION HSCG38-08-Q-200090

(7) Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable. The Contracting Officer determines that the anticipated price will be fair and reasonable based on a comparison to market prices for similar items, published price list and the government estimate.

(8) Description of the market research. Market research is continually conducted to identify new sources of supply for the HH65 components and spare parts. The first and most comprehensive is the Coast Guard’s Aviation Maintenance Management Information System (AMMIS) which 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. The USCG did not purchase the technical data rights as part of the initial system acquisition for the HH-65 aircraft. The necessary manufacturing drawings, data, and special tooling are proprietary and available only to the foreign original equipment manufacturers. The performance and acceptance data are also proprietary. The USCG does not have adequate technical descriptions to enhance competition. Historical data indicates that several domestic vendors have supplied the Coast Guard with the servos used on the HH65 aircraft.

(10) Listing of the sources, if any, that expressed in writing, an interest in the acquisition. In accordance with FAR 5.201, the intent to contract for these items will be publicized via FedBizOps.

(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. Complete specifications and drawings for the HH65 are not available to the Coast Guard. The Coast Guard does not possess technical expertise nor were the data rights to spares purchased as part of the initial system acquisition for the HH65 aircraft. 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 FedBizOps. In support of the Competition in Contracting Act, ARSC established the New Product Development Branch (NPD) and a representative of the NPD Branch is assigned to the HH65 Product Line. This representative has the responsibility to locate alternate sources of supply/services and alternate acceptable products. Since distributors within the U.S. are limited, NPD is exploring avenues of reverse engineering hard to find items. However, this process is lengthy, costly and a labor intensive effort. Engineering, contracting and New Product Development representatives continuously conduct market research through sources sought notices, posting RFQs and RFPs in FedBizOps, 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 Association Int’l, a major industry trade show – in 3/08 Houston, 3/07 Anaheim, 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.

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION HSCG38-08-Q-200090

(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.

__________________________ Date: _____________________

CYNTHIA D. SOULES

Contracting Officer

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.

__________________________ Date: _____________________

PATRICIA ROZANSKI

H65 SUPPLY CELL LEADER

APPROVAL:

__________________________ Date: _____________________

CYNTHIA D. SOULES

Contracting Officer