Redacted J A_HSCG3808Q300037 .doc

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION NO. HSCG8-08-Q-300037

(1) Agency and Contracting Activity -- U.S. Coast Guard, Aircraft Repair and Supply Center, HC-130 Product Line, Elizabeth City, North Carolina, presents this Justification for Other Than Full and Open Competition for review and approval.

(2) Nature and/or description of the action being approved. – Approval is requested to procure, on a sole-source basis, a contract for the purchase of HC-130J propeller blades (Dowty Type No. R391/6-132-F/3) for spare parts. These are commercial items that will be procured utilizing the procedures in FAR Part 12. The proposed contractor is GE Aviation LLC, Dowty Propellers, of Gloucester, England, the original equipment manufacturer (OEM) of the propellers. It is anticipated that a contract with firm-fixed prices will be established.

(3) Description of Supplies/Services – The requirement is to provide spare parts for the C-130J aircraft fleet. The total estimated value of this procurement is $____________ for a quantity of 3 propeller blades.

(4) Identification of Statutory Authority Permitting OtherTthan Full and Open Competition. – 10 U.S.C. 2304(c)(1) as implemented by the Federal Acquisition Regulation (FAR) 6.302-1. Only one responsible source and no other supplies or services will satisfy agency requirements.

(5) Demonstration That the Nature of the Acquisition Requires Use of the Authority Cited. – GE Aviation LLC, Dowty Propellers is the original equipment manufacturer of the R391 propeller. This is the only known firm who can provide approved spare parts, engineering design changes and product improvements. GE Aviation LLC, Dowty Propellers owns the rights to the proprietary data, specifications and drawings necessary for performance and has the staff and extensive experience necessary to maintain and improve propeller performance/reliability.

(6) Description of efforts made to ensure that offers are solicited from as many potential sources as is practicable. A combined synopsis/solicitation will be submitted via Federal Business Opportunity upon approval of this J&A. GE Aviation LLC, Dowty Propellers is the only known OEM authorized manufacturer for this procurement.

(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 prices ultimately negotiated for this procurement will be fair and reasonable based on a comparison to commercial prices, a comparison to historical pricing information on similar items, and an analysis of other than cost and pricing data.

(8) Description of Market Research Market research was conducted by researching FedLog for additional suppliers and contacting GE Aviation LLC, Dowty Propellers for distributors. Since GE Aviation LLC, Dowty Propellers is the only firm owning the rights to the proprietary technical data required for performance, additional competition is not expected. Any other feasible source would have to build or modify existing equipment utilizing GE Aviation LLC, Dowty Propellers drawings that are proprietary and cannot be provided to third parties.

(9) Any Other Facts Supporting the Use of Other Than Full and Open Competition. All of the data, specifications, manuals, and drawings necessary to perform this requirement are proprietary to the OEM. GE Aviation LLC, Dowty Propellers is the only firm who has the technical data necessary to produce the required tooling, test equipment, and approved replacement parts necessary for performance.

(10) A Listing of the Sources, if Any, That Expressed, in Writing, an Interest in the Acquisition. A combined synopsis/solicitation will be submitted via Federal Business Opportunity upon approval of this J&A. If any responses are received, the file will be documented accordingly and the requirement competed among all eligible offerors.

(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 Supplies or Services Required.. – Complete specifications and drawings for the C130J 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 C130J aircraft. As the Aircraft Inventory Control Point (AICP), ARSC is tasked with supporting systems that have been deployed for use in the aviation community. In support of the Competition in Contracting Act, ARSC established the New Product Development Branch (NPD). In an effort to increase competition among affiliates and distributors, NPD members annually attend aviation trade shows, extensive Internet database research is conducted and procurements are advertised in FedBizOpps. A representative of the NPD staff is assigned to the HC-130 Product Line. This representative has the responsibility to locate alternate sources of supply/services and alternate acceptable products. Engineering, contracting and New Product Development representatives continuously conduct market research to ensure that companies interested in doing business with the USCG are given every opportunity to compete for our requirements.