JOTFOCBladeO RContractFBO_Post.pdf

HSCG38-09-R-J00009 Enclosure (1)

Justification for Other than Full and Open Competition for the Repair of MH-60J/T Main and Tail Rotor Blades

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 United States Coast Guard (USCG), Aviation Logistics Center (ALC), Elizabeth City, NC, 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. This Justification for Other Than Full and Open Competition seeks approval to contract with the original equipment manufacturer (OEM), Sikorsky Aircraft Corporation (78286), located in Stratford, CT. Request approval to proceed with this sole source acquisition for a firm fixed-price five year Indefinite Delivery Indefinite Quantity (IDIQ) contract for the repair of Main Rotor Blades and Tail Rotor Blades used on the USCG’s Sikorsky MH-60 J/T fleet of aircraft. The contract will contain a base year with four one year option years. The delivery/task orders will be issued on a firm fixed-price basis. The total estimated cost with a base and four option years is approximately $34,522,000.00.

(3) Description of the Supplies/Services. This is a repair requirement for Main Rotor Blades (MRB), National Stock Number (NSN) 1615-01-158-9679, part number (P/N) 70150-29100-041, estimated at 84 each year over a five year period and Tail Rotor Blades (TRB), NSN 1615-01-158-9678, P/N 70101- 31000-046, estimated at 74 each year over a five year period. Repairs consist of minor and major, and strip and rebuild of the Main Rotor Blade (MRB); and minor and major repair of the Tail Rotor Blade (TRB), on an as needed basis. The MRB minor repair includes tip block and tip cap corrosion, minor wire mesh corrosion, patch, plug replacements, cuff repair and laminate repair. The MRB major repair includes all minor repairs as mentioned above and heater mat and cuff replacement due to high time.

The MRB strip and rebuild includes complete stripping of the blade to the spar and rebuild the blade to serviceable condition along with heater mat. The TRB minor repair includes plug replacement, patch, cuff repair and laminate repair. The TRB major repair includes all minor repairs mentioned above and horn replacement. In addition, this contract will incorporate service bulletins, modifications, engineering change proposals, local engineering change proposals and time compliance technical orders. There will be a fixed price for scrapping the blades due to spar damage, damage beyond repair limitations, high time on spar and excessive water in the paddles. Main Rotor Blades are to be balanced by placing on a whirl tower and spun against an OEM certified master blade.

Period Total Price Base Year 12 months $6,375,000.00 Option Year 1 12 months $6,598,000.00 Option Year 2 12 months $6,896,000.00 Option Year 3 12 months $7,181,000.00 Option Year 4 12 months $7,472,000.00 Total $34,522,000.00

(4) Identification of the justification and the rationale. The statutory authority permitting other than full and open competition is 10 USC 2304(c)(1) implemented by the Federal Acquisition Regulation (FAR) Subpart 6.302-1(a)(2)(ii) entitled “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. The Main and Tail Rotor Blades to be repaired are manufactured by Sikorsky Aircraft Corporation, the OEM. Sikorsky is the only known and approved manufacturer for the Main and Tail Rotor Blades. They design and manufacture the rotor blades for the MH-60 J/T aircraft. The data and specifications are owned exclusively by Sikorsky. They are the only known company that has the technical expertise to repair, incorporate service bulletins and test the main rotor blades. The Naval Aviation Inventory Control Point, Philadelphia, PA (NAVICP) is the Primary Inventory Control Activity (PICA) for the blades. In accordance with PL.108-136, 802, NAVICP has the sole responsibility for certifying manufacturing and servicing contractors for common MH-60 items used by Navy and Coast Guard. The parts listed in this requirement are currently used on the Coast Guard MH-60 J/T aircraft fleet. The Main and Tail Rotor Blades are interchangeable throughout the Coast Guard MH-60 J/T Fleet. There are no acceptable alternate part numbers. Market research through speaking with blade vendors at the Helicopter Association International (HAI) trade shows, internet searches and searches of various subscription inventory locator services such as Haystack and PartsBase have not resulted in locating any other approved sources other than Sikorsky.

(6) A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable. A Request for Information/Sources was posted to the Electronic Posting System (EPS)/Federal Business Opportunities (FEDBIZOPPS) on June 30, 2009 with a closing date of July 14, 2009 requesting sources with the technical capability of providing the blade repairs. A solicitation was posted on FEDBIZOPPS on November 16, 2009 with a closing date of December 15th with the statement that all responsible sources may submit a capability statement which shall be considered by the Agency. No additional approved sources responded to either notice.

(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 price analysis techniques and comparison with current prices and previously paid prices.

(8) Description of market research. A Request for Information/Sources was posted to the Electronic Posting System (EPS)/Federal Business Opportunities requesting sources with the technical capability of providing the blade repairs. Two companies responded. The only NAVICP approved source is Sikorsky Aircraft. A solicitation was posted on FEDBIZOPPS on November 16, 2009. Sikorsky was the only company to respond. Market surveys are continually conducted to identify new sources of supply for the MH-60 J/T components and spare parts for the MH-60 J/T aircraft. Haystack, PartsBase, Federal Logistics Data (FEDLOG), and web searches have not resulted in locating any other sources of supply. Emails to several helicopter blade repair facilities resulted in one company expressing interest in repairing blades. Currently, no other sources have the authority to repair the MH-60 J/T Main and Tail Rotor Blades.

(9) Any other facts supporting the use of other than full and open competition. This is a follow-on contract for repairs. In December 2005 ALC released a solicitation for a firm fixed-price IDIQ contract with a base year with three one year option years. This current contract expired in December 2009.

The only approved vendor was Sikorsky Aircraft Corporation (SAC).

(10) A listing of the sources, if any that expressed, in writing, an interest in the acquisition. As a result of posting a Request for Information/Sources to the Electronic Posting System (EPS)/Federal Business Opportunities on June 30, 2009 for blade repairs, two companies responded (See paragraph 8, Market Research). Three blade repair companies were contacted via email as possible sources. Also, in accordance with FAR 5.201, the intent to contract for these repairs was submitted to the Electronic Posting System, Federal Business Opportunities.

(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 required supplies or services. The USCG did not purchase data rights as part of the initial system acquisition for the MH-60 J/T aircraft. The manufacturing, performance and acceptance data are proprietary to Sikorsky Aircraft. The Coast Guard does not have the technical data to provide information to potential offerors for manufacturing or to perform the repairs. The blades are Critical Safety Item’s (CSI) and the repair sources are restricted to the sources approved by the Navy. This is regardless of whether the repair is performed by the Government or a contracted entity. CSI parts that fail have the potential for catastrophic or critical consequences to personnel or equipment. The NAVAIR Research and Engineering Group (AIR-4.0) and NAVICP are responsible for providing the engineering policies, processes and support necessary to ensure design integrity and airworthiness throughout the life cycle of maintained unique military aviation systems and equipment. Sikorsky Aircraft is the only approved source at this time.

Requirements are in place for revalidation of sources and establishment of alternative sources.

(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 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 accurate and complete.

Inventory Management Specialist, MRR PL

(14) Reviewers:

Chief of the Contracting Office (ALC)

I have reviewed this justification and determined to be legally sufficient:

Attorney Date

HQ Procurement Activity Competition Advocate

(15) Approval:

Senior Procurement Activity Competition Advocate