JANDAOPEN.docx

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

SOLICITATION NO. HSCG38-11-Q-011077

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

(1) Agency and Contracting Activity

The Department of Homeland Security, United States Coast Guard (USCG), Aviation Logistics Center (ALC), Medium Range Surveillance (MRS) Product Line, Elizabeth City, NC proposes to enter into a contract on a basis of Other Than Full and Open Competition with the respective Original Equipment Manufacturer (OEM) for EADS CASA spares used on the HC -144 aircraft.

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

This Justification and approval (J and A) for Other Than Full and Open Competition seeks approval of a acquisition on an other than full and open competition basis, for a firm-fixed-price, firm-fixed quantity contract for the acquisition of the following:

1. NSN: 1620-01-HS2-4320, LOWER ELEC HARNESS L, P/N D22624000-2, QTY 4 EACH MFGCD: 0DAF1

2. NSN: 1560-33-202-5611, DOOR, NLG, RH, P/N 95-21150-0002, QTY 1 EACH: MFGCD: 0117B

3. NSN: 4820-33-001-2554, VALVE, NON RTURN, P/N CA45000-0001, QTY 1 EACH: MFGCD: 7926B

4. NSN: 1560-01-HS2-3516, COVER ASSY, P/N 35-25978-0001A03, QTY 1 EACH, MFGCD: 0DAF1

5. NSN: 4820-14-435-0140, VALVE, P/N L97F63-201, QTY 1 EACH: MFGCD: F0422

6. NSN: 5310-01-526-0529, NUT, PLAIN HEX, P/N J3937-5, QTY 50 EACH: MFGCD: 76005

7. NSN: 5365-99-107-7832, RETAINER GREASE, P/N AH088409, QTY 20 EACH MFGCD: K1037

8. NSN: 5330-33-001-9884, JOINT, P/N 35-71202-0403, QTY 20 EACH, MFGCD: 0117B

9. NSN: 5360-01-HS2-4297, SPRING, P/N 35-51249-0601, QTY 50 EACH; MFGCD: 0DAF1

10. NSN: 5310-01-HS2-4296, WASHER, P/N 35-21190-6901, QTY 100 EACH: MFGCD: 0DAF1

11. NSN: 5330-14-543-9559, PACKING, P/N BT20-3, QTY 50 EACH: MFGCD: 7926B

12. NSN: 5330-99-983-9258, RING, P/N DAS2217-2, QTY 100 EACH: MFGCD: U8018

13. NSN: 5310-01-341-8036, WASHER, P/N J4144-1, QTY 100 EACH: MFGCD: 0DAF1

14. NSN: 1680-HS2-4294, GEAR, P/N 35-21190-6501, QTY 5 EACH: MFGCD: 0DAF1

15. NSN: 1680-01-HS2-4295, AXLE, P/N 35-21190-6701, QTY 5 EACH: MFGCD: 0DAF1

16. NSN: 4810-33-004-8616, VALVE ASSY, P/N CA91300-0001, QTY 2 EACH: MFGCD: 0DAF1

17. NSN: 1680-01-HS2-3677, RUD LOCK SYSTEM, P/N 35-46734-0023A01, QTY 1 EACH: MFGCD: 0DAF1

18. NSN: 5325-33-001-0365, RETAIN RING, P/N 35-45010-0401, QTY 100 EACH: MFGCD: 0DAF1

19. NSN: 5310-33-200-0007, WASHER, P/N 35-46358-1501, QTY 100 EACH: MFGCD: 0DAF1

20. NSN: 1650-99-471-1750, FIL ELEMENT, P/N QA07647, QTY 13 EACH: MFGCD:U0088

21. NSN: 1650-99-126-9454, FIL ELEMENT, P/N QA07646, QTY 21 EACH: MFGCD: U0088

22. NSN: 1650-14-452-0431, VALVE ASSY, P/N A24282032, QTY 1 EACH: MFGCD: 7926B

23. NSN: 4710-33-201-1007, ALTERNATOR COOLING, P/N 35-51204-0005, QTY 2 EACH: MFGCD: 0117B

24. NSN: 6115-01-HS2-4303, A/C GENERATOR, P/N 31342-0006, QTY 4 EACH: MFGCD: 99551 These components are manufactured by EADS CASA North America, 8100 EADS CASA, Mobile Al. The U. S. Coast Guard intends to negotiate with the Original Equipment Manufacturer (OEM).

(3) Description of Supplies/Services This requirement is to procure 24 line items of spare parts in support of the HC144 Coast Guard aircraft. The Coast Guard must maintain an inventory of spare parts for maintenance and repair of the HC144 Coast Guard aircraft and associated components. A situation involving a shortage of spare parts would adversely affect delivery of aircraft undergoing programmed depot level maintenance. Not only would this delay delivery and escalate depot maintenance costs, but would also impact aircraft readiness rates in the field resulting in a decreased effectiveness of Coast Guard commanders’ ability to execute missions. This requirement is to procure new EADS CASA spare parts that will be used as a repair pipeline spare to support ALC repairs of the HC144.

(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 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.

This procurement must be restricted to EADS CASA North America, the OEM, and their distributors that can provide documented traceability for components they offer as part of this acquisition. The necessary manufacturing drawings, data, test equipment, and tooling required for the manufacture of this equipment are proprietary and controlled by the OEM. They were not available or procured as part of the initial system acquisition for this aircraft.

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

In an effort to increase competition, MRS Product Line Division, HC-144 Section members attended aviation trade shows, performed extensive Internet database research and contacted the original manufacture of the current indicating system inquiring if a modernized system existed. In addition, this requirement will be advertised in the Electronic Posting System (EPS/FedBizOps), as a combined synopsis/solicitation.

(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 prices will be fair and reasonable based on comparison of the commercial published prices lists by the OEM’s, previous AMMIS procurement history, and comparison of quotes submitted by interested offerors, if applicable.

(8) Description of Market Research.

The market survey consisted of utilizing the Inventory Locator System (ILS), EADS CASA North America catalog and internet data. Market research has indicated no government sources are available to support this requirement.

(9) Any Other Facts Supporting the Use of Other Than Full and Open Competition.

The Coast Guard did not purchase the data as part of the initial system acquisition for the HC-144A aircraft. As a result, it would be difficult to take steps to foster competition as the manufacturing performance and acceptance data are proprietary to the OEM and the Coast Guard does not have adequate technical data to provide to potential offerors at this time.

(10) A Listing of the Sources, if Any, That Expressed, in Writing, an Interest in the Acquisition.

If responses to the synopsis indicate additional sources are available, 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.

The Coast Guard did not purchase the data as part of the initial system acquisition for the aircraft; as a result, it would be difficult to foster a competitive procurement effort. Complete specifications and drawings are not available and the cost to procure them is not easily quantifiable. As the AICP, ALC is tasked with supporting systems that have been deployed for use in the aviation community. As such, our budget does not include funding to procure data for these systems. The data for these components are proprietary to the OEM and therefore future competition for this effort is not known. In an effort to increase completion the HC-144A Division member annually attend aviation trade shows and conduct extensive Internet data research and procurements are advertised in FBO.

(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

(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.

Technical Representative Date

(14) APPROVAL:

Contracting Officer