J A for EGI Modification 1308-JV02.docx

EGI Modification

Justification for Other than Full and Open Competition Under 10 USC 2304(c)(1).

“Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements”

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 FAR 6.303-2.

1. Agency and Contracting Activity. The Department of Homeland Security, U.S. Coast Guard, Aviation Logistics Center (ALC), H60 Medium Range Recovery (MRR) Product Line Division, Elizabeth City, NC, proposes to enter into an order on a basis of other than full and open competition.

2. Nature and/or description of the action being approved. The Justification for Other Than Full and Open Competition seeks approval to issue a firm-fixed priced order on a sole source basis to Honeywell Intl., 13350 US Highway 19 North, Clearwater, Florida 33764, for the repair and modification of Embedded Global positioning system/Inertial navigation system (EGI). Honeywell is the original equipment manufacturer (OEM) of the Coast Guard’s EGI’s which are identified by NSN 6605-01-HS1-4577 and P/N 34201700-3M13. EGI’s will be issued in this configuration and modified to NSN 1680-01-HS1-9691, P/N: HG9869K1-001 which is required for system compatibility and safe system operation in the Coast Guard’s “T” model MH-60 aircraft. In accordance with 1H-60T-4, MH-60T Illustrated Parts Catalog, TCTO H60-934080, Technical Manual 1-1520-237-23 (SUP), and COMDT CG 711 (Avionics Operational Requirements Document) no other EGI part number or configuration is authorized for use on the Coast Guard’s MH-60 aircraft. The services required have been determined to be commercial in nature and this action will be processed in accordance with FAR Part 12 and Subpart 13.5 for commercial item acquisition.

3. Description of Supplies/Services. – The MH-60T has two independent, self-contained Embedded Global positioning system/Inertial navigation system (EGI) components which generate aircraft attitude and present position derived from either a purely inertial solution, a direct GPS solution, or a blended solution of both. The EGI is a self-contained, all-attitudinal navigation system. Modification of the EGI’s include decreasing the size of the actual box from 12.75 inches to 9 inches and making several internal card changes to ensure the software integration between the “J” and the “T” models is accurate, efficient and compatible with the on-going CAAS cockpit conversion.

The estimated cost for modification of nineteen (7) EGI’s is shown in the table below.

34201700-3M13, HG9924A01

HG9869K1-001,

34209200-RJAD-001

Total Mod Cost

4. Identification of the Justification and the Rationale: The statutory authority permitting other than full and open competition is 10 USC 2304(c)(1) as implemented by the Federal Acquisition Regulation (FAR) Subpart Regulation 6.302-1: Only one of a limited number of responsible sources and no other supplies or services will satisfy agency requirements.

5. Demonstration that the Nature of the Acquisition requires use of the authority cited: Honeywell Int’l is the Original Equipment Manufacturer (OEM) of the Coast Guard’s EGI’s and all data necessary to accomplish these services is proprietary to Honeywell. The modification data required to upgrade the EGI’s to NSN 1680-01-HS1-9691, P/N: HG9869K1-001 is also proprietary to Honeywell. In accordance with 1H-60T-4, MH-60T Illustrated Parts Catalog, TCTO H60-934080, Technical Manual 1-1520-237-23 (SUP), and COMDT CG 711 (Avionics Operational Requirements Document) no other EGI part number or configuration is authorized for use on the Coast Guard’s MH-60 aircraft. Honeywell Int’l is the only source in possession of the proprietary data required to accomplish the required modification services.

6. Description of efforts made to ensure that offers are solicited from as many potential sources as is practicable. The intent to issue a firm-fixed repair priced commercial order for the modification of items specified in paragraph 3 will be submitted to Federal Business Opportunities upon approval of this 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 prices ultimately negotiated for this procurement will be fair and reasonable based on historical cost data, price analysis and comparison with previous acquisitions for modification of similar EGIs.

8. Description of Market Research. Market research has been conducted using FEDLOG, Haystack, and WEBFlis to identify other alternative modification sources. None of the aforementioned databases provided any sources for these services other than Honeywell Int’l, OEM. Jim Western, Customer Business Leader, Honeywell Int’l was contacted regarding the existence of authorized service centers and access to the necessary proprietary data. Mr. Western responded via email, dated 19 July 2011 (attached) with information that confirms the previous market research. According to Mr. Western’s response, there are no authorized service centers for Honeywell’s EGI’s and access to the proprietary data would be cost prohibitive.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition. The Coast Guard did not purchase data rights as a part of the initial system acquisition for the MH-60 helicopter. Therefore, it would be difficult to take steps to foster competition as the manufacturing performance and acceptance data are proprietary and the Coast Guard does not have adequate technical data to provide to potential offerors. Due to the maturity of the Coast Guard’s conversion effort and the EGIs, the Coast Guard has not found it to be feasible to attempt to purchase the data rights for these items. The initial set up and recurring cost for equipment, documentation, training, management and licensing for purchase of Honeywell’s technology would not be cost effective.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition. To date, there have been no inquiries from other potential sources regarding this requirement. This requirement will be publicized via Federal Business Opportunities (FBO) with a complete and comprehensive description of the Government’s needs. The FBO posting will inform interested parties that the Government does not own and cannot provide data of any kind to facilitate this work.

11. A statement of actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for required supplies and services. Absent access to a complete data package, there is little the Government can do to overcome the present barriers to competition. Data packages which would facilitate competition were not purchased as part of the initial acquisition of the HH-60 aircraft nor has any additional data been purchased to support competition for the upgrade to the “T” model. Given the maturity of the “J” to “T” conversion effort and the limited funding available for this effort, it is doubtful that additional funding would be appropriated to support the acquisition of the proprietary data necessary to promote completion. In the event that funding for data acquisition is made available, the Coast Guard will actively pursue data procurements.