J A_for_HSCG3814QJ00101_Wheel_Assembly_Buy.pdf

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

For the Procurement of Main and Tail Wheel Assemblies

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (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, Aviation Logistics Center, Medium Range Recovery Product Line, located in 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 solicit, negotiate, and award a requirements type contract with firm-fixed pricing on a sole source basis for the procurement of main and tail wheel assemblies. The wheel assemblies, listed on the following page, are used on the Coast Guard’s fleet of MH60T aircraft. These assemblies are manufactured by Meggitt Aircraft Braking Systems, Cage Code 0B9R9, 1204 Massillion Road, Akron, OH 44306-4188. Meggitt Aircraft is the original equipment manufacturer (OEM) and is the only known source for procuring the wheel assemblies. The total estimated value of the anticipated contract is $849,722.13.

3. Description of Supplies/Services. This requirement is for the procurement of the following wheel assemblies at a total estimated cost of $849,722.13 which includes a one-year base and four (4) one-year option periods.

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NOMENCLATURE

NATIONAL

STOCK

NUMBER

PART

NUMBER

ESTIMATED

QUANTITY

ESTIMATED

UNIT PRICE

ESTIMATED

TOTAL

BASE PERIOD

Main Wheel Assembly

1630-01-158- 5752 5004769 5 each $13,478.45 $67,392.25

Tail Wheel Assembly 1630-01-161- 8343 5004924-2 28 each $5,012.27 $140,343.56

Estimated Total for Base Period $207,735.81

OPTION PERIOD ONE

Main Wheel Assembly 1630-01-158-5752 5004769 5 each $13,923.24 $69,616.20

Tail Wheel Assembly 1630-01-161-8343 5004924-2 24 each $5,177.67 $124,264.08

Estimated Total for Option Period One $193,880.28

OPTION PERIOD TWO

Main Wheel Assembly 1630-01-158-5752 5004769 5 each $14,382.71 $71,913.55

Tail Wheel Assembly 1630-01-161-8343 5004924-2 12 each $6,052.72 $72,632.64

Estimated Total for Option Period Two $144,546.19

OPTION PERIOD THREE

Main Wheel Assembly 1630-01-158-5752 5004769 5 each $14,857.34 $74,286.70

Tail Wheel Assembly 1630-01-161-8343 5004924-2 12 each $6,252.46 $75,029.52

Estimated Total for Option Period Three $149,316.22

OPTION PERIOD FOUR

Main Wheel Assembly 1630-01-158-5752 5004769 5 each $15,347.63 $76,738.15

Tail Wheel Assembly 1630-01-161-8343 5004924-2 12 each $6,458.79 $7,7505.48

Estimated Total for Option Period Four $154,243.63

ESTIMATED GRAND TOTAL $849,722.13

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The procurement of main and tail wheel assemblies will continue to enhance the Coast Guard’s ability to perform the congressionally mandated missions such as search and rescue, law enforcement, international ice patrol, marine environmental protection, and marine resource conservation. These assemblies are part of the MH60T main landing gear. The main wheel assemblies function as a rim for the tires installed as part of the main landing gear. The tail wheel assemblies function as part of the rolling ground contact point for the tail landing gear.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c) (1) implemented by the 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.

These main and tail wheel assemblies are manufactured by Meggitt Aircraft Braking Systems, the OEM. The OEM maintains all proprietary data. The Naval Aviation Inventory Control Point (NAVICP), Philadelphia, PA is the primary inventory control activity (PICA) for the main and tail wheel assemblies however, the Navy is unable to support the Coast Guard at this time or in the near future as confirmed by the Navy via an email dated 26 March 2014. The Navy will reevaluate this position of support prior to calendar year 2020. These assemblies are reparable through the exchange process with the Navy but the Navy is only able to support repairing four

(4) assemblies per year. NAVICP will continue to be the primary source of supply for these wheel assemblies based on their availability. No other part numbers can be utilized. No acceptable alternate vendors have been identified.

6. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential

Sources as is Practicable. A Sources Sought Notice was posted on the Federal Business Opportunities (FBO) Governmentwide Point of Entry (GPE) website, www.fbo.gov, on 3 March 2014 with a response date of 19 March 2014; no responses were received. As required by FAR Subpart 5.102(a)(1), the intent is to issue a combined synopsis/solicitation through the GPE FBO website, www.fbo.gov, upon approval of this document. All responsible sources may submit a quotation, which shall be considered by the agency. However, market research reveals that only Meggitt Aircraft Braking Systems is Navy approved for manufacturing these assemblies and owns all proprietary rights. Market research was conducted from 11/4/13 through 3/26/14.

7. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable. The Contracting Officer anticipates prices ultimately negotiated for this requirement will be fair and reasonable based on a price analysis comparison with historical prices paid, IGCE, and the current market price.

8. Description of Market Research. Market research has been conducted in accordance with FAR

Part 10. Market Research was conducted to identify new sources of supply for the main and tail wheel assemblies used on the Coast Guard’s MH60 aircraft.

Market research included a search of the Inventory Locater Service (ILS), Federal Logistics Data (FEDLOG), and WebFLIS. The results of the market research identified the following potential vendors: Lockheed Martin Corporation, Goodrich, UTC Aerospace, Sikorsky Aircraft Corporation, and Meggitt Aircraft Braking Systems. Upon further research and by contacting each of these vendors, the Coast Guard was informed by each of these vendors, with the exception of Meggitt Aircraft, that they each get their supply of wheel assemblies through http://www.fbo.gov/

Meggitt Aircraft and the wheel assemblies are for their use and not for resale. Further research confirmed Meggitt Aircraft, the OEM, is the only supply source available. The Navy is listed as a mandatory source in the Coast Guard system however the Navy is unable to support the Coast Guard with the major purchase of the wheel assemblies at this time or in the near future as they are experiencing a high scrap rate as well and have limited inventory and can only support their needs at this time.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition. The Coast

Guard did not purchase the technical data packages, specifications, and documentation necessary to enable full and open competition, 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.

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

A Sources Sought Notice was posted on the FBO website, www.fbo.gov, on 3 March 2014; no responses were received. A combined synopsis/solicitation will be issued through FBO upon approval of this document. To date there has been one inquiry about this procurement from Meggitt Aircraft Braking Systems.

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 does not have the required data or drawings to overcome the sole source barrier to competition. The items require specific qualified standards to ensure the components are manufactured by agents in possession of the most current OEM data.

12. 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.

Pamela Johnson Date Technical Representative

13. 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.

NANCY DEBERRY Date Contracting Officer

APPROVAL:

Legal Review and Concurrence. I have reviewed this justification and deemed it legally sufficient.

Attorney Date USCG Legal Service Command-Norfolk

LSE-9E

DAVID BURGESS Date Chief of the Contracting Office

J. F. MARTIN, CAPT Date

CG ALC

Command Procuring Activity Competition Advocate (CPACA)