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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 Procurement of Main Landing Gear Wheels Solicitation Number: HSCG38-16-Q-010036

Pursuant to the requirements of the Competition in Contracting Act as implemented by Federal Acquisition Regulation (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), Medium Range Surveillance (MRS) Supply Cell, Elizabeth City, North Carolina proposes to enter into a purchase order on the basis of other than full and open competition.

(2) Nature and/or Description of the action being approved:

The USCG, ALC, MRS seeks approval for other than full and open competition for the acquisition of Main Landing Gear Wheels as identified in paragraph three (3) to support the HC-144 Maritime Patrol Aircraft (MPA). The Original Equipment Manufacturer (OEM) is Dunlop Aircraft Tyres, United Kingdom.

It is anticipated that a firm-fixed price Purchase Order will be awarded. The estimated price for this requirement is REDACTED.

The proposed contractor is: TBD, multiple vendors. Prospective vendors who are not the OEM must prove traceability back to the OEM.

(3) Description of Supplies/Services:

This activity seeks approval to procure the following Dunlop Aircraft Tyres Main Landing Gear Wheels to support the HC-144 MPA.

(4) Identification of the Justification and the Rationale:

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

In order to maintain structural integrity of the aircraft and ensure complete compatibility of the Main Landing Gear Wheels listed in this requirement must be obtained from the OEM or an OEM approved source. Use of OEM parts will ensure the parts are manufactured in accordance with OEM specifications and standards, conform to original form, fit, and function, and are compatible and interchangeable with existing components. For these reasons, it is in the USCG’s best interest and in the interest of the safety of our flight crews to procure only the Dunlop Aircraft Tyres authorized parts.

(6) A Description of the Efforts made to ensure that offers are solicited from as many potential sources as is practicable:

This procurement is forecasted in DHS-Acquisition Planning Forecast System (APFS) No. F2015030475 at www.apfs.dhs.gov.

In accordance with FAR 5.201, the intent to purchase these spare parts will be advertised on the Federal Business Opportunities (FBO) website as a combined synopsis solicitation under streamlined acquisition procedures for commercial items utilizing FAR Part 12.6 and 13.5. Any responsible vendor may submit a proposal; all responsible offers will be considered. If any responses are received as a result of this solicitation, the file will be documented accordingly and the requirement competed among all eligible offerors.

(7) Determination by the Contracting Officer that the Anticipated Cost will be Fair and Reasonable:

It is the Contracting Officer’s opinion that prices offered will be determined fair and reasonable prior to contract award, based on competition and previous commercial history data.

(8) Description of the Market Research:

Market research indicates the wheels are not listed on a General Services Administration (GSA) contract or available through GSA Advantage. Market research also consisted of querying the Industry Base System called Inventory Locator System (ILS) and previous procurement history reveals a very competitive marketplace. Multiple vendors have been found capable of providing the spare parts with traceability back to the OEM.

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

The spare parts to be procured under this acquisition are highly specialized parts, designed and manufactured by a non-Government activity and the technical data required for acquisition by other than the Original Equipment Manufacturer (OEM) is not available. Dunlop Aircraft Tyres is the prime contractor and OEM for the Main Landing Gear Wheels. The MRS Engineering Officer has determined that the required parts are critical for flight and has assigned an Acquisition Method Code (AMC) of 3 or 5 and Acquisition Method Suffix Codes (AMSC) of C, Q, or R. In accordance with DoD 4100.39 (series) Volume 10, Table 71, an AMC of 3 or 5 require the purchase of the items from the actual manufacturer or prime contractor only. An AMSC of C, Q, or R stipulates that the part requires engineering source approval by the design control activity in order to maintain the quality of the part or the data or rights to use the data needed to purchase this part from additional sources are not owned by the Government.

(10) A Listing of Sources, if any that expressed, in writing, an Interest in the Acquisition:

A combined synopsis/solicitation will be submitted to FBO upon approval of this document. Any responsible offer capable of providing the spare parts with traceability back to the OEM will be considered. 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 Required Supplies or Services:

The spare parts to be procured are complex and must meet critical operational and reliability requirements, the achievement of which require unique production techniques and extensive and/or sophisticated testing, and the Government has not yet acquired or developed the technical data, nor are there any plans to do so.

(12) Contracting Officer’s Certification I certify that the data supporting the recommended use of other than full and open competition 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

(14) Legal Review and Concurrence:

I have reviewed this justification and deem it legally sufficient.

Approval:

Contracting Officer, USCG, ALC, MRS