INTENT_JA.pdf

Justification and Approval for Other than Full and Open Competition Under 10 U.S.C. 2304 (c) (1)

Only One Responsible Source and No Other Supplies Will Satisfy Agency Requirements

A800 Searchlight Procurement

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Pursuant to the requirements of the Competition in Contracting Act (CICA), as implemented by 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 supported by the facts and rationale required under FAR 6.303-2 as follows:

(1) Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), Aviation Logistics Center (ALC), Medium Range Recovery Product Line (MRR), proposes to enter into a contract on a basis of other than full and open competition.

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

The MRR Procurement Branch requests approval to solicit and award, on a sole source basis, a Purchase Order for MH-60T A800 Searchlights and A800 Pelican Cases. As the Aviation Inventory Control Point, ALC is required to provide effective supply support for all USCG Aviation Units and for Program Depot Maintenance (PDM) support. In support of this mission, the MRR has a requirement to procure A800 Searchlight inventory replacements and A800 Pelican Case. The A800 Searchlight is a repairable component which serves as the primary searchlight on the MH-60T aircraft. The A800 Searchlight focuses a high energy light beam with energy concentrated towards the outer edge to ensure the best possible search capability for aircrews to identify targets in the water or on land. The A800 Searchlight includes an integrated filter system which provides six different colored light beams, including infrared.

This procurement will provide inventory spares. Trakka USA (Trakka), a small business, is the Original Equipment Manufacturer (OEM) and is the only known source of procuring the A800 Searchlight utilized by the USCG. Trakka is not the OEM of the A800 Pelican Case P/N 1660-020-110, however due to the delicate nature of the A800 Searchlight’s optics, a special shipping container is required for transport. Purchasing the special containers in conjunction with the Searchlights is in the best interest of the government to save time, money, and it will provide protection during shipping.

This requirement will be solicited utilizing FAR Part 12 Acquisition of Commercial Items and FAR Part

13.5 Simplified Procedures for Certain Commercial Items. Approval is requested to award a sole source purchase order for the procurement of twelve (12) A800 Searchlights along with twelve (12) A800 Pelican Cases. The total estimated value for this requirement is $0.00. The proposed contractor is:

Trakka USA 6817-B Academy Parkway East NE Albuquerque, NM 87109-4463 Cage Code: 6CF53

Only One Responsible Source and No Other Supplies Will Satisfy Agency Requirements

(3) Description of Services.

This procurement will provide inventory replacements for A800 Searchlights. Trakka is the OEM of the A800 Searchlight. Delivery is anticipated to be 120 days after receipt of the purchase order.

NOMENCLATURE

NATIONAL

STOCK

NUMBER

(NSN)

PART

NUMBER

(P/N)

EST

QTY

IGCE

TOTAL

A800 Searchlight 1680-01-HS2-1787 031001 12 $0.00 A800 Pelican Case 8115-01-641-3215 1660-020-110 12 $0.00

(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 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 specifications, manufacturing drawings, data, test equipment, and tooling required for the manufacture of the A800 Searchlights is proprietary to the OEM, Trakka. The USCG did not purchase rights to the proprietary data required to foster a competitive environment as part of any original provisioning for use on the MH-60T aircraft. The A800 Searchlights installed on the MH-60T aircraft are commercially available, but are not available from any other source of supply besides Trakka. A Federal Logistics Information Web Search confirmed that Trakka is the only source for the manufacture of the A800 Searchlights used on the MH-60T aircraft. Given the maturity of the MH-60T platform, utilizing other than the existing A800 Searchlight configuration would require engineering design changes altering the existing Form, Fit, and Functional characteristics resulting in prohibitive costs and unjustifiable delays to the Government.

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

This procurement forecast is posted as DHS – Acquisition Planning Forecast System (APFS) No:

F2016032276 on http://apfs.dhs.gov. Prior to award, a notice of intent to award a sole source purchase order fulfilling the notice requirement of FAR 5.201 will be posted to the Government Point of Entry (GPE) via http://www.fbo.gov. A copy of the approved J&A will be uploaded with the notice. Any quotations or capability statement received in response to the notice will be considered prior to award.

http://apfs.dhs.gov/ http://www.fbo.gov/

Only One Responsible Source and No Other Supplies Will Satisfy Agency Requirements

(7) Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer anticipates prices will be determined fair and reasonable using price analysis techniques including comparison of the proposed price with prices found reasonable on previous purchases and comparison of the proposed price to the Independent Government Cost Estimate (IGCE).

(8) Description of market research.

A Federal Logistics Information System Web Search confirmed that Trakka is the only source for the manufacture of the A800 Searchlight utilized on the MH-60T aircraft. Further market research was performed using Federal Logistics (FEDLOG), GSA Advantage, DOD Emall, and historical information in the USCG’s database for the same and similar items. Additional sources were not identified. Market research confirmed that Trakka is the only known source of supply for this component.

(9) Any other facts supporting the use of other than full and open competition.

Trakka was contacted to inquire about the release of any proprietary data to the USCG or any other distributors. Trakka responded that their data is proprietary and resale of their proprietary data is prohibited.

(10) Listing of the sources, if any, that expressed in writing, an interest in the acquisition.

To date no other sources of supply have expressed interest in this requirement or are able to.

(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 or services.

The USCG did not purchase rights to the proprietary data required to foster a competitive environment as part of any original provisioning for use on the MH-60T aircraft, and Trakka has not agreed to release their proprietary data at this time. The USCG will continue to request that Trakka release information required to foster a competitive environment prior to the execution of any subsequent purchases. In addition, continuous market research will be conducted in an attempt to identify additional sources.

Only One Responsible Source and No Other Supplies Will Satisfy Agency Requirements

(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.

Tony R. Twiddy Date Contracting Officer, MRR PLD

(13) Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

Brian McGowan Date Inventory Manager

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

Attorney Date USCG Legal Service Command-Norfolk

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(15) Approval

Tony R. Twiddy Date Contracting Officer, MRR PLD