J&A_Signed.pdf

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Justification for Other than l'ull and Open Conrpetition lJndtr l0 U.S.C- 2304 (c) { I )

Only One icsponsible Sourte (Limited $ource) and No Other Services Will Satisty Agency Rctluirutttttts

Overhaul of Pitch Trim, Roll Trim, md Yuw Boost Assemblies

Solicitation Number: HSCG38-16'R'J{n005 pursuant ro the requiremenrs of the Competition in Contracting Act (CICA), as implenrcrrted try tlrc

Fedcral Acquisition Regulation (FAR) Subpart 6.3 and in accordance with the requirclrcrtts ol [:AR

6.303-1, the justificatiori tbr rhe use of the siatutory authority under FAR Subpart 6.3 is .iustrl'icd bV thc

Igllowing tacts and rationale rcquired under FAR 6.303-2 as follows:

(l) Agency and Contracting Activity.

The Departmcnr of Hgmclantt Security (DHS), United States Coast Guard (USCG). Ar iitlittr l-o::isties

Ccntcr inlCl. Medium Rangc Recovery (MRR) Procurement Branch, proposes lo enlcr ittlo rt t:iltlllrlt't on a basis of other than full and open competition.

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

The MRR procurement Branch rcquests approval to award. on a limitcd sources hitsis, ittt hrdct'inite

Delivery Requirements Type Contract for the overhaul of MH-60T Pitch Trim. Roll 'f|illt. atld Yaw

Bo's[ Assem-blics, hcrcafter rcferrcd to as Assemblies- Firm FixeclPricc (FFP) task ordcrs will lic is'ttctl off the base contract as Assembly Overhaul Services are required. These overhauls ure esscttliitl t() x\()l.l grounding of the aircraft. The specifications, manufacturing drawings. data, tcst cquiprllcnt, and ttrolittg

Iequired ior the overhaul of rhcie Assenrblies is proprietary to Sikorsky Aircraft Corporatitttt (S;\C) arrd

MOOC Incorporated (MOOC).

Responsiblc sources are limited to Naval Supply Weapons Systems Support (NAVSUP wSS) r:r [.rSC]C

Aviation Engineering approvetl sources. SAC is the only NAVSUP WSS approved source and Nloo(l is the 'nly USCG-ei'iation Engineering approved sourcc. l'or thc Asselnbly ovelhatrl Scrriccs.

Stakeholdcis inclucle rhe MRR Product Line and thc supponed USCG Air Stations. Tltc hasrs ol tttt'arcl wig be Lowest pricc Tcchlically Acccptable (LPTA) using FAR Part 12. Acquisition ol Conttrlcreill

Irenrs an6 FAR parr 15. Contracting by Negotiation. The cstimatecl dollar value itJrtliiclt includcs a one (l) year irase ordering period and four (4) one (l) year 0ptiorlal ttrclct'itts Pt'rt,tlr

Asscmbly Overhaul Scrvices arc currently pertormed under HSCclS-ll'D-J00009. rn lrrclclirtrte

Delivery Requircments type contract with FFP task orclers. The contract includes a ollc ( I ) ycitt ltitsc ordering periorl a,d lour ii) on. ( I ) year optional ordering periods. The current contract wits sttliciLed ott a linrited sources basis and awarded to MbOG, a large busirtess. The curretrt contract cxPit'cs Jtrlv ll.

2016. SAC's ancl MOOG's contact informatiorr is as follows:

Sikorsky Aircraft CorPoration 6900lvlain Street

Stratford. CT 06614

Cagc Cnde 78286

MOOG. Inc.

Seneca Street & Jamist;rt Road

Aurora. NY 14052

Cage Code 94697

(3) DescriPtion of Services.

The USCG currently operates a tleet of fcrrty-fcrur (44) MH-60T rotary wing aircraft' This specialrzcd' rrigi, o"nrund. aircr.lr currently enablcs ttre iJscc to perform missions such as scarch alltl lcsuttc' lltrr' enlbrccmcnt, international iCe patr6l' marine environmental prgtectioll' and tttal itlc t c\()ttl ct' c'uservatio,. witS sgch adenranding operationaltempo. aircraft condition and availalrilitl irre csrcrtlial ro nrilisiop success, When properly outfi(rcd there is one ( t) Pitch "l'rim AsscntblY, ottc ( I ) Rull 'l'rirn

Asscmbly. antl one ( I ) yaw Boost Assemhiy per aircrafi. Thc hasic service otrjectivc ot' {hi} t"ctliri,.tttrtttl i: ro prescrve service life. reduce Iife cycle cost. and increase rnission capahililies tltrotrgh tltc perfonnancc of Assembty Overhaul Services as requircd. Delivery shall be sixty (60) eltlettdrl drvr ll'lrt" irrductkrn. lrrductiqn shall take place no later than twenty (20) calendar dfiys nlicr rccciPt ill tlrc

Assemhlies at thc Contractor's facility'

The Assernblies are consitlered flight Critical Safety ltems (CSI) and are interchangeahlc througltoul tltc

MH-60'f fleet. In order to successfully maintain airworthiness ol' the aircraft and aircrrrlj slstcnls.

protect personnel safery, and perfonn the USCG's mission. acquisition of CSls is restricted lo appro|cd

*,,ur."r- A CSt is a part, assembly, installation or production system with oriu oI nlorc critiuill characteristics tllat. if not confonning to the design data or quality requiretnenls, wottld reslrll itt lttt unsafe conelltion. Unsat'e conditions relate to mishap scverity categorics I (Catastrophic) and ll tClritrcall' alrd inclutlc corrditions which could cause loss or serious darnage to the end item or lllirjt)r ('ortrP()llct)1.

I,ss o[ control, serious injury to per$onnel- or death of personnel. In order to successfullv rruirtt*in airworthiness of the aircrift and aircraft system$, protect personnel safety. and pertix'm the t.ISCfi's mission. the acquisition of CSIs is restricted to approvcd sources.

'FRounded lo neercsi 100K

(4) Identification of the justification and the rationale'

-l"he $tarurory aurhority pcrmitring other than full and opcn competition is l0 u.s.C. 23()4 (cXl) its implenrenred uy rm 6.302-l entided "only one Responsible source and No other scrlicc.r u'ill

Satisfy Agency Requirentcnts." This is l'urtherexpounded in FAR 6.302-l(bXlXii) to irtclLttl: a lirilitcd number of sourccs. Responsible sources are lirnitecl to NAVSUP WSS and USCC Aviatior, l:trgiilccrrrrg approre.l sources. SAi and M0OC are the only approvcd sourccs tbr overhaui tlf thc i\sstnrl'rlit"

There werc no othcr ovcrhaul sources or alternate pirt numbers available to meet tlre (iov*nrltterll's requirements.

Iulv 13.2016- July I2,2017Pitch Trinr Assemtrly

NSN: 6615-01-474-612?

P/N: 704 I 0-22760-053 or NSN: 661 5-01 -l 5tJ-5987

P/N: 70410-7776$'A5t Total Estimated QtY: 125

RollTrim AssemtrlY

NSN: 6615-01-158-5986

PIN: 70410-22760-050

Teital Estimated Qty: 120

Yaw Boosi AssernblY NSN: 661 5-0 l- I 5tt-5985

I'lN: 70410 22q10-04.5

Total Estimated QtY: t85

2017 * July 12, 2018

Julv 13. 201& - Julv 12, 2019

July 13,2019 * July 12, 2020

July 13. 20?0 - July 12" 2021

Total Estimated Contract Valuc

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(5) Drmonstration that the nature of the acquisition requires use of the authority cittrl.

Thc specilications. manufacturing drawings, data, test cquipmcnt. and tooling requireil [o pr'r{brttt

Assernbly Ovcrhaul Selices are proprietary to SAC and MOOG. The USCG did not put'clrarc riultts to thc proprictary data required to lbster a competitive cnvironntent as part of any original provrsiottittu lor' use on thc Mll-60'[ rotary wing aircraft and the costs to procurc this data would hr' cost prohihttivc

SAC and MOOC were conlactcd to inquire ahout the relea.se of any proprietary tcchnology to the l.lS( (i or ilny distributors. SAC and MOOG responded that their technology is proprietar,r' lntl rcsuI rrl'thcir proprietary tcchnology is prohibiteei.

Thc Aviation Critical Safety Item Management Handbook, March I6.2011, Page 3, Paragraph ?.1, ('lSt

Prrrcurement Rcstrictions. statcs "CSIs and services (such as repair, ovcrhaul, etc.) lbr (lSIs trrir't hc procurcd only liom approvcd sources." Per ALC Instruction 4200.3A. ALC Spare Parts l}rcukourlNeu' Product Dcvelopment. dated January 2'7 ,Z{Jl I, ClSls may only be procured through source\ approvccl h1

USCG Aviatiort Engineering. MOOG is approved to perform Assembly Overhaul Sr:rviecr hr tiS('(i Aviation Engincering.

In addition. NAVSUP WSS is the Primary Inventory Control Agency and has sole lulhorirl arrrl rcsponsibility for certifying sources of supply and support for H-60 components. Certil'icatir:rrr ol' sourccs of supply was executed in accordance with Public Law 108-136 Section 802 of thc l)cl'rnsc Appropriations Act of 2004 and Naval Air Systems Comnrand Instruction (NAVAIRINS.l')"4100.56., SAC is the only NAVSUP WSS certified source to perform the Assembly Overhaul Serviccs. i

(6) Description of efforts made to ensure that offers are solicited from as m&ny potential soulcer+..+r as practicable. r r

."s#t" . -* This procurerncnt ftrrecast is posted as DHS * Acquisition Planning Forccast Systcrn (APFST Ntr:

F2ol5030tt02 on lrttp:/lapl.s.tlhs.gov and was included in the DHS Forecast ol' Sru:rll lltrrincss Opportunities. Sources Sought Notice HSCG38-15-S-JU[15 was posted to the Covcrrrrncrrtrvit[: Poirrr of Entry (GPE) via http:/igwwjet!!,[lopp;gr' on July 29, 2Al5 with a response clatc ol" Augusr 15.

2015. No capability statements wcrc received in response. However. on October 21.2015. i\lOO(;

provided a capabilities stalcmcnt expressittg interest in this effort. Market research conl'irrncd SA('artrl MOOG are the only approved overhaul sources for the Assemblies specified hereir:. Prior tu arrald. a

Noticc of Intent tcl solicit on a limited sources basis and award a cor)tract full'illing lht-: rroticc requirements of FAR 5.201 will be posted to the CPE via http:l/wrvw.fedbiztlrlts.gor'. A copv ul'tlrc approvcd Justification for Other Than Full and Open Competition (J&A) on a lirnited soulccs hasis u,ill be uploaded with thc notice. Any capability statcment, proposal. or quotation receivetl in l'cs1'lonsc lo tlrr:

mltice will be considered prior to award-

(7) Determination by the contracting ollicer that the anticipated cost to the Governrnent rvill he fair and reasonable.

Pricing inforrnation collected fiorn market research and the cunent contract was usctl irr lhc developlncnt ol'the Independent Covernment Cost Estimatc (ICCE) fbr this requirenteut.'l.hc irrcrasr' ovcrhaul priccs were rnultiplied by the quantity estimated for each Assernbly requiring ovcrlraul to derive the basc and optional ordering pcriod pricing. The current Producer Pricc lndcx (PPl)cscalatiorr ratc bascd on the Firral Dcmand-Intermediate Demand (FD-lD) aggrcgatiorl system u,ar apgrlietl to tlrt' optional ordering periods. 'l'he Contracting Officer anticipates competition and cornparison ol' pr^ict's proposed with historical pricing and thc IGCE will establish price reasonablcncss.

(8) Description of market research.

Market research was conductcd in accordance with FAR Pan l0 liom January 2015 through Decettrbtt'

2015. Sources Sought Notice HSCC38-15-S-J00015 was released to thc GPE on July 29. 2015 itnd closcd August 15, t015. No capability statements were received in response. Howevcr. on octohcr ll' 2915. MOfuC respontled with acapabilities statement cxpressing intercsl in this ellbrr Mfu'kct Rcseitt'ch conflirmed SAC antl MOOG are the only approved ovcrhaul sources for the Assenrtllies specil'ied ltcicitt.

SAC and MOOG will be rcquired to submit a subcontracting plan for Contracting Ol'l'icer appror itl' I ltc

Assernblics rlrc conlnrercial in nature and prevalcnt in private aviatiotr. comtncrcial llvilttitttt. atttl rnilitary aviation workl-wide. AII terms and conditions are not expected to dilfer li'otn custrttllillY lcrrrrs anl colrditions ir.r the marketplace or standard Governmcnt praclices. Contract t'ittattcittg is ttirt applicable to this requirement. There are no laws or regulations unique to lhis requiret"ncnt. N<t eirvironmentally pref'erahlc services were ittentiiied during market research and Buy Anrericat/'l't'ldc

Agrcements Acts/Section 508 regulations/Safety Act ure rrr:t applicable to this requireurent.

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

SAC and MOOG are the only approved sources to perform the Assentbly Overhaul Scrviccs. Frilitrt' ttr approve this limitcd sources J&A will jeopardizc performance of MRR's mission due to groutttlitt{ ol' rhe aircrali as a result ol safety concerns stetnming from non-availability of Rcady liot'lsstrc iRl;lt Assemblies.

(10) A listing of the sources, if any, that expressed in writing, an interest in the acquisitior'

S6urces Sought Notice HSCG38-15-S-J00015 was released to the GPE on July 29.2t)l-5 tnd closctl

August 15.2b15. No capability statements were rcceived in response. However. on Octobcr ll. 1015.

UOOC responded with a capabilities statement expressing interest in this effort.

(lt) A statement of the actions, if any, the agency may take to remove or overcome anv harrit'rs ltr competition hefore any subsequent acquisition for required supplics or services.

Therc arc a limirecl number of responsible sources approved by NAVSUP WSS or USCC r\viittiort

Engineering for the Assembly Overhaul Serviccs. The USCG did not purchase rights to thc proltrietilrv tccf,nologylcquired to foster a competitive environment as part of any original ptovisiorring Ibt ttse ott rne Ug-6if ,,itary wing aircra{i, Every reasonable effort will be madc to rcmove harriers ttt conrPctiliott tbr futurc requireinents. There etforts will include continuing to identil'y additional sorlrccs thal tttit\ cvcntually beconre approved by NAVSUP WSS or LISCG Aviation Engineering to pcrl()rrrl Assr:trrhl-r

Overhaul Services.

(12) Contrrcting (X[ccr'r Ccrtificrtion.

I eertify that the data supporting &e recommended use of other than full and open competition is accurate and complete to the bestof my knowledge and belief.

e Contrrctirf0fficcr, USCG, ALC, MRR froduct Line

( 13) TochnicrURcquircncltr Pcrrorncl Crrlilicrlion.

I ccrti$ that this rcquiremcot mects tlrc Govcmment's minimun nced and that the supporting dat4 , is accunte and complae.

(lA) Lcgd RcYhm, ud Concurreucc:

I have reviewod this jusification and deemed it legally sufiicicnt.

(ls) C0NCURRENCE:

I agree with the Contracting Officer that the data supporting the recommended use of other thau futl and opcn competition is accurate and complete to tlre best of my knowledge and belief.

Drtel

Itcm Mrnrgen USCG, ALC, MRlt Product Liuc

Drie

Chief of rbc Contrrctirg Ofiice USCG, ALC

(16) APPROV

Commrad Procurirg Ac{Mty Competitioa Advocrlc (CPACA)