H65_Special_Tools_J&A_Redacted.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

Procurement of MH-65 Special Tools and Support Equipment

Solicitation Number: HSCG38-17-Q-500013

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), Engineering Services

Division (ESD), 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, ESD seeks approval to award a purchase order based on other than full and open competition for the procurement of special tools as identified in paragraph three. The Original

Equipment Manufacturer (OEM) of these parts is Airbus Helicopters, Inc. Airbus Helicopters, Inc.

maintains the proprietary data rights for the manufacture of the special tools. For this reason, Airbus

Helicopters, Inc. is the only source capable of providing the required special tools.

It is anticipated that a firm-fixed price purchase order will be awarded. The estimated purchase order value is

The proposed contractor is:

Airbus Helicopters, Inc.

2701 N Forum Dr.

Grand Prairie, TX, 75052-8927

Cage Code: 3GSZ1

(3) Description of Supplies/Services:

This requirement is to purchase special tools utilized on the USCG H-65 aircraft on a firm-fixed price purchase order. The estimated purchase order is The following table lists the parts that will be purchased as part of this acquisition.

Line NSN/LSN Part Number Nomenclature QTY

1 1730-14-525-5285 365A92-1175-03 BLADE FOLDING ASSY. 3

2 5315-14-426-8796 A0023C06R45N-W PIN, PIP 24

3 5120-01-HS1-6409 365A92-1148-02 PLIERS ASSEMBLY 4

4 1730-01-HS1-6806 365A92-1154-00 LOCK SECURITY ASSY 12

5 5315-14-370-9012 703A91-0002-21 LOCKPIN "AXIX7A12" 24

6 3040-14-489-1341 365A92-1153-16

STRUT,YELLOW POLE

ASSY 4

Only One Responsible Source and No Other Supplies or Services Will Satisfy

Agency Requirements

7 1730-14-391-8111 365A92-1153-12 STRUT, BLUE POLE ASSY 4

8 1730-14-543-6118 365A92-1153-18 STRUT, RED POLE ASSY 4

9 1730-14-391-8113 365A92-1153-10

STRUT, BLACK POLE

ASSY 4

10 1730-14-578-8285 365A91-2140-02 JACKING ADAPTER,FWD 9

11 1730-14-391-8166 366A92-4200-01 RESTRAINER,NLG ACTU 12

12 1730-14-391-8163 366A92-4100-01 RESTRAINER,MLG ACTU 6

13 4920-01-HS1-7510 703A94-0015-04 SIGHT UNIT 3

14 1730-14-391-8120 365A92-4140-01 RETRACTION TOOL,M 7

15 1730-14-385-3388 365A94-2749-00 SHIM,COMB.COLLECTIV 3

16 1730-14-369-1890 365A94-2743-00 SHIM,MIXING UNIT 2

17 1730-14-378-5107 365A94-2744-00 SHIM,PITCH LOCK 2

18 1730-14-397-0769 365A92-1160-01 M.R.B. SOCKS ASSY 6

19 1730-14-370-8894 703A92-0201-00 CAP,BLANKING,TOTAL 70

20 4920-14-486-3922 365A94-3441-02 ALIGNMNT,T ROTOR DR 2

21 5340-14-391-8138 365A94-3441-12 STRAP 1

22 5120-14-369-1864 365A93-3440-00 DRIVE SHAFT BEARING 2

23 1730-14-369-1888 365A94-2742-00 SHIM,COMBINATOR 1

24 1730-01-HS2-2308 365A94-2753-01 SHIM,50% 1

25 1730-14-385-3391 365A94-2751-00 SHIM,COMB,PITCH 1

26 5120-14-386-1641 703A94-1130-01 TOOL 2

27 1730-14-344-1262 703A92-0205-04 STOPPER,STATIC PORT 33

28 1730-14-449-2087 366A92-7202-01 BLANK,CLIMATIZATION 12

29 1730-14-449-2088 366A92-7201-01 BLANK,INTAKE 12

30 1730-01-HS2-5403 365A91-0040-02 SLING,A/C HOIST 6

31 4920-14-486-3922 365A94-3441-02 ALIGNMNT,T ROTOR DR 2

(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:

The special tools are uniquely designed and manufactured to perform maintenance and installation of flight safety critical aircraft components. This is the only equipment that can be used to ensure the aircraft’s continuous airworthiness of these peculiar components.

Only One Responsible Source and No Other Supplies or Services Will Satisfy

Agency Requirements

The OEM, Airbus Helicopters, Inc. considers all the specifications and drawings for these special tools to be proprietary. They will not release the drawings or data rights to the USCG for the purpose of reverse engineering nor will they allow another company to duplicate their designs to re-manufacture under different part numbers.

In order to maintain structural integrity of the aircraft and ensure complete compatibility of replacement parts, the special tools 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 critical to the safety of our flight crews to procure only the Airbus Helicopters, Inc. 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 Department of Homeland Security (DHS)-Acquisition Planning

Forecast System (APFS) No. F2016034761 at www.apfs.dhs.gov.

A combined synopsis will be advertised on the Federal Business Opportunities (FBO) website and IAW

FAR 5.207(c)(16)(ii) the synopsis will include a statement that all responsible sources may submit a quote or capability statement which shall be considered by the agency. Should a quote be received by an offeror other than Airbus Helicopters, Inc. with evidence of being able to provide the items or OEM authorization to provide the items, the quote shall be considered. However, based on the market research results, it is not anticipated any sources other than Airbus Helicopters, Inc. will respond to the solicitation.

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

Reasonable:

The Contracting Officer anticipates that the prices for this procurement will be fair and reasonable based on a price analysis utilizing a combination of price analysis techniques to include comparison of proposed prices to historical prices paid (FAR 13.106-3(a)(2)(ii)) and current published catalog prices

(FAR 13.106-3(a)(2)(iii)).

(8) Description of the Market Research:

Airbus Helicopters, Inc. is the OEM for the special tools being procured. Market research was completed 15-Dec-2016 thru 06-Feb-2017. Federal Logistics (FEDLOG ), General Services

The Federal Logistics (FEDLOG) is a federally supported program which lists all manufacturers/suppliers by cage code and is updated monthly. This program provides a valuable tool for supplier information and is utilized by requirements personnel to determine if alternate sources of supply exist. Information is accessed by National Stock Number, Nomenclature, item name, supplier name and cage code.

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

Only One Responsible Source and No Other Supplies or Services Will Satisfy

Agency Requirements

Administration (GSA) Advantage, Department of Defense (DOD)-Emall, and North Atlantic Treaty

Organization (NATO) were searched and no additional information was obtained regarding these special tools. Inventory Locator Mart (ILS), a website used to locate difficult parts, was also used to see if other distributors had the special tools available. No inventory was found to be available at the time of the search, which further supports that no other distributors are able to provide these special tools. The procurement was also forecasted in APFS. No other company has contacted the USCG to request information on the APFS entry.

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

The USCG did not purchase data rights as part of the initial system acquisition of the H-65 aircraft and therefore; manufacturing, performance, and acceptance data is proprietary to the OEM. Procurement history indicates that no other source has manufactured these items with the same or similar characteristics in the past. Any other source would require access to the most current revisions of OEM manufacturing data. In addition, the USCG does not possess adequate technical descriptions for release to new sources. Due to the maturity of the H-65 aircraft, the cost to procure data rights, presuming they would be made available, would be cost prohibitive.

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

A synopsis will be submitted to FBO upon approval of this document. To date, there have been no inquiries regarding this requirement. Any responsible offer received from a Airbus Helicopters, Inc.

approved source will be considered.

(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:

As stated in paragraph five (5) the OEM will not sell the data rights to any of their parts which has limited the USCG’s ability to provide adequate technical descriptions to potential new sources.

Therefore, it is difficult to take steps to foster competition as the manufacturing, performance, and acceptance data are proprietary to the OEM. The USCG will continue market research efforts for future procurements.

Only One Responsible Source and No Other Supplies or Services 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 accurate and complete to the best of my knowledge and belief.

(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.

(14) Legal Review and Concurrence:

I have reviewed this justification and deem it legally sufficient.

(15) Approval: