redacted_justification.pdf

Justification for Other than Full and Open Competition Under 10 U.S.C. 2304 (c)(l) Only One Responsible Source (Limited) and No Other Supplies or Services Wiil Satisfy Agency

Requirements Overhauls and Modifications of T700 Engine Starters

Solicitation Number: HSCG38-1 7-Q-J00025

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 (DHS), United States Coast Guard (USCG), Aviation Logistics Center (ALC), Medium Range Recovery (MRR) Procurement Branch, located in Elizabeth City, North Carolina, proposes to enter into a contract with firm hxed pricing on a basis 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 limited sources basis, an

Indefinite Delivery Requirements Type contract to the Original Equipment Manufacturer (OEM), Honeywell Intemational (Honeywell) or Honeywell's authorized repair facilities/authorized distributors for overhauls and modifications of T700 Engine Starters, hereafter referred to as Starters. Firm Fixed Price (FFP) task orders will be issued as Starters are required. The overhaul of Starters is essential to avoid grounding of the aircraft. The specifications, manufacturing drawings, data, test equipment, and tooling required for the overhaul of the Starters are proprietary to Honeywell. 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. Stakeholders include the MRR Product Line and supported USCG Air Stations. This requirement will be solicited utilizing FAR Part 12 Acquisition of Commercial Items and FAR Part 13.5 Simplified Procedures for Certain Commercial Items. The estimated dollar value I which includes a one (1) year ordering period. The overhaul of Starters are currently performed under various purchase orders as needed and required. The following sources have been identified but as stated above services are limited to the OEM, OEM repair facilities or authorized repair distributors that are approved for the overhaul and modifications of the starters.

Honeywell International Inc.

7227 West Harry St.

Wichita, KS 61209-2944 Cage: lE4D6

(3) Description of Services.

Kellstrom Defense Aerospace, Inc Sherwood Aviation 15501 SW 29 St. Suite 101 4690 NW 128th St.

Miramar, FL 33027 Opa Locka, Fl 33054

Cage: lZK2l Cage:3EM37

The USCG currently operates a fleet of forty-four @\ MH-60T rotary wing aircraft. This specialized, high demand, aircraft currently enables the USCG to perform missions such as search and rescue, law enfbrcement, intemational ice patrol, marine environmental protection, and marine resource conservation. With such a demanding operational tempo, aircraft condition and availability are essential to mission success. The Starters were purchased as part of the original provisioning of the H60 aircraft in 1989. The Starters specified herein are currently used on all USCG MH-60T model aircraft and are interchangeable throughout the fleet. These parts are inspected during scheduled maintenance, during

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

Only One Responsible Source (Limited) and No Other Supplies or Services Will Satisff Agency Requirements

Overhauls and Modifications of T700 Engine Starters Solieitation Number: HSCG38-17-Q-J00025 all programmed depot maintenance, and are replaced due to corrosion, damage, and failures. The

Starters are considered a flight Critical Safety Item (CSI) and are interchangeable throughout the MH- 60T fleet. The basic service objective of this requirement is to preserve service life, reduce life cycle cost, and increase mission capabilities through the performance of comprehensive overhauls and modifications. Delivery time is sixty (60) calendar days after receipt of starters. The Starter Overhaul

Services required are as follows:

(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 the FAR 6.302-l entitled "Only One Responsible Source and No Other Supplies or

Services will Satisfy Agency Requirements." This is further expounded in FAR 6.302-1(b)(1)(ii) to include a limited number of sources. Responsible sources are limited to the OEM, OEM authorized repair facilities and OEM authorized repair distributors or those sources authorized by the OEM, to p.ifor- Starter Overhaul Services with access to the proprietary technology required to perform the iervices. Market research confirmed there are a limited number of responsible sources capable of performing the Services specified herein.

(5) Demonstration that the nature of the acquisition requires use of the authority cited.

The specifications, manufacturing drawings, data, test equipment, and tooling required to overhaul and modiiy the Starters are proprietary to Honeywell. The USCG did not purchase rights to the proprietary data required to foster a competitive environment as part of the original provisioning for use on the MH-

60T rotary wing aircraft and the costs to procure this data would be cost prohibitive. In order to successfuily -uintuin airworthiness of the aircraft and aircraft systems, protect personnel safety, and perform th; USCG's mission,'the acquisition of CSI is restricted to approved sources. A CSI is a part, assembly, installation, or production system with one or more critical characteristics that, if not conforming to the design data, or quality requirements, would result in an unsafe condition. The Starters are CSI. Unsafe condiiions relate to mishap severity I (Catastrophic) and II (Critical), and include conditions which could cause loss or serious damage to the end item or major component, loss of control, serious injury to personnel, or death ofpersonnel.

3505300-6- I

Modified to:

3505300-9- I

2995-0 I -208-7809 Modified to:

2995-01-464-4318

Pneumatic Starter Overhaul /Modified

350s300-9- r2995-01-464-4318Gas Turbine Engine Overhaul

Note* Rounded to the nearest lK

National Stor Number fNSl

Estimated I Ouantity l0

Justification for Other than Full and Open Competition Under l0 U.S.C. 2304 (cXl) Only One Responsible Source (Limited) and No Other Supplies or Services Will Satis$ Agency

Requirements Overhauls and Modifications of T700 Engine Starters

Solicitation Number: HSCG38-17-Q-J00025

(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:

F2016035239 on htlp://apl.s.dhs.r{oi,, published 11l1612016, and was included in the DHS Forecast of Small Business Opportunities. A Request for Quotation (RFQ) for this requirement will be posted to the

Government wide Point of Entry (GPE) via http:/lur.rr,v'.fbo.gov to fulfill the notice requirement at FAR

5.201. Market Research confirmed there are a limited number of responsible sources capable of performing the Starter Overhaul Services specified herein.

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

Pricing information collected from market research and the current contract was used in the development of the Independent Government Cost Estimate (IGCE) for this requirement. The average overhaul prices were multiplied by the quantity estimated for each type of Starter to derive the base ordering period pricing. The Contracting Officer anticipates comparison of prices proposed with historical pricing and the IGCE will establish price reasonableness.

(8) Description of market research.

Market research for this service requirement was conducted from June 2016 through October 2016 and confirmed Honeywell or Honeywell's authorized repair facilities/authorized distributors are the only approved overhaul sources for the Starters specified herein. Starter overhaul services are commercial in nature and prevalent in private aviation, commercial aviation, and military aviation world-wide. All terms and conditions are not expected to differ from customary terms and conditions in the marketplace or standard Government practices. Contract financing is not applicable to this requirement. There are no laws or regulations unique to this requirement. No environmentally preferable services were identified during market research and Buy American/Trade Agreements Acts/Section 508 regulations/Safety Act are not applicable to this requirement.

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

There are a limited number of responsible sources to include the OEM, OEM authorized repair facilities and OEM authorized repair distributors, and those sources authorized by the OEM to perform Starter Overhaul Services with access to the specifications, manufacturing drawings, data, test equipment, and tooling required to perform the required services. This requirement falls within the guidelines of an

"Other Than Full and Open Competition (Limited Sources)" and is not suitable for "Full and Open

Competition." Failure to approve this J&A on a limited sources basis will jeopardize performance of MRR's mission due to grounding of the aircraft as a result of safety concerns stemming from non-availability of Ready For Issue (RFI) Starters. Honeywell was contacted to inquire about the release of any proprietary data to the USCG or any other distributors. Honeywell responded that their data is proprietary and resale of their proprietary data is prohibited.

Justification for Other than Full and Open Competition Under l0 U.S.C. BOa (c)(l) Only One Responsible Source (Limited) and No Other Supplies or Services Will SatisS Agency

Requirements Overhauls and Modifications of T700 Engine Starters

Solicitation Number: HSCG38-17-Q-J00025

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

To date, no sources of supply have expressed interest in this requirement.

(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.

There are a limited number of responsible sources to include the OEM, OEM authorized repair facilities and OEM authorized repair distributors and those authorized by the OEM, to perform Starter Overhaul Services with access to the proprietary technology required to perform these services. The USCG did not purchase rights to the proprietary technology required to foster a competitive environment as part of any original provisioning for use on the MH-60T rotary wing aircraft. Every reasonable effort will be made to remove barriers to competition for future requirements. These efforts will include continuing to identify additional sources that may eventually become authorized by the OEM to perform Starter Overhaul Services and be granted access to the proprietary technology required to perform these services. However, granting access to this proprietary technology is solely a Honeywell business decision.

Justification for Other than Full and Open Competition Under 10 U.S.C. 2304 (c)(l) Only One Responsible Source (Limited) and No Other Supplies or Services Wiil Satisfy Agency

Requirements Overhauls and Modifications of T700 Engine Starters

Solicitation Number: HSCG38-1 7-Q-J00025

(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.

(I3) 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 the justification, is accurate and complete.

(14) LEGAL REVTEW AND CONCURRENCE:

I have reviewed this justification and deemed it legally sufficient.

(15) APPROVAL: