J&A.pdf

Justification for Other Than Full and Open Competition Under l0 U.S.C. 230a (c)(l) Only One Responsible Source and

No Other Supplies will Satisfy Agency Requirements Procurement of Rivets

Solicitation Number: HSCG38-17-Q-J00109

Pursuant to the requirements of the Competition in Contracting Act, 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) Product Line Division, 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.

As the Aviation Inventory Control Point, ALC is required to provide effective supply support for all USCG Aviation Units for Program Depot Maintenance support. In support of this mission, MRR has a requirement to procure various sized aircraft Rivets, here after referred to as Rivets.

The Rivets are consumable parts used to secure the skin of the aircraft to the fitting/structure of the MH-60T aircraft model. Various sizes are used throughout the aircraft.

The Original Equipment Manufacturer (OEM) of these rivets is Cherry Aerospace Division, a large business. The rivets are manufactured by the OEM to meet the needs of the USCG, and are used throughout the MH-60T fleet. All specifications, manufacturing drawings, data, test equipment, and tooling required to manufacture the various rivets is limited to the OEM.

Stakeholders include the MRR Product Line and supported USCG Air Stations. The estimated value for this requirement is $0.00. Approval is requested to solicit, on a limited source basis, for the acquisition of the various rivets, some of which are listed in paragraph 3. This acquisition will be funded using the Operating Expenses (OE) appropriation for Operating and Maintenance. Sources are limited to distributors that will provide rivets traceable back to the OEM. Based on the market research, there are multiple distributors that can provide rivets traceable back to the OEM. Examples of these distributors include, but are not limited to: Avant Aerospace Inc., Peerless Aerospace, and Rapid Rivet & Fastner.

(3) Description of Supplies/Services.

This procurement will provide for 112 various types of rivets that are issued to the fleet and programmed depot maintenance. Cherry Aerospace Division is the OEM of the rivets. Desired delivery is ninety (90) calendar days after receipt of order. Some of the rivets are listed in the table below with the National Item Identification Numbers OJIIN), Part Numbers (P/N), Nomenclatures, and quantities included.

01HS18220 cR-3212-4-2 RIVET.BLIND 3,200 01HS 18276 cR32t3-4-2 RIVET,BLIND 5,000 01HS18274 cR3213-4-3 RIVET,BLIND 5,000 01HS18303 cR3213-5-2 RIVET,BLIND 6,000 0l HS 1 8302 cR3213-5-3 RIVET,BLIND 3,000 0lHSl8337 cR3214-4-2 RIVET, BLIND 4"000

0lHSl8326 cR3243-4-2 RIVET.BLIND 3.000 01HS18279 cR3243-5-2 RIVET.BLIND 7,000 01HS18311 cR3243-5-3 RIVET.BLIND 7,000

0rHS18362 cR3243-s-4 RIVET.BLIND 3,000

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 enforcement, international ice patrol, marine environmental protection, and marine resource conservation. With such a demanding operational tempo, aircraft conditions and availability are essential to mission success. The rivets listed above are necessary for the support of the MH-60T aircraft.

*Figures have been rounded to the nearest lK.

(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) (l) as implemented by FAR 6.302-1 entitled "Only One Responsible Source and No Other Supplies will Satisfy Agency Requirements." This is further expounded in FAR 6.302-1(bXlXii) to include a limited number of sources.

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

All specifications, manufacturing drawings, data, test equipment, and tooling required for manufacturing these rivet are limited to Cherry Aerospace Division. The USCG did not purchase rights to the proprietary technology required to foster a competitive environment as part

Lf u.ry original provisi,oning for use on the MH-60T aircraft and the cost to purchase rights to this proprietary technology would be cost prohibitive.

Cherry Max Rivets May I ,2017 - April 30, 2018

May l, 2018 - April 30,2019 May I ,2019 - April 30,2020 May I ,2020 - April 30,2021 May I .2021- April 30.2022

Total IGCE l)arcl

P/t{ Duantitv

NOItrCI clature Independent Government Cost fi r. , /r^ffi\

$0 $0 $0 $0 $0 s0

Only Cherry Max Rivets have been found and tested to meet the requirements for proper expansion, load distribution and resistance to water intrusion to prevent subsequent airfiame corrosion.

(6) A description of the efforts made to ensure that offers are solicited from as many potential sources as is practicable.

The intent to issue a requirements contract with firm-fixed pricing for the acquisition of the various rivets will be solicited to Federal Business Opportunities (FBO) upon approval of this document. Any eligible offeror may submit a quote. Only offers that can provide rivets with traceability back to the OEM will be considered.

(7) Determination by the Contracting Officer that the anticipated cost to the government will be fair and reasonable.

The contracting officer determines that the anticipated prices will be fair and reasonable using the price analysis technique to include, competition, comparing the proposed price with other pricing previously determined reasonable and pricing information collected from market research used in developing the IGCE for this requirement. The Contracting Officer anticipates competition will satisfy the requirement to perform a price analysis.

(8) Description of market research.

A market rr*.y has been conducted concerning the acquisition of the various rivets. Past history indicates there are several companies that can supply these required rivets. Every effort will be made to obtain quotes from these firms. All terms and conditions (including payment, delivery, inspection, u.""ptu.r.", and warranties) are not expected to differ from customary terms and

.onditio.rr in the marketplace or standard Government practices. Contract financing is not available for this requirement.

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

The ALC PDM hull shop has determined that the quality of the Cherry Max brand Rivets hold up better than any other Rivets previously procured. These rivets were approved and accepted

Uy fr4nn Engineering. As a result, only rivets that meet the Original Equipment Manufacturer

(OEM) specffications will be technically acceptable. Only the distributors meeting the OEM traceability requirement will be considered.

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

No sources have expressed interest in writing for 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.

The USCG will continue to monitor the market place for acceptable vendors who can supply quality rivets and will notify the Contracting Office when changes occur'

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