JA 70Z03820QB2000141.pdf

April 2019

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIMPLIFIED ACQUISITION PROCEDURES (SAP) FAR 13.106-1(b)

SOLICITATIONS MAY BE LIMITED TO ONE SOURCE ONLY IF THE CONTRACTING OFFICER DETERMINES THAT ONLY ONE SOURCE

IS REASONABLY AVAILABLE. THIS DETERMINATION MUST BE SUPPORTED WITH FULL JUSTIFICATION FOR SOLE SOURCE FROM THE CUSTOMER. WHEN THE CUSTOMER DESCRIBES AN ITEM WITH A PURCHASE DESCRIPTION WHICH LIMITS THE

AVAILABILITY TO ONE SOURCE, THE JUSTIFICATION MUST EXPLAIN WHY THE ITEM IS THE ONLY ONE THAT WILL MEET THE

GOVERNMENT’S REQUIREMENT. STATEMENTS SUCH AS "ONLY KNOWN SOURCE" OR "ONLY SOURCE WHICH CAN MEET THE

REQUIRED DELIVERY DATE" ARE INADEQUATE TO SUPPORT A SOLE SOURCE PURCHASE.

PURCHASE REQUEST OR REQUISITION NUMBER

PROJECT/TASK

NUMBER

ESTIMATED AMOUNT (Over Micro-Purchase Threshold, but up to the SAT)

IDENTIFICATION OF THE AGENCY AND THE CONTRACTING OFFICE, AND SPECIFIC IDENTIFICATION OF THE DOCUMENT AS A

“JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION.” PLEASE CITE THE AUTHORITY AND TYPE OF

JUSTIFICATION. The United States Coast Guard (USCG), Aviation Logistics Center (ALC), Short Range Recovery

(SRR) Division has a requirement to purchase spare parts on a sole source basis utilized on the MH-65 helicopter.

The statutory authority permitting other than full and open competition is 41 U.S.C. 1901; FAR 13.501(a)

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE.

This procurement is for the following spare parts to be utilized on the MH65 helicopters:

Three (3) GEAR, REDUCTION NSN: 3020-14-472-7359 PN: 365A32-7100-20

Twenty (20) TUBE EQUIPPED NSN: 4710-14-404-0455 PN: 366A52-1123-02

UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON NO OTHER SUPPLIES OR

SERVICES CAN BE USED.

This acquisition is restricted to the only source of supply known to have the capability of furnishing the required supplies. The aircraft Original Equipment Manufacturer (OEM) and the USCG has determined that these parts can only be acquired directly from the OEM’s U.S. affiliate, which is not the manufacturer. Furthermore, the

Government does not have adequate data or lacks rights to data, and it is not economical to buy the data or rights to the data.

A DESCRIPTION OF EFFORTS MADE TO ENSURE THAT QUOTATIONS OR OFFERS ARE SOLICITED FROM AS MANY POTENTIAL

SOURCES AS PRACTICABLE (INCLUDE YOUR MARKET RESEARCH EFFORTS HERE).

The spare parts to be procured under this acquisition are highly specialized parts, designed and manufactured by a non-Government activity and the technical data required for acquisition by other than the OEM or an OEM approved source is not available. Airbus Helicopters France (F0210) is the OEM for the H-65 helicopter. Airbus

Helicopter France does not sell directly to the USCG and have stated that “Airbus Helicopters, Inc. (3GSZ1) is the only approved source of supply for Airbus Helicopter France products for the MH-65 aircraft.” Therefore, procurement of any parts from other than the OEM or an OEM approved source will compromise the safety of the aircraft and the crew. The solicitation and resulting purchase order will require all materials delivered to have clear, documented traceability to the OEM and a completed Certificate of Conformance, certifying compliance with this contract condition, in accordance with FAR clause 52.246-15, Certificate of Conformance, which will be incorporated.

REASON THAT SUGGESTED SOURCE IS THE ONLY SOURCE WHICH CAN PROVIDE THE SUPPLIES OR SERVICES.

These parts are proprietary to the OEM, Airbus Helicopter France, and maintenance procedures were written specifically to interact with these parts. Based upon the technical certification on file, technical data is not available and cannot be developed to permit full and open competition.

EXPLAIN WHY AN ADEQUATE PURCHASE DESCRIPTION OR OTHER INFORMATION SUITABLE TO SOLICIT BY FULL AND OPEN

COMPETITION HAS NOT BEEN DEVELOPED OR ARE NOT AVAILABLE.

The required specifications of suitable alternate spare parts would not be sufficient for equipment selection. After receiving responses from the solicitation, an initial test and evaluation would have to be completed on the aircraft to ensure compatibility. It would not be cost or time effective to test multiple spare parts from manufacturers due to time restraints of Coast Guard Air Stations testing procedures.

April 2019

PROVIDE A STATEMENT OF ACTIONS, IF ANY, THE GOVERNMENT MAY TAKE TO REMOVE OR OVERCOME ANY BARRIERS TO

COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED.

The OEM owns the proprietary data rights, specifications and drawings to these items which have limited the

USCG’s ability to provide adequate technical descriptions to potential new manufacturers. Therefore, it is difficult to take steps to foster competition as the manufacturing, performance, and acceptance data are proprietary to the

OEM.

SIGNATURE AND TITLE OF CUSTOMER

CODE

TELEPHONE

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE