JA Other than Full Open Competition_Redacted.pdf

Last Updated 07/23/26 2

(h) Background information about the requirement: This is a new requirement.

3. Description of Supplies/Services.

Air Station Kodiak has a requirement for two (2) pallets for HC-130J aircraft to replace existing pallets that currently do not meet crash standards.

The first, a Command & Control / Very Important Person (VIP) pallet, will be used to transport senior government officials, including Senators and Congressmen, Cabinet Level Secretaries and Staff, Senior Coast Guard (CG) and Military Leaders, as well as Arctic District Command and Control Staff. This pallet will allow secure, seated transport of senior officials and mission-critical personnel.

The second pallet is a medical pallet that will be used to secure critically ill and injured patients, as well as the medical personnel necessary to provide treatment. This pallet will enhance onboard patient care, providing integrated life support including oxygen, suction, and power in a crashworthy system.

Purchasing crash-worthy pallets will reduce the risk of death or serious injury during an aircraft crash or hard landing, a moderate possibility for aircraft conditions in the Arctic District. Both pallets are roll-on/roll-off configurations that will facilitate modular, rapid-response capability for the diverse operations of Air Station Kodiak. Both systems comply with airworthiness and crash standards necessary for in-flight occupancy and are designed for quick installation and removal on the HC-130J cargo floor.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. § 3204(a)(1) as implemented by RFO 12.102(b), and RFO 6.103 and in accordance with the requirements of RFO 6.104.

5. Identification of Exception to the Buy American Statute.

No exception to the Buy American Statute is being requested.

6. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The subject vendor is the only source available that can meet the Government’s requirement within the required timeframe because it currently holds the applicable airworthiness certification for the C-130 pallets being procured. These pallets are intended for use in C-130 aircraft operations and must meet applicable airworthiness, safety, and operational requirements before they can be placed into service. Airworthiness is the legal and physical state where an aircraft matches its approved design and stays safe for flight.

Last Updated 07/23/26 3

In government and military operations, it is essential to protect personnel, ensure mission success, prevent costly equipment loss, and maintain operational readiness under extreme environments that standard commercial rules do not cover.

Use of any other vendor would require that vendor’s pallet design, configuration, materials, and supporting technical documentation undergo the required airworthiness review, validation, and approval process before the equipment could be authorized for operational use. This process would introduce significant schedule risk and delay delivery and fielding of the pallets. Because the subject vendor’s pallets already possess the required airworthiness certification, they are immediately eligible for procurement and integration into operational use, subject to normal acceptance and inspection procedures.

If the Government were required to use another vendor, mission readiness and operational capability would be adversely affected. Delayed availability of certified C-130 pallets would limit the Government’s ability to safely transport mission-essential cargo, reduce operational flexibility, and potentially cause mission delays or cancellations. Use of pallets that have not completed the required airworthiness process would also present unacceptable crew safety, aircraft safety, and compliance risks. Award to the subject vendor is therefore necessary to ensure timely delivery of certified equipment and continuity of safe C-130 operations.

6. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

The government has been posted an entry on the Acquisition Planning Forecast System (APFS) on 13 Aug 2026. Additionally, the government has queried operators at various US Coast Guard Air Stations to identify any other sources capable of fulfilling this requirement.

Additionally, the government will place an announcement on SAM.gov to notify industry of its intent to purchase these pallets on a sole source basis.

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 price for these pallets will be fair and reasonable based on price analysis techniques consistent with FAR Part 12 commercial acquisition procedures. The Contracting Officer will evaluate the proposed price based on available commercial market information, which may include comparison to published or catalog prices, commercial price lists, prior sales of the same or similar commercial items, prices paid by other Government or commercial customers, market research for comparable airworthy aircraft cargo pallets, and any discounts or terms offered to the Government.

Because the pallets must be airworthy and suitable for use in C-130 operations, the price analysis will consider the commercial availability of comparable certified aircraft cargo handling equipment and the value associated with existing airworthiness certification. The analysis may also consider whether the proposed price reflects the specialized

Last Updated 07/23/26 4 configuration, certification status, delivery schedule, and operational suitability required for use in C-130 aircraft.

8. Description of Market Research.

Market research was conducted to determine whether commercial sources are available to satisfy the requirement for two airworthy C-130 pallets. The Government reviewed commercial availability, vendor capability, prior acquisition information, available product information, and whether potential sources could provide C-130-compatible pallets with existing airworthiness certification suitable for operational use upon receipt. Additionally, surveys were conducted by contacting other Coast Guard Air Stations to understand the availability of this equipment.

The Government identified the subject vendor as capable of providing the required pallets with existing airworthiness certification. Market research did not identify another responsible source able to meet the Government’s airworthiness and schedule requirements within the required timeframe. Other vendors would require completion of the applicable airworthiness review and approval process before their pallets could be used, resulting in unacceptable delays to fielding this critical equipment.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

The vendor’s existing airworthiness certification is critical because the C-130 pallets must be approved for safe operational use before they can be placed aboard aircraft. Procuring from a source without existing certification would require additional airworthiness review and approval, creating schedule delays and mission impacts. The subject vendor’s certified pallets allow the Government to obtain and field the equipment within the required timeframe while maintaining compliance with applicable safety and operational requirements.

10. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the Acquisition.

A Notice of Contract Action will be posted on SAM to request capability statements from any other vendors that may be capable of providing this airworthy equipment. The results of that notice will be included as an addendum to this justification.

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

By posting this notice of contract action, the Government is providing industry awareness of the requirement for airworthiness certification for this type of equipment. This notice may enable interested firms to take the steps necessary to obtain the required certification for future requirements.