JA - Redacted.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

41 U.S.C. § 1901

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

Requirements

Procurement of Commercial Off The Shelf (COTS) Reuseable, Pressurized, Metal

Shipping Containers for CT7-9C3 Propeller Gearboxes (PGB)

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In compliance with Federal Acquisition Regulation (FAR) 13.501(a)(1)(ii), this justification uses the format at FAR 6.104-1 and is modified to state that the procedures in

FAR subpart 13.5 are used.

1. Agency and Contracting Activity.

The Department of Homeland Security, United States Coast Guard (USCG), Aviation

Logistics Center (ALC), Medium Range Surveillance (MRS) Division, proposes to enter into a contract on the basis of other than full and open competition.

2. Nature and/or Description of the Action being Approved.

(a) Nature of action: The USCG intends to procure on a sole source basis, eighteen (18) Commercial Off The Shelf (COTS) CT7-9C3 Propeller

Gearbox (PGB) shipping containers for logistics support of the HC-144

Aircraft.

(b) Name and address of the contractor:

Aviation Repair Resources Inc.

12136 E. FM 917

Alvarado, TX 76009

Cage Code: 8KZX4

(c) Type of action: Firm Fixed Price Contract

(d) Estimated total value (including options): $479,708 broken down as follows:

Period Duration Yearly Total

Base Year 12 months $97,500

Option Year 1 12 months $210,990

Option Year 2 12 months $171,218

Total $479,708

(e) Type of funding: Operations and Support (O&S) funds

(f) Year of funding: Fiscal Year 2026

(g) Solicitation number: 70Z03826RL0000003

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(h) Background information about the requirements: The HC-144 Aircraft is a medium range, twin engine turboprop aircraft used in search and rescue and maritime patrol missions. The procurement of COTS CT7-9C3 PGB shipping containers are required to support USCG missions.

3. Description of Supplies/Services.

The contractor will provide COTS CT7-9C3 PGB shipping containers to support the HC-

144 aircraft. These supplies are essential to avoid grounding the aircraft.

NSN Part Number Nomenclature

8145-01-HS3-7047 M-001-01-0019 CT7 PGB Container

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

Competition.

The statutory authority permitting other than full and open competition is 41 U.S.C.

1901(e)(2), as implemented in Federal Acquisition Regulation 13.501(a), “Sole Source

Acquisition”.

5. Identification of Exception to the Buy American Act.

This requirement meets the exception to FAR 52.225-5 Trade Agreements.

6. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Require Use of the Authority Cited.

(a) The COTS CT7-9C3 PGB containers have been assigned an Acquisition Method Code

(AMC) Code of 3 which requires they be procured from the actual manufacturer or prime contractor. The Original Equipment Manufacturer (OEM) of the COTS CT7-9C3 PGB containers is Aviation Repair Resources Inc. Using the OEM, or an OEM authorized source, will ensure the COTS CT7-9C3 PGB containers are manufactured in accordance with OEM specifications and standards, conform to original form, fit, and function, and are compatible with preexisting aircraft components. Procuring the requirements from an unauthorized source could result in part failure or other unsafe conditions. The USCG does not have adequate technical data to provide to potential offerors to promote competition.

(b) Details covering what events lead to the situation requiring use of other than full and open competition procedures including whether any portion of the work can be segregated to allow for competition;

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The COTS CT7-9C3 PGB containers specified in this requirement are considered Critical

Safety Items (CSIs). A CSI is a part with one or more critical characteristics that, if not conforming to the design data or quality requirements, would result in an unsafe condition. Unsafe conditions relate to mishap severity categories I (Catastrophic), an II

(Critical) of Military Standards MIL-STD 882 and MIL-STD-100, System Safety

Program Requirements. USCG Engineering has determined that in order to ensure safety of flight, procuring these tires must come from the OEM.

(c) Summarize alternatives considered and why they will not work;

The COTS CT7-9C3 PGB containers are to be utilized to preserve PGB’s in support of the HC-144 aircraft and must maintain an airworthy condition, which restricts the requirement to the OEM. There are no alternatives to acquire these supplies from other than the OEM due to the critical safety, proprietary data and maintaining airworthy condition of the aircraft.

(d) Impact to the mission that would result if the J&A is not approved and, consequently, the product or service not provided;

This procurement will provide COTS CT7-9C3 PGB containers required to support operational maintenance of the PGB. Without these containers to preserve the PGB’s, aircraft could potentially be grounded for extensive periods of time until the OEM containers can be procured. Failure to approve this J&A will jeopardize the performance of the USCG’s mission due to insufficient stock availability for operational aircraft.

(e) Section is required to be completed when the J&A includes the exception listed under

FAR 25.103(b)(2) or FAR 25.202(a)(2). Not Applicable.

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

(a) If an announcement has already been made in beta-SAM.gov, provide the date of publication.

This acquisition is forecasted in the Department of Homeland Security (DHS)

Acquisition Planning Forecast System (APFS), number F2025070403 published on

August 05, 2025, and can be found at https://www.apfs.gov. There were no responses received as a result of the APFS posting.

(b) If an announcement is being planned for posting in beta-SAM.gov, provide the estimated date of publication.

This Justification for Other Than Full and Open Competition will be posted to the

Government-wide Point of Entry (GPE), via https://www.sam.gov as a combined synopsis solicitation that the USCG intends to award to Aviation Repair Resources Inc.

on a sole source basis. Any capability statement, or quotation received will be considered prior to award and the Contracting Officer will make a determination to solicit the

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

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(c) If an announcement will not be published, identify the applicable exception under FAR

5.202. Not Applicable.

(d) If an announcement will be published after award, cite the applicable exception under

FAR6.305. Not Applicable.

8. 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 in accordance with FAR 13.106-3. The prices will be determined fair and reasonable based on a comparison of proposed pricing with prior Asset Maintenance Management Information System (AMMIS) history, current published price lists, and the IGCE.

9. Description of Market Research.

(a) Describe the market research techniques utilized, the specific results of the market research, the date when the market research was conducted, and how the market research was used by the contracting officer to determine price reasonable.

Market research techniques used consisted of reviewing the AMMIS history database and

Government databases such as General Services Administration (GSA), Federal Logistics repository (FEDLOG) and FEDMALL. Review of these government databases determined they were outside the scope of this requirement Aviation Repair Resources

Inc. is the only approved source to distribute these containers. All terms and conditions are not expected to differ from customary terms and conditions in the marketplace or standard Government practices.

(b) Describe the market research results that support the determination that the items are non-available.

The J&A requirement does not include the exceptions at FAR 25.103(b)(2) for FAR

25.002(a)(2) for the Buy American Act.

(c) If market research was not conducted, a reason for its absence must be cited here.

Not Applicable.

(d) If patents, copyrights, and/or intellectual property are applicable to the acquisition, describe the circumstances for acquiring a patented or copyrighted product on the representation of the intellectual property holder that has not been licensed for resale.

Not Applicable.

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

(a) An explanation why technical data packages, specifications, statement of work, or purchase descriptions are not suitable for full and open competition.

Aviation Repair Resources Inc., the OEM, are the only approved sources for the procurement of the COTS CT7-9C3 PGB containers. Therefore, this requirement is not suitable for full and open competition. The technical data package, including drawings, specifications, manuals, and publications required to develop additional sources to procure these parts were not procured by the government and are proprietary to the OEM.

(b) Discuss why your requirement cannot be modified to enhance competition.

This requirement cannot be modified to enhance competition because the components and the subsequent technical data are not available from any distributor other than the

OEM.

(c) For a proposed contract subject to the restrictions of FAR 6.302-1 for follow-on acquisitions as described in 6.302(a)(2)(iii), provide an estimate of the cost to the

Government that would be duplicated and detailed information on how the estimate was derived. Not Applicable.

(d) For a proposed contract subject to the restrictions of FAR 6.302-2(d) or HSAR 3006.302-

270 and where FAR 6.302-2 is cited as the authority, describe the exceptional circumstances allowing for an award for a period of performance in excess of the one-year limitation (applicable to all federal agencies) or the DHS-specific statutory 150-day limitation. Not Applicable.

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

Acquisition.

SSN 70Z03825IL0000008 was posted on SAM.gov on April 28, 2025, with a response date of May 30, 2025. The USCG received two (2) timely responses to the SSN: BHPE, and Aviation Repair Resources Inc. Any potential source would have to demonstrate possession of technical requirements of the OEM licensure, which in turn, ensures the most current OEM data rights and OEM replacement parts. If responses from the notice indicate additional sources are available, the file will be documented accordingly and the requirement competed among all eligible offerors.

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.

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(a) Will the Government revise overly technical specifications, acquire data rights, etc.?

At this time, for reasons set forth in this document, the USCG does not possess the technical data required to foster a full and open competition. The USCG will continually conduct market research to ensure that companies interested in doing business with the USCG are given every opportunity to compete for future USCG requirements.

(b) When a J&A is issued for the purposes of acquiring goods or services while a competitive procurement is being conducted, the justification should include a detailed timeline for completion of the competitive procurement. The period of performance for the sole source action should fairly balance the time needed to complete the competitive procurement. The focus should be on minimizing the need for additional sole source awards. Not Applicable.

All Signatures can be found in the Contract File.