JOTFOC AK064.pdf

Last Updated 03/03/2026

U.S. COAST GUARD JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

COMMERCIAL PRODUCTS AND SERVICES AT OR BELOW THE SAT

FAR 12.102(a), FAR Class Deviation 25-21 Rev. 1 for FAR Part 12

PURCHASE REQUEST OR REQUISITION NUMBER:

2126406B4500

ESTIMATED TOTAL VALUE, INCLUDING OPTIONS:

(Over Micro-Purchase Threshold, but up to the SAT) $ 43,200.00

AUTHORITY JUSTIFICATION TYPE

Restricting Competition FAR 12.102(a), FAR Class Deviation 25-21 Rev. 1 for FAR Part 12

☐ Only One Source Is Available (e.g., urgency, exclusive licensing agreements, or industrial mobilization).

☒ Brand Name - Items peculiar to one manufacturer: The particular brand name, product, or feature is essential to the Government’s requirements, and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency’s needs

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED AND THE INTENDED USE:

The purchase of Five (5) Controls, Generator; P/N: 8440-2083, NSN: 6110-01-688-2412, component of the 87’ WPB and 154’ WPC patrol boat generator control system.

OEM: Woodward Inc.; Cage: 31361 (UEI: QHSALYLFAC85)

SUGGESTED SOURCE NAME, ADDRESS, & UNIQUE ENTITY IDENTIFIER (UEI):

Vendor 1: Motor Services Hugo Stamp Inc.

UEI: MS5BUY1ZLGL1 CAGE: 1JPZ7

Vendor POC: Aida Narvaez

Phone Number: 954-462-7404

Email: aida.narvaez@mshs.com

Website: www.mshs.com

Estimate: $ 43,200.00

Business Size Category: Large

Ordering Vehicle Name and Number, if applicable: N/A

Vendor 2: Philadelphia Electric Equipment Co.

UEI: FSEYK6JYXEG6 CAGE: 7W024

Vendor POC: Tim Reagoso

Phone Number: 484-840-0860

Email: treagoso@speecoenergy.com

Website: www.peecoenergy.com

Estimate: $ 43,200.00

Name 3: Woodward Inc.

UEI: QHSALYLFAC85, CAGE: 31361

POC: Justin Mueller

Phone Number: 970-988-1286

Email: justin.mueller@woodward.com

Website: www.woodward.com

Estimate: $ 43,200.00

Vendor 4: Pacific Power Group, LLC

UEI: VCWRFP45TJA9

Vendor POC: Mercedes Mogel

Phone Number: 253-520-5166 ext. 15166

Email: parts.kent@mshsppg.com

Website: www.mshs.pacificpowergroup.com

Estimate: $ 44,500.00 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-12#FAR_12_102 https://www.acquisition.gov/far-overhaul/far-part-deviation-guide/far-overhaul-part-12#FAR_12_102 mailto:aida.narvaez@mshs.com https://www.mshs.com/ mailto:treagoso@speecoenergy.com https://www.peecoenergy.com/ mailto:parts.kent@mshsppg.com https://www.mshs.pacificpowergroup.com/

The procurement of genuine original equipment manufacturer (OEM) Generator Controls, designed and manufactured by

Woodward Inc., is critical to maintaining the operational readiness of the 87’ WPB Protector Class fleet. The primary purpose of the requested generator controls (NSN: 6110-01-688-2412) is to act as the central logic unit that automatically regulates, monitors, and protects the ship's electrical generation plant to maintain mission-critical power continuity. Because the

Government does not possess the proprietary technical data, precise tolerances, material specifications, or reproduction manufacturing drawings required to solicit full and open competition, these generator controls must be procured from the

OEM or its authorized distributors, if any. Sourcing unproven aftermarket alternatives represents an unmitigated risk, as there is no government-held baseline against which to verify or certify the performance and safety of non-OEM alternatives.

Attempting to substitute these critical components with non-OEM alternatives would likely require a formal engineering change in accordance with the Joint Surface Engineering Change Process Guide, CGTO-PG-85-00-900-G. This process triggers months of costly system re-engineering, extensive mechanical analyses, technical design reviews, and operational shipboard testing to certify alternative generator controls can handle the operational requirements. Such protracted delays would divert critical logistics funds and could force affected cutters into a non-operational or restricted status, actively degrading the Coast Guard’s readiness and its ability to execute statutory missions, including securing U.S. borders, facilitating maritime commerce, and responding to national contingencies. Consequently, strict adherence to the proven OEM configuration is mandatory to guarantee reliable cutter operations and comply with Coast Guard Configuration Management

Policy under Commandant Instruction 4130.6C.

Utilizing non-OEM alternative parts introduces unacceptable safety and operational risk to the vessel and crew. During critical operations on a Coast Guard vessel, the failure of a non-OEM generator control module can trigger a catastrophic sequence of events: it risks an immediate shipboard blackout that disables propulsion, steering, and emergency anchoring systems, leaving the vessel vulnerable to collision or grounding. For the crew, such a failure introduces physical hazards like engine room fires from sub-standard materials, alongside severe cognitive overload from cascading alarms and non-standard recovery procedures that delay power restoration. Ultimately, substituting OEM-certified equipment with unapproved aftermarket controls violates critical marine safety regulations, compromises the vessel's machinery monitoring systems, and directly jeopardizes both mission success and safety of life at sea. While SFLC Equipment Specialists remain committed to conducting continuous market research to identify alternative vendors, the current lack of proprietary technical data makes achieving full and open competition highly improbable at this time, making the procurement of Woodward Inc. generator controls necessary to sustain fleet readiness.

CONTRACTING OFFICER - FAIR AND REASONABLE PRICE DETERMINATION METHODS:

☐ MARKET RESEARCH

☐ COMPARISON OF PROPOSED PRICE WITH PRICES FOUND REASONABLE ON PREVIOUS PURCHASES

☐ CURRENT PRICE LIST

☐ COMPARISON WITH SIMILAR ITEMS IN A RELATED INDUSTRY

☐ COMPARISON TO IGCE

☐ CONTRACTING OFFICER’S PERSONAL KNOWLEDGE (EXPLAIN)

☐ OTHER (EXPLAIN)

SIGNATURE AND TITLE OF TECHNICAL AND REQUIREMENTS POC DATE

SIGNATURE OF CONTRACTING OFFICER

DATE