Limited-Sources Justification for FAR 8.4_Parrot Anafi USA Mil_Approved_9-15-2022.pdf

Limited-Sources Justification

Pursuant to the Multiple Award Schedule Program (as authorized by 40 U.S.C. § 501), this justification is prepared in accordance with the requirements of Federal Acquisition Regulation (FAR) 8.405-6(b) for the use of sources limited to fewer than those required in FAR 8.405-1, FAR 8.405-2, and FAR 8.405-3. The circumstance justifying restriction is FAR 8.405-6(b)(1) through the following facts and rationale:

(1) Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG), Office of Contract Operations (CG-912) proposes to enter into call order on the basis of a limited-sources justification.

(2) Nature and/or description of the action being approved.

(a) Nature of action: USCG Short Range Unmanned Aviation Systems (SR-UAS), Parrot Anafi USA Mil

(b) Name and address of the contractor: W.S. Darley & CO., 325 Spring Lake Dr., Itasca, IL 60143-2072

(c) Contract type: Firm-Fixed-Price

(d) Estimated total value (including options): Call Order value is $699,996.00

(e) Type of funding: Operations and support funds

(f) Year of funding: Fiscal Year 2022

(g) Solicitation number: N/A

(h) Background information about the requirement: DHS and its Components require a supplemental airborne reconnaissance, surveillance, and tracking capability to enhance situational awareness for field commanders and agents in areas that lack nearby traditional surveillance systems or available manned air support. Blue sUAS offers the requirements needed to meet the mission of DHS and its Components.

(3) Description of Supplies/Services.

The requirement is to provide the USCG with the capability to perform all statutory missions, including surveillance for law enforcement (LE), search and rescue (SAR), aids to navigation (ATON), investigations, civil engineering inspections, pre- and post-storm assessments, training, and any other mission that requires overhead, high-definition day or infrared imagery. The Parrot Anafi is the only device of the four approved systems that demonstrated a consistent and reliable capability to conduct underway take-offs and recoveries while in the marine environment. Further, the Parrot Anafi’s optics capability for both standard video and infrared radar (IR) meets the varied mission capabilities of the USCG, especially for SAR and LE.

(4) Identification of the justification and the rationale.

Pursuant to FAR 8.405-6(b)(1) the particular brand name product is essential to meet the Government’s requirements, and the market research indicated that other companies with similar products lack particular features necessary for varied mission sets, and those do not meet and cannot be modified to meet the Government’s requirements.

USCG intends to procure a brand-name product, Parrot Anafi USA Mil in accordance with FAR 8.405-6(b). The particular brand name product, the Parrot Anafi USA Mil, is unique and highly specialized to perform some of the SR-UAS needs for USCG. The Parrot Anafi USA Mil is compliant with Section 848 of the National Defense Authorization Act for Fiscal Year 2020. The Department of Defense (DoD) Defense Innovation Unit (DIU) developed a list of “trusted” drone options for DoD and Federal Government partners. In addition, this product is in accordance with DHS Policy Memorandum 119-08 and the DHS sUAS Cybersecurity Guidance.

The Parrot Anafi USA Mil is one of four options available under the Blanket Purchase Agreement (BPA) established as a strategic sourcing vehicle by DHS.

In order for USCG to operate an SR-UAS, the device must have an authority to operate (ATO) issued by CG-CYBER. USCG sought an ATO, based on reciprocity with DIU for systems that agency has evaluated. The Parrot Anafi USA Mil has an ATO for USCG use, and is one of two devices on the BPA with the ATO.

The need to order this brand name product is based on specific capabilities the Parrot Anafi USA Mil possesses, that the other qualified device does not. Specifically, the Parrot Anafi USA Mil is able to conduct underway marine launch and recovery and includes a high-resolution optics package to include infrared. The name-brand product is the only one which meets the need of USCG operators for this need-set.

(5) Determination by the ordering activity Contracting Officer that the anticipated order represents the best value consistent with 8.404(d).

The Contracting Officer has determined that issuing the proposed call order to W.S. Darley & CO. represents the best value, and will result in the lowest overall cost alternative, considering price and administrative costs, to meet the Government’s needs. Additionally, the total price is reasonable based on the fact that DHS has established four (4) Blanket Purchase Agreements (BPAs), which allows all DHS components to procure sUAS, their accessories, and associated parts and services.

(6) A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

Market research was conducted by DIU for the purpose to identify potential sources, cyber analysis, demonstration and testing. Through DIU’s research, it has identified the “Blue” UAS, is a commercial American-made product, and also meets the strict cybersecurity requirements. At the moment, only 4-products meet this criteria for SR-UAS, each with different capabilities. All four of these products were evaluated by USCG. In addition, DHS established an Initial Planning Team (IPT) to develop 4 strategic source contracts (BPA) for the procurement of SR- UAS. The SR-UAS on these BPAs have been evaluated and approved by DoD DIU, and are in accordance with DHS Policy Memorandum 119-08 and the DHS sUAS Cybersecurity Guidance and Aviation Governance Board (AGB).

(7) Any other facts supporting the justification.

There are no additional facts at the moment.

(8) A statement of actions, if any, the agency may take to remove or overcome any barriers that preclude the agency from meeting the requirements of 8.405-1 and 8.405-2 before any subsequent acquisition for the supplies or services is made.

The Government will continue to identify ways to increase competition. However, at the moment, there are limited products in the commercial marketplace that meet the strict requirements of DoD and DHS cybersecurity.

(9) Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

William E. Lewis Date Contracting Officer

(10) Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

LCDR Sammy A. Hill Date Technical Representative/COR

APPROVAL:

William E. Lewis Date Contracting Officer