Redacted J and A - 70Z03821QB20000142.pdf

August 2020

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

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 repair parts on a sole source basis utilized on the MH-65 helicopter.

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

This procurement order is for the repair of the following parts to be utilized on the MH65 helicopter: Five

(5) Floor LHX885-X3000 (P/N: 366A21-0101-0901, NSN: 1560-14-464-0809) and Two (2) Aft Floor (P/N:

366A21-0108-09, NSN: 1560-14-404-0386).

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

SUPPLIES OR SERVICES CAN BE USED.

The items to be repaired under this solicitation can only be completed by a company that has access to all applicable maintenance manuals and has been approved by the Original Equipment Manufacturer (OEM) and USCG SRR Engineering. At this time, the only known repair facility capable of repairing these Floor

Board Assemblies is the OEM authorized repair facility, Applied Composites Engineering, Inc. (Cage

Code: (0WTG1). ”

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 repair to be performed under this acquisition involves 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 authorized distributor is not available. These parts are repaired by Applied

Composites Engineering, Inc. (0WTG1). The solicitation and resulting repair 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 incorporated on the resulting purchase order.

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

Applied Composites Engineering is the suggested source of supply for the repair of the parts on this requirement based on the fact that they are the OEM and only repair source authorized that can repair the part in accordance with OEM Specifications. The OEM is the only known source that has designed drawings and specifications that have been approved by SRR Engineering. Applied Composites

Engineering has maintained their status as the only source qualified to fulfill this requirement in that they are the only known contractor with proprietary data required to perform the work, which is vital for the continued operational readiness of the aircraft. If any other potential sources are found they will be evaluated by SRR Engineering to whether or not they can modify these aircraft skins as per SRR

Engineering approved drawings and specifications.

August 2020

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 USCG did not purchase data rights as part of the initial system acquisition of the MH-65 helicopter.

The USCG does not possess adequate technical drawings and specifications to provide to potential new sources and is unable to provide proprietary repair information to outside vendors. Due to the maturity of the MH-65 platform, the cost to procure data rights, presuming they would be made available, would be cost prohibitive.

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

BARRIERS TO COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED.

As stated above, Applied Composites Engineering possesses the proprietary rights for the repair of these

Floor assemblies which has limited the USCG’s ability to provide adequate technical descriptions to potential new sources. Therefore, it is difficult to take steps to foster competition as the repair process is proprietary to Applied Composites Engineering.

SIGNATURE AND TITLE OF CUSTOMER

CODE

TELEPHONE

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE