Redacted J and A 70Z03821QB2000085.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

NUMBER

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 H-65 helicopter: Fifteen (15) Electro Valve (p/n 6910A01, NSN: 4810-14-448-1714) with an option for increased quantity up to a maximum of twenty seven (27).

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

CAN BE USED.

The repairs 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), Liebherr-Aerospace Toulouse SAS (Cage Code: F1958) and USCG SRR Engineering. At this time, the only known repair facility capable of repairing these Electro Valves is the OEM authorized repair facility, Eurotradia International (Cage Code: F0521).

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 repair facility is not available. Eurotradia International owns the proprietary data rights, specifications, and drawings to these items which has limited the USCG’s ability to provide adequate technical descriptions to potential new manufacturers. The solicitation and resulting purchase order will require all materials delivered to have clear, documented traceability to the OEM, and a completed Certificate of Conformance, certifying compliance with this condition, in accordance with FAR clause 52.246-15, Certificate of Conformance, which will be incorporated in the resulting purchase order.

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

Eurotradia International is the suggested source of supply for the repair of the parts on this requirement based on the fact that they are the OEM approved repair facility and authorized to repair the part in accordance with OEM Specifications.

They are the only known source that has designed drawings and specifications that have been approved by SRR Engineering. The part identified in this procurement must be repaired by the OEM, or OEM approved repair facility, in order to maintain structural integrity of the aircraft and ensure complete compatibility of replacement parts. The USCG neither compromises nor makes exceptions in matters of human safety and protection of Government property, and does not accept lower standards in these matters. 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 H-65 aircraft. The required specifications of suitable alternate parts would not be sufficient for selection. After receiving responses from the solicitation, an initial test and evaluation would have to be completed on the aircraft to ensure compatibility. It would not be cost or time effective to test spare parts from alternative manufacturers due to time restraints of Coast Guard Air Stations testing procedures.

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

COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED.

The OEM, or OEM repair facility, owns the proprietary data rights, specifications, and drawings to these items which have limited the USCG’s ability to provide adequate technical descriptions to potential new manufacturers. Therefore, it is difficult to take steps to foster competition as the manufacturing, performance, and acceptance data are proprietary to the

OEM.

SIGNATURE AND TITLE OF CUSTOMER

CODE TELEPHONE NUMBER

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE NUMBER

DATE