Redacted J and A 70Z03821QB2000086.docx.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 Engine Extinguishers on a sole source basis utilized on the MH-65 helicopter.

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

This procurement is for the following parts to be repaired and utilized on the MH65 helicopter: Thirty

Four (34) Engine Extinguisher, (P/N: 10230-01, NSN: 1680-14-562-8832).

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 vendor 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 the Engine

Extinguishers is Shoreline Marine, Inc., Doing Business As (DBA) Safetech. (Cage Code 06ZV6)

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 parts to be repaired under this acquisition are 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 approved sources are not available. L’HOTELLIER SAS (Cage F9211) 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 sources. 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.

These repair services for the parts identified in this requirement are proprietary to Safetech. Safetech is the only OEM-approved repair facility capable to perform the work, possess the technical expertise to interpret the data, and the ability to solve technical problems; all of which are vital for the continued operational readiness of the aircraft. The USCG neither compromises nor makes exceptions in matters of human safety and protection of Government property, nor does not accept lower standards in these matters.

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 modification 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 from the OEM, would be cost prohibitive.

August 2020

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, Safetech possess the proprietary right for the repair of these Engine Extinguishers which has limited the USCG’s ability to provide adequate technical description to potential new sources.

Therefore, it is difficult to take steps to foster competition as the modification process is proprietary to

Safetech.

SIGNATURE AND TITLE OF CUSTOMER

CODE

TELEPHONE

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE