Redacted J and A - 70Z03821QB2000089.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 various 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 is for the following parts to be repaired and utilized on the MH65 helicopter: Four (34) Cable Assy, (P/N: 14479-1, NSN: 1680- 01-217-5780).

UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON NO OTHER SUPPLIES OR SERVICES CAN BE USED. This part is used for the manufacture and repair of the Door Handle Assy Components specific to the MH65 aircraft. No alternate part numbers are acceptable. Accepting alternate part numbers at this time could cause a malfunction in the aircraft, causing a hazardous outcome. The technical data required for acquisition by other than the Original Equipment Manufacturer (OEM) or an OEM approved source is not available. Furthermore, the Government does not have the adequate data lacks rights to the data and it is not economical to by the data or rights to the data.

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.

Breeze Eastern LLC (CAGE 08484) is the OEM for the parts identified in this requirement. 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 Breeze Eastern LLC. Breeze Eastern LLC 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. All parts shall be new and traceable to OEM. Use of OEM parts will ensure the manufactured in accordance with the OEM specifications and standards, conform to original form, fit, and function requirements, and are compatible and interchangeable with existing components.

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 required specifications of suitable alternate repair sources 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 multiple repair procedures from multiple sources due to time restraints of Coast Guard Air Stations testing procedures.

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. The OEM owns the proprietary data rights, specifications and repair procedures to these items which have limited the USCG’s ability to provide adequate alternate repair sources. Therefore, it is difficult to take steps to foster competition as the repair data is proprietary to Breeze Eastern LLC.

SIGNATURE AND TITLE OF CUSTOMER CODE

TELEPHONE

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE