Redacted J and A - 70Z03821QB2000132.pdf

November 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 purchase spare 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 Five (5) Oil Filling Spouts (P/N: 365A32-6505-01), NSN: 4710-14-389-4427 to be used on the MH65 helicopters.

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

SUPPLIES OR SERVICES CAN BE USED.

This acquisition is restricted to the only source of supply known to have the capability of furnishing the required supplies. The aircraft Original Equipment Manufacturer (OEM) and the USCG has determined that these parts can only be acquired directly from the OEMs’ U.S. affiliate, which is not the manufacturer. Furthermore, the Government does not have adequate data or lacks rights to data, and it is not economical to buy 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 spare parts to be procured 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 source is not available. Airbus Helicopters France (F0210) is the OEM for parts used on the MH-65 helicopter. Airbus Helicopter France does not sell directly to the USCG and has stated that “Airbus Helicopters, Inc. (3GSZ1) is the only approved source of supply for Airbus Helicopter

France products for the MH-65 aircraft.” Therefore, procurement of any parts from other than the OEM or an OEM approved source will compromise the safety of the aircraft and the crew. 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 contract condition, in accordance with FAR clause 52.246-15, Certificate of Conformance, which will be incorporated.

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

These parts are proprietary to the OEM, Airbus Helicopter France, and maintenance procedures were written specifically to interact with these parts. Based upon the technical certification on file, technical data is not available and cannot be developed to permit full and open competition.

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 spare parts would not be sufficient for equipment 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 spare parts from manufacturers due to time restraints of Coast Guard Air Stations testing procedures.

November 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 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

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE