Redacted J and A - 70Z03821QB2000144.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 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 is for the following parts to be repair and modify/upgraded to ready for issue which is utilized on the MH65 helicopter:

Ten (10) STARTER/GENERATOR NSN: 2925-01-HS1-5227 PN: 524-230 (UPGRADE TO 524-240) w/ the option for (15) Fifteen additional repairs within 1 calendar year

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 known to have the capability of repairing the scheduled parts to the equipment manufacturer (OEM) specification and modification upgrades. The USCG has determined that these parts can only be repaired directly from the OEM. Furthermore, the Government does not have the adequate data or lacks right to the 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 parts to be repaired and modified/upgraded 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. The USCG uses past performance history and Inventory Locator Service (ILS) Mart to seek available sources. Soliciting to other than the OEM or OEM approved will compromise the safety of the aircraft and crew.

REASON THAT SUGGESTED SOURCE IS THE ONLY SOURCE WHICH CAN PROVIDE THE SUPPLIES

OR SERVICES.

Market research has determined that the Thales Avionics Inc. (CAGE 3J0E6), has maintained their status as the only source qualified to fulfill this requirement, in that they own the proprietary data required to perform the work, 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.

November 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.

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

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

OVERCOME ANY BARRIERS TO COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED.

Thales Avionics Inc. 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 for modifications/upgrades. Therefore, it is difficult to take steps to foster competition as the data is proprietary to the OEM.

SIGNATURE AND TITLE OF CUSTOMER

CODE

TELEPHONE

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE