Redacted J and A - 70Z03821QB2000198.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

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 purchase spare parts on a brand name basis utilized on the MH-65 helicopter.

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

This procurement is for the following spare parts to be utilized on the MH65 helicopters:

One Thousand One Hundred Thirty Nine (1,139) Module, Grounding (P/N: NSA937916-20 NSN: 5999-14-

346-0639).

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

SUPPLIES OR SERVICES CAN BE USED.

These grounding modules are utilized during the rewire for the MH-65 echo model upgrade. The part number provided is the Original Equipment Manufacturer (OEM)’s part number and alternate part numbers are not acceptable. The ALC Wire Shop has requested this specific product due to past performance and reliability in these repairs. No alternate parts are authorized for the repair of USCG aircraft parts. Accepting alternate part numbers at this time could cause extra labor hours and material used to repair these parts.

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 authorized distributor is not available. These parts are manufactured by Airbus

Operations (CAGE: F6198). 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 on the resulting purchase order.

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

The parts on the schedule must be provided by the OEM, Airbus Operations (CAGE: F6198) or an OEM authorized distributor 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.

All parts shall be new and shall be traceable to the OEM. Use of OEM parts will ensure the parts are manufactured in accordance with OEM specifications and standards, conform to original form, fit and function, 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 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.

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 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