Redacted J and A - 70Z03821QB2000215.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 utilized on the MH65 helicopter:

One Hundred (100) BLADE ATTACH PIN NSN: 5315-14-550-7949 PN: 365A33-3535-20

With optional quantity purchase of Two Hundred (200) within year of award.

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(s) of supply known to have the capability of furnishing the required supplies. The aircraft Original Equipment Manufacturer (OEM) and the USCG have determined that these parts can only be acquired directly from the OEM’s U.S. affiliate, Airbus Helicopter Inc.

(Cage Code 3GSZ1) as their authorized stateside distributor capable for source selection and is the only USCG approved source of supply. Additionally, 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 procured under this acquisition are highly specialized parts, designed and manufactured by a non-Government 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 the MH-65 helicopter. Airbus

Helicopters 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 Helicopters France products for the MH-65 aircraft.” Therefore, procurement of any parts from other than OEM or an OEM approved source will compromise the safety of the aircraft and 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, as required.

August 2020

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

The scheduled item is a key component utilized on the MH-65 aircraft, engine backup control auxiliary unit.

Alternate part numbers are not acceptable or authorized for use on the USCG G366 platforms. Accepting alternate part numbers could cause catastrophic consequences should the part fails during flight operations, due to specification inadequacies during manufacture. The US Coast Guard and the aircraft OEM have limited the source of supply to Airbus Helicopter Inc. (Cage Code 3GSZ1). Additionally all maintenance procedures have been tested and written specifically to interact with the aircrafts. 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 parts would not be sufficient for source selection. After receiving responses from the solicitation, extensive exclusive testing and evaluation involving interaction with the aircrafts engines and fuel systems would have to be completed and certified to ensure compatibility. It would not be cost or time effective to test spares from 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.

Airbus Helicopters France owns the proprietary data rights, specifications and manufacturing procedures to the listed item, which have limited the USCG’s ability to provide adequate alternate procurement sources.

Therefore, it is difficult to take steps to foster competition as the maintenance, data and repair criteria are proprietary to the OEM.

SIGNATURE AND TITLE OF CUSTOMER

CODE

TELEPHONE NUMBER

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE NUMBER

DATE