Redacted J and A - 70Z03821QB2000247.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

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 components 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 repair of the following component utilized on the MH-65 helicopter: Two (2) Valve (P/N: 861C010102, NSN: 4820-

14-464-2750). With an option to repair six more.

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 known source to have the capability of repairing the scheduled components back to Ready for Issue condition in accordance with the Original Equipment

Manufacturer (OEM) specifications. The USCG has determined that these components can only be repaired by a

USCG approved repair facility, which is not the manufacturer. Furthermore, the Government does not have the adequate data or lacks rights to the data and it is not economically feasible 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 components 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/USCG approved source is not available. Liebherr-Aerospace Toulouse SAS (CAGE F1958) is the OEM for the component identified in this requirement, but is not capable of providing repair services and no OEM authorized repair facilities have been identified. The only USCG approved source for repair of the identified component in this requirement is Coastal Mechanics Company, Inc. (5N111), whose repair procedures and data are protected under proprietary data rights. Coastal Mechanics Company, Inc. is the only authorized facility with the technical expertise to interpret the data and ability to solve technical problems, all of which are vital for the continued operational readiness of the identified component. However, USCG will accept quotes for these components from any OEM approved authorized repair facilities, should any be identified.

REASON THAT SUGGESTED SOURCE IS THE ONLY SOURCE, WHICH CAN PROVIDE THE SUPPLIES OR SERVICES. Due to the age of the components in this requirement, they are no longer procurable or repairable through the OEM.

Therefore, the USCG approved the following proprietary engineering change with Coastal Mechanics (16001-

861C01010X-ML-ECP rev 2) authorizing the vendor to test, repair and make modification criteria for the services listed in the schedule. The referenced ECP is proprietary to Coastal Mechanics Company, Inc. Based upon the technical certification on file, technical data is not available and cannot be developed to permit full and open competition.

August 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. The USCG did not purchase data rights as part of the initial system acquisition of the MH-65 aircraft and did not purchase data rights to the approved ECP. The required specifications of suitable alternate parts 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. Coastal Mechanics Company, Inc. owns the proprietary data rights, specifications, and drawings to repair these components back to OEM specifications, which has 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 repair data is proprietary to the Coastal

Mechanics Company, Inc.

SIGNATURE AND TITLE OF CUSTOMER

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TELEPHONE

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SIGNATURE OF CONTRACTING OFFICER

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