Redacted J and A - 70Z03822QB2000052.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 Generator Control 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 repaired and utilized on the MH65 helicopter: Seventeen (17) Generator Control

(P/N: 82564-6-D NSN: (6110-01-HS2-7996)

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

SUPPLIES OR SERVICES CAN BE USED.

This part is used on the Electrical Components specific to the MH65 aircraft. No alternate part numbers are acceptable. The technical data required for acquisition by other than the Original Equipment

Manufacturer (OEM) or an OEM approved source is not available.

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 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. OECO , LLC (CAGE 02101) is the OEM for this part and this affiliate owns the proprietary data rights, specifications, and drawings to these items, which has limited the USCG’s ability to provide adequate technical descriptions to potential new repair facilities. The solicitation and resulting purchase order will require all repaired fans delivered to have clear, documented traceability to the OEM, and a completed Certificate of Conformance, certifying compliance with this condition, in accordance with FAR clause 52.246-15, Certificate of Conformance, which will be incorporated in the resulting purchase order.

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

OECO is the only authorized repair facility for the repair of the parts on this requirement, based on the fact that they are the OEM’s only authorized repair facility that can repair the parts in accordance with

OEM Specifications. The OEM is the only known source that has designed drawings and specifications that have been approved by SRR Engineering. OECO, LLC has maintained their status as the only source qualified to fulfill this requirement in that they are the only known contractor with proprietary data required to perform the work, which is vital for the continued operational readiness of the aircraft.

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 required specifications of suitable alternate repair facilities 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.

As stated above, the OEM possesses the proprietary data rights and specifications for the repair of these

Fans, which has limited the USCG’s ability to provide adequate technical description to potential new sources. Therefore, it is difficult to take steps to foster competition as the repair data is proprietary to

OECO, LLC .

SIGNATURE AND TITLE OF CUSTOMER

CODE

TELEPHONE

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE