Redacted J and A - 70Z03822QB2000192.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

2022135-DD03

PROJECT/TASK

NUMBER

SRR

ESTIMATED AMOUNT (Over Micro- Purchase Threshold, but up to the SAT)

$216,000.00

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/overhaul on a sole source basis spare parts used on the MH65 helicopter.

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

This procurement for the repair/overahaul of Twelve (12) [with an option for the repair/overhaul of an additional quantity of Twenty-Eight (28)] Generator AC (P/N: 82562-7, NSN: 6115-01-HR1-9211) to be used on the MH65 helicopter.

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

SUPPLIES OR SERVICES CAN BE USED.

This part is used for the manufacture and repair of the AC Generation System 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).

This acquisition is restricted to the only source known to have the capability of repairing the scheduled parts back to original equipment manufacturer (OEM) specification. The USCG has determined that these parts can only be repaired/overhauled by OECO, LLC (Cage Code:

02101). OECO, LLC owns the proprietary data rights to repair/overhaul the parts in this requirement and does not distribute any of this data to any other entities. 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.

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

The parts to be repaired/overhauled 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 only approved source for repair/overhaul of the parts identified in this requirement is OECO, LLC. Soliciting to other than the USCG approved repair/overhaul source will compromise the safety of the aircraft and the 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, which will be incorporated.

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 and overhaul 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 spare sources for repair/overhaul capabilities due to time restraints of USCG 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.

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

Robert E. Askew Jr.

CODE

DD

TELEPHONE

NUMBER

252-334-5406

DATE

5/17/2022

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

NUMBER

DATE