Redacted J and A - 70Z03822QB2000194.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 procure overhaul services on a sole source basis for parts utilized on the MH-65 helicopter.

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

This procurement is for the overhaul of parts to be utilized on the MH65 helicopter: Twenty-Five (25)

Fans (P/N: VCT1518D, NSN: (1660-01-HS1-7052).

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

SUPPLIES OR SERVICES CAN BE USED.

This overhaul is for parts used for the Engine Cooling Components specific to the MH65 aircraft. No alternate part numbers are acceptable. The technical data required for overhaul 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 spare parts to be overhauled 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 is not available. SAFRAN Ventilation Systems S.A.S. Blagnac, France (Cage Code: F4957) is the manufacturer of this part and supports the fan through its approved repair center: SAFRAN Ventilation

Systems USA LLC (Cage Code: 3TRJ7). SAFRAN Ventilation Systems 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 repair/overhaul facilities. The solicitation and resulting purchase order for overhaul will require all materials 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.

The parts on the schedule must be overhauled by the OEM’s only approved overhaul source in order to maintain structural integrity of the aircraft and ensure complete compatibility of overhauled 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. Use of OEM’s approved repair center will ensure the parts are overhauled 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 USCG did not purchase data rights as part of the initial system acquisition of the H-65 helicopter.

The USCG does not possess adequate technical drawings and specifications to provide to potential new sources and is unable to provide proprietary modification information to outside vendors. Due to the maturity of the MH-65 platform, the cost to procure data rights, presuming they would be made available, would be cost prohibitive.

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.

As stated previously, 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

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE