Redacted J and A- 70Z03823QB0000269.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 Brand Name 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 for the procurement of spare piece part 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 following spare part to be utilized on the MH-65 helicopter:

Ten (10) Detector, Chip (P/N: 1B7807 or 704A34-5430-17, NSN: 5999-01-HS1-5228).

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

CAN BE USED.

The piece part referenced is manufactured by the aircraft Original Equipment Manufacturer (OEM) Airbus

Helicopters France (Cage Code F0210). The USCG has determined that since Airbus Helicopter France does not sell parts directly in the United States, this item can only be procured from the OEM’s US affiliate Airbus

Helicopters Inc. (Cage Code 3GSZ1) and as such they are the only vendor approved to supply an OEM

Certificate of Conformance and or an EASA Form 1.

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 part to be procured under this acquisition is a highly specialized flight critical piece part, designed and manufactured by a non-Government activity specifically for the USCG G366 platform Main Gearbox

Hydraulic System. The only manufacturer of the listed component is Airbus Helicopters France (Cage Code

F0210). Procurement of this item from any other manufacturer, than the OEM would result in catastrophic consequences to 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 FAA 8130 or

EASA Form 1, certifying compliance with this contract condition, in accordance with FAR clause 52.246-15, Certificate of Conformance, which will be incorporated.

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

The scheduled item primary use is for the electronic detection of metal particles that may be introduced to the

MGB either by accident or if metal particles chip during aircraft operations. The part number provided is the

OEM’s part number. As such, alternate part numbers are not acceptable nor authorized for use in electronic metal chip detection with USCG MH-65 MGB hydraulics system. Accepting alternate part numbers at this time would cause catastrophic consequences should the required piece parts fail during flight operations, due to specification inadequacies during manufacture. The USCG neither compromises nor makes exceptions in matters of human safety and protection of Government property, nor does it accept lower standards in these matters. All parts shall be new and traceable to the OEM. Use of OEM manufactured parts ensure they are manufactured in accordance with the OEM specifications, standards, and that they conform to original form, fit, and function requirements, thus ensuring compatibility and are interchangeable with existing components.

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. The flight critical required specifications of suitable alternate piece parts would not be sufficient for source selection.

After receiving responses from the solicitation, extensive exclusive testing and evaluation involving interaction with the aircrafts main gear box and hydraulics systems would have to be completed 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.

The OEM owns the proprietary data rights, specifications, drawings, and manufacturing procedures to the listed items, 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 maintenance, data and manufacturing criteria are proprietary to the OEM.

SIGNATURE AND TITLE OF CUSTOMER

CODE

TELEPHONE NUMBER

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE NUMBER

DATE