Redacted J and A - 70Z03823QB2000034.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

2022296-DD01

PROJECT/TASK

NUMBER

SRR

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

$175,996.08

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 on a sole source basis spare parts used on the MH-65 helicopter.

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

This procurement for repair services of Six (06) [with an option for the repair of an additional quantity of Eighteen (18)] Electrovalves (P/N: 6910A01, NSN: 4810-14-448-1714) to be used on the MH-65 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 in the manufacture and repair of the Bleed Air Supply System specific to the

MH-65 aircraft. No alternate part numbers are acceptable. The technical data required for repairs 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 these parts can only be repaired by Eurotradia International (Cage Code: F0521).

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. Market research did not reveal any additional

Maintenance, Repair and Operations (MRO) facilities available for repairing these

Electrovalves.

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

The repair service vendor Eurotradia International, Inc. (Cage: F0521) referenced for the items identified in this requirement are at present the only known repair source capable of providing the materials needed to complete this specific repair for the US Coast Guard’s Electrovalves on the MH-65 Bleed Air Supply System. 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 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 repair 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.

PROVIDE A STATEMENT OF ACTIONS, IF ANY, THE GOVERNMENT MAY TAKE TO REMOVE OR OVERCOME ANY

BARRIERS TO COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED.

Not owning proprietary rights for the repair of these electrovalves has limited the USCG’s ability to provide adequate technical descriptions to potential new repair sources. Therefore, it is difficult to take steps to foster competition for this repair process, SIGNATURE AND TITLE OF CUSTOMER

Robert E. Askew Jr.

CODE

DD

TELEPHONE

NUMBER

252-334-5406

DATE

10/24/2022

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

NUMBER

DATE