Redacted J and A - 70Z03823QB2000053.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

2325-DF01

PROJECT/TASK

NUMBER

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

$85,262.00

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 purchase spare parts on a brand name 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 parts to utilize on the MH-65 helicopters:

Three (3) Armature (P/N: P503684 NSN: 2925-14-586-8953). With an optional quantity request for

(7) additional.

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

OR SERVICES CAN BE USED.

The Armature is the rotating coil or coils of an electric motor. Used to combine the magnetic field, which creates a current over the field (armature) causing the shaft to rotate within the aircraft. The part numbers provided are the Original Equipment Manufacturer (OEM)’s part number and alternate part numbers are not acceptable. Starter Generator part numbers 524-230 and 524-240 are specific to SAFRAN Helicopters Arriel

2C2 Turbine Engine and both the OEM SAFRAN Helicopters Engines Inc. (Cage Code 7Y709) and the USCG have only authorized Thales Armature part number P503684 for repair of the starter generator. As the aircraft engines are a safety of flight critical component the USCG is not approving alternate part numbers for usage by the USCG at this time.

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 procured 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 authorized distributor is not available. Thales Avionics Electrical Systems SAS (CAGE F0296) is the

OEM and manufactures these parts. 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 on the resulting purchase order.

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

Thales Avionics Electrical Systems SAS, is the OEM and the parts on the schedule must be provided by Thales

Avionics or an authorized Thales distributor in order to maintain structural integrity of the aircraft engines/ starter generators and ensure complete compatibility of replacement 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. All parts shall be new and shall be traceable to the OEM. Use of OEM parts will ensure the parts are manufactured in accordance with OEM specifications and standards, conform to original form, fit and function, and are compatible and 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 required specifications of suitable alternate spare parts would not be sufficient for equipment 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 parts from manufacturers 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 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

Vernon Clark

CODE

DF

TELEPHONE

NUMBER

335-6641

DATE

11/21/2022

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

NUMBER

DATE