Redacted J and A - 70Z03823QB2000126.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

3040-DK01

PROJECT/TASK

NUMBER

ESTIMATED AMOUNT (Over Micro-Purchase

Threshold, but up to the SAT)

$200,191.86

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 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 parts to be utilized on the MH-65 helicopters:

Nomenclature NIIN P/N Quantity

Union 14-374-1350 DHS613-511.02 16

Seal 14-382-6583 365A27-3623-20 21

Assy Bent Section, R 14-503-6453 366A21-1114-06 11

Support 14-403-5935 365A87-3011-21 24

Insulating Cup 14-388-5925 365A62-1402-20 50

Former, Assembly, LH 14-488-8207 366A21-1114-05 5

Shim 14-374-7653 365A32-1052-22 15

Pin Assy 14-485-2105 366A25-1267-07 4

Attachment Pin 14-411-2649 365A72-1399-20 40

Spacer 14-369-3247 366A84-0214-21 14

Spigot 14-369-1505 365A27-3152-20 170

Access Cover 14-383-5866 366A27-3610-20 22

Requesting an optional quantity of (16) Union (NIIN:14-374-1350, P/N: DHS613-511.02), (21) of Seal (NIIN:

14-374-1350, P/N: DHS613-511.02), (11) of Assy Bent Section, R (NIIN: 14-503-6453, P/N: 366A21-1114-06),

(24) of Support (NIIN: 14-403-5935, P/N: 365A87-3011-21), (50) of Insulating Cup (NIIN: 14-388-5925, P/N:

365A62-1402-20), (5) of Former, Assembly, LH (NIIN: 14-488-8207, P/N: 366A21-1114-05), (15) of Shim

(NIIN: 14-374-7653, P/N: 365A32-1052-22), (4) of Pin Assy (NIIN: 14-485-2105, P/N: 366A25-1267-07), (40) of Attachment Pin (NIIN: 14-411-2649, P/N: 365A72-1399-20), (14) of Spacer (NIIN: 14-369-3247, P/N:

366A84-0214-21), (170) of Spigot (NIIN: 14-369-1505, P/N: 365A27-3152-20), and (22) of Access Cover

(NIIN: 14-383-5866, P/N: 366A27-3610-20) with the potential to be utilized within one year, 365 calendar days from date of award.

August 2020

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 approved source is not available. Airbus Helicopters France (F0210) is the OEM for the MH-65 helicopter. Airbus Helicopter France does not sell directly to the USCG and have stated that

“Airbus Helicopters, Inc. (3GSZ1) is the only approved source of supply for Airbus Helicopter France products for the MH-65 aircraft.” Therefore, procurement of any parts from other than the OEM or an

OEM approved 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.

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

These parts are proprietary to the OEM, Airbus Helicopter France, and maintenance procedures were written specifically to interact with these parts. Based upon the technical certification on file, technical data is not available and cannot be developed to permit full and open competition.

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

Loretta Sassin

CODE

DK

TELEPHONE

335-6134

DATE

2/9/23

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE