Redacted J and A - 70Z03823QB2000145.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 purchase repair services on a sole source basis used on the MH-65 helicopter.

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

This procurement for the repair services of Twelve (12) [with an option for an additional quantity repairs of One-Hundred and Fifty (150)] Generator Control Units (GCUs) (P/N: GC-

1010-24-9AREVA, NSN: 6110-01-HR1-9578) to be used on the MH65 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 for the manufacture and repair of the USCG Auxiliary Electrical Starter system specific to the MH65 aircraft. This part monitors abnormal voltages which if detected will shut down the aircraft generator preventing over or under excitation of the aircraft electrical system. No alternate part numbers are acceptable. The technical data required for repair 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 Original

Equipment Manufacturer (OEM) Phoenix Aerospace (Cage Code: 29632) informed the USCG

Short Range Recovery Division they were no longer in business and all Component Maintenance

Manuals (CMM) pertaining to the GCU were turned over to Consolidated Aircraft Supply

Company (Cage Code: 8M168) and should be contacted for all future requirements. A first article evaluation was conducted and SRR Engineering conducted form, fit, function testing and approved Consolidated Aircraft Supply for repairing these GCUs per OEM specifications.

Furthermore, 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.

August 2020

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

The GCUs to be repaired 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 sources are not available. The only approved source for repair of the parts identified in this requirement is Consolidated Aircraft Supply Company. Soliciting to other than the USCG approved repair 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.

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 repair 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.

Consolidated Aircraft Supply Company owns the proprietary data rights, specifications, and repair procedures to these items which have limited the USCG’s ability to provide adequate alternate repair sources. Therefore, it is difficult to take steps to foster competition.

SIGNATURE AND TITLE OF CUSTOMER

CODE

TELEPHONE

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE