Redacted J and A - 70Z03824QB0000060.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

3355-DP01

PROJECT/TASK

NUMBER

SRR-S

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

$112,000

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 repair AC to DC power conversation 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 repair of the following component utilized on the MH-65 helicopter: Four (04) Transformer Rectifiers (P/N: 684-

1009-200, NSN: 5950-14-400-1897). With an additional request for 10 each.

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

SERVICES CAN BE USED. This acquisition is restricted to the only source of supply known to have the capability of repairing the scheduled items back to the Original Equipment Manufacturers (OEM) specifications. The USCG has determined that the scheduled listed parts can only be repaired directly from the sole source contractor, which is not the manufacturer. Due to the age of the aircraft the spare parts required to repair the component to Ready for Issue (RFI) condition as outlined in the component

CMM are no longer available, therefore the USCG solicited for a source of supply capable of reverse engineering the parts needed to return the Transformer Rectifier back to RFI condition. Because of the aforementioned solicitation, SRR Engineering and New Product Development have approved several

Engineering Change Proposal Product Improvements with Coastal Mechanics (Cage Code 5N111) for repair.

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 services required to repair the scheduled items under this acquisition are highly specialized. The listed components were designed and manufactured by a non-government agency and are required to convert the aircrafts electrical system from AC to DC power, which is instrumental for powering the aircraft flight components instrument panels, engines and is a necessary safety of flight piece part component. Since the piece parts required to return the transformer rectifier back to RFI condition are no longer available by the OEM or an OEM approved source of supply it was necessary for the USCG to seek a source of supply other than the OEM. Airbus Helicopters France (F0210) is the OEM for the MH-65 helicopter and is the prime contractor for the parts listed under this requirement; however, they do not repair the component. To date the only approved repair source of supply approved by the USCG is

Coastal Mechanics Cage Code (5N111), whose procedures and data are protected under proprietary rights. Therefore re-soliciting to any other than the USCG repair source would compromise the safety of the aircraft and crew. The services required will be advertised on the Federal Business Opportunity website and all responsible sources will be considered and must supply 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.

August 2020

REASON THAT SUGGESTED SOURCE IS THE ONLY SOURCE, WHICH CAN PROVIDE THE SUPPLIES OR SERVICES. Due to the age of the components in this requirement, they are no longer procurable or repairable through the OEM.

Therefore, the USCG approved the following proprietary engineering change with Coastal Mechanics (16001-

861C01010X-ML-ECP rev 2) authorizing the vendor to test, repair and make modification criteria for the services listed in the schedule. The referenced ECP is proprietary to Coastal Mechanics Company, Inc. Based upon the technical certification on file, technical data is not available and can’t 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 USCG did not purchase data rights as part of the initial system acquisition of the MH-65 aircraft and did not purchase data rights to the approved ECP. The required specifications of suitable alternate parts would not be sufficient for 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 repair procedures from multiple 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. Coastal Mechanics Company, Inc. owns the proprietary data rights, specifications, and drawings to repair these components back to OEM specifications, 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 repair data is proprietary to the Coastal

Mechanics Company, Inc.

SIGNATURE AND TITLE OF CUSTOMER

Kelly L Montgomery

CODE

DP

TELEPHONE

NUMBER

X6058

DATE

12/21/2023

SIGNATURE OF CONTRACTING OFFICER

Terrie L. Pickard

CODE TELEPHONE

NUMBER

DATE