Redacted J and A - 70Z03824QB0000104.pdf

March 8, 2023 Version

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. Do not use marketing language in this document. Language such as “This company has made its mark,” “This company is recognized as industry’s best,” and “This company is the leader in…” is unacceptable.

PURCHASE REQUEST OR REQUISITION

NUMBER

4004-DF03

PROJECT/TASK

NUMBER

ALC SRR

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

$91,560.60

CITE AUTHORITY & JUSTIFICATION TYPE – READ FAR 6.302 TO DETERMINE APPROPRIATE TYPE

10 U.S.C. § 3204(a)(1)

ONLY ONE RESPONSIBLE SOURCE AND NO OTHER SUPPLIES OR SERVICES WILL SATISFY

AGENCY REQUIREMENTS.

☐ 10 U.S.C. § 3204(a)(2) UNUSUAL AND COMPELLING URGENCY

10 U.S.C. § 3204(a)(3)

INDUSTRIAL MOBILIZATION; ENGINEERING, DEVELOPMENTAL, OR RESEARCH CAPABILITY; OR

EXPERT SERVICES

☐ 10 U.S.C. § 3204(a)(4) INTERNATIONAL AGREEMENT

☐ 10 U.S.C. § 3204(a)(5) AUTHORIZED OR REQUIRED BY STATUTE – MUST PROVIDE IT

☐ 10 U.S.C. § 3204(a)(6) NATIONAL SECURITY

☐ 10 U.S.C. § 3204(a)(7) PUBLIC INTEREST [SECRETARY OF HOMELAND SECURITY NEEDS TO APPROVE THIS DOC]

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 (2) Armatures

(P/N: P503684 NSN: 2925-14-586-8953). With an optional quantity request for an additional (10).

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 that is used to combine the magnetic field, which creates a current over the field (armature) causing the shaft to rotate within the aircraft starter generator. The part number provided is the Original Equipment Manufacturer (OEM) 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 Engines and both the OEM Safran Helicopters Engines

Inc. (Cage Code 7Y709) and the United States Coast Guard (USCG) have only authorized Thales’s 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 in the USCG helicopters.

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 Inc. manufactures these parts (CAGE 0J2T3). 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.

https://www.acquisition.gov/far/part-6#FAR_6_302 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204 https://www.govinfo.gov/link/uscode/10/3204

March 8, 2023 Version

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

Thales Aviation, Inc. is the OEM and the parts on the schedule must be provide by Thales Aviation 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.

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

IM DF

TELEPHONE

NUMBER

(252) 335-6641

DATE

12 Feb 2024

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

NUMBER

DATE