Redacted J and A - 70Z03826QB0000191.pdf

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JUSTIFICATION AND APPROVAL FOR

OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION NO. 70Z03826QB0000191

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by Federal Acquisition Regulation (FAR) 12.102(b), FAR Class Deviation 25-21 Rev. 1 for FAR Part 121, FAR 6.103, FAR Class Deviation 25-11 for FAR Part 6 and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO 12.102(b) is justified by the following facts and rationale required under RFO 6.104-1 as follows:

1. Agency and Contracting Activity.

Department of Homeland Security, United States Coast Guard (USCG), Aviation Logistics Center (ALC), Short Range Recovery (SRR) Product Line.

2. Nature and/or Description of the Action being Approved.

(a) Nature of the action: Sole source procurement of the Small Tactical Terminal (STT) KOR-24A-Naval Variant and STT Fan Trays to support the Tactical Data Link (TDL) on the USCG MH-65E aircraft.

(b) Name and address of the contractor:

L3 Technologies, Inc. (L3) 640 North 2200 West Salt Lake City, UT 84116-0850 Cage Code: 06401

(c) Contract Type: Firm Fixed-Price Purchase Order

1 In this document, citations to RFO Parts 12, 6, 10, 15, and 25 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-21 Rev. 1 for FAR Part 12, FAR Class Deviation 25-11 for FAR Part 6, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 Rev. 1 for FAR Part 15, and FAR Class Deviation 26-09, Rev. 1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), which was implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

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(d) Estimated total value (including options):

NSN P/N Nomenclature Qty Estimated Unit Cost

Estimated Extended Cost

N/A 1349582 SMALL TACTICAL TERMINAL

(STT) KOR-24A-NAVAL VARIANT

20 $214,613 $4,292,260

N/A 1117574 STT FAN TRAY 21 $13,913 $292,173

Total Value: $4,584,433.00

(e) Type of funding: Operations and support funds

(f) Year of funding: Fiscal Year 2026 strategic funds will be used as appropriate.

(g) Solicitation number: 70Z03826QB0000191

(h) Background information about the requirement: This requirement has no previous procurement history.

3. Description of Supplies/Services. This requirement is to provide the STT KOR-24A- Naval Variant, a version of the Small Tactical Terminal, which is a radio system used on naval platforms and STT Fan Trays, which are cooling components that help keep the terminal from overheating. These two parts support the Tactical Data Link (TDL), a secure communication network.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

competition

5. Identification of Exception to the Buy American Statute.

Not applicable.

6.

the acquisition requires use of the authority cited.

(a) L3 Technologies, Inc. is the OEM and the only authorized distributor for the required spare parts (as validated in Attachment 1). No other distributor or manufacturer possesses the proprietary technical data, licensing, or manufacturing rights required to produce or supply these specific components.

Utilizing non-OEM parts or unauthorized distributors poses an unacceptable risk to mission readiness, component compatibility, and system integrity. Procuring directly from the OEM ensures all parts meet strict aviation airworthiness and quality standards.

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(b) The USCG self-of Federal Regulations (CFR) and the Federal Aviation Administration (FAA).

The CFR Title 14, Aeronautics and Space, Part 21, Certification Procedures for Products and Articles, governs the procedural requirements for issuing and changing design approvals, production approvals, airworthiness certificates, and airworthiness approval. 14 CFR 21 defines airworthiness approval as a document issued by the FAA for an aircraft, aircraft engine, propeller, or article which certifies that the aircraft, aircraft engine, propeller, or article conforms to its approved design and is in a condition for safe operation.

The FAA issued Advisory Circular (AC) 20-62(series) to provide information and guidance for use in determining the eligibility, quality, and identification of aeronautical replacement parts and materials intended for installation on United States (U.S.) type-certificated products and articles, and to enable compliance with CFR Title 14. The AC states that acceptable replacement articles should be identified using one of the following methods:

1) If applicable, Certificate of Conformance;

2) FAA Technical Standard Order (TSO) markings;

3) FAA PMA symbol;

4)

5) Direct ship authority. In order for manufactured parts with direct ship authority approval, the manufacturer must specifically authorize the shipping supplier, in writing, and must establish procedures to ensure that the shipped parts conform to the approved design and are in condition for safe operation;

6) Maintenance release document;

7) Identification of critical components; and

8) Marking of life-limited parts.

The AC also states that aircraft part distributors and aircraft supply companies cannot provide a certificate of conformance for the parts they advertise and/or sell, airworthiness and request documentation establishing traceability to a PAH.

Parts provided that do not meet the CFR and FAA requirements could compromise structural and system integrity of the aircraft, putting aircrew personnel and Government property at risk. The USCG neither compromises nor makes exceptions in matter of human safety and protection of Government property and does not accept standards in these manners.

Use of OEM parts will ensure the parts are manufactured IAW OEM specifications and standards, conform to original form, fit, and function, and are compatible and interchangeable with existing components.

The requirement for these specific L3 Technologies parts arose from the initial

Last Updated 07/23/26 4 integration and qualification of proprietary L3 mission systems and avionics architectures aboard Coast Guard aircraft. During the system design and airworthiness certification phases, these specific components were engineered, tested, and certified as safety-of-flight and mission-critical hardware. Because L3 Technologies holds the proprietary technical data packages and manufacturing rights, no alternative technical specifications exist for third-party replication. Utilizing non-OEM components would void current flight clearances, require cost-prohibitive recertification testing, and introduce critical safety and interoperability risks to active flight operations.

(c) To promote competition, the Aviation Logistics Center (ALC) evaluated both alternative components and alternative supply channels. Physically replacing the L3 components with alternative parts is technically unfeasible, as third-party hardware lacks the proprietary design specifications required to maintain form, fit, and functional interface with the aircraft's mission systems; additionally, integrating non- OEM hardware would immediately invalidate the aircraft's airworthiness certifications and degrade flight safety. Simultaneously, market research was conducted to locate alternative commercial distributors or surplus vendors for the genuine L3 parts. This research confirmed that L3 Technologies retains exclusive distribution rights and does not utilize authorized resellers or third-party distributors for these items. Because alternative components cannot meet critical technical and airworthiness standards, and no alternative sourcing channels exist for the genuine parts, procurement directly from L3 Technologies is the only viable method to satisfy this requirement.

(d) If this Justification and Approval is not approved and the required OEM parts are not provided, ALC will be unable to provide a mission critical part that is required for the safe execution and communication link between the U.S. Coast Guard and U.S.

Air Force when executing the Rotary Wing Air Intercept mission in support of Operation Noble Eagle. The provided parts will additionally confirm the location of the MH65 and verify the helicopter as friendly and not a target while being tracked by the U.S. Air Force.

(e) This J&A requirement does not include the exceptions at FAR 25.103(b)(2) for FAR 25.202(a)(2) for the Buy American Act

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many

Potential Sources as is Practicable.

(a) This procurement forecast was posted on the DHS-Acquisition Planning Forecast

System (APFS), APFS No. P2026074792 at http://apfs.dhs.gov, published August 06, 2026, and included in the DHS Forecast of Small Business Opportunities. There were no inquiries received in response to the published APFS.

(b) Announcement has not been posted to SAM.gov.

(c) The estimated date of publication is August 28, 2026.

(d) Not applicable. The exceptions under RFO 5.302 do not apply to this requirement.

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8. Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable. The contracting officer determines that the anticipated price(s) will be fair and reasonable based on comparison to historical prices paid or similar items in a related industry.

9. Description of Market Research. IAW RFO Part 10, various methods of market research were launched for this requirement:

(a) Market research was conducted from May 2026 to August 2026. A Request for

Information (RFI) was posted to SAM.gov on August 6, 2026 and closed on August 13, 2026. The RFI was issued to survey the market and assist the United States Coast Guard (USCG) in determining possible sources that could fulfill the requirement. In response to the RFI, Timber Sweet provided information, however they are not an authorized distributor per the OEM. Based on historical data, and the OEM letter certifying L3 Technologies Inc. as the sole authorized vendor for the KOR-24A and the Fan Tray, it has been determined that it is in the best interest of the Government to solicit this requirement on an other than full and open, sole source basis.

(b) This J&A requirement does not include the exceptions at RFO 25.103(b)(2) or RFO 25.202(a)(2) for the Buy American Act.

(c) Market Research was conducted.

(d) This requirement does not have or require patents, copyrights, and/or intellectual property.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

(a) The USCG does not own the necessary technical data required to support the manufacture of the required supplies. The drawings and technical data are proprietary and available only from the OEM. Due to proprietary rights, it will be difficult to take steps to foster competition.

(b) The parts in the schedule cannot be reversed engineered and/or modified by other sources, because in order to maintain structural integrity of the aircraft and ensure complete compatibility of replacement supplies, the parts listed in this requirement must be obtained from the OEM and their authorized distributors.

(c) This requirement is not a follow-on for the continued provision of highly specialized services pursuant to RFO 6.103-1(c)(2)(i).

(d) Not applicable to RFO 6.302-2(d) or HSAR 3006.302-270, this is not an unusual and compelling urgency.

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11. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the Acquisition.

Timber Sweet Consulting, LLC provided a response to the RFI that was posted to SAM.gov stating they have the ability to re-sell the Small Tactical Terminal. Per the OEM, L3, Timber Sweet is not listed as an authorized distributor.

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

(a) In support of the Competition in Contracting Act, ALC established the New Product

Development Branch (NPD), and a representative of the NPD Branch is assigned to the SRR Product Line. This representative has the responsibility to search for alternate sources of supply/services and alternate acceptable products. Engineering, Contracting, and NPD representatives continuously conduct market research to ensure that vendors interested in doing business with the USCG are given every opportunity to compete for requirements. NPD is exploring avenues of reverse engineering for some of the hard to find or expensive to repair items, which should further encourage competition, however, this process is lengthy, costly, and labor intensive.

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Alyson Harrison Rectangle

LB071326

L3Harris Proprietary

Luke Baxter Sr. Specialist, Contracts

L3 TECHNOLOGIES INC.

Wholly Owned Subsidiary of L3HARRIS TECHNOLOGIES, INC.

COMMUNICATION SYSTEMS-WEST Operating Division 640 North 2200 West, Salt Lake City, UT 84116 Luke.Baxter@l3harris.com | m +1 385-388-9279

July 13, 2026 In Reply Refer To: LB071326

USCG Aviation Logistics Center

Attention: CWO-2 Jacinto Sabangan

Subject: Sole Source Authorized Vendor for KOR-24A and Fan Trays

Dear Mr. Sabangan, L3 Technologies Inc., Communication Systems-West (L3H) Operating Division hereby certifies that L3H is the sole authorized vendor for the following items and their variants: the Small Tactical Terminal (STT) KOR-24A (PN 1349587) and the STT Fan Tray (PN 1117574). This certification further confirms that L3Harris is authorized to offer these items for purchase to eligible customers and end users, including the United States Coast Guard (USCG), in accordance with applicable regulations, export control requirements, and contractual obligations.

Please note that the KOR-24A is a COMSEC item and must be delivered to a COMSEC-authorized facility. Prior to shipment, L3Harris will require verification of the receiving location's COMSEC authorization to ensure compliance with applicable handling and delivery requirements

Please direct any technical questions that you may have to Mr. Carlos Sosa, Central Sales Specialist at (760)331-4826 or via email at Carlos.Sosa@L3Harris.com for any questions you may have.

Sincerely, Luke Baxter

Senior Specialist, Contracts Luke.Baxter@L3Harris.com

Attachment 1