Redacted J and A.pdf

April 2019

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

0225-DE03

PROJECT/TASK

NUMBER

SRR

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

$27,720.00

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 brand name basis utilized on the H-65 helicopter.

The statutory authority permitting other than full and open competition is 41 U.S.C. 1901; FAR 6.302-1.

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

This procurement is for the following spare parts to be utilized on the H-65 helicopter:

Thirty (30) NVIS RED LAMP HOLDE NIIN: 01-HS3-3042 PN: F9999-0394

Thirty (30) NVIS YELLOW LAMP NIIN: 01-HS3-3041 PN: F9999-0344

With the option to purchase sixty(60) each of the above parts within the next 12 months after award.

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 known to have the capability of providing the scheduled parts in accordance with Original Equipment Manufacturer (OEM) specifications. The USCG has determined these parts can only be purchased directly from the OEM. No alternate part numbers are provide per the IPC nor authorized per the OEM’s maintenance manuals or SRR Engineering and Tech

Services. Furthermore, the Government does not have the adequate data or lacks rights to the data and it is not economical to buy the data or rights to the data.

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 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. Cevians LLC (CAGE: 7B9T2) is the OEM for this part.

Procurement of any parts from other than the OEM 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.

The part on schedule must be provided by the OEM in order to maintain structural integrity of the aircraft 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 the OEM specification and standards, conform to original form, fit, and function requirements, and are compatible and interchangeable with existing components.

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April 2019

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 aircraft. 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 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

Kristin R. Pelton, Inventory Manager

CODE

DE

TELEPHONE

NUMBER

252-384-7198

DATE

_____/_____/2020

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

NUMBER

DATE

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