Redacted J and A.pdf

April 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

2020281-DF02

PROJECT/TASK

NUMBER

SRR-S

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

$248,140

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 sole source requirement for the repair of spare parts utilized on the MH65 helicopter. The statutory authority permitting other than full and open competition is 41 U.S.C. 1901; FAR 13.501(a).

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE. This procurement is for the following spare parts repair utilized on the MH65 helicopter: Quantity Ten (10) and Optional Quantity Ten (10) Main, Rotor Blades (P/N: 366A11-0010-07 NSN: 1615-01-HS2-0025).

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 authorized source of supply known to have the capability of returning the scheduled items back to Ready For Installation (RFI) condition. The USCG has determined that these parts can only be repaired by the aircraft Original Equipment Manufacturer (OEM) Airbus France

Cage (F0210) US based affiliate Airbus Helicopter Inc. (Cage Code 3GSZ1) which is not the original manufacturer but is the only OEM and USCG approved repair/ overhaul facility. Furthermore, the

Government does not have adequate data or lacks rights to 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 spare parts to be repaired/overhauled under this acquisition are highly specialized, designed and manufactured by a non-

Government activity specifically for the HH65G platforms rotor head assembly and is a safety of flight piece, vital for the safety of the aircraft and crew. Airbus Helicopter France (CAGE F0210) is the OEM for the MH-

65 aircraft and the item identified in this requirement was designed and manufactured by the OEM to be incorporated with the engine, rotor head and gearbox assembly configurations. Since the aircraft configuration is proprietary to Airbus France. The only OEM/ USCG approved source of supply for returning the scheduled items to RFI condition is Airbus Helicopters Inc. (CAGE 3GSZ1), the helicopter OEM’s only listed and authorized US repair overhaul facility, whose drawings, data and testing procedures are protected under proprietary rights. Soliciting to other than an OEM or approved USCG source would compromise the safety of the aircraft and the crew. The solicitation and resulting repair order will require all materials delivered to have clear, documented traceability, and OEM, MRO compliance 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 main rotor blades are vital for the aircraft to hover, maneuver and for providing the thrust that counteracts aerodynamic drag in forward flight. The scheduled listed piece part number provided are the OEM’s part numbers and use of alternate Component Maintenance Manuals (CMM) are not acceptable or authorized for repair referencing of the MH65 aircraft main rotor blades on USCG aircraft. Because the main rotor blades require specific calibration techniques, composite material and balancing before installation, accepting un-authorized repair or

CMM procedures at this time could cause catastrophic consequences should a main rotor blade fail during flight. The USCG and the aircraft’s OEM have restricted the only known sole source to Airbus Helicopter Inc.

(Cage Code 3GSZ1). Additionally all maintenance procedures have been tested and written specifically to interact with the aircraft. Based upon the technical certification on file, technical data is not available and cannot be developed to permit full and open competition.

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April 2020

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 sources would not be sufficient for source selection. After receiving responses from the solicitation, extensive exclusive testing and evaluation involving interaction with the aircrafts, rotor head, transmission and structural assembly would have to be completed to ensure compatibility. It would not be cost or time effective to test repaired from 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. Airbus Helicopter France owns all the proprietary data rights, specifications, testing and procedures to repair/ overhaul the listed items which have limited the USCG’s ability to provide adequate alternate procurement sources. Therefore, it is difficult to take steps to foster competition as the maintenance, data and repair criteria are proprietary to the OEM.

SIGNATURE AND TITLE OF CUSTOMER

Vernon L Clark

CODE

TELEPHONE NUMBER

(252)335-6641

DATE

10/07/20

SIGNATURE OF CONTRACTING OFFICER

Charles E. Leslie

CODE TELEPHONE NUMBER

DATE