Redacted JA- 70Z03821QB2000018.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

PROJECT/TASK

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

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 repair spare parts on a sole source basis utilized on the MH-65 helicopter. The statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c) (1); FAR 6.302-1.

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE. This procurement is to repair: Sixty (60)

Oil Cooler (P/N: 53139, NSN: 2930-12-348-4886) with an Optional Quantity of Sixty (60) 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 known to have the capability of repairing the scheduled parts back to original equipment manufacturer (OEM) specification. The USCG has determined that these parts can only be repaired directly from an OEM approved repair facility, which is not the manufacturer. The Government does not have the adequate data or lacks right 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 services to be procured under this acquisition are highly specialized parts, designed and manufactured by a non-Government activity and the technical data required for acquisitions by other than the OEM or an OEM approved source are not available. Mahle Industrial Thermal Systems

GMBH & CO. Germany (Cage Code: D8093) is the OEM and has only authorized Drake Air Inc. as their only US based source of supply and is the only source that the USCG has authorized for past repairs. Soliciting to other than the USCG approved repair source will compromise the safety of the aircraft and the crew.

their only US based repair facility(Cage Code: 0GDJ0) as their authorized US repair facility. The USCG uses past performance history and Inventory Locator Service (ILS) Mart to seek available sources.

REASON THAT SUGGESTED SOURCE IS THE ONLY SOURCE WHICH CAN PROVIDE THE SUPPLIES OR SERVICES. The repair services and procedures for the parts identified in this requirement are proprietary to the OEM Mahle Industrial Thermal Systems

GMBH & CO. Germany (Cage Code: D8093) and they have only authorized Drake Air as their only source qualified to fulfill this requirement. As they are the only US based repair facility with the proprietary data from the OEM required to perform the work, the technical expertise to interpret the data, and the ability to solve technical problems, all of which are vital for the continue operational readiness of the aircraft. However, the USCG will be accept quotes for these items from the OEM and any OEM approved authorized repair facility.

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 helicopter. The USCG does not possess adequate technical descriptions to provide to potential new sources and is unable to provide proprietary repair information to outside vendors. This information must be obtained directly from the OEM. Due to the maturity of the HH65 platform, the cost to procure data rights, presuming they would be made available, would be cost prohibitive.

PROVIDE A STATEMENT OF ACTIONS, IF ANY, THE GOVERNMENT MAY TAKE TO REMOVE OR OVERCOME ANY BARRIERS TO

COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED. Because the necessary data rights to repair this item is proprietary to the OEM the government has not been willing to bear the cost of procuring the necessary OEM data for this service, USCG ALC SRR still continues to check maintenance and repair web-based subscription services, alternate approved systems, industry periodicals, industry periodicals, and sends representatives to various trade show and conference to seek out all possible legally achieved service option and source.

SIGNATURE AND TITLE OF CUSTOMER

CODE

TELEPHONE

DATE

August 2020

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE