Redacted JA 70Z03821QB2000081.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 parts on a sole source basis utilized on the MH-65 helicopter.

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

This procurement order is for the following parts to be utilized on the MH65 helicopter: Twenty Five (25)

RH Lower Fire Wall (P/N 366A08-0554-11) NSN: 1560-01-HS1-8997 and Twenty Five (25) RH Inner Fire

Wall (P/N: 366A08-0554-13) NSN: 1560-01-HS1-8995

Requesting an optional quantity of Thirty-Five (35) each for RH Inner Fire Wall (P/N 366A08-0554-13) NSN:

1560-01-HS1-8995 and optional quantity of Twenty-Five each for RH Lower Fire Wall (P/N 366A08-0554-11)

NSN: 1560-01-HS1-8997

UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON NO OTHER SUPPLIES

OR SERVICES CAN BE USED.

This acquisition is required to the only source(s) of supply known to have the capability of repairing the request spares. This Fire Walls is used on the engine components specific to the MH65E aircraft. No alternate part numbers are acceptable. The technical data required for acquisition by other than the Original

Equipment Manufacturer (OEM) or an OEM approved source is not available.

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 under this acquisition involves 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. Airbus Helicopters France (F0210) is the OEM for the

H-65 helicopter and the prime contractor for the parts under the requirement. However, they do not overhaul or repair these items. The only known approved source of repair that the U.S. Coast Guard has authorized for the repair is Western Aerodynamics, Inc. Cage (3Q596). These parts are repaired by Western

Aerodynamics Inc. Cage (3Q5P6). The solicitation and resulting repair 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 incorporated on the resulting purchase order.

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

Western Aerodynamics, Inc is the suggested source of supply for the repair of the parts on this requirement based on the fact that they are an OEM approved repair source and can repair the parts in accordance with

OEM specifications. Western Aerodynamics, Inc is the only source of supply that the USCG has utilized for the repair of the parts on this requirement in the recent past.

August 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 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

CODE

TELEPHONE

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE

DATE