Redacted JA - 70Z03822QB2000185.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

NUMBER

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 for the procurement of spare piece part components on a sole source basis utilized on the MH-65 helicopter.

BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED, AND THE INTENDED USE. This procurement is for the following spare parts utilized on the MH65 helicopter: Fourteen (14) Magnetic Plugs, (P/N:365A32-7701-00, NSN:5340- 14-465-2920), Twenty (20) Hinge, Fwd, RH, (P/N:365A24-1176-01, NSN:1560-14-386-1457), Two (02) LH Fitting, (P/N:366A69-1017-20, NSN:1560-01-HS1-8948) and Five Backing Plate, (P/N:365A81-2141-01, NSN:4820-01-HS1-8862).

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(s) of supply known to have the capability of furnishing the required supplies. The piece parts referenced are manufactured by the aircraft Original Equipment Manufacturer (OEM) Airbus Helicopters (CAGE Code F0210). The USCG has determined that, since the aircraft OEM does not distribute or sell directly in the US, the piece parts referenced in the schedule can only be procured from the OEM’s only authorized US based affiliate, Airbus Helicopters, Inc. (CAGE Code 3GSZ1), which is not the manufacturer, and is the only USCG approved source of supply. 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 procured under this acquisition are highly specialized parts, designed and manufactured by a non-Government activity specifically for the USCG G366 platforms Reduction Gear and Cabin Door Assemblies. The only manufacturer of the listed component is Airbus Helicopters (CAGE Code F0210) and the only approved source of supply is Airbus Helicopters, Inc. (CAGE Code 3GSZ1). Procurement of any parts from other than the OEM or an OEM approved source could 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 schedule items are key components utilized on the MH-65 helicopter platforms. The part numbers provided are the OEM’s part number. As such, alternate part numbers are not acceptable nor authorized for use on the USCG G366 platforms cabin door assemblies. Accepting alternate part numbers at this time could cause catastrophic consequences should the required piece parts fail during flight operations, should specification inadequacies occur during manufacture. The USCG neither compromises nor makes exceptions in matters of safety and protection of Government property, nor does it accept lower standards in these matters. All parts shall be new and traceable to the OEM. Use of OEM parts ensure the parts manufactured are accordance with OEM specifications and standards. They conform to original form fit function requirements, and are compatible/ interchangeable with higher assembly components.

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 USCG did not purchase data rights as part of the initial system acquisition of the G366 platforms. The required specifications of suitable alternate piece parts would not be sufficient for source selection. After receiving responses from the solicitation, extensive exclusive testing and evaluation involving interaction with the aircrafts door assemblies would have to, be completed to ensure compatibility. It would not be cost or time effective to test spares 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. The Aircraft OEM owns the proprietary data rights, specifications, drawings, and manufacturing procedures to the listed items, which has 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 maintenance, data and repair criteria are proprietary to the OEM.

SIGNATURE AND TITLE OF CUSTOMER

CODE

TELEPHONE NUMBER

DATE

SIGNATURE OF CONTRACTING OFFICER

CODE TELEPHONE NUMBER

DATE