REDACTED Limiting-Competition.docx

Control No: AP61B1-4089-4168

CUI

Memorandum for Record – Limiting Competition at or below the Simplified Acquisition Threshold

1. Contracting Activity: Army Contracting Command – Redstone Arsenal – Corpus Christi Army Depot, Contracting Office (CCAM-ALC) 9035 Ocean Dr. Bldg. 10, Mail Stop 18 Corpus Christi, TX 78419-5260.

2. Description of Action:

Nature: New Requirement Follow-on Requirement

Order #_______ against a single award IDC Contract Modification # _______ to existing PO/TO/DO/Call Order #________________

Pricing/Contract Type: Fixed Price Time & Materials/Labor Hours Cost Reimbursable Hybrid

Funds: Operations & Maintenance, Army (OMA) Other Funds: Army Working Capital Funds FY: 2024

Name of Proposed Contractors and Addresses:

IGCS International (Cage:6SPP7 – Small Business) 1608 Covered Brg.

Gunter, TX 75058-4237

SOL Aerospace (Cage:9FEK9 – Small Business) 100 Duffy Avenue, STE 510 Hicksville, NY 11801-3636

Pacific Coast Composites (Cage:3A4X2 – Small Business) 418 Valley Ave NW, STE 115 Puyallup, WA. 98371-3312

Brand Name Buy: Yes No

3. Description of Services or Supplies: 3M Scotch Positioning Fabric AF 3306-2, 1 Roll.

Delivery Date: 30 Days ARO Total Value:$

4. Authority: FAR 13.106-1(b)(1): For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

5. Reasons for Authority Cited:

This is a Brand Name requirement for 3M Scotch-Weld Positioning Fabric Style AF-3306-2. In accordance with Sikorsky drawing SS8613 (retained in the contract file and not authorized for distribution outside the DoD and authorized DoD Contractors), 3M products that have been tested and have passed the qualification tests as defined by Materials and Process Engineering and have been listed in the Qualified Products List in said drawing. Qualification data shall be provided only with the consent of Sikorsky Aircraft Materials and Process Engineering. A supplier shall not supply production material until listed on the QPL.

In addition, the 3M Scotch-Weld Positioning Fabric Style AF-3306-2 is the only authorized positioning fabric for use on main rotor blades for Sikorsky helicopter platforms, which is a Critical Safety Item, meaning a failure of the blade is likely to lead to loss of aircraft and crew.

Since the 3M Scotch-Weld Positioning Fabric Style AF-3306-2 is an authorized Brand for a Critical Safety Item, no other Brand or item would be authorized for use on the Main Rotor Blades.

6. Publicizing Contract Actions: For FAR Part 13 actions, the public display and synopsis requirements of FAR 5.101 and FAR 5.203 apply and will be followed.

Requirement to post justification in accordance with FAR 8.405-6(b)(3), FAR 13.105(c), or FAR 16.505(a)(4)(iii)(A) Action is NOT a brand name restriction and is under $150K, no posting required Action is a brand name restriction, under $25K, no posting required Action is a brand name restriction, over $25K. It will be redacted and posted with the solicitation.

Action is a brand name restriction over $25K but will not be posted due to exception:

FAR 8.405-6(b)(3)(iii)(B)

7. Market Research:

Sarah Robertson, Purchasing Support Strategy Branch – October 2023 through December 2023, Terry Clark, Contract Specialist – April 2024

Contact with knowledgeable persons in Government and/or industry regarding the commercial nature of this requirement and/or standard industry practice in this area of supplies/services. From October 2023 to December 2023, Ms. Robertson emailed various 3M distributors, inquiring about availability of the required item. Pacific Coast (PC) Composites (small business) (michael@pccomposites.com) and R.S. Hughes (large business) responded with quotes via email.

Publication of a formal request for information. On 24 April 2024, the Contract Specialist posted a source sought on SAM.GOV through 02 May 2024. On 30 April 2024, IGCS International, a small business, provided a quote for the AF-3306 aircraft material. On 2 May 2024 Liliana Ortez from Sol Aerospace, a small business, sent an email showing interest.

Review of Government and/or commercial databases for relevant information.

Ms. Robertson researched the following databases:

LMP – Oct 2023 – Dec 2023 (Non-Provisioned unable to order within LMP) FEDLOG- Oct2023 - Dec2023 (non-provisioned) GSA- Oct2023 – Dec 2023 (Unable to locate material in GSA)

Ms. Clark reviewed the 3M Distributer List in April 2024.

8. Other Facts: N/A

9. Technical/Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Equipment Specialist

10. Contracting Officer Certification/Approval:

I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable based upon price analysis.

I certify that this justification is accurate and complete to the best of my knowledge and belief, and that completing this purchase as a sole source is in the best interest of the Government. Additionally, I approve this justification to limit competition subject to the availability of funds and provided that the services or supplies herein described have otherwise been authorized for acquisition.

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