S1.4d - JA 154' WPC Rudder Stock Seal Service Kit 70Z08025Q16006B00_Redacted.pdf

70Z08025Q16006B00 154’ Rudder Stock Seal Service Kit

6. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Require Use of the Authority Cited. The Defense Maritime Solutions, Inc. rudder seal service kits listed in this requirement are commercial items, comprised of multiple interrelated service, designed, and manufactured by Defense Maritime Solutions, Inc. The rudder seal service kits were procured as a whole and was originally described as such by the Government. Procurement was not based on Government specified descriptions of all the various components contained within; and the Government has not bought those descriptions from Defense Maritime Solutions, Inc.

Other than basic part/component descriptions (part numbers, etc.) provided by Defense Maritime Solutions, Inc., the Government does not possess descriptions adequate for procuring all the various rudder seal service kits full and open.

The use of rudder seal service kits not manufactured in accordance with OEM specifications, materials, tolerances etc. could cause equipment failure rendering an affected vessel unable to complete mission requirements. For the cutters to meet their mission requirements, the Coast Guard must maintain an aggressive part purchasing program. It is imperative that the Coast Guard work in partnership with the OEM, Defense Maritime Solutions, Inc., in providing rudder seal service kits to keep these vessels at their original operating capability. The actual equivalency of any non-Defense Maritime Solutions, Inc.

rudder seal service kits is not known, may not be easily determined, and the risk of accepting those rudder seal service kits without fully vetting their equivalence is unacceptable and may result in excessive cost to the Government, reduced reliability, reduced safety, and may hamper the Coast Guard mission requirements. Coast Guard policy requires vessel configuration management.

It is not uncommon for these vessels to experience heavy seas and extreme weather during normal operations. In these conditions, these vessels and crew are exposed to various conditions that could make their duties and environment unsafe or extremely difficult. The Defense Maritime Solutions, Inc. rudder seals service kits were designed and tested to meet vessel manufacturer requirements and specifications when the vessels were built. The failure of any of rudder seal kit would allow sea water into the engineering spaces. This failure could affect vessel propulsion, electrical power, and cause vessel instability. Since the 154’ WPC vessels operate in a wide variety of weather and sea state conditions and in close proximity of other vessels or fixed objects the loss of propulsion, electrical power or vessel instability could be catastrophic possibly causing injury or death to the vessel crew or persons being assisted, loss of property or damage to the environment.

All reproduction manufacturing drawings, specifications, and other technical data pertaining to the rudder seal service kits were not purchased when these vessels were fitted with these systems and are not available for use by the Coast Guard now. The Coast Guard does not possess the service manufacturing technical data required to obtain full and open competition. Further, the scope of manufacturing, special tools and equipment required to manufacture the various rudder seal service kits are unknown. The technical data that is needed is proprietary to the OEM.

. The use of OEM rudder seal service kits will ensure components and processes are sufficient to enable physical and functional interchangeability, as well as meeting source, size, configuration and performance requirements.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential

Sources as is Practicable. Pursuant to FAR Subpart 5.2, in an effort to solicit as many potential sources as practicable, a Sources Sought Notice was posted on SAM.gov from November 5, 2024 – November 19, 2024, requesting that parties express their interest in writing to the Contract Specialist. The vendors were asked to respond with a positive statement of their intent to submit a quote while documenting their ability to provide the required rudder seal kits. The notice was sent directly to Defense Maritime Solutions, Inc. on November 5, 2024. On November 5, 2024, BHPE LLC submitted an email expressing interest in the requirement. A follow-up email was sent to them on November 6, 2024, advising that their response did not include the necessary information specified in the notice.

They were advised to read the notice thoroughly and ensure that their response addressed all outlined items, but they did not respond. Defense Maritime Solutions, Inc was the only company found responsive to the notice. In an email dated November 14, 2024, they expressed their interest in the resulting solicitation and confirmed that there are no authorized distributors. The rudder seal service kits requirement was published in the Acquisition Planning Forecast System (APFS) on December 3, 2024, and updated on January 29, 2025 and March 6, 2025. No inquiries from industry were received.

8. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

9. Description of Market Research. Extensive market research as prescribed in FAR Part 10 was conducted by SFLC PBPL Equipment Specialists and the Contract Specialist (KS) from October 2024 through March 2025. Market Research has shown that the rudder seal service kits utilized on the 154’ WPC class vessels are only available from the OEM, Defense Maritime Solutions, Inc., who does not use distributors to sell these parts.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition. None.

11. A Listing of the Sources, if Any, that Expressed, in Writing, and Interest in the

Acquisition. A Sources Sought Notice was posted on SAM.gov on November 5, 20204, requesting that parties express their interest in writing to the Contract Specialist. The vendors were asked to respond with a positive statement of their intent to submit a quote while documenting their ability to provide the required rudder seal service kits. Defense Maritime Solutions, Inc., the OEM, was the only company found to be responsive to the notice.

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome

Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required. The USCG does not own the required drawings, specifications, or technical data to evaluate non-OEM rudder seal service kits and it is unlikely that Defense Maritime Solutions, Inc. will sell the data rights to the USCG or another company. Prior to subsequent rudder seal service kits acquisitions, the USCG will continue its attempt to obtain the applicable drawings, specification, etc. from the OEM and will conduct follow-up market research to determine the availability of distributors for Defense Maritime Solutions, Inc. products.