Streamlined Sole-Source Justification Memo 26-014 - C-17A Flight Deck Seat Cushions_FINAL.pdf

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Control Number: 26-014

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JUSTIFICATION AND APPROVAL (J&A) FOR OTHER THAN FULL AND

OPEN COMPETITION

REQUIREMENT: 167 OG - C-17 Flight Deck Seal/Bunk Cushions

ESTIMATED VALUE: $788,600.00

(1) Identification of the agency and the contracting activity, and specific identification of the document:

• Agency and Contracting Activity: Department of the Army

• Requiring Activity: National Guard Bureau (NGB) / 167th Airlift Wing (167 AW)

• Contracting Office: 167 MSG/MSC

• Document Identification: This document is a formal “Justification for other than full and open competition” submitted to the Command Advocate for Competition (CAFC) for approval.

(2) Nature and/or description of the action being approved:

Approval is requested to award a new, sole-source, firm-fixed-price (FFP) commercial contract to Coastal Seat Cushions (the sole authorized military distributor for Oregon Aero, Inc.) for the acquisition of proprietary Oregon Aero® C-17A Aircraft Seat and Bunk Cushions supporting the Air National Guard (ANG) Fleet.

(3) A description of the supplies or services required to meet the agency's needs (including the estimated value):

A. Aeromedical, Human-Performance, and Safety-of-Flight Background The Government’s requirement is not merely for replacement utility foam cushions, but for an engineered crew seating solution with documented human-factors and physiological performance. Published aeromedical literature establishes that prolonged constrained seating and whole-body vibration are significant occupational concerns for military aircrew, with low back pain prevalence rates reported between 50% and 92%. This directly impacts operational effectiveness, mission endurance, and flight safety.

The specialized nature of C-17A strategic airlift involves long-duration, high-tempo sorties where aircrew fatigue represents a primary operational risk. Therefore, the requiring activity has established a mission-essential need for a seating system that can demonstrably mitigate these physiological stressors and prevent physical cockpit degradation.

B. Commercial Product Determination Based on extensive market research and manufacturer published data (available at www.oregonaero.com), the requested C-17A seating, bunk, and cargo ramp systems are classified as Commercial Off-The-Shelf (COTS) products. Oregon Aero currently manufactures these specific part numbers for the commercial aerospace marketplace, where they are sold to the general public, allied foreign militaries, and domestic aviation agencies via published catalogs through their exclusive distributor, Coastal Seat Cushions.

Because these items are of a type customarily used by the general aerospace public and are offered for sale commercially without requiring major government-funded modification, they meet the definition of a commercial product under FAR Part 2.101.

C. Required Supplies and Estimated Costs The agency requires the procurement of the following Oregon Aero COTS seating systems:

http://www.oregonaero.com/

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National Stock Number (NSN) / Part Number

Description / Nomenclature Qty Estimated Cost

Estimated Total Cost

P/N: 6A-0140-1 or 31140- 1-A

C-17 Crew Cushion Set With Covers, Blue Fabric & Gray Wool.

Consists of Bottom and Back Cushion.

250 $1,640.00 $410,000.00

P/N: 31140-3-A C-17 Crew Bunk Cushion w/fabric 100 $2,425.00 $242,500.00

P/N: 6A-0152-1 C-17 CRACM Cushion Set w/Cover, Blue Fabric (3 piece).

Consists of Two (2) each Back Cushions and One (1) each Bench Cushion.

50 $2,375.00 $118,750.00

Total Estimated Value All ANG Cushion Requirements 400 — $771,250.00

Shipping Five (5) ANG Air Base Locations — — $17,350.00

TOTAL: $788,600.00

(4) An identification of the statutory authority permitting other than full and open competition:

This acquisition is conducted under the authority of 41 U.S.C. 1901, which authorizes the use of simplified procedures for certain commercial products and commercial services, as implemented by RFO FAR 12.102(b) and RFO FAR 12.201-1.

(5) A demonstration that the proposed contractor's unique qualifications or the nature of the acquisition requires using the authority cited:

A. Factor 1: Minimum Essential Agency Needs (Defined Specifications) To satisfy the Government's safety and human-performance requirements, any proposed seating system must provide documented evidence of performance. The minimum essential specifications for the three required components are defined as follows:

1. C-17 Crew Cushion Set (P/N 6A-0140-1 / 31140-1-A): Must absorb energy during hard landings or crash impacts to prevent spinal compression injuries, interface seamlessly with the C-17A’s existing cockpit seat frames without airframe modification and hold active military airworthiness certification.

o Documented Pressure Distribution: In a U.S. Air Force Research Laboratory (AFRL) human-subject study (AFRL-HE-WP-TR-2006-0163), the Oregon Aero prototype produced the largest average occupant contact area of all cushions tested: 236.3 in² (a 9.1% increase over standard operational cushions).

o Vibration Attenuation: A DoD evaluation demonstrated the Oregon Aero system reduced weighted vertical acceleration by approximately 36% and reduced dominant 16-Hz frequency acceleration by approximately 43% (p < .005).

o Required Durability: Upholstery fabrics must exhibit no significant wear or pilling when subjected to 100,000 8-Deck rubs via the Wyzenbeck method and must exhibit a minimum burst strength of 275 PSI per Federal Standard 191A-5122.

2. C-17 Crew Bunk Cushion (P/N 31140-3-A): Must fit the designated sleep/rest physical envelope of the C-17A crew bunk station, support proper physiological recovery during long-duration strategic

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missions, and utilize proprietary temperature-sensitive viscoelastic foam to mitigate aircraft engine vibration during crew rest cycles.

3. C-17 CRACM Cushion Set (P/N 6A-0152-1): Must be configured as a three-piece system (two back cushions, one bench cushion) compatible with the Cargo Ramp Crew Accommodation Module (CRACM) seat frame, providing critical impact absorption, posture correction, and safety compliance for personnel stationed in the cargo bay.

4. System Flammability: Core materials and cover fabrics used in the construction of all three systems must meet FAA Flammability requirements of 14 CFR 25.853(a).

B. Factor 2: Elimination of Alternative Supplies A sources sought synopsis (Special Notice W50S8V26Q0006) was published to identify alternative sources. One vendor, First State Manufacturing, responded; however, their standard utility foam products were evaluated and determined not to meet the salient technical characteristics for ergonomic support and vibration attenuation documented above.

Further market research confirms that other aerospace seating industry leaders (such as IPECO and Martin- Baker) build seating products based on conventional foam that do not utilize the specific, data-proven visco-elastic vibration damping required for this C-17A requirement. An alternative is not technically equivalent merely because it fits the seat pan; it must demonstrate comparable, documented performance in pressure distribution, vibration attenuation, and safety certification.

C. Factor 3: Single Source and Barriers to Competition Oregon Aero, Inc. is the sole manufacturer capable of producing these seat and bunk cushions because they possess the proprietary data rights, patented multi-material foam compositions, and established airworthiness certifications. The Government does not own the technical data rights or drawings required to manufacture or contract out these patented designs. Furthermore, Oregon Aero, Inc. maintains an exclusive distribution agreement and has designated Coastal Seat Cushions (operating as Coastal Aircraft Parts, LLC) as the sole authorized distributor. No other vendor can legally obtain or supply these certified products.

Attempting to develop a competitive alternative to Oregon Aero's commercially available product would result in an insurmountable barrier to competition due to massive duplication of costs and unacceptable mission delays:

• Time Analysis (Unacceptable Delay): A competitor would need to conduct basic R&D, prototype manufacturing, and extensive human-factors testing. Following development, the vendor would require an estimated 18 to 24 months to navigate FAA flammability testing and obtain DoD Military Safe-To-Fly certifications. By contrast, Boeing and NGBA4M have confirmed that no other formal approvals are required for the installation of these pre-approved Oregon Aero products as replacement items for the C-17A flight deck, CRACM, and bunk positions.

• Cost Analysis (Duplication of Cost): The cost of funding a competitor's non-recurring engineering (NRE), dynamic crash sled testing, and specialized aviation burn testing is estimated to exceed $450,000. The Government would indirectly bear this development cost, which heavily eclipses the entire $788,600 value of procuring the pre-certified commercial items.

D. Conclusion Accordingly, Coastal Seat Cushions (acting as the exclusive distributor for Oregon Aero, Inc.) is the only responsible source capable of providing the required C-17A flight deck, bunk, and cargo ramp seat cushions, and no other type of supplies or services will satisfy the agency requirements.

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(6) A description of efforts made to ensure that offers are solicited from as many potential sources as possible:

A sole source special notice (W50S8V26Q0006) was published to SAM.gov for 15 days on 3 April 2026 to ensure transparency, promote subcontracting opportunities, and evaluate if any other sources could meet the strict airworthiness, safety, and configuration requirements.

(7) A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer will determine that the anticipated cost to the Government is fair and reasonable prior to award in accordance with RFO FAR Part 12 and RFO FAR 15.4 pricing policies. The contractor’s proposed pricing will be verified against historical purchase contracts for Oregon Aero aircraft seat components, and through a review of the exclusive distributor's manufacturer-certified commercial price list.

(8) The market research conducted and the results:

Market research was conducted in accordance with FAR Part 10. A complete Market Research Report (MRR) was finalized in July 2026. This active market research confirmed that Coastal Seat Cushions, Inc., is the only source capable of satisfying the Government's highly specialized requirements without requiring prohibitive redesign, re-certification, and testing costs. No other commercial alternative meets the mandatory airworthiness, physical envelope, and dynamic impact performance criteria.

(9) Any other facts supporting using other than full and open competition:

• Safety & Supply-Chain Deficit: Denying this sole-source procurement would result in an immediate flight-deck equipment deficit for active ANG units. Forcing aircrews to operate with degraded, uncertified seat cushions poses an immediate physical safety risk and directly degrades mission readiness on long-duration strategic transport profiles.

• AFI & AMC Compliance: Fleet uniformity is mandated by Air Force Instruction (AFI) 63- 101/20-101 (Integrated Life Cycle Management) and Air Mobility Command (AMC) directives, requiring compliance with flight-deck equipment baselines certified under Technical Order (TO) 1C-17A-1 and TO 1C-17A-2-12 (Crew Accommodation/Furnishings).

(10) A listing of the sources, if any, that expressed an interest in the acquisition in writing:

One (1) vendor, First State Manufacturing, responded to the SAM.gov special notice. However, their standard utility foam product was evaluated and determined not to meet the salient technical characteristics for ergonomic support, vibration attenuation, and safety compliance documented in Section 5. Additionally, market research indicated that their product lacked the required USAF airworthiness certifications for C-17 flight-deck integration and has been documented to break down prematurely.

(11) A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition:

The strategy to increase competition for future requirements will align with the Small Business Innovation Research (SBIR) program. The agency will explore opportunities to fund conceptual designs that allow potential small business offerors to develop aircrew seat cushions equivalent to the Oregon Aero designs.

This strategy seeks to cultivate alternative certified sources, eliminating the long-term dependency on a single manufacturer once technical data rights can be established or replicated.

(12) Contracting officer certification that the justification is accurate and complete:

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.

Typed Name: RONALD R GLAZER, SMSgt Title:167 AS/Assistant Loadmaster Superintendent

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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.

Typed Name: CHRISTOPHER P. BROSCHART, 2d Lt Title: Base Contracting Officer, 167th AW

CONTRACTING OFFICER (KO) CERTIFICATION & CONCURRENCE:

I certify that this J&A is accurate and complete to the best of my knowledge and belief. I concur and recommend forwarding to the CAFC for final approval.

Typed Name: CHRISTOPHER P. BROSCHART, 2d Lt Title: Base Contracting Officer, 167th AW

COMMAND ADVOCATE FOR COMPETITION (CAFC) APPROVAL:

Based on the authority of 41 U.S.C. 1901, as implemented by RFO FAR 12.102(b), and having given due consideration to the facts and justifications presented above, I hereby approve this streamlined sole-source justification for the acquisition of C-17A Flight Deck Seat Cushions.

Typed Name: Jamaal K. Valentine Title: Command Advocate for Competition (CAFC)