USCG JA for G700 Final CPO signed 10.6.2025 redacted.pdf

Commandant, US Coast Guard (CG-AIR-C) 2703 Martin Luther King Jr. Ave SE, Stop 7828

Washington, DC 20593-7828

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

10 U.S.C. § 3204

G700 Long Range Command and Control Aircraft (LRCCA)

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.103 (FAR Class Deviation 25-11) and in accordance with the requirements of FAR 6.104 (FAR Class Deviation 25-11), the justification for the use of the statutory authority under FAR 6.103 (FAR Class Deviations 25-11) is justified by the following facts and rationale required under FAR 6.104-1 (FAR Class Deviation 25-11) as follows:

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG) Headquarters, Assistant Commandant for Air (CG-AIR), Washington DC, proposes to enter into a contract on a basis of other than full and open competition.

2. Nature and/or Description of the Action being Approved.

(a) Nature of the Action: USCG intends to procure two (2) G700 aircraft with related supplies and services, from Gulfstream Aerospace Corporation (Gulfstream) on a sole source basis. The Long Range Command and Control Aircraft (LRCCA) and related supplies and services delivery are required on or before 31 December 2025.

(b) Name and Address of The Contractor:

Gulfstream Aerospace Corporation 500 Gulfstream Rd.

Savannah, GA 31408-9643

(c) Type of action: Firm-Fixed Price (FFP) Contract

(d) Estimated Total Value: The estimated dollar value of this procurement is .

per G700 per aircraft for paint, Starshield installation, cabin refresh/modification, secure communication requirements, and initial parts sparing.

(e) Type of Funding: Procurement, Construction, and Improvement (PC&I) available for obligation for up to five (5) years after appropriation.

(f) Year of Funding: Fiscal Year 2025

(g) Background Information About the Requirement: The Coast Guard currently operates two (2) LRCCA aircraft out of Air Station Washington, DC located at Ronald Reagan Washington National Airport. One LRCCA (C101) is a Gulfstream V aircraft (military designation C-37A) owned by USCG since 2002. This aircraft, aged 23 years, is currently facing increasing obsolescence and maintenance costs commensurate with an aging aircraft and operating beyond the 20-year structural warranty provided by Gulfstream. The second LRCCA (C102) procured under Contract No.

70Z02321FLRC00100 is a Gulfstream G550 / C-37B variant purchased by USCG in FY2020. The C-37B is the well-established military adaptation of the G550. The G550 with over 600 aircraft in operation is no longer in production, therefore the USCG is looking to increase range and capability of the LRCCA fleet transitioning to the G700.

The USCG intends to purchase additional LRCCAs in support of long-term investment and expanded needs that are not suitable for shorter range aircraft. The G700 is currently in production and evaluated to recapitalize and expand the CG fleet.

3. Description of Supplies/Services.

The LRCCA fleet operates to ensure Department of Homeland Security (DHS) and USCG’s operational commanders can address key mission requirements across domestic and international areas of responsibility, including reliable access to secure communication suites during principal movements. Similarly, the aircraft provide the capacity to respond quickly to emergent contingent conditions at all times and serve as a highly capable platform that extends the reach and effectiveness of the Coast Guard across a wide range of critical missions and safeguarding national interests. Functionality includes secure and non-secure airborne communications, seating for staff / security details, and connectivity to perform coordination and administrative duties while airborne. The requirement is to purchase two (2) Gulfstream G700 aircraft inclusive of next generation satellite connectivity and support services including training, specialized paint, cabin enhancements, secure communication integration, and initial parts/technical modifications.

4. Identification of Statutory Authority Permitting Other Than Full and Open

Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C.

3204(a)(1), as implemented by the FAR Subpart 6.103-1 (FAR Class Deviation 25-11), entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

Specifically, FAR 6.103-1(c)(2)(i) apply whereas continued provision of highly specialized services to avoid

(A) Substantial duplication of cost to the Government that is not expected to be recovered through competition; and

(B) Unacceptable delays in fulfilling the agency’s requirements.

5. Identification of Exception to the Buy American Act.

Not applicable.

6. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Require Use of the Authority Cited.

Award to any other source or introducing a different aircraft Original Equipment Manufacturer (OEM) to the LRCCA mission would result in both substantial duplication of cost to the Government and unacceptable delays in fulfilling the mission.

The USCG currently owns and operates two (2) LRCCA Gulfstream aircraft (GV and G550), which have been modified and equipped to USCG missionization requirements. The Coast Guard has also utilized Gulfstream aircraft (leased or owned) for the LRCCA mission for several decades, investing an for infrastructure (hangar, maintenance and supply facilities, offices), logistics (inventory and configuration management, supply chain management, operational and technical data, operations), pilot and aircrew training, and maintenance and servicing equipment to supporting Gulfstream LRCCA aircraft since 2005.

The upgrade to an in-production platform has proved necessary to meet the requirements of the LRCCA mission. While a platform upgrade necessitates the establishment of a new branch of logistical support, logistical pipelines with the OEM are already in place, along with established contract vehicles to facilitate and streamline the process. To minimize downtime and ensure mission readiness, logistical support through our current OEM is the most efficient path. This approach leverages existing G550 support frameworks and requires the shortest transition period to reassess the additional scope of personnel, supply support, support equipment, and facilities for the two (2) G700s, while leveraging efficiencies between the G550 and the G700. This will significantly reduce the transition period for both operators and maintainers compared to establishing support with a new OEM, which would take significantly longer to get on contract.

A period of having dissimilar aircraft is necessary when recapitalizing the LRCCA fleet.

Much of the burden has already been mitigated by adding pilots, maintainers and support staff to meet growing mission needs. A study done in 2015 by the Coast Guard Office of Aviation Forces (CG-711) identified the weaknesses during a recapitalization period.

Operating dissimilar aircraft for a prolonged time is not recommended and historically has created several resource-intensive challenges such as standardization, proficiency, logistics, infrastructure, staffing constraints, and aircrew staging for worldwide deployments. While these challenges do exist, the USCG is able to mitigate with proper planning and continued business with Gulfstream Aerospace Company (GAC).

Procuring directly from the OEM, Gulfstream, is the only viable path to meet the aggressive delivery schedule, which does not permit delays to account for a newly built aircraft off the production line, as that can take up to 1.5 years. Gulfstream currently possesses the requisite number of aircraft ready to sell and are able to meet the aircraft modification requirements, moving rapidly while ensuring the most advantageous cost and technical solution. Procuring G700s directly from the OEM with certified cost and pricing data ensures price stability and avoids the challenges of cost duplication and fair market value uncertainties inherent in the volatile used aircraft market. This ensures direct access to proprietary technical data, and optimal warranty and post-delivery support. No other source, including authorized resellers, possesses the inherent ability to control the schedule, technical modifications, and delivery timeline with the same precision and speed as Gulfstream within the required timeframe.

The USCG remaining with Gulfstream and procuring an in-production aircraft with increased range and capability provides the most overall benefit to the Government by continuing to leverage existing USCG and Department of War (DoW) logistics footprints, while growing to meet the requirements of DHS. While the G700 remains in production, the aircraft benefits from the latest technological advancements and ongoing support from the OEM, with a structure warranty included for an estimate of 20 years. The G700 provides a combination of increased range, speed, seating capacity, and enhanced avionics in comparison to a used G550. While a G550 is capable, it is no longer in production and USCG is at the mercy of the re-sell market to grow the LRCCA fleet in the required time.

Gulfstream's resources, including prior support in building and converting the C102, reduces performance risks. With Gulfstream currently supporting the DoW and their service leaders, this reduces the Government’s risk by utilizing a trusted OEM and continued logistic support provider, reducing the potential associated costs to the Government to recreate the support systems in a time sensitive environment.

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

Many Potential Sources as is Practicable

The Coast Guard has conducted market research soliciting information from several vendors in the form of a Request for Information (RFI) for a used G550, leasing a G550 and G650, engaging with industry respondents and through the commercial market with brokers and determined there is no viable option other than Gulfstream available to meet new mission requirements and timelines. The acquisition of two (2) G700s will be executed through a sole source contract with Gulfstream for the procurement of (2) G700 aircraft with related supplies and services to ensure DHS and Coast Guard needs are met within the required timeframe.

8. Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable.

The Contracting Officer will determine that the price is fair and reasonable in accordance with techniques as specified in FAR Part 15, to include analysis of proposed prices against the Government’s independent cost estimate, comparison of the proposed price to historical prices paid by other Government agencies and other commercial entities for the same or similar aircraft, or use of the remaining techniques outlined in FAR Part 15 as appropriate.

9. Description of Market Research.

Pursuant to FAR Part 10, the USCG conducted market research, finalized in October 2025. As detailed in paragraph 7 above, the USCG conducted outreach with industry.

While the USCG received responses from industry, only one vendor meets applicable USCG security requirements (e.g. not of foreign registry, configuration or connectivity suitable for required secure communications), timeline, and USCG specific modifications due to their familiarity with their proprietary data on C102 which we are recapitalizing. A rapid procurement of the two (2) G700s will allow the Service to meet rising mission demands, posture for additional required users, and plan for the divestiture of the Service’s oldest C-37.

Gulfstream (as the OEM) is the only vendor capable of acquiring G700s under a secure, strict, and time-sensitive process. DHS and USCG require exacting follow-on cabin refresh, next generation satellite connectivity, and open the potential for a secure command and control communications suite to replicate capabilities of the C-37B. Any effort to divide purchase and integration of secure command and control suite among separate companies would incur undue cost and schedule increases, as well as security concerns.

Based on USCG’s market research, USCG does not find any source besides Gulfstream capable of providing an aircraft to meet USCG specific requirements and expedited timeline. Any aircraft purchased will have to be inspected by a Gulfstream certified Maintenance Repair and Overhaul (MRO) to determine the airworthiness of the aircraft in addition to the required modifications that rely on the preexisting proprietary data Gulfstream owns exclusively. This relieves the Coast Guard of any pass through and provides cost and time cutting to the aggressive schedule and modification.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

Competition is neither available nor feasible for this requirement. Procuring directly from Gulfstream, the OEM, is not merely the preferred path, but the sole viable means to meet the highly aggressive delivery schedule. Gulfstream is uniquely positioned as the only source capable of providing the required platform, with its integrated systems and proprietary modifications, within the critical timeframe without incurring unacceptable delays or compromising the technical integrity of the solution.

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

Acquisition.

Not applicable.

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 executive aircraft manufacturing market is highly competitive, and the upfront cost associated with manufacturing new executive aircraft creates a barrier to entry. Previous efforts by the Government to acquire rights to the design of a secure command and control communications suite installed in the C-37B from Gulfstream for separate production measures have been unsuccessful. The USCG does not possess the technical data required to manufacture the G700. Therefore, the USCG will ensure to compete future actions to the maximum extent practicable within the LRCCA program requirements. While the contract is ongoing, USCG will continue to explore options and engage with the aviation industry to make parts of the requirement available for competition including further discussions with Gulfstream on the acquisition of its data rights for the C-37B configuration.

13. Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Date Contracting Officer

14. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Chief Acquisition Officer

RECOMMENDED FOR APPROVAL

Procuring Activity Advocate for Competition (PAAC)

Head of the Contracting Activity (CG-HCA)

APPROVAL:

Chief Procurement Officer