REDACTED LSJ.rtf

Control No: CCAM-LSJ24-1912

Version – February 2017

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

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

Description of Action: This is a non-personal services contract to provide liner replacement for the non-rotating control swashplate P/N 7-311527061.

Nature: Follow-on Requirement Contract Vehicle: Purchase Order Number to be determined Pricing/Contract Type: Firm Fixed Price Funds: Army Working Capital Funds FY: 2025

Name of Proposed Contractor(s) and Address:

Sargent Aerospace & Defense, LLC (Cage Code 97613 – Other Than Small Business) 5675 W. Burlingame Road Tucson, Arizona 85743-9453 Brand Name Buy: No Description of Services or Supplies: Service contract for the replacement of liner bearings in the Non-Rotating Control Swash Plate P/N 7-311527061 in support of the Rotor Control Branch (J3P63B4).

Period of Performance: 12 Months Total Value:

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.

Reasons for Authority Cited:

Request the Sole Source purchase of liner bearing replacement and reapplication of Dicronite, for Directorate of Accessories and Rotor Blade Production. The recommended source is Sargent Aerospace & Defense, LLC (Cage Code 97613), 5675 West Burlingame Rd, Tucson, AZ 85743.

This liner replacement is based on DMWR 1-1615-315 requirement for original equipment manufacturer (OEM) (Sargent Aerospace & Defense, LLC (Cage Code 97613)) to perform the process. Dicronite application is a proprietary process and Corpus Christi Army Depot (CCAD) does not have the ability or technical data to execute as Sargent Aerospace & Defense is the OEM.

If not approved the overhaul of AH64 swashplates cannot commence as this is a mandatory replacement item. This may lead to CCAD not acquiring the current available workload. Buy vs repair variance is over $9,000 per asset.

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. This justification will be published with the solicitation.

Market Research: Market Research was performed by Carlos Caba, Contracting Officer Representative, Purchasing Support Strategy Branch / Material Support Strategy Division, on July 2024 and Terry Clark, Contract Specialist, ACC-RSA CCAM-DSC, on 04 September 2024.

Carlos Caba has been developing contract requirements packages and managing contracts of this nature since 2018 for CCAD. Mr. Caba has developed and managed the last three contracts for this same requirement: W912NW22P0079 awarded 25 August 2022, W912NW23P0023 awarded 29 December 2022 and W912NW-24-P-0019 awarded 17 January 2024.

On 12 August Carlos Caba, Contracting Officer Representative contacted Aircraft Maintenance Engineer, Richard Medrano to provide alternate approved source of supply for the liner repair. Mr. Medrano confirmed Sargent was still the only approved source. Mr. Caba also contacted the following individuals:

Danh Nguyen - Quality Assurance Specialist, CCAD - 8/6/24 Eric McDade - Product Manager, Aerospace & Defense - 8/1/24 Justin Cook - Industrial Engineering Branch Chief - 8/6/24

Through market research Mr. Caba confirmed that DMWR 1-1615-315 mandates the swash plate requires replacement by Original Equipment Manufacturer (OEM) of self- lubricating liner systems. The liner system qualified for use in this assembly is KAHR- LONX-1200S and is manufactured by OEM cage code 97613 (Sargent Aerospace & Defense).

Mr. Caba reviewed the contractor’s website; www.sargentaerospace.com - July 2024.

SAM.gov - July 2024 used to verify cage code: 97613, LMP: July 2024 used to look up document numbers W45N7V425200LP and W45N7V229801S7 as reference points for 2110s (funding documents). Depot Maintenance Work Requirement (DMWR) 1-1615-

315. July 2024.

Mr. Caba performed market research and states the DMWR 1-1615-315 states original equipment manufacturer (OEM) of self-lubricating liner system must be used. Inputting cage code into FEDLOG shows Sargent Aerospace & defense as the OEM, July 2024.

On 04 September 2024 the contract specialist reviewed PCF with the last three contracts for the same item awarded to the same sole source contractor Sargent Aerospace & Defense, LLC.

On 13 September 2024 the contract specialist posted a source sought on SAM.GOV. Two companies showed an interest in this requirement, BHPE LLC. (Cage code: 9SWS7, Small Business) and Federal Government Contractors LLC. (Cage code: 9MCL9, Small Business). However as stated above, DMWR 1-1615-315 mandates the swash plate requires replacement by Original Equipment Manufacturer (OEM) of self-lubricating liner systems Mr. Caba performed market research in the following databases:

www.sargentaerospace.com - July 2024 SAM.gov - July 2024 used to verify cage code: 97613 LMP: July 2024 used to look up doc #s W45N7V425200LP & W45N7V229801S7 as reference points for 2110s Depot Maintenance Work Requirement (DMWR) 1-1615-315. July 2024 Sole Sourced to:

Sargent Aerospace & Defense, LLC (Cage Code 97613 – Other Than Small Business) 5675 W. Burlingame Road Tucson, Arizona 85743-9453 Other Facts: Past contracts for swashplate liner replacement have been sole sourced to Sargent Aerospace & Defense LLC (CAGE 97613): W912NW23P0023, W912NW22P0079, and W912NW-24-P-0019.

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.

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.

Contracting Officer