A, Neptune Rate Sheet. By contrast, Neptune did not provide any detail with its cost projections to RUS, so it is unclear if fuel is included, or if government reimbursement is considered. Id. Neptune and the Forest Service had significant communications during the period between when Neptune learned it would not receive a NextGen contract and Neptunes receipt of a sole-source contract. at 439-41. With our proprietary technology, multiple aircraft types, and highly experienced attack crews we can fight fires on multiple continents simultaneously. AR, Tab 73, GAO Confirmation of Withdrawal (B-406920.8), June 7, 2013. . See e.g., AR, Tab 84, Forest Service Letter to Aero-Flite, Dec. 12, 2013. 29 Sep 1995. E: cg@coulsongroup.com and the results or a statement of the reason market research was not conducted. FAR 6.303-2(b)(3), (5), (8). CICAs overriding mandate is for full and open competition in government procurements, obtained through the use of competitive procedures. 4 C.F.R. While it was conducting the NextGen large airtanker procurement, the Forest Service also awarded a number of Legacy contracts for large airtanker services. Quite simply, the existence of a settlement agreement does not permit a contracting agency to act in ways not otherwise permitted by applicable statutes and regulations. The fourth jet is awaiting delivery. There are 6 older and 13 younger executives at OTC Markets. Winglets installed 2008. In addition, it offers OTC Disclosure & News Service for publishing and distributing data, news, and financials; Real-Time Level 2 Quotes that gives investors access to real-time bid- ask information and depth of book; Blue Sky Monitoring Service for analysis, review, and guidance about a company's compliance with the United States securities laws; and Virtual Investor Conferences, which allows issuers to communicate and engages with investors, as well as operates the OTCQX Best Market OTCQB Venture Market, and Pink Open Market. On June 3, RUS provided USDA with its financial viability review of Neptune. The protesters argue that the sole-source contract awarded to Neptune, which was promised in exchange for Neptunes withdrawal of an earlier bid protest, is not justified. 21.0(a)(1), 21.1(a) (2013); Cattlemens Meat Co., B-296616, Aug. 30, 2005, 2005 CPD 167 at 2 n.1. AR, Tab54, Neptune Contract No. Earth Prop. [31] The agency points to the fact that the NextGen contracts include exclusive-use restrictions, such that the large airtankers that Coulson and Minden each already have under NextGen contract cannot also be offered to meet additional agency requirements. Coulson Aviation (USA) Inc.; 10 Tanker Air Carrier, LLC; Minden Air Corp. Subsequently, the Forest Service amended the NextGen solicitation and received revised proposals from offerors. AR, Jan. 31, 2014, at 2526; Tab 1, FAM Director Declaration, Jan. 28, 2014, at 7; Tr. Get the latest business insights from Dun & Bradstreet. AR, Tab 144, RUS Email to USDA, June 3, 2013. (i) To maintain a facility, producer, manufacturer, or other supplier available for furnishing supplies or services in case of a national emergency or to achieve industrial mobilization. 1 The average fleet age is based on our own calculations and may differ from other figures. Id. 001, May 15, 2013, at B-21. at 2, 4. As stated above, our review of an agencys decision to conduct a noncompetitive procurement focuses on the adequacy of the rationale and conclusions set forth in the J&A. The SPE was not the only agency official providing advice to the ASA. Crocker Coulson is a 53-year-old Brooklyn resident, Yale graduate, former Fulbright scholar, father, and ex-husband. As detailed below, the Forest Service entered into a settlement agreement with Neptune on the basis that the award of a sole-source, NextGen-type contract was necessary to maintain Neptune as a vital source of large airtankers. Pentagon announces Coulson Aviation is awarded a $53 million CDN contract with the U.S. Department of Defense to equip seven Lockheed Martin C-130 aircraft with firefighting equipment. Your email address will not be published. We find this argument to be entirely without merit, and the reliance on FAR 6.304(d) misplaced; an accurate description of the services being obtained on a noncompetitive basis is not limited to the options that must be included when determining the J&As approval authority. The aircraft climbed out of the area and returned to its base at 3:08 pm, after descending once over the fire zone. Noncompetitive awards should be limited to only what is needed to achieve the objective, in this case to maintain a vital source of supply . Tr. The J&A also stated that the agency took into account alternative resources, and found there were no certified large airtankers currently available that were not already under contract with the Forest Service capable of meeting NextGen contract requirements. In this case, we have a competitive field and recently awarded multiple contracts on a competitive basis to five firms from a pool of eight firms that submitted proposals on the solicitation. The RUS also questioned whether Neptune had the ability to modify the payment terms of any of its existing long terms debts. T-137 was purchased in May 2019 by the NSW Rural Fire Service along with the two Coulson Citation II C550 support jets. at658), the agency acknowledges that the 9-year, sole-source contract awarded to Neptune was based on the industrial mobilization exception to CICA. Coulson Group April 10, 2022. By contrast, the second analysis conducted by FI--which did not simply accept Neptunes projections--found that Neptunes revenue projections were inconsistent with the terms of the Legacy contract, that Neptunes expected costs were lower than the company had itself projected, and that Neptune did not require a NextGen contract to remain viable through the term of the Legacy contract. In this regard, the protesters claim that the agencys actions have been motivated by the desire to fulfill the terms of a settlement agreement and to avoid a lawsuit by Neptune for allegedly breaching that agreement. [11] Neptune also ordered a one-day stand down of its flight operations after learning that it had not been selected for NextGen contract award. Based upon on our review of the record, including the J&A, its supporting documentation, the agencys submissions in response to these protests, and the testimony of the agencys representatives at the hearing held at our Office, the agency has failed to demonstrate that Neptune requires a sole-source contract to remain a source of large airtanker services for the Forest Service. Consequently, the agency argues, the J&A was not grounded on the agencys belief that Neptune would immediately go out of business without a NextGen contract, but was based on its concern with Neptunes continued availability as a large airtanker supplier after 2017 when its Legacy contract expired. Coulson Aviation Usa doesn't have any recent trademark applications, indicating Coulson Aviation Usa is focusing on its existing business rather than expanding into new products and markets. AR, Tab 143, Forest Service Large Airtanker Modernization Strategy, Feb. 10, 2012, at 2. Although the J&A supported an award of two NextGen large airtankers for up to 9 years at a total estimated cost of $141,774,740, the contract actually awarded to Neptune permitted (by mutual agreement) the addition of two more airtankers to the first CLIN and three more airtankers to the second CLIN in each contract year. Id. Agency Report (AR), Tab 143, Forest Service Large Airtanker Modernization Strategy, Feb. 10, 2012, at2. The company was formerly known as Pink OTC Markets Inc. and changed its name to OTC Markets Group Inc. in January 2011. Coulson Aviation (USA) Inc.; 10 Tanker Air Carrier, LLC--Costs, supra, at 2. On November 26, the NRE Undersecretary recommended the award of a sole-source contract to Neptune. As the only aerial firefighting company operating both fixed-wing aircraft and Type 1 helicopters, Coulson Aviation (USA) Inc. is fully equipped to carry out aerial firefighting across the globe. Competition encourages innovation and lower prices. The Forest Service has determined that based on all the above reasons, it has become necessary to invoke this authority with respect to Neptune Aviation, whose resources and equipment must be available to provide key services if the Forest Service is to successfully fulfill its mission. In responding to the protests, the agency has acknowledged that it was initially concerned that Neptune would immediately go out of business in during [sic] the 2013 fire season, leaving the Forest Service without any of the Legacy air tankers Neptune supplied under the contract awarded March 27, 2013. Agency Post- Hearing Comments, Mar. . FAR 6.302-3(a)(2)(i). Servs., Inc., B-237742, Mar. Coulson points to the fact that in October 2013 it offered to provide the Forest Service with two additional large airtankers under the NextGen contract, and argues it would be available and ready to perform by an April28, 2014, start date (as established by the contract awarded to Neptune). . Neptunes CEO was quite familiar with the FAM Director and other agency officials, as the CEO had been the Forest Services AQM Director until his retirement in December 2010. [14] Neptune had also previously made an advance payment request of $424,750 under its Legacy contract for cash-flow reasons (i.e., the lack of revenue in advance of the fire season). Agency Post-Hearing Comments, Mar. Id. However, changing its focus during the course of the protests, the agency has also argued that its actual concern is whether it could obtain sufficient NextGen airtankers for the 2014 fire season. Where a federal agency makes a sole-source award for purposes of maintaining a particular source for an item or service, concern for maximizing competition is secondary to the agencys industrial mobilization needs. They pride themselves on being the most efficient and safety conscious aerial firefighting team in Australia. Coulson Aviation recently purchased four Cessna Citation II C550 jets that it will convert into aerial firefighting intelligence aircraft. [10] The total estimated cost was based on the 5-year base period for a single aircraft. Accordingly, we recommend that the agency reassess whether a sole-source contract with Neptune--for industrial mobilization reasons or any other reason--is necessary to meet its needs with regard to large airtanker services. When an agency uses noncompetitive procedures under 41 U.S.C. & Engg Co., B-403561, Nov. 18, 2010, 2010 CPD 276 at 3; SSI Tech., Inc., B-298212, B-298212.2, July 14, 2006, 2006 CPD 183 at 4. Coulson has not released any additional specific technological modifications or upgrades it is making to the aircraft. Coulson Aviation operates the only aerial firefighting fleet in the world consisting of both fixed-wing and Type 1 rotary-wing aircraft. The aircraft was the 2762nd 737 built, and was delivered new to Southwest Airlines in November 1995. Rationale The rules do not support the issuance of a sole source award based on the fact that a firm did not win a competitive procurement or in exchange for a particular action, such as the withdrawal of a protest or [Freedom of Information Act] request. However, FI also expressed its opinion to the SPE that Neptune remained viable (without a sole-source award) through the end of its Legacy contract (2017). Coulson Protest, Feb. 10, 2014, at 55. Coulson Protest, Dec. 20, 2013, at 7-8; Coulson Protest, Feb. 10, 2014, at 4. Specifically, the J&A describes the services to be provided by Neptune as two NextGen large airtankers for up to 9 years, at a total estimated value of $141million. After also finding Neptunes expected costs to be lower than the companys projections, FI concluded that Neptune would have the financial capacity to operate and continue performing on its in-place Legacy contract with the Forest Service through, at a minimum, calendar year 2016, without any further contract awards. In accordance with the Competition in Contracting Act (CICA), 31U.S.C. This redacted version has been approved for public release. Neptune currently has available and ready to operate two airtankers that meet the specifications of the NextGen contract. Neptune would undoubtedly prefer the financial security that would accompany a long-term NextGen contract, but this is simply not the standard by which an agency is permitted to make a noncompetitive award for industrial mobilization purposes. Have a story idea you would like to suggest? Its also the only large airtanker capable of carrying 63 firefighters to a fire without the need to reconfigure the cabin providing support, speed and flexibility to fires. . AR, Jan. 31, 2014, at 57. The SPE had several conversations with the ASA in which she recommended that he not approve the J&A as there was not a valid justification for doing so. See AR, Tab49, Neptune J&A, Dec. 9, 2013, attach. at 735; Agency Post-Hearing Comments, Mar. [39] This is significant because where, as here, an agency proposes to award a sole-source contract under the industrial mobilization exception to the general competition requirements, the amount being ordered must meet--not exceed--the objectives of this authority. at 441, 451; AR, Tab24, SPE Email to AQM Requesting Additional Neptune Information, July12, 2013, at 1-2. Aircraft fuel was to be provided by the government or, if contractor-incurred, separately reimbursed. The record also reflects that, after August 26, there generally was no longer any disagreement among the parties about Neptunes present financial viability. Neptune subsequently withdrew its request before any advance payment was made, stating that the company no longer needed the advance payment. With contracts for aerial firefighting across the world, the work of the Coulson Aviation team has been featured in the aviation industry and media recently. The decision issued on the date below was subject to a GAO Protective Order. Tr. Although not stated in the award abstract, based on all aircraft and performance period options, the total amount per CLIN was approximately $350-$400 million. E: michael.strain@bowmanslaw.com. at 464. Mr. Coulson is responsible for the Companys overall growth and strategic direction and has led the transformation of the company into an operator of regulated financial markets for U.S. and global companies. . 7. at 2; Tab 146, Neptune CEO Email to FAM, Sept. 23, 2013; Tab 147, FAM Email to Forest Service Chief, Oct. 4, 2013. See Tr. 18, 2014, at 7. AR, Jan. 31, 2014, at 9. Airtankers (of various sizes) are but one type of aviation resource used by the Forest Service to perform fire suppression missions; other assets include helicopters, aerial supervision fixed-wing aircraft, smokejumper aircraft, heat-detecting infrared aircraft, and water scoopers. See AR, Tab 22, Contracting Officer Letter to RUS, June 25, 2013. Following a May 21 meeting between Neptunes CEO, Forest Service FAM and AQM Directors and staffs, and USDA counsel, the parties engaged in a series of settlement discussions concerning the Forest Services noncompetitive award of a NextGen contract to Neptune pursuant to FAR 6.302-3 (industrial mobilization) in exchange for Neptune withdrawing its May 16 protest. at45253. One such example was the difference in Neptunes revenue projections detailed above. On 6 February 2023, a Boeing 737-300 owned by Coulson Aviation and used as an air tanker crashed in the Fitzgerald River National Park in the Great Southern Region of Western Australia while fighting multiple fires. Coulson GroupCoulson AviationCoulson Ice BlastCoulson Unical, Designed by Elegant Themes | Powered by WordPress, https://www.youtube.com/watch?v=CgCgo-cpQxk, Coulson Aviation Australia (https://www.youtube.com/watch?v=CgCgo-cpQxk). AR, Tab 67, NextGen RFP, at M-4. [6] Although the agency considered these communications to be clarifications rather than discussions, a number of offerors were questioned about substantive issues, and their responses provided major revisions to their proposals. Rather, the record demonstrates, as acknowledged by the agency, that Neptune is presently financially viable and is expected to remain financially viable through the term of its Legacy airtanker contract (2017). [18] The settlement agreement specified that the contract to be awarded to Neptune would be the same duration as the NextGen contract awards (i.e., a 5-year base period with five 1-year options). There are no executives at OTC Markets getting paid more. [26] Id. [27] See 41 U.S.C. The newest addition to our fleet are the Coulson modified 737 FireLiner aircraft. 41 U.S.C. Michael Strain is one of East Africa's most active corporate/M&A lawyers; based in Tanzania but also covering the wider region. The Forest Services procurement of NextGen airtanker services has a long and contentious history. Coulson Aviation @CoulsonAviation Global leader in aerial firefighting, emergency personnel transport, and heavy lift operations operating a fleet of fixed and rotary wing aircraft. Vertical and Vertical Valor are part of MHM Publishing Inc. All Rights Reserved 2020 | Terms of Use | Privacy Policy. The NRE Undersecretary emphasized the importance of large airtankers for wildland firefighting and the Forest Services need for additional airtankers, particularly with regard to the 2014 fire season. Specifically, the protesters argue that: (1) Neptune is not a vital supplier such that the large airtanker industrial base can be maintained without resorting to noncompetitive procurements; and (2)Neptune does not require a sole-source contract to remain a source of large airtankers. In this regard, however, the J&A did not address the fact that both 10Tanker and Coulson had previously approached the Forest Service about adding additional airtankers to their NextGen contracts (two additional airtankers in the case of Coulson), and that 10Tanker had delivered a second certified airtanker to the Forest Service for the 2013 fire season. AR, Tab23, RUS Financial Analysis of Neptune, June 26, 2013, at 1-4. After receiving the offerors responses, the TEB prepared an evaluation report that included the evaluators final consensus evaluation and analysis of the offerors evaluated prices. On its third mission, it took off at 3:32 pm. A stand down may be undertaken when the operator believes there is something which might distract the pilots from safely completing their missions. The adequacy of the rationale and conclusions set forth in the J&A is dependent on the completeness and accuracy of the information included in the J&A. See Agency Post-Hearing Comments, Mar. [12] AR, Tab 71, Neptune Protest (B-406920.8), May 16, 2013. Likewise, Minden states that it owns a second aircraft (BAe-146) that it is converting into an airtanker, and would be able to submit a proposal should the Forest Service conduct another competitive procurement. at 52. As the Australian business arm of global company Coulson Aviation, Coulson Aviation Australia also supports other Australian States with the provision of large aircraft and experienced team members. Rus financial Analysis of Neptune, June 25, 2013, at 55 the specifications of reason. | terms of use | Privacy Policy its financial viability review of Neptune be undertaken when the believes. Own calculations and May differ from other figures the area and returned to base. In Contracting Act ( CICA ), June 26, the agency acknowledges that the company was formerly known Pink... Tab 144, RUS provided USDA with its financial viability review of Neptune the decision on. 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