A16_JOFOC_Leadplane_Signed_0002.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

AUTHORITY: Revolutionary FAR Overhaul (RFO) 6.103, 41 U.S.C. 3304

Solicitation: 140D0426R00080

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by RFO 6.103 and in accordance with the requirements by RFO 6.104-1, the justification for the use of the statutory authority under RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-2 as follows:

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for other than full and open competition.”

This document is a justification for other than full and open competition for the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (ADQ) on behalf of the U.S. Wildland Fire Service (USWFS), Aerial Supervision Module (ASM) Program.

2. Nature and/or description of the action being approved.

This is a follow-on lease for five brand name Beechcraft King Air B200 airplanes to be operated by the USWFS under its ASM Program during wildfire seasons over the next five years (2027-2032).

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

The USWFS ASM Program requires the lease of five Beechcraft King Air B200 aircraft to support mission needs during wildfire season. The Period of Performance will run from February 1, 2027 through January 31, 2032, with a five‑year ordering period to include FAR 52.217‑8, Option to Extend Services. The Government intends to award a single‑award IDIQ; however, it will retain the flexibility to issue multiple single‑award IDIQs if a vendor possesses fewer than the five required aircraft and awarding a portion of the requirement to that vendor is determined to be in the best interest of the Government.

Task orders will cover an exclusive‑use period of 240 days per aircraft, running annually from February 1 through September 27. During unusually active wildfire seasons, the Government and contractors may mutually agree to extend the exclusive‑use period on a day‑by‑day basis until conditions stabilize.

Contractors will provide and maintain the aircraft throughout each wildfire season. The Government will pay a daily availability rate and a dry‑hour flight rate for actual flight time. All aircraft will be flown by Government‑furnished pilots, and the Government will supply aviation fuel for operational missions.

Solicitation: 140D0426R0080

The Aviation Operations and Management (AOM) has found that a particular group of Beechcraft King Air B200 aircraft, approved by the manufacturer (Beechcraft), with a specific wing construction allows them for use as ASM lead planes. The aircraft must have been manufactured between 1984 and 2013, the aircraft serial numbers must be from BB-1192 through BB-2019, and the aircraft must not have been modified for winglets or a cargo door. The estimated value of this requirement is $36,900,000, which applies solely to the brand‑name portion of the requirement. This value includes the additional potential six‑month performance period authorized under FAR 52.217‑8.

4. An Identification of the statutory authority permitting other than full and open competition.

RFO 6.103-1(d) -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements (Application for brand-name descriptions). 41 U.S.C.

3304(a)(1).

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The USWFS ASM Program requires seven active lead planes to accomplish its mission during wildfire season. Two of these aircraft are Government‑owned Beechcraft King Air B200s, and the remaining five will be leased. Because aerial supervision of firefighting resources is an inherently governmental function, all ASM lead planes are flown by Government pilots who are trained, qualified, and standardized specifically on the King Air B200 platform.

For mission execution, only the Beechcraft King Air B200 or aircraft with the same make, model, and supported configuration will meet operational needs. The ASM mission requires precise coordination, standardized cockpit procedures, and consistent aircraft performance characteristics to ensure safe and effective direction of air tankers over complex wildfire environments. Government pilots rely on uniformity in aircraft handling, instrumentation layout, performance profiles, emergency procedures, and communications systems to maintain safety during high‑risk, high‑tempo operations.

Because the pilots are trained exclusively on this platform, and because operational safety depends on the predictable performance and configuration that only the Beechcraft King Air B200 provides, no other aircraft type can meet these requirements.

Using a single, standardized make and model ensures interoperability across all lead‑plane missions, reduces pilot workload, minimizes the risk of error, and allows pilots to transition seamlessly between Government‑owned and leased aircraft. For these reasons, only the Beechcraft King Air B200 will satisfy the ASM Program’s technical and safety requirements, and alternative aircraft cannot provide the necessary capabilities or risk profile for this mission.

There is a safety benefit to the Government when pilots can focus on one aircraft and its operations. ASM pilots must memorize standard and emergency operating procedures for any aircraft they fly. If pilots are only operating one, make and model of aircraft over the entire 240-day wildfire season it eliminates the need to learn/memorize operational procedures for multiple aircraft. The use of one make and model of aircraft allows the USWFS ASM program manager to assign any pilot, at any time, to either a Government or leased aircraft with minimal risk. The Forest Service (FS) ASM Program also uses Beechcraft King B200 aircraft. There are times when pilots from one ASM program are asked to assist the other. Because both the FS and USWFS will be operating B200/B200GT aircraft, the pilots may be approved under both the USWFS and FS program without the need to possess additional pilot qualifications, training, or a minimum number of flight hours required for the use of different makes and models of aircraft.

6. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by RFO Subpart 5.1 and, if not, which exemption under RFO 5.101 applies.

To ensure transparency and adequate notice to industry, the Government will issue the solicitation together with the presolicitation information rather than posting a separate presolicitation notice. The solicitation will include the brand-name specifications and the supporting brand-name justification, in accordance with RFO 5.101(d) Table 5-2 and RFO 5.201(c)(3).

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

The Beechcraft King Air B200 aircraft are commercial items that are readily available in the marketplace. For over 20 years the Government has received competitive offers when soliciting for the leased of aircraft for the USWFS ASM Lead Plane Program. In accordance with FAR 15.404-1 the contracting officer has determined that the pricing will be fair and reasonable based on competition and historical pricing from prior requirements.

8. A description of the market research conducted (see RFO Part 10) and the results or a statement of the reason market research was not conducted.

Market research included a search of the FAA Registry Database for qualified aircraft, a Dynamic Small Business Search (DSBS) for possible vendors, federal contract schedules, and the System for Award Management (SAM) for registered vendors.

Market research indicates that approximately 390 Beechcraft King Air B200 aircraft manufactured between 1984 and 2013 have serial numbers supported by Beechcraft for use in the ASM lead‑plane role. Three vendors responded to the Sources Sought notice issued on July 14, 2026. The notice was posted on SAM.gov and remained open for 14 days. The estimated vendor pool consists of three vendors. Two are large businesses, and the one small business that possesses all five required aircraft. As a result, the government does not anticipate receiving quotes from two small businesses.

9. Any other facts supporting the use of other than full and open competition;

such as:

As discussed in paragraph 5, allowing the ASM Lead Plane Program to use one make and model of aircraft (Beechcraft King Air B200) is safe, cost efficient, and effective.

When pilots are operating only one type of aircraft the instruments and aircraft controls are all located in the same position and operate the same, the opportunity for error is dramatically reduced.

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

Greenwood Group and Yingling, both large businesses, indicated that they have the capability to fulfill the requirement. J. Mack Enterprises, a small business, also expressed interest.

11. A statement of any actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required.

The USWFS ASM program requires the use of a single make and model of aircraft to ensure interoperability and enhance overall safety. Because this standardizes the fleet, any future procurements will require a brand name justification. To preserve an adequate level of competition despite this constraint, the Government will utilize commercially available aircraft and structure future solicitations as multiple single‑award IDIQs. This approach will allow vendors with only one aircraft to participate and submit proposals, thereby maximizing competitive opportunity even within the limited pool created by the brand‑name requirement.

12. Contracting officer certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

I certify that this justification is accurate and complete to the best of my knowledge and belief.

Justin Kondeff Contracting Officer

13. Requirements personnel certification.

I certify that the technical data which forms a basis for this justification is complete and accurate and meets the Government’s minimum needs.

Jedediah Johns Aerial Supervision Program Manager

14. Reviews and Approvals

Approve

Sharon Roberts Head of the Contracting Activity