2861039_JUSTAPPR (Redacted).pdf

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

I. CONTRACTING ACTIVITY

United States Air Force

AFSC/PZA

3001 Staff Drive Tinker AFB, OK 73145

Purchase Request # FD2030-18-03073

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING PROCESSED

This individual Justification and Approval (J&A) authorizes the use of other than full and open competition procedures to obtain a follow-on firm fixed priced (FFP), sole source Indefinite Delivery Indefinite Quantity (IDIQ) contract. The contemplated contract is for remanufacture of oxygen cylinder assemblies and flow regulating valve on the B-1B aircraft. The Original Equipment Manufacturer (OEM) is Carleton Technologies Incorporated, Commercial and Government Entity (CAGE) code 04577. A 3-year IDIQ contract with a 3-year performance period is considered to be appropriate for this acquisition. The previous acquisition under contract FA8118-18-P-0012 was remanufacture. The acquisition is not a Bridge Action as defined in AF Bridge Action Reduction Plan. Market research revealed this to be a non-commercial acquisition. The estimated total value of this contract action is $1,150,395.00 with an estimated award date of December 2019.

Previous Contract Number: FA8118-18-P-0012 Contractor Name: Carleton Technologies Incorporated Date of Award: 07 June 2018 Completion Date: 06 Jue 2019 Basis of Award: Sole-Source

III. DESCRIPTION OF THE SUPPLIES/SERVICES REQUIRED TO MEET THE

AGENCY’S NEEDS

Under the contemplated contract, Carleton Technologies Incorporated will remanufacture the oxygen cylinder assemblies and flow regulating valves used on the B-1B Aircraft. The Contractor will provide the disassembly, cleaning, inspection, maintenance, re-assembly, testing, and finishing actions required to return the end item to a like new condition. This effort is a supply. Dollar values below reflect the anticipated contract value.

Contract Summary

Period of Performance Estimated Dollars

December 2019 - December 2022 Total: $1,150,395.00

PR Line Item 0001

Remanufacture of NSN: 1660-01-214-9800BO P/N: 8210031-401 Noun: Oxygen Cylinder Assembly Application: B - 1 B Aircraft Item Function: The oxygen cylinder assembly provides an emergency backup oxygen source for use in the event of an oxygen system failure, exhaustion of supplementary oxygen supplies, and/or during egress (bailout) from the aircraft at high altitudes.

Item Material: Multiple metal and rubber components Type of Appropriation: 97X4930 Total estimated dollars for PR Line Item 0001: $205,440.00

Period of Performance MIN Qty.

BEQ MAX

Qty.

Unit Price Estimated Dollars

December 2019 - December 2022 15 10 48 $4,280.00 $205,440.00

PR Line Item 0002

Remanufacture of NSN: 1660-01-214-9801BO P/N: 8210031-402 Noun: Oxygen Cylinder Assembly Application: B - 1 B Aircraft Item Function: The oxygen cylinder assembly provides an emergency backup oxygen source for use in the event of an oxygen system failure, exhaustion of supplementary oxygen supplies, and/or during egress (bailout) from the aircraft at high altitudes.

Item Material: Assorted metals (steel, aluminum, etc.) rubber and plastic.

Total estimated dollars for PR Line Item 0002: $179,760.00

BEQ MAX

Qty.

Unit Price Estimated

December 2019 - December 2022 15 10 42 $4,280.00 $179,760.00

PR Line Item 0003

Remanufacture of NSN: 4820-99-740-1368BO P/N: 8920024-1 Noun: Flow Regulating Valve Application: B - 1 B Aircraft Item Function: The regulating valve reduces the bleed air inlet pressure for supply gas to the B- 1B oxygen concentrator.

Item Material: Multiple metal and rubber parts

Total estimated dollars for PR Line Item 0003: $762,195.00

BEQ MAX

Qty.

Unit Price Estimated

December 2019 - December 2022 45 25 105 $7,259.00 $762,195.00

PR Line Item 0004

Description: Over and Above Effort

Total Estimated dollars for PR Line Item 0004: $3,000

Period of Performance Qty. Unit Price Estimated

December 2019 - December 2022 1 LT $3,000.00 $3,000.00

PR Line Item 0005

Description: Data Not Separately Priced (NSP), IAW CAV AF SOR and CDRLs

Total estimated dollars for PR Line Item 0005: NSP

Period of Performance Qty. Unit Price Estimated

December 2019 - December 2022 1 LT NSP NSP

Due to the circumstances described below in Sections V, IX and XI, there are no additional actions that could be taken to develop competition. Therefore, it is considered appropriate to seek approval for more than one fiscal year’s requirements. If other qualified or approved sources become known during the life of this contract, full and open competition will be considered and utilized to the maximum extent practicable.

IV. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION

10 U.S.C. 2304(c) (1), as implemented by FAR 6.302-1 (a)(2)(ii).

V. DEMONSTRATION THAT THE CONTRACTOR’S UNIQUE

QUALIFICATIONS OR NATURE OF THE ACQUISITION REQUIRES THE

USE OF THE AUTHORITY CITED ABOVE (APPLICABILITY OF

AUTHORITY)

This anticipated acquisition is for remanufacture of NSN 1660-01-214-9800BO oxygen cylinder assembly, NSN 1660-01-214-9801BO oxygen cylinder assembly and NSN 4820- 99-740-1368BO flow regulating valve. The intended action is a follow-on contract with the OEM, Carleton Technologies Incorporated. The oxygen cylinder assemblies are critical emergency oxygen supply assemblies installed directly on the aircraft. The flow regulating valve support the depot overhaul of the life support systems. These oxygen cylinder assemblies and the flow regulating valve are considered highly specialized because they are designed to provide life support on the B-1B and are imperative to allow the Government to be mission ready at all times. The oxygen cylinder assemblies and flow regulating valve are critical application items, as defined in the Aviation Critical Safety Item Management Handbook. Therefore, this acquisition will be a follow-on contract for the continued production of highly specialized equipment.

The Government has established Qualification Requirements (QRs) for the oxygen cylinder assemblies and the flow regulating valve. Potential sources will be required to independently demonstrate capability via the Source Approval Request (SAR) process. Prospective sources must meet these requirements prior to being identified as an approved source. This item requires engineering source approval in order to maintain its quality and technical baseline. The 423rd Supply Chain Management Squadron has determined that Carleton Technologies Incorporated is the only source that has met the defined QR at this time, and thus has been listed as the only approved source. Carleton Technologies Incorporated is the only company with the special tooling/equipment, personnel and technical data to satisfy the Air Force’s minimum need. The repair data, acceptance test procedures, specialized tools and test equipment necessary to foster competition are not presently available to the government and it is not possible for the Government to draft adequate specifications for the repair. Efforts by the Government to purchase technical data from Carleton Technologies Incorporated have been unsuccessful. A request for information was made to Carleton Technologies Incorporated on 27 September 2016 and 08 May 2019 regarding the potential release and/or sale of the associated remanufacturing data. Carleton Technologies Incorporated responded 23 May 2019 and stated no to our current request.

The 423rd SCMS believes that award to any other source would result in unacceptable delays in fulfilling the Air Force’s requirement. Development of additional sources to remanufacture this item is not feasible within allowable timeframes. The Government does not expect that any other source could become qualified in time to avoid unacceptable delays. Any interested sources would be required to submit a Source Approval Request (SAR) for review by the cognizant engineering authority. Interested vendors would need to submit a SAR package demonstrating capacity to access the necessary data, independently develop maintenance/remanufacture procedures or other proof of capability. As of 28 May 2019, there have been no SAR packages submitted for review. Once a source has been identified and a SAR package has been submitted, it can take in excess of one year to qualify the potential source. During this time the Government must review and approve the SAR package, complete any potential site visits and validate/verify any developed technical requirements. If deliveries do not begin by January 2020, delays in procurement will disrupt the availability of parts to the B-1B aircraft, thereby leaving the Air Force unable to meet critical mission requirements and hampering the Air Force’s ability to execute its global mission. To date Carleton Technologies Incorporated is the only approved source.

Accordingly, Carleton Technologies Incorporated is the only firm capable of providing the supplies described in Section III above without the Air Force experiencing unacceptable delays in fulfilling its requirements.

VI. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE

SOLICITED FROM AS MANY POTENTIAL SOURCES AS DEEMED

PRACTICABLE

On 24 January 2019, this requirement was synopsized through a Sources Sought Synopsis (SSS) and posted on the Federal Business Opportunities (FedBizOps) website for 30 days (closing on 25 February 2019) under FD2030-18-03073. As of 25 February 2019, zero vendors showed interest and no SAR packages were submitted in response to the SSS.

Government defined pre-award qualification requirements of potential sources have been identified and documented on the QR. All SAR package submissions submitted prior to contract award will be evaluated in a timely manner to ensure the highest level of competition possible. The QRs were synopsized on https://www.fbo.gov 24 January 2019 and can be found by searching for the keyword “RQR-848”.

This requirement will be synopsized in https://www.fbo.gov as a notice of proposed contract action IAW FAR 5.201. The estimated date of publication is August 2019.

Consideration will be given to potential sources, prior to award.

VII. DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND

REASONABLE

The Contracting Officer will ensure that the items described herein are negotiated at a fair and reasonable price to the Government. IAW FAR as supplemented, the contractor will be required to submit Certified Cost or Pricing Data and/or Other Than Certified Cost or Pricing Data. A detailed cost analysis and price analysis will be performed. The Contracting Officer may request a technical evaluation from the Defense Contract Management Agency (DCMA) to aid in the evaluation of the contractor’s proposal. The Contracting Officer may seek audit assistance from the Defense Contract Audit Agency (DCAA) if necessary.

VIII. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AND THE

RESULTS, OR A STATEMENT OF THE REASONS MARKET RESEARCH WAS

NOT CONDUCED

IAW FAR 10.002(b)(2), market research was conducted on the B-1B oxygen valve assemblies and the flow regulating valve coupling by a multi-functional team consisting of the Item Manager, Equipment Specialist, Logistics Officer and Engineer. This research included a Sources Sought Synopsis (see Section VI) and on 16 April 2019, searches into Internet sites including Google secure components, the Thomas Register, Haystack, and similar item manufacturer’s websites. Searches included part number, nomenclature, and like items. Other sources manufacture similar items but none have sought qualification against the requirements described in Section IV. Further, these requirements can neither be modified nor be satisfied with commercial or modified commercial items.

Based on this market research, Carleton Technologies Incorporated was found to be the only source able to fulfill the requirement described in Section III.

IX. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND

OPEN COMPETITION

No further information

X. LIST OF SOURCES, IF ANY, THAT EXPRESSED INTEREST IN THE

ACQUISITION

Carleton Technologies Incorporated CAGE: 04577 10 Carleton Technologies Incorporated Dr.

Orchard Park, NY 14127-4121 Email: www.Carleton Technologies Incorporated.com Phone: 716-662-0747

See Section VI for more details.

XI. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO

REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE

MAKING SUBSEQUENT ACQUISITIONS FOR THE SUPPLIES OR SERVICES

REQUIRED

As a result of continued refusal by the sole source contractor to provide or license data as well as the unacceptable delay of developing additional sources per Section V and IX, there are no known additional actions which can be taken to remove barriers to competition and therefore, specific actions and milestones cannot be established.

Per PGI 206.304(a)(S-70)-As indicated by signature on the Coordination and Approval Document, the previous J&A has been reviewed and the Approval Authority determines that all stated actions to remove barriers to competition have been accomplished.

XII. CONTRACTING OFFICER’S CERTIFICATION

The Contracting Officer’s signature on the Coordination and Approval Document evidences that he/she has determined this document to be both accurate and complete to the best of his/her knowledge and belief.

XIII. TECHNICAL/REQUIREMENTS PERSONNEL’S CERTIFICATION

As evidenced by their signatures on the Coordination and Approval Document, the technical and/or requirements personnel have certified that any supporting data contained herein IAW FAR 6.303-2(c), which is their responsibility, is both accurate and complete.