BR3-17-004_GIII_JOFOC.pdf

Enclosure

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA)

LYNDON B. JOHNSON SPACE CENTER (JSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

Pursuant to 10 United States Code (U.S.C.) 2304(c)(1) and Federal Acquisition Regulation

(FAR) 6.302-1

For the Gulfstream III (G-III) Aircraft

1. FAR 6.303-2(b)(2) – The nature and/or description of the action being approved: This justification provides the rationale for contracting by other than full and open competition to support the acquisition of a G-III aircraft using a brand-name description to specify a particular product peculiar to one manufacturer.

2. FAR 6.303-2(b)(3) – A description of the supplies or services required, to meet the

Agency’s needs (including the estimated value): This justification provides the rationale for contracting by other than full and open competition for the acquisition of a G-III aircraft.

NASA JSC currently operates a G-III aircraft, Tail number N992NA, to support airborne science missions worldwide as well as provide a backup aircraft to the Gulfstream-V for the astronaut direct crew return mission. NASA JSC will part out the acquired G-III aircraft to support and repair N992NA.

The G-III is an aging aircraft manufactured in 1979. The acquisition of spare components to continue safe operations of the G-III is becoming increasingly costly, especially the cost of spare engines. The maintenance schedule for the G-III’s engines requires major inspections on defined intervals. The costs associated with these inspections are extensive. The inspections and associated maintenance for the currently installed engines on the N992NA are expected to cost the Agency $1.5 million over the next 3 years to sustain the engines.

When completing this scheduled engine maintenance, the time to the next major maintenance on the engines is reset to give the maximum “engine life” available on these engines. The currently installed engines will reach their maximum “engine life” within the next 3 years which will require the purchase of new engines. Used engines could be purchased separately to meet these requirements (approximately $200 thousand - $300 thousand per engine), however, in addition to the engines, a parts aircraft would provide a complete reservoir of spare parts to include expensive components like engine cowlings and flight controls. The

Agency has spent over $900 thousand the last 3 years to repair and replace broken components on the G-III and the purchase of a G-III airplane for spare components would significantly offset future material purchases.

Given that the overall G-III fleet has been replaced by newer, faster, and more capable aircraft in the private business jet market, the price of a G-III has plummeted to the point that purchasing a complete aircraft is significantly less expensive than the sum of the prices of the individual parts and components. Therefore purchasing a G-III aircraft for its parts, as a means to acquire spare engines and parts is an extremely cost effective maintenance strategy.

The G-III N992NA aircraft operated by JSC is currently scheduled to fly critical missions for

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NASA’s airborne science and human spaceflight programs through at least 2021. Over the last 5 years, NASA has invested approximately $3 million in the modification and maintenance of N992NA to ensure that the aircraft is capable of supporting agency airborne missions into the future. These modifications and maintenance include the installation of the

1,000 pound Uninhabited Aerial Vehicle Synthetic Aperture Radar, a sonobuoy launch system, hush kits to comply with Federal Aviation Administration Stage-III noise abatement requirements, the design and installation of a new avionics suite to comply with future airspace navigation requirements, and the completion of major airframe and engine maintenance that included the refurbishment of all of the aircraft’s flight controls. The continued operation of this uniquely modified aircraft N992NA is vital to the success of

NASA missions. With these modifications, and the engines and spare parts that will be realized through the purchase of a G-III for parting, the ability of N992NA to perform

NASA’s unique missions, including airborne science and human spaceflight programs, will be ensured into the future. If the airplane and engines are maintained properly, the aircraft will be viable for flight into the 2030’s.

The Agency will not operate the G-III aircraft once it has been procured. Per Agency regulations, the acquisition of aircraft whose sole intended use is for a “parts aircraft”, NASA

JSC is only required to notify NASA Headquarters (HQ) of the intent to purchase such an aircraft. JSC notified NASA HQ of its intent to procure a G-III aircraft for parts on August

1, 2017. Once the aircraft is procured and delivered to JSC, JSC will remove the data plates from the aircraft and deliver them to the Agency for disposition. In addition, the aircraft will not be entered into the computer system that provides the flight release authorization. As such, JSC cannot and will not fly the procured aircraft, and the “parts aircraft” does not constitute an additional aircraft to the fleet.

The “parts aircraft” will be flown to Ellington Field in Houston, TX, where it will be parted out to support the flying G-III aircraft. Other delivery options of trucking the airplane over the road or flying inside a larger aircraft, like the Agency’s Super Guppy, are not practical or possible.

3. FAR 6.303-2(b)(4) – An identification of the statutory authority permitting other than full and open competition: The statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c)(1). As contemplated by the provisions of FAR 6.302-1(c), the supplies required are a “brand name description” G-III aircraft.

4. FAR 6.303-2(b)(5)&(9) – A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited and any other facts supporting the use of other than full and open competition: A G-III aircraft is the only viable aircraft that can provide a complete set of replacement components that are compatible with the G-III aircraft currently operated by JSC. All other aircraft make and models, by definition, are different than the G-III, and these variations ensure that they cannot provide a complete set of compatible replacement components and parts.

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5. FAR 6.303-2(b)(6) – A description of the efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies:

A synopsis of the proposed contract action will be posted with the solicitation in accordance with FAR 6.302-1 (c) to the Government Point of Entry in accordance with the provisions of

FAR Subpart 5.2. In addition, the justification will be posted with the solicitation in accordance with FAR 6.302-1(c)(ii)(C). Any responses received as a result of the publication will be thoroughly evaluated and documented in the contract file.

6. FAR 6.303-2(b)(7) – A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable: A determination that the anticipated cost of this procurement is fair and reasonable will be based upon competition between available

G-III aircraft from multiple sources. This determination will be made only after ensuring that all technical requirements are met by the offerors as defined by the solicitation’s statement of work.

7. FAR 6.303-2(b)(8) – Description of the market survey conducted, and the results, or a statement of the reasons a market survey was not conducted: The market survey for this procurement was conducted to determine market conditions and pricing. Industry brokers as well as market place websites were assessed to determine availability of aircraft.

Approximately 10 G-III aircraft were found to be available on the open market.

As a part of market research other aircraft make and models were evaluated. No other aircraft type has been identified as an appropriate candidate to supply a complete set of spare parts and components as all other aircraft make and models, such as a Gulfstream-IV, a

Gulfstream-V and a Global Express, are different than the G-III, and these variations ensure that they cannot provide a complete set of compatible replacement components and parts.

The purchase of another make and model is not appropriate as they are distinct airplanes from the G-III, and therefore cannot supply a complete set of spare parts and components to support our highly specialized G-III aircraft.

FAR 6.303-2(b)(9) – Any other facts supporting the use of other than full and open competition, such as: Over the last 5 years, NASA has invested approximately $3 million in the modification and maintenance of the G-III N992NA to ensure that the aircraft is capable of supporting agency airborne missions into the future. The continued operation of this uniquely modified aircraft N992NA is vital to the success of NASA missions. If this procurement was a “full and open competition” to other makes and models of aircraft, the government would be procuring components and parts not compatible and not usable on the

G-III.

8. FAR 6.303-2(b)(10) – A listing of the sources, if any, that expressed an interest in writing in the acquisition: In accordance with FAR 6.302-1(c)(1)(ii)(C), the posting for this document will be posted with the solicitation. Any sources expressing an interest about this acquisition will be assessed.

9. FAR 6.303-2(b)(11) – A statement of actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the

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supplies or services required: No actions can be taken. As noted above, only the acquisition of a G-III aircraft provides a complete set of components and parts that are compatible to repair the flying G-III aircraft.