A02 - JA EPG Redacted.pdf

Control Number: JA-22-Hua-562 United States Army Electronic Proving Ground (USAEPG) Scientific Engineering Support Services

CUI

Controlled by: Army Controlled by: ACC APG Huachuca Division CUI Category(ies): Source Selection Limited Dissemination Control: FEDCON

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Justification Review Document for Other than Full and Open Competition - FAR Part 6

Program/Equipment: United States Army Electronic Proving Ground (USAEPG) Scientific Engineering Support Services

Authority: 10 United States Code 3204(a)(1) as implemented by FAR 6.302- 1(a)(2)(iii)(B), �Only one responsible source and no other supplies or services will satisfy agency requirements� � for DoD, NASA, and the Coast Guard, services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in unacceptable delays in fulfilling the agency�s requirements.�

Nine-Month Period of Performance

(Source Selection Information See FAR 2.101 and 3.104 4) CUI Page 2 of 15

Reviews

I have reviewed this justification and find it adequate to support other than full and open competition.

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Justification and Approval for Other than Full and Open Competition � FAR Part 6

1. Contracting Activity: U.S. Army Contracting Command - Aberdeen Proving Ground (ACC-APG), Huachuca Division, 2133 Cushing St., Bldg. 61801, Ft. Huachuca, AZ.

85613-7070

2. Description of Action: The United States Army Electronic Proving Ground (EPG) requests approval to modify the existing Cost-Plus Award Fee (CPAF) contract, W91RUS16C0006, awarded to Jacob�s Technology Inc., 600 William Northern Blvd., Tullahoma, TN 37388-4729 for Scientific and Engineering Support Services (SESS).

The proposed modification is for 9 additional months of service, and is anticipated to be executed between 15-22 September 2022, utilizing current Research, Development, Test and Evaluation funds. This is a non-competitive bridge action requiring a Federal Acquisition Regulations (FAR) Part 6 justification to retain the current Scientific and Engineering Support Services to allow for continued developmental testing in direct support of Army Futures Command, Program Executive Offices, Department of Defense (DoD) partners, and industry partners to ensure our Warfighters are enabled to dominate the future battlefield. The current SESS contract expires on 30 September 2022.

Request Senior Contracting Official (SCO) approval because as further described in Section 5, Jacob�s Technology is the only vendor capable of providing the required bridge SESS on behalf of EPG without unacceptable delays in the execution of the mission and a detrimental break in service. Furthermore, as detailed below, it is estimated that a short-term award to another vendor would result in of duplicative costs to the Government which would not be expected to be recovered via a competition for a short-term bridge contract. As the current SESS contractor, Jacob�s provides EPG with non-personal engineering, technical, and scientific services to support test planning, test conduct, and test reporting. Services include, but are not limited to, planning, engineering, test design and analysis, software and hardware development, and support of testing activities conducted by the EPG.

3. Description of Supplies/Services: The United States Army Electronic Proving Ground (USAEPG) is located at Fort Huachuca, Arizona, one of the DoD�s foremost tests and training ranges, supporting both military and commercial materiel developers by testing a broad spectrum of equipment throughout its life cycle from concept through deployment. EPG is a DoD Major Range Test Facility Base (MRTFB) and is a tenant on Fort Huachuca with an area of operation which includes, but not limited to, more than 62 million acres of both public and private lands and the Fort Huachuca Military Installation.

EPG has the capacity to extend its testing events into the protected Radio Frequency Environment � the Buffalo Soldier Electronic Testing Range (BSETR) comprising 1.6 million acres.

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The contractor provides non-personal engineering, technical, and scientific services to support test planning, test conduct, and test reporting. Services include, but are not limited to, planning, engineering, test design and analysis, software and hardware development, and support of testing activities conducted by the EPG. Intrinsic test services functions comprise data collection, reduction, and processing; compilation, review and reporting; technical writing; help desk/computer operations; and typing and editing of Government correspondence and technical reports on a wide variety of automotive, military, electronic, general equipment, and software materiel undergoing extensive testing. EPG provides testing via bench tests, lab tests, field tests, and large-scale, geographically distributed systems of systems tests, employing a mix of live and simulated instrumentation and assets.

Based on historical information on the current contract

4. Authority Cited: 10 U.S.C. 3204(a)(1) as implemented in Federal Acquisition Regulation (FAR) 6.302-1(a)(2) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. When the supplies or services required by the agency are available from only one responsible source, or for DoD, NASA, and the Coast Guard, from only one or a limited number of responsible sources and no other type of supplies or services will satisfy agency requirements, full and open competition need not be provided for. FAR 6.302-1(a)(2)(iii) further provides that �for DoD, NASA, and the Coast Guard, services may be deemed available only from the original source in case of follow-on contracts for the continued provision of highly specialist services when it is likely that the award to any other source would result in, (A) Substantial duplication of cost to the Government that is not expected to be recovered through competition, or (B) Unacceptable delays in fulfilling the agency�s requirements.� Both A and B are supported.

5. Reason for Authority Cited: Pursuant to FAR 6.302-1(a)(2)(iii)(A) and (B), "Only one responsible source (or limited sources) and no other supplies or services will satisfy agency requirements," services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in

CUI Page 5 of 15 unacceptable delays and duplication of costs in fulfilling the agency's requirements for this short-term bridge.

The EPG-SESS incumbent contractor, Jacobs Technology, Inc., 600 William Northern Boulevard, Tullahoma, TN, is the only available source capable of meeting the Government�s minimum requirements, as described in paragraph 3 of this document, within the necessary timeframes and without a break in service. The incumbent contractor is currently performing the full range of testing requirements and has the experience, technically trained management with trained and qualified personnel in place to continue to provide uninterrupted support without a break in service. A break in service, even the slightest amount, would create a significant and unacceptable interruption of developmental testing and validation of emerging technologies and capabilities to EPG and its testing partners throughout DoD. Furthermore, a loss of experienced scientists, engineers, and testers, some with Top Secret � Sensitive Compartmented Information (TS-SCI) security clearances, would put ongoing tests at risk and cause severe delays in capability development which would delay the deployment of these vital capabilities to the warfighter.

a. The USAEPG executes developmental testing in direct support of Army Futures Command, Program Executive Offices, DoD partners and industry partners to ensure our Warfighters are enabled to dominate the future battlefield. To fulfill this mission, EPG provides quality, efficient, timely, value-added test services that support the acquisition process, providing comprehensive test and evaluation data products and performance information to its customers.

The impact if this J&A is not approved to allow for continued services is complete mission failure. Contract support provides the Subject Matter Expertise (SME) needed to meet EPG�s customer requirements, specifically Cross Function Teams (CFT), which are the Army�s top priority to develop. CFTs were established to narrow existing capability gaps by developing capability documents, informed by experimentation and technical demonstrations, to rapidly deliver requirements to the Army Acquisition System. CFTs are in direct support of Army Futures Command and are the Army�s modernization priorities necessary for future readiness and multi-domain operations. EPG�s customers are Army Futures Command, Program Executive Offices; program, project, and product managers; evaluators; acquisition decision makers; and those supporting the Soldier directly. If this J&A to extend the current contract is not approved, EPG would be unable to support its customers in developmental testing of equipment utilized to support the warfighter.

b. The Government has analyzed and evaluated the use of potential alternatives such as: a) allowing expiration of contract, b) using in-house resources, and c) awarding to a different contractor to perform this effort. This analysis concluded that none are practicable in the short term. The Government does not have, nor expects to have, the expertise or in-house resources to perform this effort in the near term.

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Award to any other vendor, either competitively or non-competitively, at this time would cause a break in service and mission failure.

c. A modification to the existing contract for nine-months will permit continued performance of the current EPG SESS contract while the award of the follow-on EPG SESS requirement is completed. This process would be the most effective use of Government resources. Considerations that drive the request to modify the existing contract reflecting the unacceptable delays and duplication of costs in fulfilling the agency's requirements for this short-term bridge are as follows:

i. Award to another source at this point would cost the Government time (a potentially extensive learning curve and familiarity with the site); significant substantial duplication of cost that would not be recouped through competition estimated ; and unacceptable delays in fulfilling the requirement. The amount of extra cost could possibly be recouped through competition for a new long-term contract; however, the Government would not expect it to be recouped through an award of a contract with a nine-month period of performance.

Another factor to consider is the amount of Government Furnished Property (GFP) that would be required to be transferred to a new contractor with 100% inventory of all GFP.

ii. A new contractor would require additional time and extensive knowledge due to the unique mission and equipment utilized to be able to satisfy the requirements, which is not available. The additional time would be spent hiring employees and acquiring vehicles, tools, and test equipment. Furthermore, competition for this bridge contract could potentially result in at least two different contractors providing services over the course of three months due to the necessity of phase-in, creating personnel turbulence, significant learning curves, and potential loss of critical employees. Turnover of this magnitude would be harmful to the mission. Historical data shows that a minimum of 90 days would be required to transition to a new contractor; therefore, it is unlikely any contractor can mobilize in time to even attempt the effort. In addition, the Government would incur substantial duplication of costs as compared to initial start-up of the current contract, W91RUS16C0006, as further detailed below. Furthermore, all efforts of duplication would also increase the probability of significant and/or unacceptable delays which could result in complete mission failure.

iii. Historical and competition data shows that a new contractor would need a minimum of a 90-day phase-in period alongside the incumbent, representing a quarter of the period of this proposed bridge modification. Based on historical costs on previous contracts and phase-in costs for the current contract, it is estimated that a new contractor in

CUI Page 7 of 15 phase-in costs, in addition to the costs of the incumbent. Although this amount of extra cost could possibly be recouped through competition for a new long-term contract, the Government would not expect it to be recouped through an award of a contract with a nine-month period or performance. Furthermore, conducting site visits, solicitation preparation, and the two-phased process to evaluate Organization Conflict of Interest (OCI) to ensure there are not any OCI�s all require additional time, based on historical timelines, anywhere from three to six months, prior to starting phase-in, which is not available. A contract could not be issued to a contractor that has not been evaluated for any OCI�s In accordance with ATEC Reg. 73-1 Regulation 73-1, System Test and Evaluation (T&E) Policy, dated 13 May 2019, which precludes Offerors from receiving ATEC T&E support contracts where those contractors may be tasked to evaluate their own products or services or the products or services of a competitor prior to submitting an entire proposal, would result in duplicative costs and effort for Government personnel.

iv.

a) v.

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Changes to EPG�s core competencies included adding requirements in support of Assured Position Navigation and Timing (APNT) and redefining requirement for Global Positioning Systems (GPS) testing and Electronic Warfare and Intelligence Surveillance and Reconnaissance Test Division (EW&ISR). In addition, there were directorates that were not properly aligned, others

CUI Page 9 of 15 that were not accounted for, and language added to allow for future growth based on Army modernization efforts and priorities with Army Futures Command. These changes were significantly important in order to accurately capture EPG�s mission and requirements to allow for Offerors to appropriately propose a technical solution and staffing. The final approved requirements package was received February 2022. The current contract expired 30 March 2022 and it was determined to exercise the six-month extension, extending the contract to 30 September 2022. In May 2022 the Mission Partner Technical Representative/Contracting Officer Representative (COR) requested to discuss the steps needed to request a bridge requirement based on unanticipated delays in the award of the competitive follow-on as it was apparent that in order to complete the below milestones for the re-compete, additional time would be required for the current contract.

Remaining Major Milestones of Re-compete:

The continuity of the SESS services is critical. It is essential that the support provided to soldiers during wartime does not have a lapse and ensures functionality on the battlefield of which the Government cannot risk mission failure. If this J&A is not approved, it will prevent EPG from providing direct support of Army Future�s Command for technical tests particularly pertaining to the Army�s Modernization Efforts utilizing CFTs; Command, Control, Communications, Computers, Intelligence, Surveillance and Reconnaissance (C4ISR) and Electronic Combat (EC)/Electronic Warfare (EW) services supporting the mission; maintaining classified and unclassified enterprise work; and supporting EPG�s local area networks. In sum, it could result in complete EPG mission failure. The Government�s need for continuity of operations and the potential of disruption to these operations are of the utmost important factors supporting approval of this J&A.

6. Efforts to Obtain Competition: The contracting office is currently preparing the

CUI Page 11 of 15 expiration date of 30 September 2022 without significant risk to critical service requirements and efforts already in place.

9. Interested Sources: There were no sources that responded to express interest in this short-term bridge action.

As discussed in paragraph 6 above and IAW DFARS 205.205-71, DFARS 206.302-1(d), and DFARS PGI 206.302-1(d), a RFI was posted to SAM.gov on 27 July 2022 and closed on 11 August 2022.

10. Other Facts:

a. Procurement history.

The USAEPG test mission has been supported by contracts since the 1950s. Since inception, USAEPG has been dependent upon Contractor personnel to support its mission. Over the years, as the USAEPG mission grew, Contractor support was achieved through multiple mission support contracts until 1996 when the decision was made to consolidate requirements under one comprehensive contract instrument. As a result, six separate support contracts were consolidated in late fiscal year (FY) 1996 into a single vehicle to provide range support and engineering support at Fort Huachuca, and engineering support at Fort Lewis. The following is a chronological summary of the last six contracts awarded to support this requirement. Prior data is not readily available due to organizational restructuring.

i. Contract W91RUS16C0006, Scientific and Engineering Support Services, awarded 01 April 2017 through 31 September 2022, inclusive of Federal Acquisition Regulation (FAR) 52.217-8, and included 60-day Phase-In, 16-month Base period and one 24-month option period and one 18-month option period. This Hybrid Firm-Fixed- Price (FFP)/Cost-Plus-Award-Fee (CPAF) contract was awarded under full and open competition to Jacobs Technology, Incorporated in the amount of

ii. Contract W91RUS16C0021, Scientific and Engineering Support Services, awarded 01 April 2016 through 31 March 2017; included 12-month Base Period. This CPAF contract was awarded as a Sole Source Bridge contract to ManTech Telecommunications and Information Systems in the amount of

iii. Contract W91RUS15C0019, Scientific and Engineering Support Services, awarded 01 June 2015 through 31 March 2016; included nine-month Base Period. This CPAF contract was awarded as a Sole Source Bridge contract to ManTech Telecommunications and Information Systems in the amount of

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iv. Contract W91RUS10C0001, Scientific and Engineering Support Services, awarded 01 December 2009 through 01 May 2015 and included a one 12-month Base Period, four 12-month Option Periods and six-month extension in accordance with FAR 52.217-8. This CPAF contract was awarded under full and open competition to ManTech Telecommunications and Information Systems in the amount of

v. Contract DAAD0700C0226, C4I Test and Engineering Support Services, awarded June 2000, included Four-year Base period and two two-year option periods.

The contract was awarded as a CPAF contract in the amount of to Newtec. Further information regarding the contract is not readily available since award and administration was done by Army Contracting Activity, Southern Region.

vi. Contract DABT6396C0028, Scientific and Engineering Services, awarded September 1996, included one year Base period and four one-year option periods;

ultimately, only three option periods were exercised. The contract was awarded as a CPAF contract in the amount of Computer Sciences Corporation. Further information regarding the contract is not readily available since award and administration was done by Army Contracting Activity, Southern Region.

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11. Technical 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.

12. 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.

13. Fair and Reasonable Cost Determination:

I hereby determine that the anticipated cost to the Government for this modification action will be fair and reasonable based upon cost analysis including comparison of proposed prices with current year prices, the Independent Government Estimate (IGE), and pricing under current contracts for similar services. In accordance with FAR 15.403- 4, certified cost or pricing data will be required.

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14. Contracting Officer Certification:

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

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Approval

Based on the foregoing justification, I hereby approve the modification of Contract W91RUS16C0006 for EPG Scientific and Engineering Support Services for an increase in the estimated amount of , and an extension of the period of performance for nine-months. This action is made on another than full and open competition basis pursuant to the authority of 10 U.S.C. § 3204(a)(1) as implemented by FAR 6.302-1, �Only one responsible source and no other supplies or services will satisfy agency requirements�, subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.