A17_JA_FAR_13_501_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

PR/SOL/CONTRACT # DOIDFBO220053

SOLE SOURCE JUSTIFICATION

SIMPLIFIED PROCEDURES FOR CERTAIN COMMERCIAL ITEMS

AUTHORITY: FAR 13.501(a), 41 U.S.C. 1901

PR/SOL/CONTRACT # DOIDFBO220053

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Sole Source Justification.”

This document is a sole source justification for the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division 2, Branch I, on behalf of the DOI Office of Aviation Services (OAS), Alaska Office.

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

This is a non-personal services for a contractor to provide a subscription for Maintenance Library Services.

The proposed vendor is Aircraft Technical Publisher (ATP) located at 101 South Hill Drive, Brisbane, CA 94005-1203.

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

This is a small business single source to ATP that provides access a library of a whole group of aircraft manuals, technical publications and regulatory content for research related to maintenance of the aircraft. Those manuals span many different makes and models; the publications coming from many different companies.

The estimated value for this action is $ for a base period of twelve months and four twelve month option periods.

4. An identification of the statutory authority permitting sole source acquisition.

This is an acquisition conducted under the authority of the Simplified Procedures for Certain Commercial Items. The statutory authority permitting sole source acquisition is 41 U.S.C 1901 as implemented by FAR 13.501(a)(1)(ii).

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

Aviation is a FAA license-regulated industry. To maintain current licensing, aircraft mechanics and inspectors are required to have immediate and continuous access to manufacturer and regulatory data. When performing aircraft maintenance, mechanics and support personnel are required to research current manufacturers and regulatory data to be certain that DOI is in compliance with all requirements.

The DOI OAS, Alaska Regional Office, operates a FAA certified repair station. In order to maintain its FAA repair station certification status, OAS must be able to show proof to the FAA that they continuously maintain an FAA-approved technical publication library applicable to each aircraft manufacturer’s model contained in the aircraft fleet. Proof of library currency must be presented during the annual FAA Repair Station Inspection or at any time an FAA representative requests it. If a comprehensive, technical, and regulatory aviation library is not continuously maintained, the OAS will lose their FAA Repair Station Certification. If that were to happen, the Office of Aviation Services would have to ground approximately 50 DOI aircraft, maintained by the Alaska OAS Repair Station.

Technical data is in a continuous state of change as aircraft are flown, maintained, and reengineered to improve or mitigate problems that appear during operations and maintenance. Because data can change so rapidly, technical publications are updated periodically. In order to retain continuous currency, aircraft owners, operators, and maintenance personnel must maintain a subscription from a manufacturer and FAA- approved source.

Aircraft Technical Publishers (ATP) subscription services allow DOI to electronically integrate DOI maintenance records with manufacturer and regulatory data retrieved from ATP, allowing maintenance profiles for each aircraft to be continuously updated with current data. ATP profiles allow maintenance personnel to integrate fleet aircraft information such as

(1) Airworthiness Directives (AD’s), (2) Service Bulletins (SB’s), and (3) aircraft weight and balance data. Changing revision service providers would require maintenance record updates and rewriting of individual aircraft records.

Changing to a different provider would cause DOI to incur additional, indirect costs for

(1) retraining staff and (2) loss of production time during data conversion and retraining.

Conversion to an alternate provider may compromise safety of aircraft operations and create maintenance delays during conversion. Due to these potential risks to safety and the indirect purchase costs incurred when converting to a new program, changing service providers is only beneficial if the new provider offers superior enhancements and services that do not overlap with the current provider.

For this procurement, award to any other source would result in (1) duplication of cost that the Government could not expect to recover through competition; i.e. retraining, additional time performing data searches in an unfamiliar program, data entry for each aircraft, and aircraft record update costs, as well as (2) unnecessary and unacceptable risks to the safety and integrity of the DOI aviation fleet operations.

6. A description of 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 FAR Subpart 5.2 and, if not, which exception under FAR 5.202 applies.

A Notice of Intent (NOI) to Sole Source was posted via System for Award Management (SAM.gov) on June 13, 2022, and an amended NOI posted on June 24, 2022, serving as notification to publicize under FAR 5.2.

One response was received, which the Government evaluated

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

As required by DOI-AAAP-0024, Enhancing Competition, pricing received will be compared to current marketing pricing since quotes will be received from only one source.

The CO will evaluate the price and make a fair and reasonable price determination prior to award.

Price reasonableness will be based upon comparisons with similar items in related industry, comparison to IGE and the CO’s personal knowledge of the services being purchased.

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

A NOI to Sole Source was posted to Systems for Award Management (SAM.gov) on June 13, 2022, and an amended NOI posted on June 24, 2022, with responses due no later than 6:00 PM EST on July 6, 2022. One Capability Statement response was received by The customer, OAS reviewed capability statement and determined that they did not show, based on the information provided, the ability to address or perform the required service.

Additionally, market research was conducted by reviewing information from the Government subject matter experts, historical contract information, and other web-based schedules and databases. This market research indicated that there is no capable source, other than the incumbent, as ATP provided libraries are based on a single source concept. ATP collects and organizes thousands of publications from hundreds of manufacturers and government agencies. A subscription to publications from a single source library is a cost-effective, time-saving tool.

Based on this research, it has been determined that ATP is the only vendor who can meet the requirements.

9. Any other facts supporting the use of other than full and open competition, such as:

None.

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

Aircraft Technical Publishers

11. A statement of the 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.

In the future, OAS and the Contracting Officer will consider any FAA approved aviation mechanic libraries that enter the market for suitability, uniformity, and safety for use on the OAS fleet.

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.

Contracting Officer

13. Requirement’s 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.

Fleet Support Specialist

14. Reviews and Approvals

Concur

Branch Chief

15. Reviews and Approvals

Approved

Division Chief