AFLCMC_C3CK Consolidation DF_ ACTT and PTT as AOC OATT_Redacted.pdf

DEPARTMENT OF THE AIR FORCE

DETERMINATION AND FINDINGS (D&F)

CONSOLIDATION OF CONTRACT REQUIREMENTS

for

Air Operations Center Communication Training Tool (ACTT) and Contract Command and Control Weapons System Part Task Trainer (C2WSPTT)

Pursuant 15 U.S.C. § 657q, as implemented by Federal Acquisition Regulation (FAR) 7.107-2 and Department of the Air Force Federal Acquisition Regulation Supplement (DAFFARS) 5307.107-2, and delegated IAW DAFFARS 5301.6, before conducting an acquisition that is a consolidation of requirements with an estimated total dollar value exceeding $2 million, the Senior Contracting Official shall make a written determination that consolidation of the requirements is necessary and justified.

FINDINGS

1. BACKGROUND:

(A) Contracting Organization:

This effort, the Air Operations Center (AOC) Operations and Administrative Training Tools (OATT), is being prepared by Kessel Run (C3C), Operations Command and Control Branch, Air Force Life Cycle Management Center (AFLCMC), Air Force Material Command (AFMC), United States Air Force

(USAF).

Current Requirements:

C2WSPTT SUSTAINMENT- This requirement was competitively solicited as a small business (SB) set-aside, under GSA Schedule 70. The resultant Task Order, is with

C2WSPTT is the modeling and simulation (M&S) tool that provides a small-scale, high-fidelity M&S capability to allow Combined Air Operations Center (CAOC) units to conduct in-garrison training without the need for outside agency support. It is designed to be used by operators to conduct interactive training not possible on operational systems. The system also provides a scenario creation capability and a training management capability which provides training status and progress. The estimated value of a standalone contract for these requirements is $ .

ACTT SUSTAINMENT- This requirement is currently met by contract with the Section 8(a) Alaskan Native Corporation (ANC), , IAW sole source acquisition authority defined at 13 C.F.R 124.506(b)(1) and accepted by the Small Business Administration (SBA) as requirement

. ACTT is a training framework for AOC system and network administrators to accomplish Mission Qualification Training (MQT). ACTT provides a unique environment for interactive training that can’t be achieved on operational systems. Additionally, the system provides a scenario creation capability and a training management feature which tracks training status and progress. The estimated value of a standalone contract for these requirements is .

2. FAR 7.107-2 CONSOLIDATION CONSIDERATIONS

FAR 7.107-2(a): Allows for a written determination that the consolidation is necessary and justified in accordance with 15 U.S.C. 657q, after ensuring that:

(A) MARKET RESEARCH (MR) HAS BEEN CONDUCTED (7.107-2(a)(1)):

The Government Acquisition Team conducted market research for the referenced consolidated requirement via a Request for Information (RFI) published, 5 June 2024, on SAM.gov. The intent of the RFI was to assess the technical capability of industry, with focus being given to Small Business. The questions contained therein were also tailored to assess the feasibility of alternative contracting approaches, to include continuing the ACTT and C2WSPTT requirements as separate efforts. The topic areas included but were not limited to, information on a company’s experience with the AOC weapon system, ability to maintain 98% uptime in accordance with the AOC Capability Development Document (CDD), an understanding of the challenges associated with providing training systems that remain synchronized with the weapon system and how to overcome those challenges, and to identify ramp-up processes required for organizations to perform and ensure continuity of support.

The Government received six responses. One was submitted by the ), which had been a small business at the time the current contract was awarded in FY20. The other five responses were from small businesses, to include the were found to be capable of fulfilling C2WSPTT requirements, while only could fulfill ACTT’s. The remaining four small businesses were determined to be incapable of performing either of the C2WSPTT or ACTT requirements, due to (a) incomplete information provided, (b) generic capability responses, (c) clear lack of experience, (d) citing contracts and acquisitions as relevant experience that when compared to the existing requirements were not relevant, and/or (e) ramp-up periods that coupled with the other shortcomings would not meet overall mission requirements. Based on the findings from market research, there is not a reasonable expectation of receiving competitive offers from two or more responsible small business concerns that meet fair market prices, quality, and delivery standards.

As it relates specifically to the C2WSPTT requirements, it is important to note that, as stated above, in FY20, a Small Business Set-Aside was conducted for the C2WPSTT requirements.

had entered an exclusive teaming arrangement with which is the developer of the development suite required at that time for C2WSPTT and was proprietary to In an effort to enhance competition for the follow-on, the 05 Jun 2024 RFI described the requirements in terms of a solutions-based approach, in which the Government would allow the contractor to propose a teaming arrangement to meet the Government’s needs based upon meeting sustainment uptime standards in the approved configuration, rather than dictating the solution, which would likely yield the same result as the past acquisition. Although only two contractors are currently deemed capable of performing the C2WSPTT requirements based on the market research, it suggests that a competitive acquisition strategy for those requirements could be considered. The , is familiar with the current configuration based upon past performance and collaboration and have confirmed their ability

IAW FAR 10.001(a)(3)(vi), the results of market research support the overall determination that consolidation is necessary and justified. Furthermore, IAW FAR 10.001(a)(3)(viii), market research supports the use of small business programs in accordance with FAR Part 19 to fulfill this requirement.

Specifically, market research supports the determination that the consolidated requirement is suitable for a sole-source Section 8(a) award to an ANC, IAW FAR Part 19.805-1(b)(2)

(B) ALTERNATIVE CONTRACTING APPROACHES THAT WOULD INVOLVE A LESSER

DEGREE OF CONSOLIDATION HAVE BEEN IDENTIFIED (7.107- 2(a)(2)):

The Government performed an analysis in consideration of continuing acquisition of the subject requirements for ACTT and C2WSPTT as separate contracts. As mentioned above, in addition to assessing the technical capability of market vendors, the market research questions contained in the RFI were tailored to assess the feasibility of alternative contracting approaches.

ACTT Alternatives

ACTT is currently a requirement under the 8(a) program. IAW 13 CFR § 124.504(d)(1), if a procurement is awarded as an 8(a) contract, its follow-on requirement must remain in the 8(a) Business Development (BD) Program unless the Small Business Administration (SBA) agrees to release it for non-8(a) competition. The determination of whether a particular requirement or contract is a follow-on includes consideration of whether the scope has changed significantly, requiring meaningful different types of work or different capabilities; whether the magnitude or value of the requirement has changed by at least 25 percent or equivalent periods of performance; and/or whether the end user of the requirement has changed. The ACTT portion of the subject requirements have not changed such that they would satisfy any of these conditions that would distinguish it as ‘new’ requirement. Therefore, it will remain in the 8(a) BD program.

DFARS 219.808-1 authorizes the award of a sole-source 8(a) contract up to $100M, without an accompanying justification in accordance with FAR 6.303 and DFARS 206.303-1(b). Therefore, based on the results of market research and the requirements of the 8(a) BD program, the only other feasible alternative contracting approach that would involve a lesser degree of consolidation to consider is to award a follow-on sole-source contract for ACTT within the 8(a) BD program and award C2WSPTT in some other fashion.

C2WSPTT Alternatives

Market research identified the existence of one large (C2WSPTT incumbent) and one small, 8(a) SDB (ACTT incumbent) business capable of performing the C2WSPTT requirements. Based on these results, there is not a reasonable expectation of obtaining offers from two or more responsible small business concerns that are competitive in terms of fair market prices, quality, and delivery, and thus the Government is unable to set aside the C2WSPTT requirements for small business. Full and open competition of the C2WSPTT requirements would be an alternative contracting approach to consolidation; however, full and open competition is not a suitable strategy to maximize small business participation or contribute towards the use of SDBs in accordance with Executive Order 14091, which calls for agencies to leverage small business growth in the nation’s supply chain. Furthermore, while competition between these two vendors may achieve cost benefits, these benefits are outweighed by other benefits of consolidation as outlined in Section 3 below.

If not consolidated and if not competed, market research does support a decision to award the C2WSPTT requirement as an 8(a) sole source contract to as a second contract. However, similar to a competitive award, this is less beneficial than consolidation as outlined in Section 3 below.

(C) SMALL BUSINESS CONSIDERATIONS REFERENCED AT FAR 7.107-2(a)(3-5) HAVE BEEN

MADE:

The preliminary strategy to consolidate requirements and award a follow-on contract to the ACTT incumbent was coordinated with the Hanscom OL SB Office and the SBA 8(a) BD Program Business Opportunity Specialist. Market Research has not identified any negative impact on small business concerns. Both requirements were previously performed by small businesses and the consolidated requirement is planned for award as a sole-source 8(a) action. This acquisition strategy approach was also conditionally approved

3. BENEFITS OF CONSOLIDATION:

The specific benefits of consolidation are outlined as follows:

(A) QUALITY (7.107-2(c)(1)):

A consolidated requirement creates synergy between the two functional groups of personnel actively working training support for both sides of the AOC training mission: Under the proposed consolidation, one contractor is responsible to maintain training environments for AOC operators as well as system and network administrators. This will result in a centralized problem and solution source. This centralization will promote dynamic multi-faceted informed problem solving and training space design that more effectively considers administrative technical integration and application of AOC systems. In addition, this collaboration can identify common and frequent outages due to operator error and offer opportunities to enable fast fix and repair, as one contractor would be responsible for both the front end and back-end training requirements. Consolidation of the two separate teams under a single contractor allows easier cyber monitoring and safeguarding and reduces potential cybersecurity human vulnerabilities. All the aforementioned factors will provide quality in the form of increased performance efficiencies, service levels, and security.

(B) REDUCTION IN ACQUISITION CYCLE TIMES (7.107-2(c)(2)):

Consolidation provides benefits in the form of reduced Government manpower resources and a reduction in the number of acquisitions required initially and throughout administration. ACTT and PTT are complementary tools. Through scenario-based training, ACTT educates AOC System Administrators how to make changes to the weapon system and PTT is the user facing tool that simulates how the systems in the AOC work given an operational scenario. Each time the AOC 10.1 baseline is updated, whether it be an upgrade or integration of a new system or technology, both PTT and ACTT need to be updated to reflect that change. One consolidated contract means a smaller footprint with respect to the multi-functional team required to award not only the instant action, but to work through the administration. By running the requirement as one effort, schedule conflicts that could occur with concurrently running acquisitions are avoided and the length of time it would take to implement those disparate changes is potentially reduced. This consideration is not limited to those directly assigned to the evaluation team; external reviews are reduced as well. Legal, SB Office, Business/Contract Review and Clearance, and other external support requirements are cut in half.

(C) BETTER TERMS AND CONDITIONS (7.107-2(c)(4)) AND OTHER BENEFITS:

Contract Management Benefits

As ACTT and PTT are complementary capabilities there is some overlap in responsibilities.

Consolidation of these requirements will a) eliminate duplication; b) introduce efficiencies; c) allow for simplified program management and lower overall costs. A single contract will reduce otherwise duplicated acquisition processes and post award administration effort, such as PMRs, IPTs, CDRL submission, personnel management and all other necessary contract management functions.

Furthermore, there is a reduction of resources required to perform administrative actions such as closeout, COR appointment, invoice processing, and contract performance management duties. A single contract permits flexible maximization of staffing resources across the program supporting the contractor and the Government to meet compliance and program needs while promoting increased quality as addressed above.

Reduction of Government and KR Contractor Costs

The Government has performed a cost- benefit analysis in consideration of the strategy to consolidate the referenced requirements. The total potential savings of includes an expected reduction of in direct costs because of potential efficiencies gained by syncing software package deliveries, the concept of one program manager refining the technical delivery of both teams, and efficiency gained in asset inventory. The analysis also revealed an additional in projected savings associated with a reduction in the number of ACAs to be executed between contractors awarded AOC support and sustainment contracts.