Attachment 0003 - Brand Name Justification (Redacted).pdf

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

CONTROLLED UNCLASSIFIED INFORMATION

March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 2 of 5March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 2 of 5

I. Contracting Activity.

The contracting activity responsible for this proposed brand-name procurement is the 48th Contracting Squadron (48 CONS), located at Royal Air Force Lakenheath, United Kingdom.

II. Nature and/or description of the action being processed.

This requirement will be awarded as a new firm-fixed-price (FFP) contract. The contracting action will not be a modification to an existing contract. A firm-fixed-price contract is planned to ensure price certainty and clearly defined deliverables associated with the engineering, furnishing, installation, and testing (EFI&T) of the required telecommunications equipment.

III. Description of supplies/services required to meet agency needs.

This acquisition is for the procurement, installation, and commissioning of fiber optic communications transport equipment in support of the Flight Systems Communications Upgrade (FSCU) at RAF Mildenhall, United Kingdom. The requirement includes engineering, furnishing, installation, and testing (EFI&T) of TC Communications brand-name telecommunications interface systems that replace obsolete Time Division Multiplexing (TDM) Charles Channel Banks and copper Outside Plant (OSP) connectivity. The equipment must support legacy analog and digital signal types (such as 4-wire E&M, FXO/FXS, RS-232/422, and contact closures) and enable their transmission over fiber optic infrastructure. This upgrade is necessary to maintain safe, reliable, and mission-critical voice, data, and radio connectivity across seven facilities supporting airfield operations and emergency communications.

The total estimated value of this acquisition is , and the requirement will be funded using Operations and Maintenance (O&M) appropriation 3400.

IV. Statutory authority permitting other than full and open competition.

DAFFARS 5313.501- 10 U.S.C. 3572, Implementation of Simplified Acquisition Procedures (41 U.S.C. 1901)

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

The supplies and services required under this acquisition are unique in nature and demand highly specialized technical capabilities only provided by TC Communications Inc. This justification supports the use of the brand name authority under FAR 13.501(a)(1)(ii), as implemented by DAFFARS 5313.501, because only one brand of equipment, the TC Communications TC8000 series and TC3800 series (JumboSwitch), can satisfy the government’s minimum requirements in both the supply and service aspects of the acquisition.

The supply portion of this requirement includes the procurement of telecommunications transport equipment capable of interfacing with a diverse set of legacy and mission-critical Air Force systems including Instrument Landing Systems (ILS), Tactical Air Navigation (TACAN), Primary Crash Network (PCN) circuits, remote weather sensors, and various radio and data systems used by the 100th Operations Support Squadron (OSS) at RAF Mildenhall. These systems currently rely on analog audio (600 ohm), 4 wire E and M signaling, RS-232 and RS-422 serial data, FXO and FXS voice lines, and contact closure circuits, many of which are transported over copper infrastructure. The existing transmission solution, based on Time Division Multiplexing (TDM) Charles Channel Banks, is now obsolete, no longer supported, and incompatible with modern fiber optic transmission standards required by the Air Force. The new system must provide seamless conversion and transmission of these diverse signal types over a fiber optic network, with proven reliability, modular scalability, and compatibility with Department of Defense (DoD) network architecture.

TC Communications is the only known manufacturer that produces a fully integrated fiber optic transport platform (TC8000 and TC3800 series) capable of supporting all the required analog, digital, and IP interfaces within a single system architecture. Other manufacturers provide partial solutions or niche devices, but none offer a comprehensive platform that can meet all signal type, port count, and environmental reliability requirements. Attempting to assemble a hybrid system using multiple brands would significantly increase integration risk, introduce potential compatibility

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 5March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 5 issues, extend system downtime, and impose higher lifecycle sustainment costs due to disparate training, spare parts, and technical support requirements. Furthermore, TC Communications has incorporated legacy Air Force signaling standards directly into their platform, eliminating the need for signal converters or protocol translators that would otherwise add complexity and failure points.

In addition, the TC Communications solution is already standardized within Air Force Engineering and Installation (E and I) teams and has been successfully fielded at several Air Force installations in nearly identical applications including NAVAIDs and ATCALS upgrades. Standardized installation diagrams, training materials, and configuration guides exist specifically for these models, which supports interoperability, reduces training time, and ensures technician readiness across multiple installations. This established compatibility and standardization further justifies the brand name requirement, as no other equipment offers such an integrated and mission aligned solution.

On the services side, this acquisition also includes the engineering, furnishing, installation, and testing (EFI&T) of the equipment into operational use across seven dispersed facilities at RAF Mildenhall and one location at RAF Lakenheath.

Due to the sensitive and safety critical nature of the systems involved, including the airfield systems that directly impact flight operations, it is imperative that the contractor performing the installation be intimately familiar with the TC Communications hardware and its configuration. The use of any other contractor or brand of equipment would require significant design and engineering effort to develop interface solutions that match the existing signal types, which would increase costs and delays while risking mission interruption.

Given that TC Communications is the sole manufacturer of the TC8000 and TC3800 series equipment and that their products are only available directly from them or their authorized resellers, this procurement meets the threshold for a brand name acquisition under simplified acquisition procedures. Both the supplies (telecommunications hardware) and services (EFI&T) are inseparable in this context and are uniquely tied to the TC Communications platform to ensure mission continuity, system compatibility, and operational safety.

Therefore, this acquisition meets the conditions set forth in FAR 13.501(a)(1)(ii) for brand name justification using simplified acquisition procedures and is authorized under DAFFARS 5313.501.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

Market research was conducted to identify potential sources capable of meeting the government’s minimum requirements. This included reviewing previously fielded solutions across other Air Force installations, consulting with engineering and installation (E and I) teams, and analyzing existing technical data. The findings confirmed that TC Communications is the sole manufacturer of the only known telecommunications platform capable of supporting all legacy and current signal types over fiber optic transport within a single integrated system.

While the equipment is manufactured solely by TC Communications, it is available through multiple authorized resellers and distributors. Therefore, solicitation will be conducted on a competitive basis among these authorized resellers to the maximum extent practicable. A brand name justification will be posted along with the solicitation on SAM.gov to ensure transparency and provide interested vendors the opportunity to submit quotes for the brand name equipment in accordance with FAR 13.501(a)(1)(iv). This approach balances the mission-critical requirement for standardized, technically compatible hardware with the intent to foster competition among authorized sellers.

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable. This determination is based on historical pricing data from similar acquisitions at other Air Force installations where the same TC Communications equipment was procured and installed, along with comparison of current price quotes from authorized distributors. In addition, market research has indicated price consistency across available resellers, affirming that the equipment pricing aligns with current industry rates for similar high-reliability, fiber-optic telecommunications transport solutions.

To ensure the final contract price is fair and reasonable, the Government will request multiple quotes from authorized resellers of TC Communications equipment. A price analysis will be conducted in accordance with FAR 13.106-3(a)(1), Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 4 of 5March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 4 of 5 comparing these quotes against each other and against previous contract prices for similar systems. Certified cost or pricing data is not required under FAR 13.5 procedures, however, if determined necessary, the Contracting Officer may request further cost information to support pricing conclusions. A technical evaluation will also be conducted by qualified government personnel to validate that the quoted solution meets all performance and interoperability requirements outlined in the Statement of Work (SOW).

For the installation services are included, a separate evaluation of labor hours, rates, and implementation scope will be reviewed to assess reasonableness. The combination of market comparison, price history, technical validation, and quote competition among authorized sources provides the Contracting Officer with sufficient assurance that the final contract award will reflect a fair and reasonable cost to the Government.

VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

Comprehensive market research was conducted in accordance with FAR Part 10 to determine the availability of equipment and services capable of meeting the Government’s unique telecommunications requirements for the Flight Systems Communications Upgrade (FSCU) and Primary Crash Network Upgrade (PCNU) at RAF Mildenhall. This research included reviewing prior installations at other U.S. Air Force bases, consultation with Air Force Engineering and Installation (E and I) teams, analysis of vendor capabilities through government sources such as SAM.gov, and outreach to industry participants.

Findings confirmed that while several vendors offer fiber-optic communications solutions, only TC Communications Inc. manufactures equipment that fully meets the Air Force’s interoperability requirements. TC Communications is the sole manufacturer of this equipment; however, they are not the sole distributor. The equipment is available for purchase through several authorized and approved distributors, including:

IX. Any other facts supporting the use of Other Than Full and Open Competition.

Several Air Force agencies, including Air Force Materiel Command (AFMC), Air Force Flight Standards Agency (AFFSA), Air Combat Command (ACC), Air Mobility Command (AMC), and Air Force Engineering & Installation (AF E&I), as well as several U.S. Army organizations, have extensively researched equipment to fill the technical and operational gap left by discontinued legacy channel banks and TDM systems. No manufacturer other than TC Communications has been willing to continue production of equipment that supports outdated communications standards. TC Communications has uniquely incorporated legacy protocols into a modernized and sustainable fiber optic product line that bridges both current mission needs and future scalability. Their equipment can support all required interfaces, voice, data, contact closure, and analog phone, while also being adaptable to meet future Defense Information Systems Network (DISN) or protocol upgrades.

X. List of any sources that expressed, in writing, an interest in the acquisition.

While no sources have submitted formal written statements of interest specifically in response to this acquisition, multiple authorized distributors have been identified through market research as capable of supplying the required TC Communications equipment. These include

Although none have formally expressed written interest, their established relationship with the manufacturer and confirmation of product availability indicate a strong likelihood of participation upon solicitation.

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.

The requirement to interface legacy communications and navigational systems with modern fiber-optic transport infrastructure remains a persistent and foreseeable need across the Air Force enterprise. The current NAVAIDs and

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 5 of 5March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 5 of 5 related communications equipment at RAF Mildenhall, as well as similar equipment installed across other installations, have only recently been procured and installed, with a projected life expectancy exceeding 25 years. As such, the demand for compatible transport and interface systems that can bridge older signaling formats with current and future data transport protocols will persist for the foreseeable future.

Because TC Communications is the sole manufacturer offering an integrated, sustainable solution that supports these older standards while remaining scalable for evolving network requirements, it is expected that future acquisitions of similar scope and functionality will also require brand name or single-source justification. While the Government continuously evaluates emerging technologies and alternative sources, no other manufacturer has demonstrated the capability or willingness to support these legacy protocols at scale.

Efforts to foster competition for future acquisitions will include regular reviews of market capabilities, outreach to industry through Requests for Information (RFIs) when feasible, and coordination with engineering and technical stakeholders to identify whether newer solutions or alternate interface designs become available. If viable alternatives are identified, actions may be taken to qualify additional sources or plan for competitive follow-on acquisitions where possible. However, due to the specialized nature of the requirement and existing system standardization around TC Communications equipment, barriers to competition are expected to remain unless another manufacturer develops a comparable product suite.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.