B25_DF_Bundle_Consolidate_FST_Redacted.pdf

D&F No.: CR-25319

CODE: NSWC Crane 0242

DETERMINATION AND FINDINGS

AUTHORITY TO CONSOLIDATE AND BUNDLE CONTRACT REQUIREMENTS

Upon the basis of the following findings pursuant to the authority of Title 15, United States

Code, Section 644(e), as implemented in Federal Acquisition Regulation (FAR) Subpart 7.107-1 and 7.107-2, and the Navy Marine Corps Acquisition Regulation Supplement (NMCARS)

5207.107-2, it is hereby determined that requirements under the two task orders described below which provide for Engineering, Technical, Logistics, and Programmatic support services for the

Airborne Electronic Attack Systems Division (AEASD), to support the Electronic Warfare (EW)

Fleet Support Teams (FST) tasking may be consolidated and substantially bundled. The proposed effort is anticipated for award in May 2026 and has an estimated value of .

FINDINGS

1. Identification of Agency and Contracting Activity

This Determination and Findings has been prepared by the Naval Surface Warfare Center, Crane

Division (NSWC Crane), Crane, Indiana, a Department of the Navy contracting activity under the authority of the Naval Sea Systems Command (NAVSEA).

2. Nature/Description of Action

NSWC Crane is executing this competitive service acquisition in support of various programs on behalf of AEASD for non-personal FST support services. This acquisition will deliver full life cycle support for Airborne EW Systems (Electronic Surveillance (ES), Electronic Protection

(EP), Electronic Countermeasures (ECM), and Electronic Attack (EA)) through engineering, software development, in-service support, measurement facilities, interoperability testing, research and development, modeling/simulation, prototyping, documentation, reliability/maintainability support, inactivation/disposal, quality assurance, training, assessments, database administration, logistics, configuration management, and comprehensive IT support – ensuring robust design, development, sustainment, and upgrade capabilities. This Determination and Findings addresses the proposed acquisition strategy involving consolidation, bundling, and substantial bundling. The requirement will be fulfilled through the award of one SeaPort-NxG task order for FST support services. The requirements are currently being fulfilled under two separate SeaPort-NxG task orders: N00178-04-D-4119-N0016419F3010, valued at $116M, and held by Science Applications International Corporation (SAIC) (a large business), and N00178-

19-D-8321-N0016423F3008, a small-business set aside valued at $39M, and held by Precise

Systems (now a large business, although initially a small business concern at time of task order award).

DEPARTMENT OF THE NAVY

NAVAL SURFACE WARFARE CENTER

CRANE DIVISION

300 HIGHWAY 361

CRANE INDIANA 47522-5001

IN REPLY REFER TO:

Large Yes

Small Yes

Based upon the responses to the three RFI/SSNs and a technical review of the responses, it was determined that three large businesses and one small business can meet the requirements of this procurement.

4. Assessment of the specific impediments to participation by small business concerns as contractors that result from substantial bundling.

The primary impediment to small business participation associated with the proposed consolidation and bundling of Task Order No. N0016419F3010 and Task Order No.

N0016423F3008 is the change in size status of several businesses since those task order awards.

Task Order No. N0016419F3010 was an unrestricted, fair opportunity SeaPort-NxG competitive procurement, while Task Order No. N0016423F3008 was a SeaPort-NxG small business set-aside procurement (an exception to the fair opportunity process). Since those awards, several small businesses have grown into large businesses, which limits the Government’s ability to set aside this new, bundled requirement for small business concerns while still meeting the key requirements. Market research indicated no significant difference in the Government’s ability to promote small business participation at the prime contract level whether the procurement was consolidated and bundled, maintained as the status quo, or further segmented into three areas instead of two. This condition exists as the three largest small business contributors that had been performing on the two task orders identified in above Table 1 are now classified as large business concerns. While the market research associated with the prospect of breaking out a small segment of support services indicated potential interest/capability of small business concerns, pursuing such a breakout would introduce inefficiency through the incorporation of a third, significantly smaller task order , while only marginally enhancing small business participation. Therefore, NSWC Crane has concluded that consolidating and substantially bundling the requirements does not itself result in significant impediments to participation by small business concerns as contractors. This strategy also optimizes small business participation at the subcontract level, as discussed in Section 6 below.

5. Actions designed to maximize small business participation as contractors, including provisions that encourage small business teaming

To ensure that small business concerns are afforded maximum practicable opportunity to participate in the consolidated and substantially bundled acquisition in a prime contractor capacity, a series of intentional outreach activities were conducted by the acquisition team.

These industry outreach engagements helped facilitate networking and potential teaming opportunities for small businesses.

As discussed in Section 3 above, to explore the potential for small business set-aside procurements, the Government issued three RFI/SSNs to industry. The RFI/SSNs sought industry feedback to help determine whether segmenting these two task orders into three areas –

(1) Support Services; (2) FST Services; and (3) Depot Support Services – would enable the

Government to conduct a small business set-aside procurement for either a segment or a combination of two segments. The Market Research conducted revealed that the evolution of the market for the required services during recent years has resulted in the growth of previously available small business concerns into large business concerns. It was concluded that the best avenue for the Government to maximize small business participation was to analyze the FST tasking historically performed under the two current task orders (N0016419F3010 and

N0016423F3008) to determine which FST tasking had previously been successfully performed by small businesses that remain classified as small business concerns, and to have the NSWC

Crane Requiring Technical Activity (RTA) perform a secondary review to determine if there is any anticipated new tasking that is expected to fall within the capability level of small business contractors. As discussed above, this research and evaluation indicated that only a very small segment of work is suitable for small business performance at the prime contractor level. This in turn resulted in the decision to compete the follow-on competitive FST SeaPort-NxG procurement on an unrestricted fair opportunity basis, and to identify an appropriate minimum small business participation threshold that offerors would be required to achieve to be eligible for task order award. The intended approach for maximizing small business participation at the subcontract level is further addressed in Section 6 below. The Government issued a draft FST solicitation on 18 November 2025 to promote the participation of small business concerns, and to provide an early-on depiction of the FST requirements and procurement to provide additional time for small businesses to explore teaming opportunities.

During the acquisition planning process, the acquisition team consulted with the NAVSEA

Director of Small Business Programs, SEA 00K, on multiple occasions, concluding on 25

September 2025 with SEA 00K concurrence with the subject consolidation and substantial bundling action.

6. Actions designed to maximize small business participation as subcontractors at any tier under the order, that may be awarded to meet the requirements

With respect to the current task orders, it has been determined that Task Order No.

N0016419F3010 (SAIC, $116M) includes in FST tasking, while Task Order No.

N0016423F3008 (Precise Systems, $39M) includes in FST tasking, resulting in a total of across both orders. SAIC’s most recent subcontracting report indicates that of the in FST tasking under Task Order No. N0016419F3010 was subcontracted to small businesses. Task Order No. N0016423F3008, initially awarded as a small business set-aside to

Precise Systems (a small business concern at the time), resulted in in FST tasking performed by Precise Systems and its similarly situated companies. Consequently, the total small business contribution to FST tasking across the two task orders was out of , representing . When setting the minimum small business contribution percentage for this follow-on FST procurement it was important to consider the fact that the three historically largest small business contributors are now large businesses. Taking this into account, the subcontracting data illustrates that only of the existing FST tasking is currently performed by businesses classified as small. Considering this level of small business contribution, the NSWC Crane Procuring Contracting Officer (PCO) consulted the RTA to determine if a 9% minimum small business contribution threshold would be viable given the planned increase in FST tasking of from . Market research, familiarity with the FST requirement, and analysis of the industrial base indicate that increasing small business participation beyond 50% of the small business contribution under the existing Table 1

FST tasking levels (adjusted to reflect current market conditions) would negatively impact effective competition and successful technical execution on the follow-on FST requirement.

Based on the initial assessment, a 10% small business contribution threshold was deemed most appropriate for the follow-on FST solicitation. A subsequent e-mail survey was sent to the four businesses identified as capable of performing the consolidated and bundled FST requirement. The survey solicited their corporate opinions on the maximum achievable and reasonable small business contribution threshold that would support effective competition and avoid negatively impacting technical performance.

recommended a maximum threshold of 20%, while recommended 30%. To minimize potential negative impacts on effective competition and technical execution, the NSWC Crane PCO, SEA 025C, and the SEA 00K Director and Deputy

Director of Small Business Programs jointly decided to set the minimum small business contribution threshold at 20% of the proposed total task order value.

Based on the historical small business participation under the current FST task order and the results of the previously stated market research efforts, the Government will require offerors to demonstrate how they will provide at least 20% of the proposed total estimated amount of the task order to small business concerns on the subject follow-on procurement. This threshold is considered to represent the optimum small business participation that can be achieved in executing subject requirement without negatively impacting the prospect of effective competition, and the successful technical execution of the requirement.

The combined value of the two current task orders (N0016419F3010 and N0016423F3008) is attributed to FST tasking ( under N0016419F3010 and under

N0016423F3008). Of this in FST tasking, was completed by small business concerns ( under N0061419F3010 and under N0016423F3008). While the three primary small business contributors on these task orders have since exceeded small business size standards, the follow-on FST task order, valued at , includes a minimum 20% small business contribution threshold. This is expected to result in approximately being allocated to small business concerns, compared to under the current FST tasking. Therefore, this acquisition strategy is expected to provide for maximum practicable participation by small business concerns.

To ensure that a large business prime offeror meets the minimum small business participation percentage as set forth in the solicitation during task order execution, the following performance monitoring will be conducted:

• The obligation made by the contractor in their proposal will be incorporated into the resulting task order; therefore, the proposed Small Business Participation percentage will become a material part of the task order.

• Small Business Participation will be an element that will be monitored and evaluated via the Quality Assurance Surveillance Plan (QASP).

• The SeaPort-NxG Standard Operating Procedure states, “All SeaPort Prime MAC holders

(large and small businesses) are required to report actual subcontracting data twice per year for each active task order in the SeaPort portal.”

• The Government will use the Contractor Performance Assessment Reporting System to document the prime contractor’s adherence to the Small Business Participation percentage that was included in its proposal. This includes a specific section to rate small business participation. If the prime contractor is not meeting the small business participation percentage during execution, the Government has the ability to provide a rating of marginal or unsatisfactory.

• As stated in FAR 17.20-4-1(b)(3)(iv), Exercise of Options, “The contracting officer may exercise options only after determining that, the contractor’s performance on the current contract has been acceptable (for example, satisfactory or better performance ratings).” If the Government assesses that the prime contractor is not performing satisfactorily in the area of small business participation, the Government has the option to not exercise out-year periods.

7. Benefits of planned consolidation and bundling and justification of their use

NSWC Crane has determined that the consolidation, bundling, and substantial bundling of task orders N0016419F3010 (SAIC) and N0016423F3008 (Precise Systems) into one combined follow-on action provides significant benefits to the Government. These benefits are tangible to the Government in terms of mission alignment, quality and schedule, cost savings, and efficiency-induced, non-quantifiable favorable cost impact.

The expected benefits in terms of mission alignment, quality and schedule are critical NSWC

Crane AEASD in providing FST support services. These benefits are as follows:

Mission Alignment: The scope of work for the FST task order directly supports Airborne EW activities for the

The proposed consolidation and bundling of FST requirements from N0016419F3010 and N0016423F3008 (which arrange the work by support for covered developmental and fielded systems, respectively) provide enhanced opportunities for efficiency in movement of contractor personnel between projects as requirements increase or decrease because the proposed task order will be dedicated to providing FST-specific subject matter expertise and experience. Furthermore, focusing on the area of FST expertise should reduce the learning curve of employed personnel while encouraging proficiency in FST mission requirements; improve training program efficiencies by increasing depth of FST specific knowledge; and allow contractor recruiting and retention efforts to focus on FST tasking specifically, which should result in a higher quality pool of talent to perform FST tasking.

Quality and Schedule: To again solicit, compete, and award separate task orders for FST services, is inefficient and would decrease consistency in the quality of services provided relative to the proposed approach. There would be duplicative Contract Data Requirements List (CDRL) and Data Item Descriptions (DID) deliverables and management of CDRLs and DIDs. The consolidation of the FST support will also reduce overlap and eliminate barriers between contractors, leading to an overall improvement in the delivery and quality of services. Instead of being in competition with the other contractors performing similar FST scope work under separate task orders, the FST task order awardee performing the consolidated FST task order would hire and manage staffing resources to service all FST requirements. An additional benefit is flexibility for the contractor to shift resources to meet surge requirements. Consolidation of the FST support will increase the quality and timeliness of services provided by having fewer task orders with FST scope and consistent terms and conditions.

Cost Savings: Based on an analysis it was determined that consolidation and bundling would eliminate contractor program management and administrative redundancies and increase efficiency associated with FST tasking in utilizing the same contractor to integrate functions and reduce contracting costs. Although these savings are not readily quantifiable, this consolidation and bundling action would result in efficiency-induced cost savings to the government. As this proposed action represents a partial consolidation and bundling of requirements from two task orders, quantifiable savings cannot be rightfully claimed in meeting the FAR 7.107-3(d)(2) threshold of to be considered a measurably substantial benefit.

However, the requested consolidation and bundling action is critical to the agency’s mission success; and also provides for maximum participation by small business concerns. Further, as the market research associated with the consolidation of FST tasking (RFI No.

N0016425SBN84) reflected a greater degree of industry interest than the initial market research

(RFI No. N0016425SNB12), there is a greater probability of achieving effective competition on the consolidated FST requirement, which may result in competition-induced savings to the

Government.

8. Alternate Acquisition Strategies

At the conclusion of the market research analysis described in Section 3 above, the EW technical team and the Code 024 contracting team at NSWC Crane conducted additional discussions to determine alternative acquisition strategies. The alternatives considered were (1) retaining the existing structure of the two task orders competed with the same approaches as previous in a manner consistent with the prior procurements (one unrestricted, one small business set-aside);

(2) segmenting the requirements from the current two task orders into three task area segments, with the goal of promoting small business participation at the prime contract level; and (3) consolidating and bundling the FST portions of the two current two FST task orders, which have a high degree of comparability and overlap, into a single task order procurement to achieve program efficiencies and improved service delivery.

The market research and subsequent discussions resulted in an acquisition strategy focused on analyzing current task orders N0016419F3010 and N0016423F3008 to align taskings and reduce performance overlap. Task Order No. N0016419F3010 provided Developmental Engineering

Support Services, while Task Order No. N0016423F3008 focused on Sustainment Engineering

Support Services for the same EW programs and systems. While maintaining the existing task order structure would have involved less consolidation and bundling, market research did not identify at least two or more small business concerns capable of fulfilling the requirements under the current structure. As discussed in section 4 above, further segmentation would result in inefficiency with only marginal benefit to potential small business participation at the prime contract level. This understanding of the market, particularly the size profiles of prospective prime offerors, led to the determination that consolidating the FST requirements from Task

Orders No. N0016419F3010 and No. N0016423F3008, into a single task order procurement was in the Government’s best interest.

9. Comparison of Benefits

The consolidation and substantial bundling approach described herein is the most efficient and effective way to meet the Government’s needs. As indicated within this Determination and

Findings, consolidating and bundling the FST taskings under a single solicitation will ensure the successful performance of the AEASD mission and provide non-quantifiable, efficiency-induced cost savings. Alternative approaches offer little benefit to the Government, increase risk, or are not currently feasible.

The NSWC Crane AEASD is responsible for performing EW activities for the

NSWC Crane AEASD has been assigned roles and responsibilities that include

FST support for the

. Due to the extensiveness and criticality of AEASD systems to U.S. and FMS mission requirements, leveraging the efficiency and effectiveness of FST support to be gained through the requested consolidation and bundling is necessary and justified and critical to the agency’s mission success.

As discussed above, the agency would obtain significant benefits through consolidation and bundling as compared to alternate contracting approaches in meeting the agency’s mission through separate smaller contracts or orders. The associated quality improvements, consistent terms and conditions, and efficiency-induced financial benefits, in addition to the critical mission alignment, will substantially exceed any benefits achieved through the status quo or greater degrees of overall requirement fragmentation.