CETS_Class JandA_CY21-25_FINAL_Redacted.pdf

Justification and Approval (J&A) for Other Than Full and Open Competition

FOR OFFICIAL USE ONLY

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I. Contracting Activity.

Contracting Activity: All Contracting Engineering and Technical Services (CETS) contract actions must be awarded by Air Force Life Cycle Management Center, Installation Contracting Division (AFLCMC/PZIEB) in accordance with AFI 21-101, Engineering and Technical Services Management and Control guidelines.

AFLCMC/PZIEB

2275 D Street, Bldg. 16, Room 128 Wright-Patterson AFB, OH 45433-7228

POC: Luke Johnston Title: Contract Specialist Phone: (937) 656-7489 E-Mail: luke.johnston@us.af.mil

Program Activity: All United States Air Force (USAF) Commands are directed to manage their individual CETS requirements under AFI 21-101, Engineering and Technical Services Management and Control guidelines.

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

a. CETS contracts provide USAF units contractor personnel on-site proficiency training, technical advice and technical assistance when organic USAF skills are not available. This Class J&A primarily applies to USAF CETS;

however, CETS may be acquired to support the Army, the Navy, and the Coast Guard for various weapon systems, subsystems, and associated equipment located at operational USAF, Army, Navy and Coast Guard installations.

b. This follow-on Class J&A covers all non-FMS CETS contract actions to be awarded between 01 January 2021 to 31 December 2025. AFLCMC/PZIEB estimates there will be up to 16 contracts awarded with a value of $79M in AF, ANG, and Navy operations and maintenance (O&M) appropriations during this five-year period. These contract actions will be negotiated as Requirements-type contracts with negotiated firm-fixed-price (FFP) man-month rates for CETS labor and not-to-exceed (NTE) cost reimbursement amounts for CETS travel and relocation expenses.

Individual task orders will be issued in accordance with the terms and conditions of the basic Requirements contracts.

c. CETS supports weapon systems and/or subsystems for the F-15 A/C, F-16 A/C, F-18 A/C, F-22 A/C, KC-135 A/C, C-130 A/C, B1 A/C, B2 A/C, KC-135, A-10C A/C (engine only), E6 A/C, and UH-60. The original equipment manufacturers (OEM) covered by this Class J&A are: Boeing, DME Corporation, DRS, General Electric Aviation, Excelis Incorporated (formerly ITT Corporation), Northrop Grumman, United Technologies Corporation, Pratt & Whitney, Rockwell Collins, Rolls Royce, Lockheed Martin (LM) Aero, LM Marietta, LM Greenville, LM Global, LM Rotary Mission Systems, and LM Global.

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

a. USAF acquires CETS for highly specialized, on-site, technical services that are essential to accomplishing the assigned missions of the weapon systems identified above. CETS contracts provide a vehicle through which the OEMs can share up-to-date technical information and training to using Commands regarding the operation and maintenance of these weapon systems as they mature or are modified.

b. AF Engineering and Technical Services (AFETS) field engineers are intended to be the primary source of ETS support in the AF. CETS engineers are an important element in developing an organic ETS capability for USAF systems. In accordance with AFI 21-101, CETS personnel may not be retained on contract beyond which time AFETS personnel have attained proficiency on assigned systems and can provide the technical assistance associated with CETS support. USAF operational units have not achieved this level of proficiency for any of the existing or planned CETS requirements.

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

The statutory authority which permits other than full and open competition for this class of contract actions is 10 U.S.C. 2304(c)(1) as implemented by FAR 6.302-1(a)(2)(iii). In the case of each individual contract, there is only one responsible source and no other services will satisfy agency requirements.

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

a. For each follow-on acquisition awarded under the authority of this Class J&A, the Agency's minimum needs can be satisfied by only one responsible source (the OEMs), and no other type of services will satisfy agency requirements. CETS support is acquired through follow-on contracts with the manufacturer of the equipment or weapon system identified above in accordance with the policies and procedures in AFI 21-101. This is the fourth successive CETS Class J&A based on FAR 6.302-1(a)(2)(iii) since 2005. In that time, CETS has been procured using a series of follow-on contracts for the continued provision of highly specialized services. These services are highly specialized because CETS engineers must have access to OEM technical data and proprietary information and have the necessary technical expertise to advise and train AF personnel regarding the maintenance and operation of critical weapon systems. Furthermore, CETS engineers must possess weapon system technical knowledge and experience beyond that of AF existing personnel, OEM certifications to operate and maintain these systems, and the ability to share this knowledge through formal and informal training. Therefore, each of these follow-on acquisitions is for the continued performance of highly specialized services that are only available from one responsible source.

b. Award to any other source would result in substantial duplication of costs to the Government that is not expected to be recovered through competition and unacceptable delays in fulfilling the Air Force's requirements. If CETS requirements were competed, non-OEMs would be required to procure technical data rights and proprietary information from OEMs to adequately perform these services. Furthermore, as a critical element of the CETS requirement is formal and informal training of using Command maintenance personnel, non-OEMs would have to prepare entirely new training materials. These duplicative efforts combined with the cost to acquire technical data rights and OEM proprietary information would offset any cost savings expected to be recovered through competition.

There is also a substantial risk that performance quality would suffer as a result of transitioning to unproven non-OEM sources.

c. Award to non-OEM sources would also result in substantial delays in fulfilling CETS requirements. The CETS representatives are the only link between an operating unit and the OEM when a weapon system technical problem arises. Due to the fact that the weapon systems involved are still in production or are being upgraded or modified, CETS personnel must rely heavily on OEM technical data and proprietary information to adequately perform the service. In the case of engineering and design drawings, OEMs can supply the drawings through their CETS representatives within hours, thus enhancing the operating Commands' ability to make an fast and informed operation and maintenance decisions that minimize weapon system downtime. OEMs are often called upon to interpret drawings and specifications as the using Commands do not always have the technical knowledge to resolve a ETS issues. Without OEM participation, the Government estimates it would take a non-OEM CETS provider between 14 to 30 days to deduce the correct technical solution for each advanced operation or maintenance issue that arises. When multiplied across the anticipated 16 CETS contracts during the active period of this Class J&A, this could result in a minimum of 224 to 480 days operational delays for the warfighter. Maintaining the OEMs as CETS providers eliminates this time-consuming process and increases the operational readiness of warfighting systems. For these reasons, it is likely that an award to any other source would result in substantial delays in fulfilling Government requirements.

d. Furthermore, a Class J&A is appropriate under the circumstances to avoid duplicative administrative efforts to across all 16 anticipated CETS contracts. Approximately 45 days have been spent in the development of this Class J&A. Therefore, each individual J&A would require approximately 45 days to develop, multiplied by the 16 AF contracts, the result would be an administrative burden of 720 days. Processing 16 separate sole source J&A's will create a loss of consolidated efforts, a loss of productivity, and create unacceptable delays in fulfilling agency requirements. The AF will save 675 days by not processing separate sole source J&A's. The Government has relied solely on the OEMs for CETS support since program inception - more than 34 years. The OEMs CETS representatives have the requisite experience, skills, and knowledge to bridge deficiencies combined with the access to proprietary data needed to support these efforts. The contracts contemplated under this Class J&A constitute the continuation of the CETS program as mandated by AFI 21-101. Accordingly, OEM's are the only firms capable of providing the services described above without the Government experiencing unacceptable delays in fulfilling its requirements.

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

A sources sought synopsis was published on 21 Mar 19 on FedBizOpps for 45 days. Four sources formally

March 2018 FOR OFFICIAL USE ONLY Page 4 of 5 responded: Northrop Grumman Systems Corporation (Northrop), Cyquest Business Solutions, LLC (Cyquest), Airdyne Aerospace (Airdyne), and Padden Design Engineering (Padden). Northrop is already identified as an OEM for CETS requirements covered by this Class J&A. After careful consideration the remaining three contractors have been determined to be unacceptable sources for the CETS requirements covered by this Class J&A.

Cyquest's capability statement indicates they provide staffing solutions, records management, database creation and management, human resources outsourcing, and other support services. None of these capabilities match current or planned CETS requirements. Airdyne expressed its interest in providing engineering services for the SABIR System installed on C-130J/H model aircraft. There are no current or planned CETS requirements for this system during the 2021-2025 period covered by this Class J&A. Similarly, Padden's core competency is the engineering of composite metal structural components for DoD systems, not the kind of holistic operation and maintenance training CETS requires. And lastly, even if these contractors did have relevant competencies, the inability to access OEM technical data and proprietary information would preclude them from being considered acceptable sources.

Individual contract synopses published over the past 3 years have not produced any qualified sources beyond the OEMs. All CETS basic contracts that meet the criteria of FAR Subpart 5.3 will be synopsized as individual Notice of Contract Actions. If new sources are identified through such synopses, this J&A will be amended.

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. Fair and reasonable price determination on individual contract actions will be made based upon the results from various tools such as audits, technical evaluations and historical information. The requiring agencies provide a Technical Services Requirement (DD255a) with each contract requirement which contains an independent government estimate for the calendar year. All proposed program costs will be thoroughly analyzed for each contract action. Contractors will be required to submit cost or pricing data to support the government's evaluation of the proposed price (in accordance with TINA threshold). When an audit is required, the technical evaluations will be provided by the Defense Contract Management Agency (DCMA) and audit assistance will be obtained from the Defense Contract Audit Agency (DCAA). When under the Truth in Negotiations Act (TINA) threshold, analysis will be performed by contacting DCAA for recommended rates and factors and by comparison to other PZIEB CETS contracts. These methods will provide the contracting officer with adequate knowledge to determine a fair and reasonable price.

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

As described previously in Section VI, market research, in accordance with FAR Part 10, was conducted by synopsis of the proposed acquisition, advising industry of the pending acquisition and soliciting inquiries from interested parties.

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

None.

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

See para. VI.

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.

a. The expertise provided by CETS for a specified piece of equipment or weapon system, is not available from any other source other than the OEM. The longer the equipment/weapon system remains in the AF inventory, the greater the possibility of the AF developing trained and experienced personnel to service the contractor's equipment. This organic capability will result in the contracted services being terminated in accordance with AFI 21-101. Other than

March 2018 FOR OFFICIAL USE ONLY Page 5 of 5 organic capability, obtaining open competition is not practical due to the constant changes in the equipment/weapon system and lack of updated technical data being readily available.

b. The previous J&A for this effort outlined the same potential for organic capability described above. However, due to the technical data being late-to-need for these various weapon systems, the AF has been unable to adequately develop the organic capability necessary to provide self-sustaining support and relies on CETS services to achieve mission objectives. Self-sufficiency will be achieved when the AF can maintain itself without external support. The technical requirements community will notify the contracting officer when they are independent and AF organic capabilities are achieved, at which time they will make the determination to terminate CETS services.

XII. Certification by the Contracting Officer.

As evidenced by his signature, the contracting officer has determined this document to be both accurate and complete to the best of his knowledge and belief (FAR 6.303-2(b)(12)).

XIII. Certification by the technical/requirements personnel.

As CETS support extends to multiple platforms and multiple users contracted through AFLCMC/PZIEB, per AFI 21-101, there is not an individual POC for technical/requirements. Each using activity provides their requirements to AFLCMC/PZIEB through a DD255a per the AFI. As evidenced by his signature on the coordination and approval document, Mr. Lynn Smith, acting as the coordinator for all program managers, has certified that any supporting data contained herein which is the using activities responsibility is both accurate and complete (FAR 6.303-2(c)).