CUI - 842573108_F-35 JA_Redacted.pdf

F-35 ODIN Hardware

CUI

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Controlled By: F-35 Joint Program Office Controlled By: Maintenance Systems Program Management Office CUI Category: Procurement Distribution/Dissemination Control: D POC: Marc Harrington; marc.harrington@jsf.mil; 703-602-8171

JUSTIFICATION FOR OTHER THAN FULL AND

OPEN COMPETITION (OTFAOC)

Federal Acquisition Regulation (FAR) Part 6 Justification & Approval (J&A), Supporting Procurements under FAR Part 12, FAR Part 13, and FAR Part 15

Purchase Request Number: To be determined (TBD) Purchase Order Number: TBD Procurement Title: F-35 Operational Data Integrated Network (ODIN) Hardware

Statutory and Regulatory Authority: 41 U.S.C.1901(a)(2) and FAR 13.501(a)(ii)

Justification for OTFAOC Number: Not applicable

Upon the basis of the following justification, I, as Contracting Officer, hereby approve the use of other than full and open competition of the proposed contractual action pursuant to the authority of FAR 13.501(a)(ii).

1. REQUIRING AGENCY AND CONTRACTING ACTIVITY:

(a) Requiring Agency:

F-35 Maintenance Systems (MxS) Program Management Office (PMO) Infrastructure Team 200 12th Street, Suite 600 Arlington, Virginia 22202

(b) Contracting Activity:

DISA/Defense Information Technology Contracting Organization PS8414 2300 East Drive, Building 3600 Scott Air Force Base, Illinois 62225

2. NATURE/DESCRIPTION OF ACTION(S):

(a) The nature of this action is to procure portable memory device (PMD) extension modules (PEMs) and ODIN Base Kit (OBK) Gammas hardware for use in austere locations, shipboard operational requirements, and the proprietary interfaces of the F-35. The required brand-name hardware will be used for forward operating North Atlantic Treaty Organization (NATO) joint maintenance operations.

(b) This will be a new firm fixed price purchase order to an authorized reseller of ITI

Engineering (ITI), the original equipment manufacturer (OEM). Fiscal Year 2025 research, development, test, and evaluation appropriations will be used.

JA25-104-F-35 ODIN Hardware

Page 3 of 7 Pages equipment must meet the Air Force, Navy, Marine Corp and partner nation’s services austere deployment requirements to include:

1. Military (MIL) Specification 901D (Shipboard Shock)

2. MIL Standard (STD) 167-1A (Shipboard Vibe)

3. MIL STD 1310H (Shipboard, Grounding, and EMC)

4. MIL STD 130N (Identification Marking of United States Military Property)

Item Unique Identification and Labeling

5. MIL STD 810F/G (Environmental Engineering Testing)

6. MIL STD 461 (Shipboard Electromagnetic Interface)

7. MIL STD 464C (Shipboard Electromagnetic Environmental Effects)

8. MIL STD 1399 (Shipboard Electric Power Interface)

9. EU CE Certified for Electromagnetic Compatibility and Safety

(2) Proposed brand name. The Government has determined that the ITI designed and built equipment is required due to its unique features and compatibility with F-35 production lines (hardening, adding proprietary interface cards to interface with the F- 35 aircraft and mil standard compliance). The essential characteristics of this equipment, including its compatibility with F-35's existing production line, unique hardening and certification by F-35, guarantee its safety and quality standards. No other brand of equipment meets these requirements. If an alternative was selected, all F-35 maintenance systems’ hardware would need to be repurchased in order to migrate from the existing proprietary interfaces that make it compliant with the F-35 aircraft. This drives the Government’s current need for compatibility with the existing F-35 equipment, which is essential to meet the Government’s requirements.

(3) Discussion regarding the cause of the brand-name situation. This procurement requires hardware compliant with established technical standards and fully compatible with existing infrastructure and installed equipment. Although this specific ITI hardware has not been procured previously, the need now arises from the following:

In the original source selection for maintenance systems equipment, Lockheed Martin selected ITI. This selection was driven by ITI's high-speed, proprietary interface, which met the critical requirement for rapid data upload from the F-35 PMD. This ITI equipment is now deployed across the entire fleet. Due to the current OBK nearing its end-of-life and the need to extend the PMD reader's functionality, procuring additional ITI equipment is necessary to maintain compatibility with existing interfaces. A future technology refresh is planned to address and eliminate these proprietary interfaces; however, this refresh is not anticipated until 2030.

(4) Impact. The inability to procure the required ITI equipment poses significant risks to the F-35 program. Without it, F-35 production will be delayed due to incompatibility, potential safety risks will arise from using non-compliant or incompatible hardware, and the need to redesign or modify existing infrastructure will drive up costs. The failure to receive PEM hardware will impede forward operating NATO joint maintenance operations, while a lack of the OBK hardware will create a critical one-year gap in future sustainment support for the F-35.

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6. CONTRACT OPPORTUNITIES ANNOUNCEMENT/POTENTIAL SOURCES:

In accordance with FAR 5.102(a)(6), the Contracting Officer shall make the solicitation and this justification for OTFAOC publicly available to all businesses through the governmentwide point of entry, SAM.gov.

7. DETERMINATION OF FAIR AND REASONABLE COST:

(a) The Contracting Officer shall determine if the prices offered are fair and reasonable before the award. The complexity and circumstances of this requirement will determine the level of analysis, and the techniques used to determine the proposed price are fair and reasonable. Such methods may include those identified in the following sections:

(1) FAR 13.106-3(a)(1) – Price reasonableness on competitive quotations or offers.

(2) FAR 13.106-3(a)(2)(ii) – Comparison of the proposed price with prices found reasonable on previous purchases

(3) FAR 13.106-3(a)(2)(vi) – Comparison to an independent government estimate

8. MARKET RESEARCH:

(a) Market research was conducted in April 2025 – August 2025. Information was gathered from a variety of sources to include data from previous acquisitions, industry catalogs, trade publications, online directories, personal knowledge as well as consultations with technical experts and industry representatives in procuring services of this type, DISA Market Research Repository, reviewing existing DISA-wide contract vehicles and other Governmentwide Acquisition Contracts (GWAC).

(b) Market research was further conducted to determine if other companies’ comparable products could meet the Government's need. The research demonstrated that only ITI equipment meets the F-35 production line's essential requirements, particularly its compatibility with existing infrastructure, unique hardening, and F-35 certification. No other products were identified that could serve as a functional replacement without significant modification or recertification, which would introduce unacceptable delays and costs.

(c) The next step in the market research was to determine the procurement method. ITI only authorizes M2 Technologies, LLC (M2), a small business, to resell the products, which are available from M2 on National Aeronautics and Space Administration Solutions for Enterprise-Wide Procurement V. The products are not available on General Services Administration, the DoD Enterprise Software Initiative, or any other GWAC. The OEM, ITI, is a large business that is not on an existing vehicle but can contract with the Government. Given the results from the market research and the Contracting Officer's assessment, there is not a reasonable expectation that at least two responsible small businesses will submit offers. An open market solicitation is the recommended

Page 5 of 7 Pages acquisition strategy, and the solicitation will be posted full and open on SAM.gov for the brand-name products.

(d) Based on current market research, dated August 2025, it has been determined that only the aforementioned ITI equipment can fully meet the Government's need. This requirement is for products, and no competitor functional replacement products exist in the market at this time to meet the Government's need without unreasonable investments of cost, schedule, and technical risk. The Government will continue to conduct market research to determine if there are changes in the marketplace that would enable future competitive actions.

9. ANY OTHER SUPPORTING FACTS:

None.

10. LISTING OF INTERESTED SOURCES:

On July 31, 2025, ITI has indicated they are able to directly sell equipment to the Government.

11. ACTIONS THE AGENCY MAY TAKE TO REMOVE OR OVERCOME BARRIERS

THAT LED TO THE EXCEPTION TO FULL AND OPEN COMPETITION:

(a) Procurement History.

There is no prior procurement that supports this acquisition.

(b) Actions to remove barriers.

The current architecture that requires the ITI equipment is at a critical phase of its lifecycle, with significant investments made in existing infrastructure and production lines. This technology will eventually be replaced, but it is expected to remain in use for approximately 5-7 years before being fully retired. During this period, it is essential to ensure continuity and stability, which requires utilization of the brand-name product.

To remove barriers and transition from a limited-sources environment to a competitive one, the agency will take specific actions to promote competition and innovation in future procurements for ITI equipment. These actions include:

(1) Conduct ongoing market research to identify alternative solutions that can meet the

Government's requirements, with a view to incorporating competition in future procurements.

(2) Include competition in future procurements for similar ITI equipment, starting with the next acquisition cycle (approximately 5-7 years from now).

(3) Develop standards and specifications for ITI equipment, which will allow for greater flexibility and competition in future procurements.

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(4) Engage with potential vendors to encourage innovation and investment in alternative solutions that can meet the Government's needs.

In conclusion, the agency will take specific actions to overcome barriers and transition from a limited-sources environment to a competitive one, promoting competition and innovation in future procurements for ITI equipment. These actions are aimed at ensuring continuity and stability during this critical phase of the F-35 production line, while also paving the way for greater flexibility and competition in future procurements.