D3 Justification and Approval_Redacted.pdf

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

CONTROLLED UNCLASSIFIED INFORMATION

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

10 U.S.C. 2304(c)(2) as implemented by FAR 6.302-1 - Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

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

Subsection 1:

(a) The MMIII ICBM mission is to deter a nuclear missile attack against the United States and execute the land-based leg of the strategic nuclear triad. The MMIII is a mature weapon system in the Operations and Support Phase of its life cycle. The operational force must be sustained in a state of readiness such that national defense strategies involving these systems can be successfully executed.

This acquisition will provide a detailed roadmap/strategy of the who, what, when, where, and how the Air Force will accomplish the retirement of the MMIII weapon system while integrating with the deployment of its replacement, the GBSD weapon system.

Since 1954, NG has supported the MMIII mission in roles like the ICBM Prime Integration Contract, Ground Subsystem Support Contract (GSSC), and Propulsion Subsystem Support Contract (PSSC). In these roles, they provided solutions for the sustainment of the weapon system and multiple Acquisition Category (ACAT) level programs. They are the current contractor for the competitively awarded ACAT I GBSD program, FA8219-20-C-0006 (expiration 28 Feb 26), on which this effort will be placed as a task order.

As the primary contractor for the GBSD effort and two of MMIII's largest sustainment contracts, GSSC and PSSC, NG is highly specialized and has unique insight into the needs of the GBSD and MMIII weapon systems. Also, NG has helped sustain the MMIII weapon system for over 60 years.

(b) This acquisition is not a “bridge” effort.

(c) Therefore, this acquisition of NG's highly specialized services is necessary to support the development of a strategic plan for MMIII D3 actions.

Subsection 2 Award to any other source would result in substantial duplication of cost to the Government that is not expected to be recovered through competition. Award to any other source would also cause unacceptable delays in fulfilling the Government's requirement.

(a) Duplication of Cost:

By using a separate D3 contractor, the Government would incur duplication of costs due to the steep learning curve associated with understanding all of the elements needed to develop an Integrated Master Schedule and D3 strategic plan. This includes the knowledge of Government and contractor resources and specific MMIII and GBSD logistical challenges. NG is currently on contract to provide a detailed deployment schedule for the GBSD effort, which will, by the reuse of MMIII assets, have dependencies that include MMIII D3 activities. The use of an additional contractor will result in redundant deliverables, which without the intimate GBSD knowledge, could pose significant risk of missing an element critical to success of MMIII D3 and GBSD deployment.

Through the development of the GBSD weapon system, decisions have been made by Government stakeholders that are crucial to the understanding of the MMIII D3 and GBSD deployment strategy. The use of a separate D3 contractor would require a significant amount of time to educate the contractor on the intricacies of the GBSD weapon system. The contractor would also need to review GBSD documentation that has already been delivered, April 2021 CONTROLLED UNCLASSIFIED INFORMATION Page 4 of 6 and they would essentially be reworking or duplicating the documents to integrate with any MMIII D3 plan.

The current estimate for the first round of documents/deliverables is , with per document to be delivered.

With the many unknowns, there are no numbers available to conduct a detailed parametric estimate. The Government estimates the cost to use a separate contractor would result in a minimum of 30%, or , of this effort being duplication of cost due to the time that a new contractor would require to review documentation and schedules, as well as inquire about historic decisions that NG would not need to do. With the first deliverables needed within 6 months of contract award, a separate contractor would need to use a large amount of time to “spin up” on the details needed to develop the documents, which could also result in additional labor hours or resources being required. However, there is no way to estimate this cost.

(b) Unacceptable Delays:

In order to develop the documentation required to create a strategic D3 plan for the MMIII weapon system, a contractor must have access and deep familiarity with GBSD decisions, documentation, and deployment. If a single element is missed, it could result in delays to the deactivation of the MMIII sites, which would then delay the installation of GBSD equipment. Due to the on alert requirements of the United States' only land based strategic nuclear deterrent, it is critical to the security of the nation that GBSD deployment is successful as any delay will cause the MMIII weapon system to continue operating at a time where as system age, a lack of critical components and supply chain issues will not allow the MMIII mission to succeed.

A new contractor would need to review historical decisions, GBSD documentation, and schedules. They would also need to obtain a general understanding of where the Government is at with the MMIII D3 effort. Therefore, the Government does not believe a separate contractor would have a realistic amount of time to familiarize themselves and provide the first deliverables within of 6 months of award as required. NG has already gathered much of this information and is already familiar with the history of MMIII and GBSD, so this issue does not exist if the contract is awarded to NG. Each subsequent revision of the GBSD schedule and deliverables will have to go through an additional review process prior to providing the documentation required to complete a strategic MMIII D3 plan, which is estimated to take a minimum of 1 week per revision. This delay would then exacerbate with the time the separate contractor would need to disseminate the updated material, update their documentation and then provide it to the Government. We estimate that a single revision would result in a 3-week delay due to this extra review period needed for each contractor. Many revisions are expected as the need date to be ready for D3 activities has changed at least 5 times during the development of the AF's acquisition strategy over the last 6 months. If a minimum of 6 more revisions are required during the 2-year period of performance of this effort, it would be delayed by at least 4 months. This delay would be unacceptable as MMIII D3 actions would be late to need, causing a delay to the GBSD deployment and resulting in more revisions and causing even more delays.

Subsection 3 Accordingly, NG is the only firm capable of providing the supplies and services described in Section III above without the AF experiencing substantial duplication of cost that could not be expected to be recovered through competition and unacceptable delays in fulfilling its requirements.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under

FAR 5.202 applies.

A Sources Sought Synopsis (SSS) was posted for 30 days starting on 28 April 2021. The SSS had respondents:

. After further development of the requirement, a revision to the SSS was posted for 15 days starting on 21 June 2021. The SSS had respondents:

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

The following steps will be taken to ensure the anticipated cost of this acquisition will be fair and reasonable. These steps are IAW the procedures and criteria contained in FAR Part 30 - Cost Accounting Standards Administration;

Part 31 - Contract Cost Principles and Procedures; and Subpart 15.4 - Contract Pricing:

1) Contractor will be required to submit Certified Cost and Pricing Data

2) Technical evaluation will be performed by the Program Office to include evaluation of the contractor's proposal

3) A Defense Contract Audit Agency (DCAA) audit of the contractor's cost/price proposal will be considered, and it will be requested if deemed necessary

4) AFSC/PZCF Pricing Office will evaluate the contractor's cost/price proposal and consider inputs from DCAA and the Program Office technical evaluation in establishing the Government's cost/price position

5) A preliminary Price Negotiation Memorandum (PNM) will be submitted and reviewed during Business Clearance, and a Final PNM will be completed following negotiations

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

As described in Section VI above, Market Research IAW FAR Part 10 & FAR 5.201 for this effort was conducted by the posting of a SSS 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.

As the margin for error to ensure the success of the GBSD program shrinks, the AF must realize every opportunity to reduce risk. Utilizing NG for the MMIII D3 effort will provide the best chance to capture the intricacies of the MMIII and GBSD perspectives when developing the D3 strategy.

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

See section VI above

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.

Future acquisitions for the MMIII D3 planning activities are not anticipated.

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.

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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.