JA M109 FOV STS as of 03 April 2024 Redacted.pdf

CMO Control Number: 2022-0056

DEPARTMENT OF THE ARMY

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Agency: The responsible contracting activity for the contracting action is the U.S. Army Contracting Command–Detroit Arsenal (ACC-DTA).

2. Description of Action: ACC-DTA proposes to award a five-year indefinite delivery, indefinite quantity contract to BAE Systems Land & Armaments, LP (BAE) for System Technical Support / Sustainment System Technical Support (STS/SSTS). BAE’s continued support of the M109 Family of Vehicles (FoV) is required as the USG lacks sufficient data rights of the vehicle hull, subsystems, critical Line Replaceable Units, (LRUs) and software as identified in paragraph 5(b) to support competition. Performing a competition or acquiring the TDPs from BAE Systems Land & Armaments L.P. would result in substantial duplication of costs to the Government and would result in unacceptable delays. This contract will be a combination of Cost-Plus Fixed Fee (CPFF) Completion and Level of Effort work directives (WD). A CPFF contract has been determined to be in the best interest of the Government as this contract will consist of legacy system support to include both currently known and unknown redesign efforts due to obsolescence concerns surrounding components as well as software. It is reasonable to anticipate the redesign work creating numerous unknowns surrounding the amount of type of labor needed, which increases the risk to the contractor.

Additionally, the large variety of the scope of services creates additional unknowns and risks to the contractor.

It is anticipated that this effort will be funded using the following Fiscal Year (FY) 2024- 28 dollars:

Type of Funding Purpose Army Procurement Appropriation (APA)/Wheeled Tracked Combat Vehicle

(WTCV)

STS for Army vehicles

Operation and Maintenance, Army (OMA) SSTS for Army vehicles Army Working Capital Fund (AWCF) SSTS for Army vehicles Research, Development, Test & Evaluation (RDT&E)

STS for Army vehicles

Foreign Military Sales (FMS) SSTS for FMS vehicles

3. Description of Supplies/Services: The proposed action supports the M109 Family of Vehicles (FOV). The M109 FOV includes the M109A6 Paladin; M109A7 Paladin Integrated Management (PIM) Self-Propelled Howitzer System (SPHS); M992A2 Field Artillery Ammunition Support Vehicle (FAASV); M992A3 Carrier, Ammunition, Tracked (CAT); and all variants and derivatives of those vehicles.

The planned contract will provide critical STS/SSTS services for the M109 FOV, which will include activities such as:

• Depot maintenance support*

• Field service representatives*

• Fielding/Deprocessing*

• Systems engineering

• System design and technical support of vehicle enhancements

• Parts obsolescence management

• Program, engineering, and quality management

• Reliability and maintainability support

• Prototype hardware and software

• Configuration management and Technical Data Package (TDP) maintenance

• Acquisition of prototype hardware, test equipment and sustainment (lifetime buys for obsolete parts)

• Development and test

• Engineering change proposals

• Contractor logistics support

• Software management and maintenance

• Technical support to production engineering and design changes

• Product improvements

• Value engineering

• Trade off studies and business cases

• Systems and equipment training

• Technical Manuals

• Problem investigations, failure analysis

• Facility vehicle support, system assessment

• Testing and test equipment

• Test vehicle refurbishment

• Technical reports

• Environmental issues

• Human factors engineering

• Manpower And Personnel Integration (MANPRINT)

• Safety

*PdD Paladin plans to initiate competition through the PEO GCS Enterprise Integrated Logistics Support competitive contract vehicle, once it is in place, for specified logistic activities. The schedule to introduce competition will be dependent upon program readiness and contract availability. The transition plan is outlined below and takes into account both the ordering period of this contract and time for award on a new contract:

• Depot Maintenance Support – January of 2026

• Fielding/Deprocessing - January of 2026

• Field Service Representative - January of 2026 in just a few years.

2) Another major barrier to competition is that the USG does not have complete technical data, including drawings, process sheets, software, and work instructions suitable for competition for the M109 FOV. BAE developed and maintains the only complete Technical Data Package (TDP) and computer software package for the M109 FOV and major subsystems, including technical analysis, trade-off studies, and problem investigation reports. BAE has knowledge of each of the new PIM subsystems as well as the common Paladin subsystems and how they interface with each other and function at the overall vehicle system level. BAE has been responsible for obsolescence planning, the timely redesign and replacement of hardware, software updates, and firmware as part of the current STS/SSTS contract. In addition, BAE is responsible for ensuring that correct versions of software are obtained, updated, and compatible with updated vehicle configurations. To have another company be responsible, there would be a significant learning curve in understanding the existing code and interfaces to support integration of software from multiple sources into a single PIM vehicle software revision.

These factors would result in a substantial schedule and cost impact to the program.

3) Under the PIM Low-Rate Initial Production (LRIP) contract, the Government exercised the option to procure a Production Level TDP for the PIM and CAT;

however, the Government does not have the pertinent technical data and computer software to enable competitive re-procurement as BAE maintains proprietary ownership of PIM and CAT technical data and computer software.

Without this information, another contractor would be unable to provide the STS/SSTS required contract in the time required.

b) Duplication of Costs:

1) BAE is the only source with the necessary technical expertise to accomplish the efforts set forth in this procurement. Award to another contractor would result in substantial duplication of costs for reverse engineering, procurement of software and components, and testing for the M109 FOV as depicted in Table 1. Based on Project Manager (PM) Self-Propelled Howitzer Systems (SPHS) Subject Matter Experts (SMEs) expertise and history, award to another contractor could result in the minimum duplication of costs of $124.1M to reverse engineer, procure components, and test propriety designs. These costs are not expected to be recovered through competition.

Table 1 Duplication of Costs Through Competition

Cost Tasks Basis for Calculations

7.5 Years Total Time Causing Unacceptable Delays

• Components Design, Component Testing, Reverse Engineering Proprietary Designs, and Software Development: This task is reflected in the chart above. The additional time can be attributed to the need to redesign and qualify components for which the Government does not have technical data and software due to on-going obsolescence redesigns, design upgrades, producibility, and safety upgrades. In order to accomplish this, another contractor would need to develop complete design parameters for components. BAE has the design parameters documented, along with Computer Aided Design (CAD) models, and performance models for the entire vehicle and each

. These estimates include reverse engineering of vehicle components, prototype builds, CAD models, and development of performance models and TDP.

• Proprietary Design System Level Testing and Software Testing: The estimated time required to test the various systems are reflected in the chart above. Testing includes the system level performance capability to verify all components function and meet all requirements called out in the performance specification.

• Proprietary Design Vehicle Level Testing including Software: Any new contractor would be required to build and test prototype vehicles. The estimated time required to build and test the vehicle system is reflected in the chart above. Reliability and Maintainability testing is required for any new vehicle configuration and is included in the estimate.

• STS/SSTS Source Selection: A competitive procurement could add two years or more. This time includes the preparation of the Request for Proposal, the evaluation of proposals, negotiations, contract award, and execution of the subsequent STS/SSTS contract.

2) The Government does not have competitive rights to the vehicle and component level software for the M109 FOVs. The M109 FOVs are highly complex vehicles that require a complicated 600v electronic software system with significant safety considerations that must be taken into account when replacing proprietary designs and software. The estimate includes the time to reverse engineer components for which the Government has only limited or restricted rights, the time to test the components both at an individual level as well as at a vehicle level, and the time for a new contractor to develop the capability to provide STS/SSTS for the M109 FOV as a whole.

d) Summary: A total investment of approximately $124.1M and 7.5 years would be required for a new contractor to begin to provide STS/SSTS for the M109 FOV program. Continuity of engineering and logistics services is critical to ensuring timely and successful M109 FOV production and any break in support would threaten planned production and present an unacceptable level of program risk for the M109 FOV. Accordingly, the anticipated schedule delay and the costs incurred would not reasonably be expected to be recovered through competition and the Government does not have the schedule flexibility required to manage the work involved in qualifying a new contractor. The Government anticipates a new contractor would take at least the same number of hours, if not more, to complete the support efforts. The Government expects that the labor categories would be similar, as would the labor rates and equivalent fee percentage.

6. Efforts to Obtain Competition:

a) Effective Competition: The Government will not obtain competition for the reasons stated in section 5 above.

b) Subcontracting Competition: The contractor will be encouraged to use small and disadvantaged businesses to the maximum extent practical for this action. The contract will contain FAR clause 52.244-5, entitled “Competition in Subcontracting,” which requires the prime contractor to competitively select subcontractors to the maximum extent possible.

7. Actions to Increase Competition:

a) In the future, if requirements for additional services are needed, the Government will conduct market research to determine market capability.

b) In addition, for the obsolescence and product improvement re-design efforts, PM

SPHS is working to limit and eliminate proprietary hardware and software.

c) As referenced in Section 3, PdD Paladin plans to initiate competition through the

PEO GCS Enterprise Integrated Logistics Support competitive contract vehicle, once it is in place, for specified logistic activities. The schedule to introduce competition will be dependent upon program readiness and contract availability.

8. Market Research:

a) Pursuant to FAR 10.002(b)(2) (i) and (ii), ACC-DTA issued a market investigation survey on the SAM.GOV website on 15 April 2022, in the form of a Sources Sought Notice, to gauge marketplace interest for the M109 FOV STS/SSTS. The survey closed on 20 May 2022.

The survey asked interested sources to state what STS and SSTS for Tracked Vehicle Combat Systems it has provided for the U.S. Government and respond to a specific list of tasks regarding its experience related to Program Management, Configuration Management, Systems Engineering, Software Engineering, System Validation/Testing, Integrated Logistics Support, and its capability to securely handle classified documentation. The specific list of tasks on the survey are as follows:

• What STS and SSTS for Tracked Vehicle Combat Systems have you provided for the U.S. Government?

• Program Management:

• Describe your company’s experience and tools to manage project cost, schedule, and performance.

• Configuration Management (CM):

• Describe your company’s CM Process, tools to perform Configuration

Management of the Technical Data Package, and experience in Configuration Management Systems Engineering:

• Describe your company’s experience and tools to manage requirements, develop specifications, assess and track risk, and address parts obsolescence.

• Describe your company’s level of certification, processes, and experience in managing software requirements, development, test, fielding and sustainment support. Describe your experience developing and verifying embedded diagnostics software on vehicles with an electronic architecture.

• System Validation/Testing:

• Describe your company’s experience performing subsystem and vehicle level integration, assembly, test, and checkout. What is your experience performing hardware/software integration and troubleshooting?

• Integrated Logistics Support (ILS) Management:

• Describe your company’s experience in developing and updating logistics support products for integrated vehicle systems. What is your experience with obsolescence and continuing support for vehicles in light of these issues? What is your process to ensure the vehicle system remains supportable through spare parts, maintenance, and logistics documents as the configuration changes?

• Classified documentation:

• Describe your company’s capability to securely handle classified documentation.

b) The survey responses were evaluated by a team from PdD Paladin. The following companies responded to the Market Survey:

i. BAE Systems Land & Armaments, LP (BAE), Large Business ii.

c) BAE's response to the sources sought clearly demonstrates its knowledge and expertise in Program Management, Configuration Management, Systems Engineering, Software Engineering, System Validation/Testing, Integrated Logistics Support, and its capability to securely handle classified documentation as it relates to the M109 FOV STS/SSTS. Furthermore, BAE has successfully managed all STS/SSTS efforts for the M109 FOV under