F100 IETMS JA__Redacted 2.pdf

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

CONTROLLED UNCLASSIFIED INFORMATION

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I. Agency and Contracting Activity.

Requiring Activity: Department of the Air Force AFLCMC/LPS Tinker AFB, OK 73145

(405) 739-8498

Contracting Office: Department of the Air Force AFLCMC/LPK Tinker AFB, OK 73145

(405) 734-6644

Purchase Request No: Planning PR# FD2030-24-30034

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

A class J&A is appropriate due to the inclusion of FAR 52.217-8, Option to Extend Services. The six-month extension of services allowed under FAR 52.217-8, will be for the same work in the basic contract and will therefore be in-scope work. A class J&A is appropriate because the task/delivery orders will be authorized by the basic contract, the orders will be for in-scope work. This acquisition will be for a new contract. This acquisition is not a Bridge Action as defined by DAFFARS 5302.101. The contemplated follow-on contract will be in accordance with FAR Part 15.

The contemplated contract is a non-commercial, Firm-Fixed Price, Indefinite Delivery/ Indefinite Quantity (ID/IQ) contract for preparation and sustainment of United States Air Force (USAF) format Technical Orders (TO) to support USAF Models F100- PW-220/220E/229 Interactive Electronic Technical Manual System (IETMS) intermediate engines and equipment, including the Engine Automated Work Package (EAWP), from Pratt & Whitney (P&W) Military Engines, 400 Main Street, East Hartford, CT 06108-0968, Commercial and Government Entity (CAGE) code: 52661. The ordering period will consist of a 1-year base and four 1-year option periods with the potential for a 6-month extension under FAR 52.217-8. Performance periods will be established for individual orders issued under the ID/IQ.

Previous Contract History:

Contract Number: FA8124-19-D-0002 Award Date: 1 March 2019 Completion Date: 31 March 2024 Contract Value: $4,465,000.00 Basis of Award: Sole source

The estimated total value of this new contract is $11,656,830.23 with an estimated award date on or before April 2024. This contract value is estimated to be more than the previous contract because this contract has a CLIN for the S1000D Conversion effort with a cost estimate of .

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

This acquisition is to obtain technical publication support services for F100-PW-220/220E/229 Intermediate Manuals, associated component and accessory manuals, and special purpose manuals. The Contractor must use MIL-DTL-87269D, MIL-DTL-38807D, MIL-STD-3408B, and Technical Manual Contract Requirements (TMCR) as a basis for development of the Type II IETM and S1000D format. S1000D is an international specification for the procurement and production of technical publications. It was initially developed by the Aerospace and Defense Industries Association of Europe (ASD). It is now jointly

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CLIN 3001 - IETMS Direct (Digital) Delivery BCU 3 CLIN 3002 - Development of RACs 1 CLIN 3003 - Development and Sustainment of IPB 3 CLIN 3004 - IETMS Direct Support 3 CLIN 3005 - Travel 6 CLIN 3006 - DATA (Not Separately Priced) NSP

CLIN 3007 - EAWP 3

CLIN 4001 - IETMS Direct (Digital) Delivery BCU 3 CLIN 4002 - Development of RACs 1 CLIN 4003 - Development and Sustainment of IPB 3 CLIN 4004 - IETMS Direct Support 3 CLIN 4005 - Travel 6 CLIN 4006 - DATA (Not Separately Priced) NSP

CLIN 4007 - EAWP 3

All CLINs listed herein will be funded with 3400 Appropriations, will include best estimated quantities (BEQ) at time of award, and may be subject to administrative changes throughout the ordering period of this firm-fixed price ID/IQ contract. There will be a CDRL CLIN to establish delivery of the TOs in S1000D format after conversion to which the Government will maintain unlimited rights to the TOs, which is consistent with the approved acquisition strategy. The preceding IP rights strategy is consistent with the Acquisition Strategy as approved by the appropriate authority. This class J&A covers all contract actions including options and ID/IQ orders for all CLINs detailed above.

The basis for the S1000D conversion pricing was established from a Rough Order of Magnitude (ROM) provided by P&W in 2022, which has been validated/ adjusted for inflation/risk.

Therefore, it is considered appropriate to seek approval for more than one fiscal year.

IV. Demonstration that the contractor's unique qualifications or the nature of the acquisition requires use of the authority cited above.

This is a follow-on effort for acquisition of technical publications support services for the F100 Engine Program. This J & A is initiated because the agency's need for these unique services can be provided by only one responsible source, P&W. P&W has provided the Government this service under the previous sole source contract listed in Section II. The Government owns the technical data within IETM, however, P&W owns the exclusive rights to the required IETM software used to view the technical data, therefore, the IETM software is not available from any other source. Failure to obtain these services will cause an adverse impact to the war fighter due to nonavailability of TO documentation/delivery and replacement drawings for the F100 engines. P&W is the only firm capable of providing these highly specialized services, which include technical OEM expertise in developing procedures and expedition of source data such as operational supplements, rapid action changes, engineering changes, and change proposals not provided for in existing contracts. Failure to procure OEM post-production support will adversely affect the USAF mission, creating a work stoppage resulting from a lack of support and services for those product requirements. Therefore, this acquisition is for continued performance of a highly specialized service.

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No IP rights or deliverables were acquired under the previous and current contract. The only IP clause included was 52.227-14 Rights in Data - General. The Government has requested the option to buy data rights in each acquisition from P&W, but it has thus far been denied. Therefore, the Government did not acquire data rights in the previous acquisition nor were data rights considered in the original acquisition of the F100 engine from P&W. Additionally, it's both cost and time prohibitive to either develop a new F100 IETM program or reverse engineer the existing one. Neither of these options are currently viable, nor are they expected to become viable in the foreseeable future. P&W is the only source capable of providing the expertise, knowledge, and exclusive data rights to meet the USAF IETM requirements. The Government requested to buy or lease the source code for the IETM software on June 16, 2023, however, P&W declined.

The AFLCMC/LPSZB office has determined that award to any other source would result in substantial duplication of cost to the agency that is not expected to be recovered through competition, as well as unacceptable delays in fulfilling the USAF requirement. Opening this effort to competition would require extensive reverse engineering and/or the redesign of the F100 IETM system. The costs include but are not limited to Non-Recurring Engineering for redesign and extensive re-engineering efforts required to establish a sustainable baseline for the technical publication support needed to fulfill this requirement.

P&W continues to be the only known source at this time. All source code is proprietary to P&W and cannot be provided by any of the interested parties mentioned in Section VI.

Accordingly, P&W is the only firm capable of providing the services described in Section III above without the U.S. Air Force experiencing substantial duplication of cost that could not be expected to be recovered through competition and unacceptable delays in fulfilling its requirements. Both the duplication of costs and time associated with reverse engineering and/or re-design of the F100 IETM system by any source other than P&W is not feasible for the Program Office's budget nor time line requirements for contract award. Therefore, award to any of the respondents listed in Section VI is not viable.

Reverse engineering or re-procurement of the F100 IETM or alternate technical publication support system would also create unacceptable schedule delays that would result in a lapse of depot maintenance and the loss of trained personnel.

This schedule delay would include 18 - 24 months for the contracting action followed by the new vendor's proposed PoP to reverse engineer, redesign, and manufacture the replacement TO support system.

A CLIN has been created for the S1000D conversion effort that would potentially make future contract efforts competitive because S1000D is an internationally used format and is not proprietary to P&W.

A Request for Information (RFI) regarding third-party licensing of proprietary software was submitted to P&W on 30 May 2023 and again on 1 Jun 2023 and 15 Jun 2023. The RFI requested P&W provide the software required to make this effort competitive. P&W responded on 16 Jun 2023 and stated that they are not willing to sell or lease their proprietary software.

Software requested included: Source Data Code, Software Design Test Code, and Compilers. As a follow-on to the RFI, P&W was asked 1) would they be amicable to selling the licensing rights of their software to the USAF, or 2) amicable to entering a shared licensing agreement with another vendor. P&W responded negatively to both questions on each separate occasion.

Technological support is needed for sustainment of F100 IETM. Also, the items and services are not commercial, and they cannot be modified to permit the use of commercial items. The software rights, owned by P&W, will not change in the foreseeable future. Therefore, there are no feasible actions that could develop future competition. Accordingly, P&W is the only firm capable of providing the supplies and services described in Section III above without the USAF experiencing substantial duplication of cost that could not be expected to be recovered through competition and unacceptable delays in fulfilling its requirements.

V. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable, March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 6 of 7March 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 6 of 7 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.

In accordance with FAR 5.201, this requirement was synopsized on the Systems for Award Management (SAM.gov) website.

Copies of the required information were provided to any potential sources who requested it. On 28 June 2023, Sources Sought Synopsis (SSS) FA8124-SS-F100-IETMS was issued stating AFLCMC/LPSZB's desire to identify potential sources that may possess the expertise, capabilities, and experience to meet the requirements of the development and sustainment of the F100-PW-220/220E and F100-PW-229 Intermediate Maintenance Manual IETMS and EAWP. The SSS clearly stated necessary source data was proprietary and could not be provided. Three interested parties submitted responses. The responses were evaluated for past experience with a similar effort, experience with Air Force Definition Type Documents (DTDs) and Technical Manual Specification & Standards (TMSS) compliant SGML, capability to provide unlimited data rights to the software, and if reoccurring software licenses or software maintenance agreements would be required. Also evaluated was the ROM (if provided) and estimated time to field a working IETMS/EAWP.

The following is a brief summary of each response:

1. Pratt & Whitney owns the proprietary software for the technical manuals viewer and specializes in sustainment efforts of the F100 engine technical manuals.

2.

3.

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

The Contracting Officer will ensure that the items described herein are negotiated at a fair and reasonable price to the Government. IAW FAR as supplemented, the contractor will be required to submit Certified Cost or Pricing Data and/or Other Than Certified Cost or Pricing Data. A detailed cost analysis and price analysis will be performed. The Contracting Officer will request a technical evaluation from the Defense Contract Management Agency (DCMA) to aid in the evaluation of the contractor’s proposal.

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

The market research report was completed on 27 July 2023 and was signed by the CO and the PM. As described in the aforementioned Section VI and IAW FAR 10.001(a)(2), market research was conducted (as detailed in the market research report, signed by the program manager and contracting officer) by SSS and RFI of the proposed acquisition, contacting known source of products or services advising industry of the pending acquisition, and soliciting inquiries from interested parties. The RFI did produce two potential vendors, however they were deemed not capable due to the need for P&W's proprietary data. Market research revealed no other potential sources, neither military nor commercial, with the ability to obtain P&W's proprietary software package to edit the TOs or provide engine manuals sufficient to meet the USAF's IETMS requirements. No other market research was conducted. The software required to provide necessary services is only available from the OEM. Commercial services are not available, nor can a commercial service be modified to meet the government's requirement in a timely and economical manner. With this knowledge the acquisition is still considered non-commercial. There was no relevant documentation the Government was able to provide and P&W denied the ability to share or sell their proprietary data.

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

No further information.

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

1. Pratt & Whitney (Cage Code: 52661) Military Engines 400 Main Street East Hartford, CT 06108-0968

(860) 557-0228

See Section V for more details.

X. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisitions for the supplies or services required.

Actions to increase competition on this acquisition will be performed by AFLCMC/LPS to ensure the following task will be accomplished per the milestones established. There will be a CDRL CLIN to establish delivery of the TOs in S1000D format after conversion to which the Government will maintain unlimited rights to the TOs.

Per PGI 206.304(a)(S-70), as indicated by signature on this document, the previous J&A has been reviewed and the Approval Authority determined all stated actions to remove barriers to competition have been accomplished.

XI. Certification by the Contracting Officer.

As evidenced by their signature, the contracting officer certifies that this document is both accurate and complete to the best of his/her knowledge and belief.

XII. Certification by the technical/requirements personnel.

As evidenced by their signatures, the technical and/or requirements personnel have certified as accurate and complete all supporting data, which is their responsibility, contained herein.