FA489019C0004 EC130_A10 JA_Redacted.pdf

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

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I. Agency and Contracting Activity.

U.S. Air Force

HQ ACC AMIC/PKB

300 Exploration Way Hampton, VA 23666

Contract Number: FA489019C0004 Purchase Request Numbers:

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

1. The purpose of this justification is to authorize and approve a commercial Firm Fixed Price (FFP) extension modification to AVIX-BGI JV, LLC, contract FA489019C0004. The need for continued support must be issued as a sole source, (1) year continued extension of services (1 Aug 2024 - 31 Jul 2025) to meet mission requirements while a Source Selection for the follow-on acquisition is being conducted. This will allow adequate time for the follow-on acquisition to be solicited and awarded to include transition to the new awardee while maintaining continuity in services without interruptions.

2. Contract History: The current effort provides commercial services for EC-130H/A-10C CAT/CWD support for 355th Wing (WG) A-10C and 55th WG EC- 130H at Davis-Monthan AFB Arizona, and the 23rd WG A-10C at Moody AFB, Georgia. The contract was solicited as a commercial, Firm Fixed Priced, 100% set aside for Service-Disabled Veteran Owned Small Business (SDVOSB). The PSC code of U009 (Education/Training) and NAICS code 611512 (Flight Training with a corresponding size standard of $27.5M) was assigned. The source selection procedures utilized was trade-off (Technical Capability, Risk and Price). The result was a single, firm-fixed price contract and awarded on 1 Dec 2018 to AVIX-BGI JV, LLC. The period of performance consisted of a (2) month transition period, (12) month base period and (4) one-year option periods. Total period of performance was (5) years (2) months (1 Feb 2019 - 31 Jan 2024).

3. In Mar 2023, the PWS for the follow on contract was completed and recompete process was started. In May 2023, DET 3/CC requested a VTC with HQ ACC TRSS and ACC AMIC to discuss the EC-130H/A-10C Contract Aircrew Training and Courseware Development (CAT/CWD) follow on recompete with members of A3CR, A3T, 355 OG, and 55 ECG.

The VTC was conducted on 1 Jun 2023. DET 3/CC discussed numerous variables that continue to change, which made the PWS submission in Mar invalid. The driving factors are, However, no definitive timelines had been set for implementation.

4. In August 2023, a request was received for the re-compete to be placed on hold by the 355WG and A3C because additional time was required to sort out the force structure changes for the A-10C, EC-130H and their replacement, the EC-37. Congress still had not made a decision concerning the A-10C deactivation, as the USAF has been trying to retire it for years. When the decision to retire the A-10C is made, it will be several years before the FTU is shut down and the plane is retired.

5. September-November 2023, the contract period of performance for Option Year 4 was to expire on 31 Jan 2024. Due to continued delays in requirements development (PWS) for the follow-on acquisition, a decision was made to extend the current contract under the auspice of FAR 52.217-8 to allow more time to figure out future requirements. The plan would be to execute the 6-month extension in order to continue current contract performance for the period of 1 Feb 2024 to 31 Jul 2024, while seeking approval for a (1) year continued extension of services modification. The 6-month extension was executed via

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6008 A-10 Base Year Data Deliverables (NSP)

6009 A-10 Registrar Support at Davis-Monthan (FFP)

6010 A-10 SLATE Tablet Labor (FFP)

6011 A-10 Reoccurring Tablet Materials/Equipment Costs (NTE)

6012 EC-130H CAT (CAT, Flight Deck, Mission Crew + CCMCS Instruction) (FFP)

6013 EC-130H CWD + Scenario Development (FFP)

6014 EC-130H FTU Scheduling (FFP)

6015 EC-130H Travel (NTE)

6016 EC-130H Data Deliverables (NSP)

6017 EC-130H CCMCS Operator (FFP)

6018 EC-130H WST Instruction/Operator (FFP)

6019 OPTIONAL CLIN: EC-130H Live Fly Instruction (FFP)

6020 Incorporate Revised PWS v0.7 and add 1 MCS Supervisor (FFP)

6021 Option Year One Wage Adjustment (FFP)

6022 AR/VR/MR & EFB Support DM (FFP)

6023 Option Year Two Wage Adjustment (FFP)

6024 EC-130 WST Expansion at DM (FFP)

6025 Add (1) A-10 Scheduler Incorporated via PWS v1.1 (FFP)

6026 Option Year Three Wage Adjustment (FFP)

6027 Converted A-10 Programmers PWS v1.2 (FFP)

6028 Option Year Four Wage Adjustment (FFP)

6029 6 Month Price Adjustment (FFP)

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

1. AVIX-BGI JV, LLC the incumbent, is currently performing the required services on contract FA489019C0004 as stated in Section III. The contract was solicited as a commercial, Firm Fixed Priced, 100% set aside for Service-Disabled Veteran Owned Small Business (SDVOSB) utilizing a tradeoff source selection process. The contract includes FAR Clause 52.217-8, Option to Extend Services. The current contract extension under this clause will end on 31 Jul 2024. A competitive acquisition in the time remaining before the current contract expires is not practical. The incumbent contractor can continue providing services IAW the PWS for the extended period with no loss in continuity, efficiency, or adverse impact on the mission. Accordingly, AVIX- BGI JV, LLC is the only vendor capable of providing the supplies and services described in Section III above without unacceptable interruption to the mission or excess costs.

2. The government is currently in the presolicitation phase of the follow-on award. Award to any other source would result in substantial duplication of costs to the government (that will not be recouped through any further type of competition), and unacceptable delays in fulfilling the Air Force's requirements.

Also, additive to the direct costs would

August 2023 Page 5 of 6 be the mission impact caused by a break in service if the competition cannot be concluded by 31 Jul 2024 (i.e., stopping production at the Formal Training Unit (FTU)). Stopping or interrupting current mission ops at the Formal Training Unit (FTU) could be detrimental to the program and operational units CONUS, OCONUS and the AOR; it can take up to six months to fully qualify new instructor cadre. Award to any other source at this time would result in substantial startup costs to potential vendors for proposal preparation, recruitment, and staffing.

3. Any attempt to award an interim competitive contract would result in further unacceptable delay and possibly complete shutdown of the training program which will reduce the ability of the warfighters to accomplish their missions CONUS, OCONUS and in the AOR. A competitive acquisition within the next 77 days before the current contract extension expires would result in unacceptable delays in fulfilling the mission requirements. The extension under FAR 52.217-8 will be exhausted 31 Jul 2024. AVIX-BGI JV, LLC is the only contractor capable of meeting the government's mission needs during the extended period. They can continue the current effort with no loss in efficiency, initial qualification training, simulator and mission flying, student and permanent party aircrew throughput/continuation training, and mission exercise training with no adverse impacts.

They have the necessary resources and fully trained/qualified personnel already in place; no other contractor can meet the government's requirements within the next 77 days. It is dependent upon contractual support to ensure the critical training requirements of the A-10C and EC-130H programs are met. If we were to solicit this requirement competitively at this time, to award and interim contract, it could possibly cause an additional six month delay if award is made to an Unpopulated Joint Venture without a proper security clearance for the new entity itself.

An Exception To Policy (ETP) package would have to be drafted and routed through appropriate channels and which can take weeks to hear whether or not the ETP package was approved, or not.

V. 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.

1. The current contract was solicited and awarded competitively as a commercial, Firm Fixed Priced, 100% set aside for Service- Disabled Veteran Owned Small Business (SDVOSB) utilizing a tradeoff source selection process. AVIX-BGI JV, LLC was selected as the best value to the Government. However, due to the requirement changes to the follow-on requirement as discussed in Section II above, it is now necessary to extend performance through an additional extension to ensure there is no break in service while the recompete effort is developed.

2. For this extension, AMIC posted a synopsis to SAM.gov on 6 May 2024 notifying prospective companies of the government's intent to award a 1-year sole source continued extension of services. The posting closed on 14 May 2024 and there were no responses from industry.

3. AMIC is currently in the pre-solicitation stage for the follow-on acquisition. The RFI/Sources Sought is scheduled to be posted by 30 May 2024 along with the draft PWS and draft DD 254. The requirement will be posted via SAM.gov, the government-wide point of entry in order to solicit as many sources as practicable. The RFI is comprised of multiple questions for interested companies to answer in order to facilitate the government in identifying available, capable sources. The RFI will also request interested offerors to submit their company's capability package.

4. This justification and approval document will be publicized within 14 days after award as required by FAR 6.305(a) via the government-wide point of entry (SAM.gov).

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

1. The Contracting Officer will ensure that the services described herein are negotiated at a fair and reasonable price to the government. IAW FAR as supplemented, the contractor will be required to submit Other than Certified Cost or Pricing Data. A detailed price analysis will be performed. The current (and follow-on) contract is governed by (3) Collective Bargaining Agreements (CBAs) that stipulate all labor rates and fringe benefits.

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

1. For this extension, AMIC posted a synopsis to SAM.gov on 6 May 2024 notifying prospective companies of the government's intent to award a 1-year sole source extension. The posting closed on 14 May 2024 and there were no responses from industry.

Based on recent requests for information (RFIs), sources sought, from other CAT/CWD contracts undergoing recompete, AMIC anticipates adequate competition. There is evidence of capable companies interested in performing the work, given there is sufficient time to finish developing the requirement and execute the follow-on acquisition process.

2. AMIC is currently in the pre-solicitation stage for the follow-on acquisition. The RFI/Sources Sought is scheduled to be posted by 30 May 2024 along with the draft PWS and draft DD 254. The requirement will be posted via SAM.gov, the government-wide point of entry in order to solicit as many sources as practicable. The RFI is comprised of multiple questions for interested companies to answer in order to facilitate the government in identifying available, capable sources. The RFI will also request interested offerors to submit their company's capability package.

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

The critical nature of the services and constant changes in the AOR environment requires the contracting activity to award a continued extension of services modification for a period of 12-months.

This will ensure the fulfillment of critical wartime mission support to the AOR and Operational base missions. It will also eliminate excessive costs and increased risk associated with soliciting for a new offeror before the recompete.

Any break in service will have an overall unacceptable negative impact which is not in the best interest of the government.

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

None.

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.

There are no known barriers to competition. The current contract was awarded competitively, and the follow-on will be awarded competitively. The recompete is currently in the pre-solicitation phase. Based on the interest of companies for current, ongoing CAT/CWD recompetes, the government is confident there will be adequate interest and competition from responsible sources.

XI. Certification by the Contracting Officer.

As evidenced by their signature, the contracting officer certifies that this justification is accurate and complete to the best of their knowledge and belief.

XII. Certification by the technical/requirements personnel.

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