2019_02-06_MRO_JA_Final.pdf

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

FOR OFFICIAL USE ONLY

March 2018 FOR OFFICIAL USE ONLY Page 1 of 7

NOTE: If a Justification and Approval was approved for the preceding acquisition, a copy of the approved J&A for the predecessor action must be included in the staff package for approval of the instant J&A. This applies to J&A staff packages that are submitted for review and approval at a level above the contracting officer. The predecessor J&A will be used as a reference document by the approving official.

Is this a new or amended J&A Document? New Amended ( Prior to Award Only! )

Is this a Bridge Action as defined in the AF Bridge Action Reduction Plan? Yes No

Funding level for this acquisition: < $700K > $700K and < $13.5M > $13.5M and < $93M > $93M

Contracting Activity: AFSC OL:H/PZIEB

Purchase Request / Local ID Number: TBD

Program / Project (and PE, if applicable): Maintenance, Repair, and Overhaul (MRO)

Program Type (PEO or Other Contracting): AFPEO/CM

Authority: 6.302-1 – 10 USC 2304(c)(1), Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

Estimated Contract Cost (including options): $54,000,000.00 J&A Type: Class Individual

COORDINATION (AFFARS 5306.304(a) ) Sign and Save Procedure

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Date

06 Feb 2019

Project Lead / Program Mgr / Requiring Activity Paul Noorda

OO-ALC/OBCB DSN 586-3547

Signature

X

Date

06 Feb 2019

Contracting Officer Sarah Hatch

AFSC OL:H/PZIEB DSN 777-8407

Signature

X

Date

06 Feb 2019

Local Legal Reviewer Michael Bassett

AFSC OL:H/JA DSN 586-4941

Signature

X

Date

07 Feb 2019

Chief of the Contracting Office (COCO) Andrew Hatch

AFSC OL:H/PZI DSN 586-8602

Signature

X

Date

07 Feb 2019

Alternate Competition Advocate Preston Davis

AFSC OL:H/PZCA/B DSN 775-3837

Signature

X

APPROVAL (AFFARS 5306.304(a) )

Date

15 Feb 2019

PEO / Head of Procuring Activity / Designated Alternate Anthony J. Baumann, SES

AFMC AFSC/PK DSN 339-3900

Signature

March 2018 FOR OFFICIAL USE ONLY Page 2 of 7

I. Contracting Activity.

Sarah Hatch, Contracting Officer United States Air Force, AFSC OL:H/ PZIEB 6038 Aspen Avenue, Bldg. 1289 Northeast Wing Hill Air Force Base, UT 84056-5838

DSN 777-8407 COM (801) 777-8407

sarah.hatch@us.af.mil Purchase Request # TBD

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

A. Upon approval to use other than full and open competitive procedures, the Air Force will issue a new, non-commercial, follow-on , Firm-Fixed Price (FFP), indefinite delivery/indefinite quantity (IDIQ) contract. This contract will be a follow-on to FA8224-12-C-0030, which was competitively awarded on 11 July 2012 and which is set to expire on 9 July 2019. While the previous contract was awarded competitively, this will be a sole source contract because there are currently no other capable contractors who can meet the government's essential requirements without delay to the government's critical mission.

B. This contract is for the implementation and sustainment of the Maintenance Business System Modernization (MABSM) program which is comprised of Impresa, Maintenance, Repair, and Overhaul (MRO) applications within the Ogden Air Logistics Complex (OO-ALC).

C. The contract will have a five year ordering period, from date of award, with an additional year for completion of performance and will also include the option to extend the term of the contract in accordance with (IAW) FAR 52.217-9, up to one (1) additional year, but the total duration of this contract, including options, will not exceed seven (7) years.

D. The estimate award date is: July 2019

E. The contract will be awarded to:

Systems Implementers, Inc. (SI) 1436 S. Legend Hills Dr., Suite 140 Clearfield, UT 84015-2188 CAGE: 1FNW9, Small Business

F. Estimated cost: $54,000,000.00

G. J&A Type: Individual

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

A. The services provided by the contractor are required to ensure MABSM compatibility and correct interfacing with 27 + legacy systems at OO-ALC and provide services associated with MRO/Impresa Software implementation and sustainment support, which includes, but not limited to, the following:

1) administration for the maintenance, sustainment, and day-to-day operation of the application(s);

2) work order document creation;

3) job and line routing procedures;

4) supply integration;

5) scheduling and planning procedures;

6) production reporting;

7) material ordering;

8) other specialized handing;

9) inventory control for serialized assets required to manage Nuclear Weapons Related Material (NWRM)

B. Funding will be provided by using Consolidated Sustainment Activity Group Maintenance (CSAG-M) 4930 working

March 2018 FOR OFFICIAL USE ONLY Page 3 of 7 capital funds (WCF).

C. Each OO-ALC maintenance group will have its own set of ACRNs based on the WCF structure.

D. The projected CLIN structure will be as follows:

CLIN# Description Type Unit Estimated Period of Performance 0001 CMXG Sustainment FFP Month Jul 2019 - Jan 2026 0002 CMXG Sustainment Modifications FFP Month Jul 2019 - Jan 2026 0003 CMXG Travel FFP Lot Jul 2019 - Jan 2026 0004 EMXG Sustainment FFP Month Jul 2019 - Jan 2026 0005 EMXG Sustainment Modifications FFP Month Jul 2019 - Jan 2026 0006 EMXG Travel FFP Lot Jul 2019 - Jan 2026 0007 MMXG Sustainment FFP Month Jul 2019 - Jan 2026 0008 MMXG Sustainment Modifications FFP Month Jul 2019 - Jan 2026 0009 MMXG Travel FFP Lot Jul 2019 - Jan 2026 0010 MXSG Sustainment FFP Month Jul 2019 - Jan 2026 0011 MXSG Sustainment Modifications FFP Month Jul 2019 - Jan 2026 0012 MXSG Travel FFP Lot Jul 2019 - Jan 2026 0013 AMXG Sustainment FFP Month Jul 2021 - Jan 2026 0014 AMXG Sustainment Modifications FFP Month Jul 2021 - Jan 2026 0015 AMXG Implementation FFP Month Jul 2019 - Jul 2022 0016 AMXG Implementation Modifications FFP Month Jul 2019 - Jul 2022 0017 AMXG Travel FFP Lot Jul 2019 - Jan 2026 0018 Data (CDRLs) NSP Lot Jul 2019 - Jan 2026 1001 CMXG Sustainment FFP Month Jul 2024 - Jul 2026 1002 CMXG Sustainment Modifications FFP Month Jul 2024 - Jul 2026 1003 CMXG Travel FFP Lot Jul 2024 - Jul 2026 1004 EMXG Sustainment FFP Month Jul 2024 - Jul 2026 1005 EMXG Sustainment Modifications FFP Month Jul 2024 - Jul 2026 1006 EMXG Travel FFP Lot Jul 2024 - Jul 2026 1007 MMXG Sustainment FFP Month Jul 2024 - Jul 2026 1008 MMXG Sustainment Modifications FFP Month Jul 2024 - Jul 2026 1009 MMXG Travel FFP Lot Jul 2024 - Jul 2026 1010 MXSG Sustainment FFP Month Jul 2024 - Jul 2026 1011 MXSG Sustainment Modifications FFP Month Jul 2024 - Jul 2026 1012 MXSG Travel FFP Lot Jul 2024 - Jul 2026 1013 AMXG Sustainment FFP Month Jul 2024 - Jul 2026 1014 AMXG Sustainment Modifications FFP Month Jul 2024 - Jul 2026 1015 AMXG Implementation FFP Month Jul 2024 - Jul 2026 1016 AMXG Implementation Modifications FFP Month Jul 2024 - Jul 2026 1017 AMXG Travel FFP Lot Jul 2024 - Jul 2026 1018 Data (CDRLs) NSP Lot Jul 2024 - Jul 2026

E. Below are the estimated costs associated with this effort and includes all potential options and possible seven (7) year total contract period:

FY19 FY20 FY21 FY22 FY23 FY24 FY25 Total

Current Group Sustainment $3,694,704 $3,767,238 $3,842,583 $3,919,434 $3,997,823 $4,077,779 $4,159,335 $27,458,896

AMXG Implementation $2,713,201 $3,606,366 $2,848,721 $866,341 $ - $ - $ - $10,034,629

AMXG Sustainment $ - $ - $1,258,123 $2,901,957 $3,843,666 $3,920,539 $3,998,950 $15,923,235

Travel $50,625 $51,619 $52,650 $53,704 $54,778 $55,873 $56,991 $376,240

Total $6,458,530 $7,425,223 $8,002,078 $7,741,435 $7,896,267 $8,054,191 $8,215,276 $53,793,000

March 2018 FOR OFFICIAL USE ONLY Page 4 of 7

F. Approval request is for more than one fiscal year. There are no feasible actions that can be taken to promote competition during the period of the acquisition as described in Section V of this document.

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

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

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

A. The above authority was selected because this requirement is for a highly-specialized service/capability. It is a highly specialized service and capability because it involves being responsible for the Implementation and Sustainment of MABSM, Configuration Management (CM), source code manipulation, and maintenance for the MRO/Impresa Software. The highly specialized services relating to the CM functions include: managing analysis; designing code changes; coordinating OO-ALC program functional changes, and scheduling code change implementation. There have been more than 242,000 engineering changes and additional tailoring by SI. The highly specialized services also include creating program specifications and test criteria, coding and testing programs, and producing program documentation that interfaces with 27+ legacy systems that are critical to maintenance, repair and overhaul in the OO-

ALC.

B. The Air Force possesses the data rights to the MABSM (Impresa and MRO applications) software that is used to perform the MRO functions in the OO-ALC. However, SI developed the application, interfaces, the coding patches/ alterations, and training for both programs while performing the current and prior contracts and has exclusively provided configuration management functions on this effort. Currently, the Government does not have the latest modifications to the application. This is the portion of the contract that anyone other than the incumbent would be required to reverse engineer.

C. Currently, the government does not possess the organic capability and knowledge necessary to use the data. A new contractor would be required to reverse engineer the infrastructure and interfaces in order to fully understand SI's software applications. A new contractor could not immediately satisfy the government's mission critical functions for sustainment.

D. The Government believes that award to any other source would result in substantial duplication of costs in the amount of $2,015,244 per year for reverse engineering. An additional cost of $21,885,831 would be required to keep SI on contract for 3 years while the new contractor ramps up for sustainment (see section III above). Award to any other source would cause an unacceptable delay in the amount of 3 years in meeting the government's mission critical requirements. The 3 year ramp up estimate is based on historical data for implementation of MRO into the current maintenance groups, the number of ECPs that have been implemented, and the complexity of the depot's business processes. Additionally, multiple contractors in the MRO system would introduce unacceptable contract performance risk.

E. Accordingly, this acquisition will be a follow-on effort for the continued performance of highly specialized services and SI is the only contractor capable of providing the services, described in section III above, without the Air Force experiencing substantial duplication of costs that could not be expected to be recovered through competition and unacceptable delays in fulfilling it's mission.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

A. To promote competition, multiple acquisition strategies were considered and researched, namely NETCENTS II, OASIS, Full and Open, and GSA. None of these options were deemed suitable, feasible, or appropriate because respondents to the Sources Sought Synopsis(SSS)/Request for Information (RFI) (detailed in Section VIII) did not demonstrate a full understanding of the requirement after multiple rounds of Q&A.

March 2018 FOR OFFICIAL USE ONLY Page 5 of 7

B. Two (2) SSS were posted, the first on 18 October 2016 - 11 January 2017 (FA8224-17-R-0006) and the second on 14 February 2018 - 16 March 2018 (FA8224-18-R-MROI). Additionally, an RFI was posted to GSA on 2 November 2018 - 13 November 2018 (FA8224-19-R-MROI). Respondents to the SSS did not adequately demonstrate the capability to perform the government's MRO sustainment and implementation requirement, and only the incumbent responded to the RFI. Further, the government does not possess the capability to provide the required, highly-specialized services nor train another vendor without experiencing unacceptable delays to the government. Therefore, the Government has determined that awarding to a contractor other than the incumbent would require a lengthy turnover (not available in the current contract) and a three (3) year ramp up time for sustainment in the current groups using MRO and three (3) years for implementation in AMXG at an additional cost not to be recovered through competition. Other than the incumbent, sources discovered during market research are not capable of providing services within the required schedule. During the Government's risk analysis, it was determined that if the follow-on was competed and awarded to a new contractor, there is no guarantee the incumbent's analysts would accept positions with the new contractor. This requirement will be synopsized on FedBizOpps for 15 days as a notice of proposed contract action IAW FAR 5.201.

C. Summary of Sources Sought/RFI results:

a. System Implementors--the incumbent, a qualified and capable source, has provided MABSM services to the OO- ALC since 2001. SI has an in-depth knowledge of the requirement and provided acceptable responses to all questions in the RFI. There is a high confidence that SI will provide a technically acceptable proposal for this requirement and execute it immediately upon award with no break in service. SI has contract employees with security clearances and an extensive understanding of the system. SI provided a sound business model and has a managerial staff that proved capable of continuing services with the OO-ALC on the current contract and past MABSM contracts.

b. Rylex Consulting--did not adequately demonstrate the capability to perform the government's MRO development/sustainment requirement, nor does the government possess the necessary highly specialized services or the organic training required to provide another vendor, which would result in unacceptable delays in meeting the government's requirement.

c. BBH Consulting, Inc.--did not adequately demonstrate the capability to perform the government's MRO development/sustainment requirement, nor does the government possess the necessary highly specialized services or the organic training required to provide another vendor, which would result in unacceptable delays in meeting the government's requirement.

d. Robbins-Gioia--did not adequately demonstrate the capability to perform the government's MRO development/ sustainment requirement, nor does the government possess the necessary highly specialized services or the organic training required to provide another vendor, which would result in unacceptable delays in meeting the government's requirement.

e. InSap Services--did not adequately demonstrate the capability to perform the government's MRO development/ sustainment requirement, nor does the government possess the necessary highly specialized services or the organic training required to provide another vendor, which would result in unacceptable delays in meeting the government's requirement.

f. ARAS Corporation--did not adequately demonstrate the capability to perform the government's MRO development/sustainment requirement, nor does the government possess the necessary highly specialized services or the organic training required to provide another vendor, which would result in unacceptable delays in meeting the government's requirement.

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

A. The following steps will be taken to ensure that the anticipated cost of this acquisition will be fair and reasonable.

The Contracting officer will comply with the procedures and criteria contained in Federal Acquisition Regulation (FAR) under Part 30 - Cost Accounting Standards, Part 31 - Contract Cost Principles and Procedures, Subparts 15.4 - Contract Pricing; to include technical evaluations from the appropriate technical experts as well as audits and support as

March 2018 FOR OFFICIAL USE ONLY Page 6 of 7 appropriate from relevant resources such as DCMA and DCAA. Additional steps to ensure price reasonableness actions will be under the guidance of the Contract Pricing Reference Guides, jointly developed by the Federal Acquisition Institute and the Air Force Institute of Technology

B. The Government will obtain certified cost or pricing data IAW FAR Subpart 15.403, when required. A Pricing Analyst will be consulted to assist in the determination of cost and pricing reasonableness. This will include an in-depth review of all costs proposed including overheads, material costs, labor costs, etc. Any costs considered to be irrelevant, unreasonable, unbalanced, or otherwise inappropriately allocated will be addressed with the Contractor directly via fact finding efforts and discussions in order to fully understand the nature of those costs. Costs wherein disagreement is found will be negotiated, mitigated, and adjusted such that the final agreement reflects fairness to all parties. The final step is to develop a Price Negotiation Memorandum (PNM). Detailed documentation and justification of price reasonableness will be disclosed in the official PNM, to be prepared upon completion of negotiations.

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

A. As described in section VI above, market research, IAW FAR Part 10, was conducted by synopsis of the proposed acquisition, advising industry of the pending acquisition, and soliciting inquiries from interested parties.

B. Additionally, the following market research was conducted:

a. Performed keyword searches through internet search engines - unable to find similar services or additional sources for these services.

b. No commercial services are available and the requirement cannot be modified to permit the use of existing commercial services.

c. There is no organic capability in source code manipulation at OO-ALC.

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

A. Currently, the Government does not have the organic capability to perform this highly specialized service nor provide adequate training to potential sources. The incumbent is the only source capable of providing this highly specialized service and/or training. Therefore, the incumbent would have to remain on contract to provide MRO sustainment services or training while a new contractor ramps up. Further, the transition to a new contractor increases the risk of service interruptions. Consequently, competing this effort would result in substantial duplication of cost and unacceptable delays to the Government.

B. SI was awarded the initial competitive contract in 2001, as well as the subsequently competed contracts in 2006 & 2012. Sole source awards were made to extend the 2012 contract in 2018 & 2019, with a total life-cycle cost of approximately $200M. With the MRO program scheduled to sunset once MROi is fully implemented, it is not in the Government's best interest to have a different vendor execute this requirement, due to the level of risk to ALC operations. This contract includes the implementation of MRO into AMXG, the most complex Group in the ALC.

C. The MROi contract is the enterprise streamlined acquisition effort to standardize and replace the current MRO contract across the AFSC including Wright-Patterson AFB, Tinker AFB, Robins AFB and Hill AFB (and its geographically separated units). The MROi contract will be deployed to each maintenance group in phases with full deployment projected to be completed by 2024, with the exception of AMXG, which was not included on the current MROi contract. The MROi program office plans to award a follow on contract to include AMXG in MROi.

D. MROi, awarded 11 July 2018, is the replacement system for MRO and was awarded competitively on NETCENTS-2 Solutions. The contract will be deployed in phases with full development and implementation to be completed by 2024. To avoid duplication of costs and unacceptable delays, it is in the Government's best interest to retain SI's institutional knowledge to maintain depot operations and to assist with the transition of MRO to MROi when deployed at Hill AFB.

March 2018 FOR OFFICIAL USE ONLY Page 7 of 7

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

See Section VI

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.

MROi, the follow-on to the MRO system, was competitively awarded in July 2018. As a result of the replacement system MROi being in place, as well as the duplication of cost and unacceptable delay of developing additional sources per Sections V and IX, there are no known additional actions which can be taken to remove barriers to competition making specific actions and milestones difficult to establish. MROi has many unknowns since it began phase-in in 2019. The MRO system is a stop gap until MROi phases in and will no longer be a requirement once MROi is fully implemented and deployed in 2024. Therefore, no actions will be taken to overcome barriers to competition; however, the government will continue to communicate with industry to determine contractor capability if other alternatives are available/needed once this contract expires.

XII. Certification by the Contracting Officer.

As evidenced by her signature, the contracting officer has determined this document to be both accurate and complete to the best of her knowledge and belief.

XIII. 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.

Remove the Guidance pages below. Remove the IACR pages below.

March 2018 Page of International Agreement Competitive Restrictions (IACR) Page of March 2018 NOTE: If a Justification and Approval was approved for the preceding acquisition, a copy of the approved J&A for the predecessor action must be included in the staff package for approval of the instant J&A. This applies to J&A staff packages that are submitted for review and approval at a level above the contracting officer. The predecessor J&A will be used as a reference document by the approving official.

Is this a new or amended J&A Document?

Is this a Bridge Action as defined in the AF Bridge Action Reduction Plan?

Funding level for this acquisition:

J&A Type:

COORDINATION (AFFARS 5306.304(a)) ** The text in the signature blocks below is editable, including the title.

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APPROVAL (AFFARS 5306.304(a)) NOTE: A signature block will appear here based on the funding level selected above.

(See "Specific Guidance for Completing this Template" below.)

I. Contracting Activity.

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

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

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

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

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

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

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

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

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

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.

XII. Certification by the Contracting Officer.

XIII. Certification by the technical/requirements personnel.

Specific Guidance for Completing this Template ( For general guidance, refer to the J&A Preparation Guide. )

I. Contracting Activity.

Fully identify the contracting agency and organizational activity responsible for the proposed contracting action.

II. Nature and/or description of the action being processed. (FAR 6.303-2(b)(2))

State whether the action will be awarded as a new contract or by modification to an existing contract (identify contract number) and identify the type contract planned (e.g., firm-fixed-price, cost-plus-incentive-fee, etc.). If exception 2 is cited (unusual or compelling urgency), state date of UCA/contract/modification issuance and amount.

An individual J&A cannot be used to support more than one contract irrespective of the quantities or the dollar value stated therein. If a proposed contract will contain unpriced options (including NTE prices), those options must be supported by a separate J&A prior to option exercise or the J&A supporting the basic contract must be a Class J&A. For Class J&A situations (covers more than one contract) where the number of contracts in the class can be identified: (1) Provide a brief general description of actions; (2) identify the supplies and services that are being acquired; and (3) for each contract in the class identify the contractor, estimated value, type of contract and rationale for contract length, and estimated award date. Where the same information applies to more than one contract within the class, it need only be stated one time.

III. Description of the supplies/services required to meet agency needs. (FAR 6.303-2(b)(3))

Specifically describe the supplies and/or services to be acquired, the total estimated value of the acquisition - including options (provide cost estimate by year and, for class J&AS, by contract action), and the estimated delivery dates/periods of performance If commodities are being procured, provide quantities. All contract line items (CLINs) e.g., technical data, support equipment, support services, etc., should be listed. If all of the ancillary requirements associated with a particular item are not specifically described in the J&A, those ancillary requirements cannot be included in the resulting contract and would require a second J&A. Also, state the type of appropriation (e.g., 3600, 3010, and 3400) that will be used to fund each requirement listed.

If approval for more than one fiscal year requirement is needed, give the rationale for this request. Generally, the scope of these actions is limited to current requirements only, so that actions may be taken to facilitate competition for out-year requirements.

In some cases, there are no feasible actions that could develop future competition, and it is reasonable to seek approval for more than one fiscal year's requirements.

For ID/IQ or requirements contracts, use the maximum dollar value of the total estimated orders as the estimated J&A dollar value.

IV. Statutory authority permitting other than full and open competition. (FAR 6.303-2(b)(4))

10 USC 2304(c)(?) (see Note 1 below), as implemented by FAR 6.302-? (see Note 2 below), and required by FAR 6.303-2(b)(4).

Note 1: Complete the 10USC 2304(c) citation with the statutory subparagraph cited in the (a) Authority (1) Citations portion of the Competition exception used for your J&A.

Note 2: Complete the FAR citation with the appropriate subparagraph.

Note 3: For class J&As, all contracts within the class should fall within the same statutory authority. Where a different authority must be used for any contract action, a separate J&A should be prepared.

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority). (FAR 6.303-2(b)(5))

Provide, in narrative form, a detailed explanation supporting and clearly relating to the conditions described by the FAR for using the particular authority cited. This section is normally the most detailed part of the justification as the essence of the justification is presented here. For acquisitions that include both supplies and services, separately justify the use of the authority for the services and supplies.

Contracting without providing for full and open competition shall not be justified on the basis of lack of advance planning by the requiring activity or concerns related to the amount of funds available (e.g., funds will expire) (FAR 6.301(c)). To assist you, the following information is provided:

A. Only One Responsible Source (FAR 6.302-1)

When using this authority, thoroughly describe the contractor's unique/highly specialized capabilities and/or qualifications (e.g., facilities, personnel, special tooling acquired), and why no other type of supplies or services will satisfy the agency requirements. This authority shall be used, if appropriate, in preference to the authority in FAR 6.302-7. This authority shall not be used when any of the other authorities apply.

This authority also applies to the use of restrictive brand name descriptions in requirements documentation. An acquisition that uses a brand name description or other purchase description to specify a particular brand name, product, or feature of a product peculiar to one manufacturer does not provide for full and open competition regardless of the number of sources solicited. If a brand name will be used, you must justify it and clearly explain why a specific brand produced by a single company is required, as opposed to allowing full and open competition. The justification should indicate that the use of such descriptions in the acquisition is essential to the Government's requirements, thereby precluding consideration of a product manufactured by another company. (FAR 6.302-1(c)) Brand-name or equal descriptions do not require justifications and approvals to support their use.

In the case of a follow-on contract for continued development or production of a major system or highly specialized equipment/services, the rationale must first justify the supplies/services as being a “major system” or “highly specialized.” The rationale must then justify “either” substantial duplication of cost to the government that is not expected to be recovered through competition, or unacceptable delays in fulfilling the agency's requirements, whichever situation applies. If both of these situations apply, the rationale can be based on either of these two situations, or both. Justifications for follow-on contracts should be organized as below:

Subsection 1

(a) Describe the system or support element to which supply/service to be procured under the contemplated acquisition relates in terms of its purpose and its capabilities. Describe how the contemplated acquisition relates to that system or support element. Describe the previous acquisition history, to include a description of the work the contractor has been performing. Additionally, include the current contract number, basis of award for that contract (competitive/sole source), when the contract was awarded, and when the contract will expire. If the work the contractor will perform under the contemplated acquisition is being done under an ACAT I or II program, state that designation. If the work will not be done under an ACAT I or II program, provide a detailed explanation from a technical perspective as to why the supplies/services to be procured are “highly specialized.” This section must summarize your justification by including the main point(s) of the justification.

(b) If the planned acquisition is a “bridge” effort, which contains options, so state and explain why options are necessary.

(c) Add a concluding sentence to the end of this paragraph, suitably tailored; e.g., “Therefore, this acquisition will be a follow-on contract for the continued production of a major system,” or “Therefore, this acquisition will be a follow-on contract for the continued development of highly specialized equipment,” or “Therefore, this acquisition will be follow-on contract for the continued development of a major system,” or “Therefore, this acquisition will be a follow-on contract for the continued production of highly specialized equipment,” or “Therefore, this acquisition is for continued performance of a highly specialized service.”

Subsection 2

Begin with the following sentence, as applicable: "Award to any other source would result in substantial duplication of cost to the Government that is not expected to be recovered through competition” or “Award to any other source would result in unacceptable delays in fulfilling the Air Force's requirements” or “Award to any other source would result in substantial duplication of cost to the Government that is not expected to be recovered through competition and unacceptable delays in fulfilling the Air Force's requirements.” Then, discuss either or both of the following situations (although only one of these situations is needed; if the facts exist to support both, then provide that information):

(a) When the rationale is based on substantial duplication of costs, estimate the amount of duplicated costs and offset that by the amount of cost savings that are likely to be generated by competition, if feasible. Include the rationale for the amount of cost that would be duplicated (e.g., training required so that another source could acquire the skills necessary to perform the effort, equipment, facilities) and how the estimates were derived (e.g., development costs incurred by the Government under the existing contract or similar programs). (FAR 6.303-2(b)(9)(ii))

(b) When the rationale is based on unacceptable delay, provide the length of the anticipated delay, state how long it would take another source to obtain this capability (e.g., months, years) and why (if applicable), provide a description of exactly what is being delayed, and provide a detailed explanation of the impact or problem caused by the delay. For example, the impact of not adding additional quantities of launch support services staff-hours to an existing contract might cause a launch to not occur as scheduled, thus delaying the operational use of a spacecraft, thus reducing the constellation's operational availability - and thus reducing (or precluding) the ability of the war fighter to accomplish specific missions.

Subsection 3

Include one of the following sentences, whichever is applicable:

(a) “Accordingly, XYZ Corporation is the only firm capable of providing the supplies and 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.”

(b) “Accordingly, XYZ Corporation is the only firm capable of providing the supplies and services described in Section III above without the U.S. Air Force experiencing unacceptable delays in fulfilling its requirements.”

(c) “Accordingly, XYZ Corporation is the only firm capable of providing the supplies and 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.”

B. Unusual and Compelling Urgency (FAR 6.302-2, DFARS PGI 206.302-2)

Contracting Officers shall contact SAF/AQC at usaf.pentagon.saf-aq.mbx.saf-aqc-workflow@mail.mil as soon as practicable when contemplating an award under the authority cited in FAR 6.302-2 for J&As requiring SPE approval. Provide an explanation why (1) the supplies or services are needed at once because of fire, flood, explosion, or other disaster, or (2) essential equipment or repairs to that equipment are needed at once, e.g., to preclude impairment of launch capabilities or mission performance of missiles or missile support equipment, eliminate imminent grounding of the XX fleet crucial to what mission of the USAF and Defense of the Nation. In other words, identify the anticipated serious injury to the Government, the nature of the urgency, the reasons for it occurring and why it is “urgent and compelling” to preclude adverse impact to military readiness. Merely citing a Joint Urgent Operational Need (JUON), Force Activity Designator (FAD) rating, Program Management Directive (PMD)/Program Action Directive (PAD) guidance, or DX priority rating is not in and of itself sufficient reason to use this exception from the requirement to obtain full and open competition. Note that only the minimum quantity required to satisfy the unusual and compelling urgency qualifies for this exception; thus, this exception might not suffice to justify option quantities. For example, a JUON covering an entire program may not necessarily warrant a class J&A for all program requirements. The inclusion of future “unknown” requirements in class J&As proceeding on this basis is disfavored. In addition, actions covered by a relevant JUON should, a) cite the JUON, b) describe the nature of the need covered by the JUON, and c) describe the relationship between the JUON and the requirements contemplated under the J&A (e.g., whether the J&A includes requirements not covered by the JUON, whether the J&A covers just a portion of the JUON's scope, etc.). JUONs can provide important support for the J&A; however, the J&A is a stand-alone document and should not rely solely upon the fact that a JUON has been issued as a basis for approval. Activities are under a continuing duty to ensure maximum competition practicable under the circumstances, and JUONs do not automatically provide relief from that duty.

The exception for “unusual and compelling urgency” does not authorize a sole source contract. This exception only authorizes limitation to the greatest number of potential sources that can fulfill the requirement in the time needed. Therefore, the J&A should also describe the method and rationale for identifying the sources to which the solicitation will be limited. If the solicitation is to be limited to only one source, the J&A must be based on an exception that authorizes selection of a single source.

C. Industrial Mobilization; or Engineering, Developmental, or Research Capability (FAR 6.302-3)

The most important part of justifications citing this authority is demonstrating the need to maintain the capability possessed by the identified source(s). Some form of market survey may be critical in demonstrating the uniqueness of this capability.

D. Authorized or Required by Statute (FAR 6.302-5)

It is imperative to identify what is being acquired and the applicable statute authorizing other than full and open competition. Note: Some statutes do not require a written J&A.

E. National Security (FAR 6.302-6)

Provide the minimum essential information needed to establish validity of the justification. This information will make the J&A a classified document. Special handling procedures are required for processing such documentation to the approval authority. Only parties with a “need to know” and the proper level of security clearance should be permitted access to the documentation. Such acquisitions are also exempt from synopsis under FAR 5.202(a)(1).

This statutory authority requires that agencies shall request offers from as many potential sources as is practicable under the circumstances. This exception may be utilized to authorize limited competition in certain narrow circumstances; however, contracting officers may not authorize sole-source contracts solely through use of the national security exception unless disclosure of the agency's need to more than one source would compromise national security.

F. Public Interest (FAR 6.302-7)

(NOTE: Requires D&F in lieu of J&A.) This authority may only be used when none of the other authorities is appropriate and may not be made on a class basis. Provide detail addressing the reasons full and open competition is not in the public interest and why no other authority is appropriate for use.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

(FAR 6.303-2(b)(6))

Describe all efforts taken (or to be to be taken) to ensure that offers are solicited from as many potential sources as practicable under the circumstances. Although Market Research is covered in Section VIII, the information in Section VI should correlate with the Market Research described in Section VI. The following issues should be addressed in this paragraph:

Sources Sought Synopsis (utilized as part of market research). If a sources sought synopsis was issued, state the date the synopsis was issued and a brief description of its content. If any responses were received, describe in detail the results of the screening process and the rationale for determining the unacceptability of any synopsis respondents. This is particularly important when citing the authority of 10 USC 2304(c)(1), “Only one (or a limited number of) responsible source(s)”, since it is this survey of the market place that confirms our assumptions regarding the capability of industry to meet our needs.

Specify whether this acquisition will require a Notice of proposed Contract Action (NOCA) IAW FAR 5.201. Include whether a NOCA was or will be publicized, and specify the dates or expected dates of publication of the NOCA. If the NOCA was not or will not be issued, cite the specific authority for not doing so (FAR 5.202) and the rationale for the NOCA exception. Note that, although a NOCA initiated pursuant to FAR 6.302-2 may not be required, use of this authority is not an automatic exemption from the NOCA requirement (FAR 5.202(a)(2)). If a NOCA is issued, the J&A cannot be signed until the required publicizing time IAW FAR 5.203 has been satisfied and the NOCA results have been included in the J&A package."

Other Actions. In this paragraph, discuss any other actions taken or planned to facilitate competition for this acquisition. The discussion should include actions tried or considered even if the actions were unsuccessful. If the efforts were unsuccessful, so state and describe why.

Qualifying Country Sources. If qualifying country sources have expressed interest, but are to be excluded, provide supporting rationale.

VII. Determination by the Contracting Officer that the anticipated cost to the government will be fair and reasonable. (FAR 6.303-2(b)(7))

Include a statement by the contracting officer that the anticipated cost will be considered fair and reasonable and provide the basis for this determination. The steps that will be taken to ensure the final contract price will be fair and reasonable are also described here. Describe the extent of cost or price analysis anticipated including the requirements for certified cost or pricing data, technical evaluations, and audits.

VIII. Description of the market research conducted and the results, or explain why market research was not conducted. (FAR 6.303-2(b)(8))

Discuss any market research conducted pursuant to FAR Part 10 and describe results of that research. Market research is any effort undertaken to determine if sources capable of satisfying the agency's requirements exist and to determine if commercial items or non-developmental items are either available or can be modified so that they will satisfy the agency's needs. Market research should be focused not only on identifying alternate sources, but also on alternate equipment or substitutes that might fulfill the Government needs with only minor modification. Regardless of the approach used, the results should provide a high level of confidence that no other qualified sources exist.

Generally, some form of market research should be conducted. But it is most critical when citing the authority of FAR 6.302-1. Under such circumstances, use the following sentence: “As described in Section VI above, market research, in accordance with FAR Part 10, was conducted by synopsis of the proposed acquisition, advising industry of the pending acquisition and soliciting inquiries from interested parties.”

When other exceptions from the requirement to obtain full and open competition are relied upon, the market research might be limited to an examination of the acquisition history and experience with the marketplace under previous acquisitions for the same or similar items.

If no market research was conducted, so state and provide the rationale.

IX. Any other facts supporting the use of Other Than Full and Open Competition. (FAR 6.303-2(b)(9)(i))

Provide any other facts supporting the use of other than full and open competition, including an explanation of why technical data packages, specifications, engineering descriptions, statements of work, statements of objectives, or purchase descriptions suitable for full and open competition have not been developed, are not being developed, are not being used, or are not available. (FAR 6.302-1(b)(2) and 6.303-2(b)(9)(i)).

X. List of sources, if any, that expressed interest in the acquisition. (FAR 6.303-2(b)(10))

If a sources sought synopsis was done and all interested sources are included in Section VI, it is acceptable to state, “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. (FAR 6.303-2(b)(11))

Describe any actions taken or to be taken to foster competition for future acquisitions of the supplies or services being acquired. Describe potential actions that could be taken to remove the barriers to competition that have been identified in the justification and include a milestone schedule, where available, for accomplishing these actions. For example, if a follow-on competitive acquisition is planned, so state and provide the planned award date (FAR 6.303-2(b)(11)), or state that the Government will attempt to acquire rights in technical data and computer software sufficient to compete follow-on acquisitions as a priced option in the contract action that is the subject of this J&A, or (if applicable) state how the Government intends to challenge nonconforming markings on technical data and computer software delivered to it under previous contracts so those markings can be removed in order that the technical data and computer software may be used in support of a follow-on competitive acquisition, or describe plans to qualify additional sources.

Address efforts to ensure competition for future spare parts and maintenance in support of systems or equipment covered by the justification, even when these acquisitions will be accomplished by other organizations. Include a discussion on available breakout data.

If no actions are planned, so state and provide reasons. If approval is sought for more than one year, explain why a sole source effort is required for the planned time duration.

For a non-competitive follow-on acquisition to a previous award for the same supply or service supported by a J&A citing the authority at FAR 6.302-1, include a discussion of the actions planned to overcome barriers to competition established in the previous justification, the status of those actions, and the results of those actions. The approval authority shall determine whether the planned actions were completed. If the planned actions were not completed, the justification for the follow-on acquisition shall be approved by the approval authority one-level above the approval authority for the previous justification (see FAR 6.304). If the previous justification was approved by the Senior Procurement Executive (SPE), the approval remains at the SPE level.

[DFARS PGI 206.304(a)(S-70)(ii)] XII. Certification by the Contracting Officer. (FAR 6.303-2(b)(12))

As evidenced by his/her signature, the contracting officer has determined this document to be both accurate and complete to the best of his/her knowledge and belief.

XIII. Certification by the technical/requirements personnel. (FAR 6.303-2(c))

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.

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The following page contains a suggested template for “International Agreement Competitive Restrictions (IACR)”. The authority to prepare an IACR has been delegated from the HCA to the Contracting Officer.

(AFFARS 5306.302-4)

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IV. Statutory Authority: 10 USC 2304(c)(4) as implemented by FAR 6.302-4,…