PR_15-93596_JA(1).docx

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

I. CONTRACTING ACTIVITY

United States Air Force (USAF), Air Force Materiel Command (AFMC), Air Force Life Cycle Management Center (AFLCMC/WLNKA, Robins AFB, GA 31098-1670. The Procurement Contracting Officer (PCO) is Timothy Hudson, DSN: 468-9610.

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING PROCESSED

This Justification and Approval (J&A) requests the authority to use other than full and open competition (OTF&OC) to award a new contract for Contractor Logistics Support (CLS) for Self-Contained Navigation System (SCNS) applicable to C-130 aircraft. The contractor will provide depot-level repair, engineering analysis, technical support for Group A, Group B, software, support equipment, piece parts required to maintain the operational integrity and logistics supportability of SCNS systems. This acquisition will be awarded to, large company, GE Aviation Systems, LLC, 3290 Patterson Ave., SE, Grand Rapids, MI 49512-1991, Cage Code 35351 as an Air Force Reserve (AFRC), Air National Guard (ANG), Consolidated Asset Management (CAM) and Foreign Military Sales (FMS) Firm-Fixed Price (FFP) contractual vehicle. The Period of Performance (PoP) is a new one-year basic contract period.

III. DESCRIPTION OF THE SUPPLIES/SERVICES REQUIRED TO MEET THE AGENCY’S NEEDS

a. This procurement action is a bridge effort to a previous CLS contract FA8504-10-C-0013, which ends 30 Jun 2015. The contractor will provide depot-level repair, engineering analysis, technical support for Group A, Group B, software, support equipment, piece parts required to maintain the operational integrity and logistics supportability of SCNS systems for a one-year basic. A long-term follow-on contract is in early stages of acquisition strategy discussions; market research has not yet been accomplished; see section XI below for further information.

b. The C-130 Self-Contained Navigational System (SCNS) is an integrated navigation system. It provides the flight crew with three (3) independent navigation solutions: flight guidance, advisory information, and control over communications and navigation radios vital to C-130 mission accomplishment. The instant acquisition, using other than full and open contracting procedures, is to support C-130 aircraft equipped with the Self-Contained Navigation System (SCNS) and the Data Transfer System (DTS).

c. The expected period of performance for this effort is 1 July 2015 through 30 June 2016. Total estimated cost of this one-year effort is $6,238,342, which is based on the most recent contract (FA8504-10-C-0013). The price has been adjusted for escalation (5%). The expected increases and fluctuations in effort over the one-year period of performance.

d. Efforts under this contract will utilize Firm Fixed Price (FFP) Contract Line Item Numbers (CLINs), 3400 O&M. Travel consist of two separate costs: replacement and return of Field Service Representative (FSR) or permanent return against Cost Reimbursable with No Fee (CRNF).

IV. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN COMPETITION

10 USC 2304(c)(2) as implemented by FAR 6.302-2, unusual and compelling urgency.

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. After 30 June 2015, the Air Force will not have a means to supply or repair of SCNS components. The SCNS is the system on the aircraft that controls all communication and navigation radios as well as the aircraft’s only Global Positioning System (GPS) and its two (2) Inertial Navigation Units (INUs). Those systems are required for flight mission. The aircraft serves various operation theatres through classified missions and humanitarian efforts. Unclassified missions may include but is not limited to supplying weapons, ammunition, food, water, shelter and medical equipment/supplies for Air Force personnel in the theatre of operation. Humanitarian efforts may include but is not limited to food, water, shelter, medical supplies to devastated areas caused by flood, earthquakes or refugee status. Each aircraft has one (1) Bus Interface Control Unit (BICU) and three (3) Integrated Display Computer Units (IDCUs). On average 55 IDCUs and 38 BICUs are repaired each month. If either component fails that aircraft is grounded. Using historical failure rates, 15 aircraft will be grounded monthly after 30 June 2015 (totaling 180 aircraft). Accordingly the Air Force has an urgent and compelling need to insure those aircraft are not grounded.

b. GE Aviation LLC has been the primary SCNS contractor since 1985, and as such, has both considerable and unique knowledge relative to SCNS. GE Aviation has been awarded all previous sole source CLS contracts. As the Original Equipment Manufacturer (OEM) and only known qualified source capable of maintaining total logistics and technical support of the SCNS/DTS Group A, Group B, software, support equipment and piece parts for depot repair capability for the SCNS. GE Aviation designed, integrated, installed, produced and currently provides logistics support for SCNS throughout the world. Over 300 systems have been delivered to the United States Air Force (USAF), Air National Guard (ANG), the Air Force Reserve (AFR) and a few Foreign Military Sales (FMS) users. GE Aviation has total system management and configuration control responsibility. Moreover, GE Aviation provides specific engineering skills, systems technical understanding and specialized logistics capabilities, as required, to evaluate system interfaces, monitor testing activities and verify the integrated performance capability of the extremely wide range of complex equipment resident in C-130 aircraft. No other source has the required data and support equipment for the repair of components at all levels of maintenance - e.g., flight line, back shop or depot-level – along with the knowledge of system integration.

c. The Government does not own the data nor the rights to the data required to support this acquisition. The OEM is not willing to sell data rights to the Government when contacted 21 Aug 2014. The system is no longer in production, parts obsolescence and diminishing manufacturers will impact the configuration of hardware and software throughout the system’s remaining life (2030). The USAF has already begun the retirement of SCNS-applicable C-130E/H/P aircraft. Therefore, this acquisition is for continued performance of a highly specialized service.

d. AFLCMC believes that award to any other source would result in cost to the Government that is not expected to be recovered through competition and unacceptable delays in fulfilling the Air Force’s requirements.

An analysis was performed to identify costs which would be duplicated should any other contractor be awarded the CLS contract. The analysis has identified a total of ~$5,069,938 in duplication costs, in now-year dollars, excluding nonrecurring engineering. While difficult to estimate, a considerable non-recurring engineering effort would also be expected to bring a new contractor up to the equivalent level of support as that provided by GE Aviation. Some special test equipment and tooling is used to support the troubleshooting and repair of SCNS hardware. The equipment is used to troubleshoot, repair, and test both Line Replaceable Units (LRUs) and Shop Replaceable Units (SRUs). The total value of this equipment, excluding development costs and associated software costs, is estimated at $1,077,580. Any contractor other than GE Aviation would need to duplicate this equipment to adequately support the CLS repair requirements.

Engineering test equipment owned by GE Aviation and valued today at $572,621 would need to be duplicated should any other contractor be awarded the CLS effort. The new contractor would also need to provide the nonrecurring engineering necessary to duplicate these resources as they represent capabilities unique to the C-130 SCNS platform.

GE Aviation designed, developed, and built a system simulation lab to support the SCNS development programs. It has since been used to support technical research, to assist in hardware fault isolation, and to evaluate reported aircraft anomalies. The GE Aviation system simulation lab includes a high fidelity simulation of the C-130 avionics environment unique to SCNS. The capabilities of the system simulation lab are essential to providing the level of technical support expected from the CLS contractor. The equipment and the simulation software are the property of GE Aviation. The original price of a single lab station, independent of the development cost, was $423,000 in 1985 and now valued $530,019.

GE Aviation designed, developed, and built the support equipment needed to field load Operational Flight Program onto SCNS hardware components independent of the Navigation System Trainer Test Set (NSTTS). This capability is used today to support field recovery loading at remote sites. The equipment, independent of the development cost, is valued at $42,602.

The bench stock necessary to support the existing CLS effort, and therefore representative of that needed for the CLS effort, is valued at ~$501,200. The bench stock is held to support the extended lead times of certain items. A transition to a new contractor may result in unacceptable delays in certain repairs due to the non-availability of long lead-time items. Although other potential contractors may have an existing bench stock, the actual value of this particular portion of GE Aviation bench stock is dominated by items unique to SCNS. The majority of these items would not be present in another contractor’s inventory.

Reverse engineering requires giving the organization doing the task a sample of the equipment to be reverse engineered. In this case, the only known examples of the Engineering Test Equipment and System Simulation Lab are being used by GE Aviation to support SCNS under their current CLS contract. If the Government owned this equipment, we could not give the equipment to another contractor without shutting down CLS support for SCNS. Reverse engineering the equipment would take at least 18 months. Without CLS support, the majority of the C-130 fleet would be grounded before the reverse engineering effort could be completed.

Majority of the special equipment is one-of-a-kind and is required to support SCNS under the current CLS contract with GE Aviations. If it could be done at all, any new contractor would take at least 24 months to set-up and qualify said repair line. GE Aviations’ repair line would have to stay operation until the new repair line was operational.

e. There are no other vendors listed as an approved, alternate source for C-130 SCNS CLS. SCNS is a complex system that interacts with a large number of other C-130 sensors and systems. GE Aviation has been the primary SCNS contractor since 1985, and as such, has both considerable and unique knowledge relative to SCNS. Therefore, due to the system’s complexity and the lack of Government data rights, CLS for SCNS requires a high level of expertise and experience that no vendor could obtain without data and engineering support from the OEM. Replacement of SCNS has been estimated using several different approaches. The least expensive approach was estimated to cost $1.2B in FY 13 dollars. Most approaches to replacing SCNS would take 13 to 15 years to get to a point where a SCNS CLS contract was no longer necessary. Accordingly, GE Aviation 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 and substantial duplication of costs in fulfilling its requirements.

VI. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED FROM AS MANY POTENTIAL SOURCES AS DEEMED PRACTICABLE

This requirement will not be synopsized on the Federal Business Opportunities based on the urgency of the requirement.

VII. DETERMINATION BY THE CONTRACTING OFFICER THAT THE ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND REASONABLE

This effort will be a new Firm-Fixed-Price follow-on contract to an existing firm-fixed-price contract. The contracting officer will ensure the cost of this acquisition will be fair and reasonable to the government in accordance with FAR 15.4. The contractor will be required to provide certified cost or pricing data to be used supporting the government’s evaluation of the proposed cost. Negotiations will utilize recommendations from the Defense Contract Audit Agency (DCAA) and AFLCMC expert technical personnel from the Defense Contract Management Agency (DCMA).

VIII. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AND THE RESULTS, OR A STATEMENT OF THE REASONS MARKET RESEARCH WAS NOT CONDUCTED

As described in Section VI above, market research was finalized on 14 April 2015 in accordance with FAR Part 10 was conducted thorough documentation searches within Government databases, combined with various internet searches (Goggle) for logistics capability, technical and engineering experiences as well as skills. Engage qualified Government subject matters experts who assisted with gathering background information. GE Aviation has been the CLS contractor since designed in the mid-1980s.

The data rights for the SCNS technical data were reviewed. GE Aviation has sole rights to the data that is needed to support systems repairs. The data also does not list other vendors besides GE Aviation as approved, alternate sources. Because of the system complexity and the lack of Government data rights, CLS for SCNS requires a high level of expertise and experience that no vendor could obtain without data and engineering support from the original OEM, GE Aviation.

Internet searches were conducted to determine if another company might possess the required repair data of experience. The results of internet keyword searches are show below. References to “Smith’s Industries” and “Lear Siegler” that appear in the search results are just past names for GE Avionics.

· “Self Contained Navigation System”:

· 10,300 results. The first 30 (approximately) were reviewed for relevancy.

· There was one reference to KVH building a self contained navigation system but that was for a navigation sensor that has nothing to do with the C-130 SCNS.

· There was one reference to an Esterline AN/APN-208 self contained navigation system but this is a doppler navigation system that has nothing to do with C-130 SCNS.

· There was one reference to Hawk Aviation Maintenance Services but that is just a resume for their owner that says while in the Air Force he involved in the C-130 SCNS program as a pilot.

· “C-130 Self Contained Navigation System”

· 38 results. About 30 of those were review for relevancy. None of those were for a company other than GE.

· “Self Contained Navigation System Maintenance”

· Two results that were not relevant

· “Self Contained Navigation System Maintenance Contractor Logistics Support”

· Zero results. The search results are all for an alternative search suggested by Google.

· In the alternate search results there was one reference to SSAI. This was for a modification done to Poland’s C-130s. The modification changed radios and GPS receivers on the aircraft and made a small change to the SCNS OFP (software). The actual software mod was done by the Government in the SCNS SIF at Robins AFB. It is not relevant to the SCNS CLS contract.

· “Self Contained Navigation System CLS”

· Zero results. The search results are all for an alternative search suggested by Google.

· In the alternate search results there was one reference to L-3 TCS. That was for a modification that included a software mod to SCNS. The actual software mod was done by the Government in the SCNS SIF at Robins AFB. It is not relevant to the SCNS CLS contract.

· "SCNS contractor logistics support”

· 5 results. Results were either not relevant or relate to the SCNS work done by GE.

· "SCNS CLS”

· 19 results. Results were either not relevant or relate to the SCNS work done by GE.

Market research techniques:

· Internet searches: As described above.

· Industry days: An industry day was not warranted based on internet search results described above.

· One-on-one industry sessions: A one-on-one industry day was not warranted based on internet search results described above.

· Requests for Information (RFIs) to Industry (Solicitation for Information or Planning Purposes): RFIs were not warranted based on internet search results described above.

· Commerce Business Daily announcements: CBD announcements were not warranted based on internet search results described above.

· Sources Sought Synopsis (SSS), SSS was not warranted based on internet search results described above.

IX. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND OPEN COMPETITION

The government has not procured technical data to support competitive procurements. The OEM is not willing to sell data rights to the Government, which means that technical data packages, specification, and engineering description suitable for Full and Open Competition cannot be developed without reverse-engineering. As noted above, market research determined reverse-engineering to be cost-prohibitive. It will also result in delays, causing degradation in logistics support and decreased aircraft availability.

X. LIST OF SOURCES, IF ANY, THAT EXPRESSED 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

As the OEM, GE Aviation provides unique capabilities and data not available to any other contractor. Their specific repair procedures, unique data (software, tools, databases, software support, and engineering notebooks) and obsolete parts resolution further support this justification for a sole source acquisition. The Government will inquire the procurement of rights in technical data and computer software sufficient to compete follow-on acquisitions throughout the system’s remaining life (2030).

As mentioned in section III above, a long-term contract is in work. For the follow-on, extensive market research will be conducted to include in-depth techniques; i.e., all reasonable efforts will be made to break barriers to competition. At a minimum, the team will establish a plan (simultaneous with award of this instant contract) to follow up with the contractor for procurement of data on a regularly-scheduled basis, elevating within the company. Should we actually receive a proposal for data, we will POM for funding of the data.

XII. CONTRACTING OFFICER’S CERTIFICATION

The contracting officer’s signature on the Coordination and Approval Document evidences that he/she has determined this document to be both accurate and complete to the best of his/her knowledge and belief (FAR 6.303-2(a)(12)).

XIII. TECHNICAL/REQUIREMENTS PERSONNEL’S CERTIFICATION

As evidenced by their signatures on the Coordination and Approval Document, the technical and/or requirements personnel have certified that any supporting data contained herein, which is their responsibility, is both accurate and complete (FAR 6.303-2(b)).