Approved_IETMS_18-31540_JA_Redacted.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 8

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:

Contracting Activity: AFLCMC/WIUKA

Purchase Request / Local ID Number: FD2060-18-31522, FD2060-18-31540

Program / Project (and PE, if applicable): C-130 IETM Sustainment Sunset

Program Type (PEO or Other Contracting): PEO

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): J&A Type: Class Individual

COORDINATION (AFFARS 5306.304(a) )

Date Project Lead / Program Mgr / Requiring Activity

Signature

Date Contracting Officer

Date Local Legal Reviewer

APPROVAL (AFFARS 5306.304(a) )

Date

10 May 2018

Competition Advocate

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I. Contracting Activity.

This Justification and Approval is to request authority for Other Than Full and Open Competition supporting requirements generated for the AFLCMC/WIUAH. The contracting activity for this requirement is AFLCMC/WIUKA. The purchase request numbers supporting this contracting action are FD2060-18-31522 and FD2060-18-31540.

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

Due to the circumstances described herein, the activity request authority to acquire continued Interactive Electronic Technical Manual (IETM) data and Integrated Maintenance Information System (IMIS) software sustainment support using Other Than Full and Open Competition (OTF&OC) as prescribed by FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. This action will result in the award of a new follow-on definitive contract which will be a type “C” contract utilizing Firm Fixed Price (FFP), Cost Plus Fixed Fee (CPFF), and Cost Reimbursable No Fee (CRNF) pricing arrangements with a basic one year period plus two one year options. The projected period of performance (PoP) is 23 July 2018 through 22 July 2021 if both options are exercised.

This sole source effort will be procured from the following company:

The Boeing Company DBA: Boeing 626 Anchors Street NW Fort Walton Beach, FL 32548- 3861

CAGE: 022T1

Large Business

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

This acquisition is for sustainment support for IETM data and IMIS software for the AC-130U and C-130H until the AC-130U aircraft is retired from service. This contract will include sustaining all tools and software supporting IETM development, integration, fielding and sustainment. It is anticipated that at the conclusion of this contract, the AC-130U aircraft will be retired and the C-130 IMIS/IETM will no longer be required.

The annual sustainment support services required are to sustain the IETM, wiring, tools, databases, software and process required to ensure the C-130 IETM/IMIS remains safe, operational, accurate, and up to date and user friendly when viewed from an approved and properly configured Air Force (AF) electronic viewing device.

The following is a breakout of the anticipated labor hours for each area of IMIS/IETM sustainment as well as ancillary requirements for travel and material:

(1) IETM Authoring and data sustainment:

(2) IETM Database Coordinator and IETM Information System Integration:

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(3) Help Desk functions;

(4) IETM database supporting tools:

(5) IMIS/IETM Supporting software sustainment; .

(6) Travel:

(7) Material:

Contract Line Item Numbers (CLINs):

(1) CLIN 0001: IETM Data Sustainment (Integrating source data to sustain the AC-130U IETM up to date) (FFP)

(2) CLIN 0002: IETM Software Sustainment (Maintain/Update C-130 IMIS software and supporting tools operational in support of the AC-130U aircraft until the aircraft retire from service) (CPFF)

(3) CLIN 0003: IETM Data Drop (FFP)

(4) CLIN 0004: Travel (CRNF)

(5) CLIN 0005: IETM Material (CRNF)

(6) CLIN 0006: IETM Over and Above (CPFF)

(7) CLIN 0007: IETM Data (NSP)

This sole source contract will include a basic one year period followed by two one year options. The projected PoP is 23 July 2018 through 22 July 2021, if both options are exercised.

The funding type for this effort is Operations and Maintenance (O&M) 3400.

Below are the anticipated PoP dates and estimated cost for the basic and options:

Period Period of Performance Estimated Value Funding Basic 23 July 2018 - 22 July 2019 FY18 3400 Option I 23 July 2019 - 22 July 2020 FY19 3400 Option II 23 July 2020 - 22 July 2021 FY20 3400 Total:

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

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

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

Boeing has been sustaining C-130 IMIS and IETM since 2003/2004 due to their assistance in the development of the IMIS and their proprietary rights associated with the IETM. IMIS/IETM was fielded for operational use by Air Force Special Operations Command (AFSOC) C-130 units in 2009.

The AF has since developed a new Technical Data (TD) specification, S1000D and has established policies which replace the previous specification used for IETM.

The C-130 IETM was developed in 2004 by the Original Equipment Manufacturer (OEM), Boeing, in the absence of an AF IETM specification, which they have sustained and upgraded since then. Boeing possesses the highly specialized skills required for maintaining and upgrading the IETM to operate on an AF Standard Desktop Compliant (SDC) device. The Quill 21 Authoring Tool, Data Courier Web, Wiring Illuminator Web (WIW) and Data Renaissance Suite are all owned by Boeing to include intellectual properties (IPs). In 2016, the three primary C-130 TD MAJCOMs, Air Combat Command (ACC), Air Mobility Command (AMC) and AFSOC, agreed to pursue a C-130 AF Enterprise TD solution for all USAF C-130s using the new S1000D AF Business Rules (BRs). AFSOC has determined they will continue to use IMIS/IETM solely for supporting AC-130U operations until the aircraft is retired which is planned no later than end of 4th QTR FY20. Therefore this follow-on acquisition is for continued performance of a highly specialized system until the AC-130U is retired.

The Government determined in 2014 that it could not sustain the IETM software organically due to Boeings proprietary Commercial Off the Shelf (COTS) software such as Data Courier Web, Quill 21 Authoring Tool, WIW and associated IPs. In 2016, the Government was able to achieve organic sustainment of the IETM through partnering with Boeing. The understanding between Boeing and the Government allowed for the Government to organically sustain the IETM in which Boeing would not charge the Government licensing fees provided the Government retains only limited OEM authoring capability. The Government now sustains 90% of the IETM data.

The IETM data would be rendered unusable without the IMIS. The IMIS was developed by Boeing but is a Government owned system. This system is the security wrapper for the IETM data and provides operational guidance specific to a C-130 Aircraft tail number. Without this data being properly vetted through the IMIS, impacts to operational safety may occur. AFSOC estimated to convert IETM TD back into PDF format would cost approximately . The current C-130 IMIS/IETM sunset will coincide with the retirement of the AC-130U from service while an S1000D solution is pursued.

Boeing is the only contractor with the capability to sustain the C-130 IETM/IMIS on the AC-130U aircraft and common slick C-130H technical data until its retirement in 2021.

The estimated time it would take the Government to reverse engineer the IETM software and its 10 GBites of data, functionality, and capability would be at least one year with a dedicated effort of at least five software engineers. Additionally, the new software would have to become certified and accredited to operate on the AF Network which takes approximately two years. In totality it could take up to three years or more resulting in high risk to the AFSOC AC-130U missions by creating disruptions to service.

The IETM software is owned by Boeing but available commercially as COTS. The IPs are proprietary to Boeing. The Government could purchase the software, but would have to re-contract with Boeing

March 2018 FOR OFFICIAL USE ONLY Page 5 of 8 for an update every time the AF Information Technology (IT) security software changed. This would cause disruption of service in our ability to provide the most current and accurate data for C-130 aircraft maintainers. Purchasing the software would initially cost an estimated with an annual licensing fee of approximately . The Government would have to pay the OEM for any changes to the current software based on changes caused by AF IT upgrades that may affect performance. The Government estimates it would take a new contractor at least one year from contract award to be capable of sustaining the AC-130U IETM. This learning curve would significantly increase risk as the AC-130U technical data would no longer remain current resulting in the technical data being unsafe for operations. Retaining Boeing for continued sustainment of the IETM and IMIS software would mitigate such risk. AFSOC would have the ability to continue essential operational capability for AC-130U operations.

This is a follow-on contract to task order FA8530-08-D-0004-0024. This task order was awarded sole source to Boeing and expires 22 July 2018.

Award to any other source would result in substantial duplication of cost to the Government that is not expected to be recovered through competition. Another vendor could potentially create a new IETM for AC-130U operations. Development of a new IETM is estimated to cost approximately and take four years to develop but would utilize the current PDF IETM technical data. This cost and time estimate is based on similar conversion efforts such as the C-17, HH-60 and the historical cost from the initial conversion of the C-130 paper/PDF into a Type II IETM. This would create an unacceptable delay in fulfilling the Government's requirements.

The agencies are estimating a two year conversion effort with fielding beginning in year three for all USAF C-130 variants. Currently there is no other technical data other than IETMs for supporting AC-130U aircraft operations. Sustaining the current IETM for the next three years is estimated to cost with no disruption in service. Therefore, any effort to pursue another source in lieu of utilizing the current IETM source for the next three years would have a negative cost impact as the MAJCOMs are in the acquisition phase to award a contract for an S1000D IETM. It would result in two overlapping efforts each costing , and the other non-S1000D IETM would not field before the joint MAJCOM C-130 S1000D IETM. The initial C-130 IETM conversion effort cost and took six years to deliver. With efficiencies learned and a far broader market, it is estimated another vendor could develop another non-S1000D C-130 IETM for approximately and take four years. The Government would not recover the investment costs by the projected retirement date of the AC-130U, 2021. This instant acquisition is projected to sunset the IETM to coincide with the AC-130U platform retiring from service. There is currently no other vendor capable of sustaining the current AC-130U IETM without incurring a lengthy delay to re-author and manipulate the existing IETM. Additionally, this would impose significant risk to the warfighter as the AC-130U only has IETM data to support day to day operations. Using another vendor would mean the current IETM would no longer remain current while the data is being re-authored and manipulated. This could result in serious injury, death or loss of equipment. To mitigate the potential harm, the C-130U aircraft would have to remain incapable of supporting operations until the new vendor was complete with the data re-authoring and manipulation.

Accordingly, Boeing is the only firm capable of providing the supplies and services described in

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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.

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

A Sources Sought (SS) / Request for Information (RFI) synopsis was posted to the Federal Business Opportunities (FedBizOpps) website on 13 October 2017 with a response date of 13 Nov 2017 under Solicitation Number AC-130U IETM/IMIS Support - FA8509-18-RFI01. The SS/RFI requested responses from interested parties capable of sustaining the current C-130 IETM. Two potential vendors responded. The Government determined neither vendor owned the necessary proprietary software or authoring tools and were therefore deemed non capable of sustaining the current C-130

IETM.

This requirement will be synopsized on the FedBizOpps in accordance with FAR 5.201. It is anticipated that sources having an interest in subcontracting may be identified through this synopsis.

Any source who responds to the Government as a result of this synopsis will be identified to the prime contractor as a potential subcontracting possibility.

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

The overall cost of this acquisition will be fair and reasonable to the Government. In accordance with FAR 15.403-4 the contractor will be required to provide certified cost or pricing data to be used to support the Government's evaluation of the proposed cost. The proposed skill mix of labor, labor hours, types and quantities of material, other direct costs, and direct and indirect rates will be negotiated by the Government based on recommendations from the Defense Contract Management Agency (DCMA) and expert technical personnel who support the program. The contract price will be negotiated in accordance with FAR Part 15 ensuring the ultimate cost to the Government is fair and reasonable.

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

Market research was conducted and completed 19 December 2017 in accordance with FAR Part

10.001 and 10.002. The market research techniques used are as follows:

A SS/RFI synopsis was posted to FedBizOpps on 13 October 2017. Two potential vendors responded.

The Government determined neither vendor owned the necessary proprietary software or authoring tools and were therefore deemed non capable of sustaining the current C-130 IMIS/IETM.

The Government team researched potential vendors on the Web but did not find any vendors who possessed the necessary proprietary software and authoring tools to sustain the current C-130 IMIS/ IETM without re-authoring and manipulation of the data. The web sites searched are as follows:

March 2018 FOR OFFICIAL USE ONLY Page 7 of 8 www.trulogic.com/ , https://en.wikipedia.org/wiki/IETM/ https://www.dtb.com/ietm-authoring/ https://www.sdl.com/software-and-services/knowledge-delivery/contenta.../ietp.html

The IMIS/IETM software is owned by Boeing but available commercially as COTS. The IPs are proprietary to Boeing. Per AFSOC direction, the Boeing IMIS/IETM software will be used to continue sustainment of the AC-130U until aircraft retirement. The Government will sustain the data and the current OEM will sustain the software they own. There are no known commercial services that will satisfy the AF's requirement.

The market research concluded Boeing is the sole owner of the IETM software and IPs in which no other contractor possesses the proprietary data associated with the software, knowledge and specialized skills to assume responsibility for providing IMIS/IETM sustainment support.

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

None.

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

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.

Based on the results of the market research, other alternatives researched, and AFSOC direction, the Government team determined it would not be in the best interest of the Government to pursue development of a new vendor. Another vendor could potentially create a new IETM but the time required to develop a new IETM would disrupt AC-130U operations. Development of a new IETM is estimated to cost and take four years to develop. Retaining the OEM for the limited time remaining (through 4th QTR FY20) eliminates the risk of disruption to the critical AC-130U operations supporting the warfighters.

A reverse engineering effort of the software is anticipated to take at least one year with a dedicated group of five software engineers. Additionally, the new software would require certification and accreditation which is expected to take an additional two years. This is not feasible based on the projected life cycle of the AC-130U.

In light of the 2021 AC-130U retirement date, no actions are planned to break barriers to competition to support the Boeing unique IMIS/IETM.

The prior Exception to Fair Opportunity (EFO) stated the Government is transitioning to primarily organic sustainment through partnering. The Government partnered with the OEM with the

March 2018 FOR OFFICIAL USE ONLY Page 8 of 8 understanding the Government would begin sustaining the IETM data but would retain limited OEM authoring capability. The OEM agreed to allow the Government to organically sustain the IETM and not charge the Government licensing fees provided the Government retains only limited OEM authoring capability. The Government now sustains 90% of the IETM data.

The prior EFO plan to break barriers to competition was to purchase the IPs if it became economically feasible. The Government would be required to initially purchase the software at an estimated cost of with an annual licensing fee of approximately , in addition to the IPs. It has been determined not economically feasible to purchase the software and IPs.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.