20_30027_Justification_and_Approval.pdf

for

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

I. Contracting Activity.

This Justification and Approval is to request authority for Other Than Full and Open Competition supporting requirements generated for the Air Force Life Cycle Management Center (AFLCMC), Agile Combat Support Directorate, Electronic Warfare and Avionics Division (WNY). The contracting activity for this requirement is AFLCMC/WNK. The purchase request number supporting this contracting action is FD2060-20-30027.

II. Nature and/or Description of the Action Being Processed. [FAR 6.303-2(b) (2)]

Due to the circumstances described herein, the activity requests authority to acquire Sustaining Engineering Services in support of AN/USM-670AA Joint Service Electronic Combat System Tester (JSECST) and Test Program Interface Hardware (TPIH) Set using Other Than Full and Open Competition as prescribed by FAR 6.301-1, “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.” This action will result in the award of a follow-on Definite “C” contract which will consist of Firm-Fixed Price (FFP) and Cost Reimbursement-No Fee (CRNF) contract line item numbers (CLINs). The contract will consist of a one (1) year basic period plus four (4) one-year options. This contract is anticipated to be awarded no later than 29 May 2020. The anticipated Period of Performance (PoP) for this effort is 29 May 2020 to 28 May 2025.

This sole source requirement will be purchased from the following company:

AAI Corporation DBA: Textron Systems (“Textron”) 124 Industry Lane Hunt Valley, MD 21030-3342 Cage Code: 97384 Large Business

III. Description of the Supplies/Services Required to Meet Agency Needs. [FAR 6.303

2(b) (3)].

This requirement is to provide engineering services support and sustainment for the AN/USM- 670A Test Program Sets (TPS). The AN/USM-670A provides an end-to-end (ETE) functional testing capability that interfaces with Electronic Combat (EC) systems using the TPS software and TPIH for multiple AFMC aircraft. Utilizing the Core Test Set (CTS), the AN/USM-670A automatically determines Go/No-Go status of the EC system with minimal technician interaction. The EW subsystems include but are not limited to the following: AN/ALR-56C, AN/ALQ-135, AN/ALR-56M, AN/ALR-46/69, AN/ALR-69A, AN/ALQ-131, AN/ALQ-184, AN/ALQ-122, AN/ALQ-155, and AN/ALQ-172v1 & v2. These EW subsystems support various AF platforms including but not limited to the A-10, AC-130U/W, F-15C/E, F-16 (High Block, Low Block and Antenna Optimized (AO) configurations), MC-130H, and B-

52H.

The support services are required to assist in the development of TPS, participation in Formal Qualification Testing (FQT), and provide field support that provides safe and effective testing of the System Under Test (SUT). The effort contemplated includes contractor assistance requiring access to the technical data package (TDP) for all supported aircraft configurations that the United States Government (USG) does not own. Under the contemplated support services contract, Textron will provide those services, which are necessary to support WNY for their JSECST TPS development, and field support.

The nominal Contract Line Item Numbers (CLINs) and estimated costs anticipated for each period are as follows:

Total estimated contract value is $ A escalation factor was applied to estimated unit price for each Out-Year Option. The basis for the estimated cost was derived from historical data based on previous contracts. The contract will be funded with Operation and Maintenance (O&M) Centralized Asset Management (CAM) 3400. This contract is anticipated to be awarded no later than 29 May 2020. The PoP of this contract will be 29 May 2020 to 28 May 2025.

IV. Statutory Authority Permitting Other Than Full and Open Competition. [FAR 6.303-2(b) (4)]

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.

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)]

The agency’s minimum needs can only be satisfied by the unique supplies or services available from Textron in support of the USM-670A TPS. This requirement is for highly specialized services. The contemplated contract includes software engineering service enabled by unrestricted access to the Technical Data Packages (TDP) for supported aircraft configurations

CLIN Basic

(FY20)

Option I

(FY21)

Option II

(FY22)

Option

III

(FY23)

Option

IV

(FY24)

TOTAL

0001 Eng Services $ 0002 Travel $ 0003 Familiarization

0004 Data NSP NSP NSP NSP NSP NSP Total by FY $ that the USG does not possess. Textron will provide those services which are necessary to support WNY for their USM-670A TPS development and field support.

Textron is the Original Equipment Manufacturer (OEM) and possess all the proprietary hardware drawings and software to support the software engineering service requirements of this effort. As such, Textron corporate knowledge and access to hardware and software design criteria, test strategies and engineering notes is required to enable development of the System/Subsystem Specifications, software requirement allocations, system functional testing, deficiency analysis planning and execution.

The required services must provide effective, timely, and comprehensive support of all SUTs TPS, which require in-depth knowledge of USM-670A core hardware and software functionality and capability. As the Original Equipment Manufacturer (OEM) of the JSECST, Textron has intimate knowledge of the systems hardware and software architecture to ensure that changes to core system counter measure systems. Additionally, Textron continues to maintain a fully qualified staff of USM-670A engineers. The Government requested a ROM to purchase the TDP via email on 23 Oct 2019. Textron responded via an email dated 1 Nov 2019, stating that the Technical Data for the JSECST is not for sale. This data would be required to complete USM-670A TPS support.

The proposed contract will re-procure software engineering services provided by Textron under contract FA8523-14-C-0002, a sole source contract with a period of performance March 2014 through September 2019. Therefore, this instant acquisition is necessary for the continued performance of a highly specialized item/system. 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 and would require a redesign and/or reverse engineering effort to develop a TDP. Based on the Air Force's engineering staff's experience and engineering project data, a redesign and/or reverse engineering effort would expose the Air Force to unnecessary cost risk, schedule risk, and technical risks with no guarantee of success.

The Electronic Warfare Systems Program Office estimates it would take at least five years and to reverse engineer the core tester hardware and qualify a replacement source of services for the USM-670A TPS. The new source would have to obtain the necessary tools/equipment, and facilities to support the effort. In addition, the new source would be required to identify and rectify any obsolescence issues, deliver qualification reports, provide first article assets for the Government's review and approval. This effort would require that the Government evaluate any new hardware and evaluate/test all software code to determine form, fit, functionality. The Government estimates that this would take a minimum of three (3) years to accomplish, and also require 12-months of follow-on hardware and software interface evaluation to ascertain operational parametric data. Finally, each TPS would have to be analyzed at the system level to validate all operational capabilities. At each step, a thorough documentation effort would have to be performed to archive the engineering data/support information required. This analysis and integration with each EW system is estimated to require an additional 12 months to accomplish. The estimated development cost for such an effort, not including the cost of production assets, is estimated at . The time required and estimated cost is based on engineering expertise. Furthermore, the Warfighter would only have a form, fit, and function replacement resulting in an inability to sustain the current USM-670A TPS.

The Government performed a breakeven analysis for a reverse engineering effort. The analysis indicated it would take a minimum of 136 years' worth of sustainment before the Government would have a return on investment (ROI). Based on the annual average sustainment cost of the cost for the life of the system is estimated at $26,853,600.00. Since the asset will reach the end of its service life in 2060, assuming a competition savings factor of 25%, reverse engineering is a substantial duplication of costs to the Air Force that is not expected to be recovered through competition, as evidenced by the following:

With a projected life until 2060, the current annual average sustainment cost is estimated at

• Estimated total life cycle cost for 40 years is $26,853,600. Assuming that a reverse engineering effort was successful and competition resulted in a 25% reduction in sustainment cost, the new annual average sustainment cost would be $503,505 or total for 40 years of $20,140,200. A savings of $

• The total reverse engineering effort is estimated to cost $25M.

• At the end of life expectancy of 2060, an $18,286,600 deficit would remain from reverse engineering effort investment.

• By taking the average estimated sustainment delta of annually over 40 years, as a result of a competitive acquisition, an additional 136 years of repair would be required for the Government to recoup a ROI.

Given the amount time necessary to receive approval and funding as well as the actual time to undertake the reverse engineering effort, the Government has deemed a reverse engineering action not economically feasible at this time. The time required for such an effort would negatively affect and degrade mission effectiveness by delaying current sustainment of the USM- 670A TPS, which would result in degradation of EW systems. Any delay in procuring USM- 670A TPS engineering support would greatly reduce the survivability of the Warfighter in the rapidly growing EW threat environment and are unacceptable. This instant acquisition is required to successfully continue sustainment services in order to maintain mission effectiveness against vulnerable threats.

Accordingly, Textron is the only firm capable of providing the supplies and highly specialized services described in Section III. Award of this requirement, to any firm other than Textron, will result in the U.S. Air Force’s experiencing substantial duplication of cost that cannot be recovered through acquisition competition and/or unacceptable delay that would jeopardize the agency’s ability fulfill its requirements.

VI. Description of Efforts Made to Ensure that Offers are Solicited From as Many Potential Sources as Practicable. [FAR 6.303-2(b) (6)]

A Sources Sought (SS) synopsis was posted to Beta.SAM.gov on 4 February 2020 with a response date of 5 March 2020 under solicitation AN_USM_670_JSECTS_SES. The SS synopsis requested responses from interested vendors that possess the expertise, capabilities, and experience to meet the requirements for sustainment support services that will consist of engineering tasks in support of the USM-670A TPS engineering support. The AN/USM-670A Integrated Product Team (IPT) received one response from SONA Networks, LLC. The Government evaluated SONA Networks, LLC capabilities statement but deemed them not capable due to lack of experienced supporting the JSECST as well as access to the proprietary technical data required to enable the JSECST test program set software development tasks under this acquisition. Even if SONA were to provide resources experienced with the JSECST, the Government is unable to provide technical data and proprietary source code to SONA. As a result, Textron remains the sole vendor capable of fulfilling this specialized engineering services requirement. Although the Government does not own data sufficient to support the acquisition of these services from any other source, any source who responds to the Government because of this synopsis will be identified to the prime contractor as a potential source for subcontracting opportunities.

The requirement will be synopsized in Beta.SAM.gov in accordance with FAR 5.201. It is anticipated that sources having an interest in subcontracting may be identified through 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. [FAR 6.303-2(b) (7)]

The overall cost of this acquisition will be fair and reasonable to the Government. In accordance with FAR 15.403-3, the Contracting Officer will require the submission of other than certified cost or pricing data. Price analysis or cost analysis based on “information other than certified cost or pricing data” will be used to examine and evaluate the proposed prices to determine fair and reasonable pricing. Price analysis techniques include comparison of proposed prices to historical prices paid for a same or similar item; comparison with published price lists, offered catalog prices and prices obtained through market research for a same or similar item; comparison of proposed prices with independent Government estimate; or analysis of data other than certified cost or pricing information.

VIII. Description of the Market Research Conducted and the Results [FAR 6.303-1(b) (8)]

Market research was conducted in accordance with FAR Part 10.001 and 10.002. The market research was completed on 16 Mar 2020. Market research techniques used are as follows:

A search was conducted on the world-wide-web in an effort to locate potential contractors with the capability to provide the required services for this requirement. A Small Business search on Dynamic Small Business Search (DSBS) using NAICS 541330 with “O-level tester” and “USM-670A” was conducted. “O-level tester” yielded Zero (0) small businesses and “USM- 670A yielded zero (0). A Google search using “USM-670A” identified one (1) unique company to provide potential sources of services, which was Textron, the OEM.

A SS synopsis was posted to Beta.SAM.gov on 4 February 2020 under Solicitation #

AN_USM_670_JSECTS_SES. One response was received from SONA Networks, LLC, which the USM-670A IPT evaluated and deemed the vendor not capable.

Surveillance: A continuous effort was upheld to provide awareness of the market or markets related to the mission area or capabilities being acquired. Information was gathered at the Association of Old Crows 2019 Dixie Crow Symposium, where vendors provided a demonstration of their services but resulted in zero potential new sources.

The USM-670 TPS does not fit the definition of a commercial item as defined in FAR Part

2.101. This item is defined as military unique and is not customarily used by the general public or by non-Governmental entities. The Government requires parts that meet an exact form, fit, and function as determined by the specific mission. There are no aircraft in the commercial market with the same or similar components.

Market research revealed that no vendor, other than Textron, was found to have the knowledge, experience, and proprietary technical data required to support the USM-670A TPS effort. The market research concluded Textron is the only vendor capable of fulfilling the Government's requirement.

IX. Any Other Facts Supporting the Use of Other Than Full and Open Competition. [FAR 6.303-2(b) (9) (i)]

None

X. List of Sources, if any, That Expressed Interest in the Acquisition. [FAR 6.303-2(b) (10)

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)]

Currently the USG has achieved approximately 90% organic capability for JSECST software development. The requirement for this effort is only 10%, which is the knowledge and data required to successfully integrate the software (TPS) with the hardware (CORE).

In an effort to overcome future barriers to competing the support required under this effort, WNY will require specialized familiarization training under this instant contract. WNY will also closely coordinate with the 402nd Software Engineering Group located at Robins Air Force Base to enable organic knowledge share via a complete database of software problems, distribute comprehensive Software Test Descriptions and Reports for each testing activity performed, and collaborate on hardware and software integration for the USM-670A TPS.

WNY aims to achieve 95% organic capability for JSECST software development by 2025. In addition, the Government will continue to engage with the OEM on an annual basis to determine the feasibility of procuring the TDP.

The plan to break barriers to competition in the prior J&A was to continue engaging the OEM on selling the TDP to the Government. That plan was executed but the OEM continues to decline to sell the TDP to the Government. Based on fulfillment of the prior plan, the current J&A does not require higher level approval in accordance with DFARS PGI 206.304(a) (S-70) (ii).

XII. Certification by the Contracting Officer. [FAR 6.303-2(b) (12)]

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. Technical/Requirements Personnel’s Certification. [FAR 6.303-2(c)]

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