Redacted_JA.pdf

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

I CONTRACTING ACTIVITY

This Justification and Approval to request authority for Other Than Full and Open Competition supports requirements generated for the Air Force Sustainment Center (AFSC), 638th Supply Chain Management Group (SCMG), 411th Supply Chain Management Squadron (SCMS)/GULA. The contracting activity for this requirement is AFMC AFSC/PZAAA; the purchase request number supporting this contracting action is

FD2060-12-01416.

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

Due to the circumstances described herein, the activity requests authority to acquire the service listed in this document using Other Than Full and Open Competition 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 contract, which will be a firm-fixed price contract with a basic year plus four one year ordering periods. This service is for depot level repair of the Control Display Unit (CDU) on the HH-60 Helicopter. This sole source requirement will be purchased from the following company:

Canadian Commercial Corporation (CCC) 50 O Conner Street Suit 1100 Ottawa ON K1A 0S6 Canada

CAGE: 98247

Large Business

Note: CCC is an intermediary agency for Government contracts with Canadian companies. This effort is subcontracted to the Original Equipment Manufacturer (OEM), CMC Electronics Inc., 600 Dr. Frederik Phillips Blvd, Saint-Laurent, QC, H4M 2S9, Canada. Cage: 38753 (formerly Canadian Marconi Corporation)

III. DESCRIPTION OF THE SUPPLIES/SERVICES REQUIRED TO MEET THE

AGENCY’S NEEDS

Under the contemplated contract, CMC Electronics Inc. will provide the following repairs which are required to support the Control Display Unit (CDU), utilized on the HH-60G, aircraft in sustainment of the USAF Special Operation Forces (SOF)/Personnel Recovery program:

Basic Requirement

NSN NOUN QTY UNIT PRICE TOTAL PRICE

5895-21-921-3286 CDU 96

Ordering Period 1

5895-21-921-3286 CDU 96

Ordering Period 2

5895-21-921-3286 CDU 96

Ordering Period 3

5895-21-921-3286 CDU 96

Ordering Period 4

5895-21-921-3286 CDU 96

TOTAL POTENTIAL CONTRACT VALUE

The total estimated cost of this service acquisition is , which is based on previous unit prices from Contract FA8524-11-D-0002 and D200 Summary computation, with a 4% inflation rate. This effort will be funded using 4930 Working Capital Funds.

RMC/RMSC code R3/D: RMC 3: Repair, for the second or subsequent time, directly from the actual manufacturer. RMSC D: If the data needed to complete contract repair is not physically available, it cannot be obtained economically, nor is it possible to draft adequate specifications or any other adequate, economical description of the repair for a competitive solicitation.

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)(A)&(B). 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

The CMA 882-5 CDU i s based on a Canadian Commercial Corporation (CCC) commercial product line and is therefore proprietary. The CDU is slated to be replaced in 2020. Starting in FY 2020 AFLCMC/WIUE will be replacing the CDU with a new improved CDU through attritions, with an estimated completion by FY 2025.

The Government does possess a drawing package; due to its proprietary nature it cannot be released outside the Government, nor is it complete to seek a secondary source of repair. The rights to the data would have to be purchased prior to its release to any potential sources. The data required to develop a depot repair capability includes engineering drawings, Acceptance Test Procedures (ATPs), firmware documentation for programmed logic devices, and software documentation for the embedded Operation Test Program. The drawing package purchased by the Government under an older contract i s n o t s u i t a b l e f o r c o m p e t i t i o n a n d does not reflect the present CDU production configuration. H o w e v e r , t his drawing package represents a “snapshot in time” of a baseline that existed in 1998 therefore is no longer current. Additionally, in a ROM given to the Government on 21 Sept 2009, CMC quoted a price of to procure unlimited, up-to-date data rights. On 31 October 2012 CMC stated that they will not sell the data rights for the CDU.

Qualifying a new source would require an extensive reverse engineering project, due to the complexity of the item and fact that the government does not own the data rights. T h e data required to develop a depot repair capability includes engineering drawings, Acceptance Test Procedures (ATPs), firmware documentation for programmed logic devices, and software documentation for the embedded Operation Test Program. CCC/CMC Electronics has been the depot repair facility for the CDU since 1988. The CDU is repaired using CCC owned and developed test stations, test software, and test procedures. However, an economic analysis by Adroit Systems, Inc in August 1998 under F09603-97-D-0174 determined the CCC depot was the most cost-effective means of repair.

Based on similar engineering project data, an estimated cost for a new vendor to redesign and/or reverse engineer the CDU would be no less than . Including delivery of a technical data package and qualification testing and reports, software development, and manufacture of the First Article assets would take approximately ten (10) years if they already owned the required FFA special tools/test equipment.

The Government has determined redesign or reverse engineering efforts to be cost prohibitive and result in unacceptable delays, significant duplication of cost and possible degradation of quality. As Part IX illustrates, 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 lead to unacceptable delays in fulfilling the agency's requirements. Between 1994 and 1998 the Government developed Test Program Sets (TPSs) and TOs for the CDU Line Replacement Unit (LRUs) and circuit card assemblies.

The organic depot for the CDU was never activated after an economic analysis by Adroit Systems, Inc. in August 1998 under FO9603-97-D-0174 determined the CCC depot to be more cost-effective. The amount spent developing the organic CDU depot repair capability was . Analysis performed in Oct 2012 found the costs to setup a second source of repair would exceed with a potential costs savings of 40% per repair, providing a minimum of 30 years for the Government to receive a Return on Investment (ROI). The program and service life of the A HH-60 is expected to be active through 2040.

Therefore, the unique supplies or services available from Canadian Commercial Corporation (CCC), Cage 98247, can only satisfy the USAF’s minimum need.

18~24 Months 54~72 Months 78~108 Months 90~132 108~156 ~14 years

CY15 CY16 CY17 CY18 CY19 CY20 CY21 CY22 CY23 CY24 CY25 CY26 CY27 CY28

18~24 Months

Award Eng Servc Contract

36~48 Months

Deliver Tech Data Package, Repair Data and First Article Test Report

24~36 Months

Award F&O Contract 18~24 Months Contractor develop capability 18~24 Months

Contractor Deliver Flight Tested and Repaired First Article and FA Test Report ~ 1 Year Contractor deliver first repaired asset

Engineer Services = $ per man year X 6 individuals X 4 years = $ Total delay in schedule to deliver first production assets = 10 ~ 14 years

VI. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE

SOLICITED FROM AS MANY POTENTIAL SOURCES AS DEEMED

PRACTICABLE

This requirement will be synopsized on the Federal Business Opportunities (FedBizOpps) web page as required by FAR 5.201. It is anticipated that sources having an interest in subcontracting opportunities may be identified through synopsis. Although the Government does not own data to support the acquisition of this CDU from any other source, any source who responds to the Government as a result of the synopsis will be identified to the prime contractor as a potential for subcontracting possibilities through the Government Primary Contracting Office (PCO).

VII. DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND

REASONABLE

IAW DFARS 215.403-1(c)(4)(C), DoD has waived the requirement for submission of cost or pricing data for the Canadian Commercial Corporation and its subcontractors.

Data other than certified cost or pricing data necessary to permit a determination by the U.S. Contracting Officer that the proposed price is fair and reasonable will be obtained.

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 on 8 September 2014, pursuant to FAR 10.001 and

10.002. Market research tools were utilized by the GOVERNMENT PROGRAM MANAGEMENT/ENGINEERING TEAM. The team members searched the internet, trade journals and the Haystack Database, which details the history of design for the item.

Also, an examination of the available technical data was conducted. A Federal Logistic Information search was performed to determine if the item was available from a different vendor. Also, an internet search was conducted, but revealed no other potential buy sources. Based on available information and engineering knowledge of the item and the aerospace industry, the only viable source for the repair of this part is CMC Electronics Inc. No small business and no small disadvantage opportunities can be met concerning this acquisition.

IX. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL

AND OPEN COMPETITION

None.

X. LIST OF SOURCES, IF ANY, THAT EXPRESSED 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

The Government does not own the rights to the data required to repair the CDUs. No sources other than the OEM are qualified to make or repair these assets, as they are proprietary to CMC Electronics Inc. On 11 October 2012, the 411 SCMS/GULA contacted the OEM concerning the procurement of data; the OEM is unwilling to sell the rights to this data to the Government. Analysis performed in Oct 2012 found the costs to setup a second source of repair would exceed with a potential costs savings of 40% per repair, providing a minimum of 30 years for the Government to receive a Return on Investment (ROI). The program and service life of the A HH-60 is expected to be active through 2040, but with the projected upgrade to the system, organic repair and reverse engineering will not provide any tangible savings. SORAP #02-009 (15 April 2002), DMI #95-0027 (25 June 2006); HQ AFMC/A4PC has issued a final recommendation that the CMC Electronics Inc., CDU remain as a contract source of repair due to a high initial expenditure/overhead that would be required for an organic workload startup. Further, the repair source data is proprietary to CMC Electronics Inc.

Starting in FY 2020 AFLCMC/WIUE will be replacing the CDU with a new improved CDU through attritions, with an estimated completion by FY 2025.

XII. CONTRACTING OFFICER’S CERTIFICATION

The contracting officer’s signature on the Coordination and Approval Document provides evidences that he/she has determined this document to be both accurate and complete to the best of his/her knowledge and belief.

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.