JA__FA8524-16-D-0002_Redacted.pdf

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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 Sustainment Center (AFSC), 638th Supply Chain Management Group (SCMG), 411th Supply Chain Management Squadron (SCMS)/GULD. The contracting agency for this requirement is AFSC/PZAAA at Warner Robins, GA. The purchase request number supporting this contracting action is FD2060-14- 01004.

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

The purpose of this action is to acquire contractor depot level repair services for the APN-239 Color Weather Radar (CWR) system assets installed on the HH-60G Helicopter. The APN-239 CWR system consists of four Line Replaceable Units (LRU).

However, there are five (5) separate National Stock Numbers (NSN) that are used for the APN-239 CWR. One Receiver-Transmitter is installed on the helicopter yet NSN 5841- 01-363-2767SO and 5841-01-267-5934SO are 2-way interchangeable. Receiver- Transmitter, NSN 5841-01-363-2767SO; Receiver-Transmitter, NSN 5841-01-267- 5934SO; Antenna Drive Unit, NSN 5985-01-009-2872SO; Indicator, NSN 5841-01-267- 5932SO; Interface Unit, NSN 5841-01-412-7459SO.

Due to the circumstances described herein, the activity requests authority to acquire the repair services listed in the document using Other Than Full and Open Competition as prescribed by FAR 6.302-1. 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 (4) Option years. This Limited Competition repair source requirement will be purchased from one of the following companies:

Telephonics Corporation Cage Code # 64694 Command Systems Division POC: David M. Simek 815 Broad Hollow Road Ph. (631) 755-7267 Farmingdale, NY 11735-3904 E-mail: Simek@telephonics.com Large Business

Capital Avionics, Inc Cage Code: 02ZD5 3701 Hartsfield Rd NAICS: 488190 (Small Business) Tallahassee, FL. 32303-1120 POCs: Donna Ingle http://capitalavionics.com Ph. 850-575-4028 E-mail: donna@capitalavionics.com mailto:Simek@telephonics.com http://capitalavionics.com/ mailto:donna@capitalavionics.com

III. DESCRIPTION OF THE SUPPLIES/SERVICES REQUIRED TO MEET

THE AGENCY’S NEEDS

Under the contemplated contract, one of the above listed companies will provide the following repair services, which are required to support the HH-60G Pave Hawk Helicopter in sustainment of the USAF Special Operation Forces (SOF) program:

TOTAL CONTRACT COST

1. NSN 5841012675932SO

4% increase

QTY EACH TOTAL EACH TOTAL EACH TOTAL EACH TOTAL EACH TOTAL

REPAIR 90

NFF 1

BER 6

Total Total Total Total Total

2. NSN 5841013632767SO

4% increase

QTY EACH TOTAL EACH TOTAL EACH TOTAL EACH TOTAL EACH TOTAL

REPAIR 45

NFF 1

BER 1

Total Total Total Total Total

3. NSN 5841014127459SO

4% increase

QTY EACH TOTAL EACH TOTAL EACH TOTAL EACH TOTAL EACH TOTAL

REPAIR 15

NFF 1

BER 1

Total Total Total Total Total

4. NSN 5985010092872SO

4% increase

QTY EACH TOTAL EACH TOTAL EACH TOTAL EACH TOTAL EACH TOTAL

REPAIR 20

NFF 1

BER 1

Total Total Total Total Total

5. NSN 5841012675934

4% increase

QTY EACH TOTAL EACH TOTAL EACH TOTAL EACH TOTAL EACH TOTAL

REPAIR 5

NFF 1

BER 1

Total Total Total Total Total

TOTAL COST

3% per contract CAV CAV CAV CAV CAV

2% per contract IUID MARK IUID MARK IUID MARK IUID MARK IUID MARK Same as contract IUID PLAN IUID PLAN IUID PLAN IUID PLAN IUID PLAN

Total Total Total Total Total

FY20 - Option 4 COST

FY20 - Option 4 COST

APN-239 Color Weather Radar Repair BASIC + 4 Option Years

FY16 - BASIC COST

FY16 - BASIC COST

FY16 - BASIC COST

FY17 - Option 1 COST

FY17 - Option 1 COST

FY18 - Option 2 COST FY19 - Option 3 COST FY20 - Option 4 COST

FY17 - Option 1 COST FY18 - Option 2 COST FY19 - Option 3 COST FY20 - Option 4 COST

FY18 - Option 2 COST FY19 - Option 3 COST

FY20 - Option 4 COST

FY16 - BASIC COST FY17 - Option 1 COST FY18 - Option 2 COST FY19 - Option 3 COST FY20 - Option 4 COST

FY16 - BASIC COST FY17 - Option 1 COST FY18 - Option 2 COST FY19 - Option 3 COST

FY16 - BASIC COST FY17 - Option 1 COST FY18 - Option 2 COST FY19 - Option 3 COST

TOTAL POTENTIAL CONTRACT VALUE =

Basis for the estimated cost for this repair is based on the repair cost from the last Ordering Period (Ordering Period 1) of the previous Repair Contract (FA8524-14-D- 0011) plus a 4 % inflation factor added to each Ordering Period. Deliveries of these repair services will occur between March 2016 and April 2021. This effort will be funded using 4930 Working Capital Funds.

IV. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND

OPEN COMPETITION

10 USC 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

The agency’s minimum needs can only be satisfied by the unique supplies or services available from only the above cited source, which possesses unique capabilities demonstrated as follows:

The APN-239 CWR System uses technology that is proprietary to Telephonics Corporation, Cage Code 64694. They are the only responsible source for manufacturing these assets and own proprietary tech data for manufacturing, engineering, test software, as well as data needed for repair for these items. The market was surveyed for other commercial repair sources and two other companies were identified as potential repair sources. Duncan Aviation Component Solutions and Capital Avionics, Inc have supplied documentation to show they successfully repaired these assets for commercial customers.

The agency’s needs for the services are required in order to support current combat search and rescue operations. The government does not own or have access to the data for these items. Telephonics is the OEM and has repaired these assets for the Air Force since 2000. Duncan Aviation Component Solutions and Capital Avionics, Inc were informed that they would be required to submit a Source Approval Request (SAR) package to the Government for evaluation by the Government Engineer in order to qualify them as repair sources for the Government. A Pre-qualification package was posted on Fed Biz Opps for 30 days to solicit any potential sources and one company, Capital Avionics, Inc, Cage Code: 02ZD5 submitted a Source Approval Request (SAR) package. The Cognizant government engineering office reviewed the SAR package and pre-qualified Capital Avionics as a repair source for these assets. Duncan Aviation Component Solutions did not submit a SAR package and the 30 day period given to submit a SAR ended 27 May 2015. The Government Program Manager sent an e-mail to Duncan Aviation on July 10 2015 asking if their company was still interested in being a potential repair source for http://www4.law.cornell.edu/uscode/html/uscode10/usc_sec_10_00002304----000-.html http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/Far/06.htm%23P77_9982 these assets and if so to please submit their Source Approval Request (SAR) package.

Duncan Aviation has not responded to the inquiry. When the Government PCO solicits for proposals, if Duncan Aviation Component Solutions or any other company provides a bid, the PCO will inform them of the requirements for a SAR package posted on the Fed Biz Opps web site. If they are able to submit their SAR package and the Cognizant government engineering office can review and qualify them prior to contract award, they will be considered. If not, they will be considered for any follow on repair contracts for these items.

Telephonics has not responded to repeated inquiries and requests on their willingness to provide data to the Government. The Government must interpret Telephonics’ non-response as their refusal to sell or provide the data at this time. However, the Government will continue to request Telephonics provide a response.

This acquisition is for continued performance of a highly specialized follow-on repair service that cannot currently be solicited as a Full and Open competition. Additionally, the HH-60G System Program Office (SPO) Manager stated that Lead Command would not support the funding required to stand up an organic depot or to reverse engineer the system because the system is at the end of its life cycle, is being studied for replacement and has multiple obsolescence issues. For example, during performance of repair contract FA8524-09-D-0001, Telephonics was unable to repair nine (9) each Indicators, NSN 5841-01-267-5932SO due to obsolescence of material needed to repair the end-item.

When the Indicator requires these obsolete components for repair, it must be condemned.

The HH-60G SPO awarded a contract with a company to research a replacement for the APN-239 Color Weather Radar system in an effort to resolve system obsolescence issues.

The recommended replacement for the APN-239 CWR system model# RDR-1400 was the next generation APN-239 CWR system model# RDR-1600.

Air Combat Command (ACC) is the Air Force’s Lead Command for the HH-60G helicopter. ACC is acquiring approximately 22 US Army UH-60L helicopters and will convert them into USAF configured HH-60G helicopters (commonly referred to as the “L2G” aircraft) to add to the fleet of 98 each HH-60G’s.

As part of this “L2G” Program, the HH60G SPO is identifying systems/components which have obsolescence issues. One of the systems identified as having obsolescence issues is the APN-239 Color Weather Radar (RDR-1400). The L2G Program Office proposed to the HH-60G SPO to replace RDR-1400 with the new RDR-1600 Color Weather Radar.

HH60 SPO plans to install the RDR-1600 on the 22 each L2G aircraft and recommend to the MAJCOM that the current fleet of 98 each HH-60G aircraft also be retrofitted with the RDR-1600.

The 22 each L2G modified aircraft are estimated to begin entering AF inventory in CY15 and complete modification by CY18. The plan for retrofitting the current fleet of 98 each aircraft with the RDR-1600 is dependent on MAJCOM funding, and is estimated to begin modification by CY17, completing retrofit to RDR-1600 by CY21.

If MAJCOM funding is granted and the retrofitting is approved, as modifications occur, the RDR-1400 spares requirements would decrease and enable the available spares to support the non-retrofitted aircraft until a time when all aircraft have been modified.

Additionally, HH-60G SPO plans to provision for a data package from the OEM for the new RDR-1600 and if successful, will allow establishment of an Organic repair capability as well as create a competitive environment for contracting repair services of the RDR-1600.

Additional repair sources were sought for evaluation by the cognizant Government Engineering office in an attempt to qualify them as a repair source for the current APN- 239 CWR, model# RDR-1400. Qualifying additional sources would provide a limited competitive environment and allow Government cost savings.

The award of a Full and Open competition contract would result in substantial and unacceptable time delays in fulfilling the Air Force’s requirements. Pursuit of a Full and Open repair contract would incur time delays that could span a total of 8 to 12 years due to test data development; first article testing, training and qualifying personnel to operate the equipment, as well as added delay to achieve the required capabilities.

A strategy to reverse engineer in order to allow Full and Open competition would cost an estimated $2.5M and take more than five years before a technical data package would be delivered. The first repaired assets from a Full and Open competed repair source would not likely produce until CY2023 and potentially CY2028, beyond the estimated end of life cycle for the system. Conversely, a 5 year limited repair contract between qualified commercial sources would estimate to award by CY 2016 and maintain repair coverage for the system until CY2021. This would allow time for the replacement of the RDR1400 with RDR-1600 to go as planned beginning CY2017 and complete by CY2021 resulting in low risk for lapses or disruptions in repair coverage.

Below break out reflects the total estimated delay in schedule for the Government to acquire competitive repair capabilities and deliver first production repair assets for the APN-239 Color Weather Radar (CWR) system assets installed on the HH-60G helicopter. These estimates are based off time lines from similar reverse engineering efforts and feedback from IPT team members.

1. Lead time for Reverse Engineering

a. Lead time to award Engineering Services Contract = 18 ~ 24 months

b. Lead time to deliver Drawings / Technical Data = 18 ~ 24 months

c. Lead time to deliver test specification and repair data = 12 ~ 18 months

d. Total estimated Reverse Engineering Lead Time = 48 ~ 66 months

2. Lead time for Full and Open repair services

a. Lead time to award competitive contract = 24 ~ 36 months

b. Lead time contractor developed ATP and Test Stations = 12 ~ 18 months

c. Lead time contractor produced First Article Test Report = 12 ~ 18 months

d. Lead time contractor to repair and deliver first assets = 6 ~ 12 months

e. Total estimated Competitive repair services Lead Time = 54 ~ 84 months

3. Total time deliver repairs (Reverse Engineer + deliver assets) = 102 ~ 150 months

18~24 Months 36 ~ 48 Months 48 ~ 66 Months 72 ~ 102 Months 84 ~ 120 Months 96 ~ 138 Months 8~12 years

CY16 CY17 CY18 CY19 CY20 CY21 CY22 CY23 CY24 CY25 CY26 CY27 CY28 CY29

Engineer Services = $250K per man year X 2 individuals X 5 years = $2.5M Total delay in schedule to deliver first production assets = 8 ~ 12 years

Assuming a Full and Open competitive contract would result in a 10% reduction in the estimated Unit Repair Costs over the limited competition source estimates, a cost analysis showed the total Return On Investment from CY2015 to CY2021 would only yield $108,770. Therefore, ROI would not expect to recover the initial $2.5M Non Recurring Engineering (NRE) investment by the time the system is expected to be replaced in CY2021. Based on this information, attempts to award to any other sources would result in significant delays and substantial duplication of costs; this would not be a reasonable plan, especially considering the impending phase out of the program.

Award Engineering Services Contract, 18 ~ 24 months

18 ~ 24 months

Deliver Drawing/Tech Data, 18 ~ 24 months

Deliver Test & Repair Data, 12 ~ 18 months

Award F&O contract, 24 ~ 36 months

72 ~ 102 months

48 ~ 66 months

36 ~ 48 months

Produce ATP and Develop / Acquire Test Stations 12 ~ 18 months

First Article Test Report, 12 ~ 18 months

First Assets, 6 ~ 12

84 ~ 120

96 ~ 138 months

102 ~ 150

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 may be identified through synopsis.

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 based upon FAR 12 negotiation procedures using price and cost analysis. Methodologies to assure this will be commercial pricing techniques utilizing publicity offered catalogs, comparison to historical contractor sales and/or analysis of limited cost and pricing information which could be made available by the contractor. In the event that limited cost and pricing information is made available, the Government negotiation objective will be developed using local technical analysis applied to direct and indirect rate factors recommended by the DCAA and/or DCMA.

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 in accordance with FAR Part 10 and was concluded on 15 June 2015. The following market research techniques were utilized in conducting the market research: The Federal Logistics Information System (FLIS) was queried to determine if the item was available under a different existing national stock number, or from a different vendor. Additionally, a search of the ThomasNet.com web (http://www.ThomasNet.com) and Information Handling System (IHS) (https://www.ihs.com/) was conducted. The results from the FLIS, IHS and ThomasNet.com queries revealed that both Telephonics Corporation and Honeywell, Incorporated were listed as vendors for the system. A Honeywell, Incorporated representative revealed that they were the original equipment manufacturer (OEM) and sold all data rights to Telephonics in January 2000, making Telephonics the owner of repair data, current OEM and a qualified repair source. An internet search for the part numbers was made using https://www.avspares.com/ web site. This search showed additional potential repair vendors. Attempts to contact them resulted in responses from Duncan Aviation Component Solutions and Capital Avionics, Inc. The Small Business Administration web site was checked and identified that Capital Avionics Inc is a small business.

http://dsbs.sba.gov/dsbs/search/dsp_profile.cfm?duns=089651327&requesttimeout=60 http://www.thomasnet.com/ https://www.ihs.com/ https://www.avspares.com/ http://dsbs.sba.gov/dsbs/search/dsp_profile.cfm?duns=089651327&requesttimeout=60

A Pre-qualification package was posted on Fed Biz Opps for 30 days to solicit any potential sources and one company, Capital Avionics, Inc, Cage Code: 02ZD5 submitted a Source Approval Request (SAR) package. The Cognizant government engineering office reviewed the SAR package and pre-qualified Capital Avionics as a repair source for these assets.

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

AND OPEN COMPETITION

This system is nearing the disposal phase of its lifecycle. Data rights were never pursued in the 1990’s when the system was initially acquired. This system has multiple obsolescence issues and is being studied for replacement. A Full and Open competition repair contract would require a full technical data package through reverse engineering the assets. Potential repair sources intending to provide repair services for this item would then need to pre-qualify their repair processes through the System Program Office’s engineering division, AFLCMC/WIUEC. Given the high cost and extended period of time required to reverse engineer the system, develop test procedures and test software for this system, and qualify the repair processes, as well as the Government’s plan for replacement of this system, it is not feasible or practical for a Full and Open competitive strategy for the repair of this system.

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

There are no opportunities for the Government to take advantage of an open business model practice or to pursue open system architecture for this system to enable support through full and open competitive alternatives. Data rights were not pursued in the 1990’s when the system was initially acquired. A pre-qualification package was posted on Federal Business Opportunities (FedBizOpps) web site for 30 days to solicit any commercial companies to submit their Source Approval Request (SAR) packages to Robins AFB Small Business Office. The cognizant Government engineer reviewed the SAR packages and qualified Capital Avionics Inc as a repair source for these assets. In some cases a site visit to the company’s facility may be required before qualifying them.

Any company vendors who submit SAR packages and successfully qualify as repair sources within the time allotted will be included in a limited competition for fulfilling this repair services requirement.

This system now has multiple obsolescence issues and is being replaced with an upgraded system. The HH-60 SPO plans to install the upgraded Color Weather Radar system on the 22 each “L2G” aircraft and thereafter, recommend to the Lead Command that the current HH-60G fleet be retrofitted with the new RDR-1600 Color Weather Radar system in order to resolve obsolescence issues. Planned dates to install the upgraded RDR-1600 system on the current HH-60G fleet are to begin in CY17 and complete by CY21. Purchasing a full Technical Data Package for this new RDR-1600 system is being considered by the SPO as well.

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(b)(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(c)).

http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/Far/06.htm%23P204_28777 http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/Far/06.htm%23P204_28777