J&A_redacted2_Redacted.pdf

CAD_FD2060-18-00126

COORDINATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

OF ACQUISITIONS NOT EXCEEDING $1 .5 MILLION

Contracting Activity: AFSC/PZAAA

PR Number: FD2060-18-00126

Estimated Value:

Category: OTHER CONTRACTING

Authority: 10 U.S.C. 2304(c)(1)

Based on the justification provided herein, acquisition of the supplies/services is recommended using Other than Full and Open Competition (OTF&OC) using the authority cited above.

COORDINATION AND APPROVAL

Symbol Date Phone

____________Symbol Date Phone

INITIATOR:

Technical/Requirements

COORDINATION /

APPROVAL < = $ 0K:

* Contracting Officer

** Contracting ______________________________ __________ ___________ ____________ Division Chief Symbol Date Phone

Staff Judge Advocate ______________________________ __________ ___________ ____________ ($500K +) Symbol Date Phone

APPROVAL:

** Competition Advocate ______________________________ __________ ___________ ____________

Symbol Date Phone

Use this document for approvals Up to $1 .5M Only:

* Contracting Officer Approval (up to $ 0K) ** Competition Advocate Approval (over $ 0K to $1 .5M)

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 (OTF&OC) supports requirements generated for the Air Force Sustainment Center (AFSC), 638th Supply Chain Management Group (SCMG), 411th Supply Chain Management Squadron (SCMS). The contracting activity for this requirement is AFSC/PZAAA at Robins AFB, GA.

The purchase request (PR) number supporting this contracting action is FD2060-18-00126.

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

Due to the circumstances described herein, the activity requests authority to acquire these repair services using 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 follow-on firm-fixed-price repair contract for 60-ea.

The repair source for this requirement is the following company:

Penny & Giles Aerospace Ltd Business Unit of Curtiss-Wright Controls (UK) Ltd 15 Enterprise Way, Aviation Park West, Bournemouth International Airport, Dorset BH23 6HH, United Kingdom

CAGE: K1474

T: +44.1202.034088 POC: ATitterington@curtisswright.com Web: http://www.curtisswrightds.com

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

AGENCY’S NEEDS

The AFSC and Air Force Education Training Command (AETC) have requirements to support training missions of the TH-1H helicopter program. The National Stock Number (NSN) cited below is required to support these training missions. The purpose of this requirement is to purchase repair services for the following part:

Nomenclature Part Number CAGE National Stock Number

ESCADU D51610-1704 K1474 6610-99-171-9024

This item is the Enhanced Software Configurable Air Data Unit (ESCADU), also referenced as an Air Data Computer in this document. The TH-1H helicopter fleet (28 total aircraft) is stationed at Fort Rucker, AL. The estimated cost for this requirement is and supports an agency need to repair 60-ea assets over a 5-year Period of Performance (PoP) spanning FY19 – FY24.

The type of funding utilized for this requirement is Consolidated Sustainment Activity Group (CSAG) Defense Working Captial Fund (DWCF) (Appropriation ).

The ESCADU is a microprocessor controlled system that calculates the air data parameters from information received from the pitot static pressure sensors and an Outside Air Temperature (OAT) probe. It is a commercial item used on the TH-1H.

Technical Description of Supplies: The ESCADU is a microprocessor-controlled system that calculates the air data parameters from information received from the pitot static pressure sensors and an Outside Air Temperature (OAT) probe.

IV. STATUTORY AUTHORITY

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)

The capability to satisfy this particular requirement is currently only available from Curtiss- Wright in Bournemouth International Airport, Dorset BH23 6HH, UK. They are the only source with proprietary rights to service this part. Awarding to an alternate repair source would require the Government to (1) independently reverse-engineer the part to establish technical data ownership, and (2) compete/award the requirement with the aim of achieving per-unit cost-savings. This path would result in a net financial loss to the Government due to never recouping the invested costs within the operational service-life of the helicopter, which is planned to fly until 2040. The following narrative will explain this methodology in more detail.

As stated above, the TH-1H helicopter is unofficially planned to fly through 2040 (roughly 22 years beyond the authorship of this document). In order to establish a basis for estimating schedule and cost requirements needed to reverse-engineer the ESCADU, the Government Integrated Product Team (IPT) assessed an analogous project that was accomplished in support of the USAF HH-60G helicopter program for a part known as the Fuel Quantity Indicator (FQI).

This effort required 5 years and to develop technical data so that the USAF could compete the repair requirement amongst the open market. The objective of these types of projects is to acquire services utilizing competition so that the per-unit cost is driven down and is less than if obtained via a sole source environment. The FQI and the ESCADU are similar in complexity; therefore, the time and financial burden to complete a reverse-engineering contract are believed to also be similar. Based on that premise, the IPT used those same factors when analyzing how much time and money would be needed to reverse-engineer the ESCADU.

The average per-unit repair cost for the ESCADU is . The average quantity repaired each year is 12-ea. Based on this basic fact, the yearly cost to repair this part would be approximately . If the Government was successfully able to obtain technical data, compete this requirement, and achieve a 30% cost-savings (resulting from competition), that would result in a per-year cost savings of . This savings would be observable roughly

7 years from 2018 because it would take approximately 1 year to establish a reverse-engineering contract, 5 years to complete the contract, and 1 year to compete/award the new “cost-savings” contract to the alternate source. Therefore, the 30% cost-savings of approximately

/year would be observable beginning in 2025. At this rate, the Government would ultimately break-even on its reverse-engineering investment in the year 2116, seventy-six years after the helicopter will no longer be in service. Following this analysis, the IPT concludes that it would not be cost-beneficial to pursue competition via reverse-engineering the

ESCADU.

VI. EFFORTS TO ADD ADDITIONAL SOURCES/SOLICIT FROM AS MANY

SOURCES AS POSSIBLE

A Request for Information (RFI) was posted on the Federal Business Opportunities (FedBizOps) 1 December 2017. The RFI closed 30 December 2017. This RFI was purposed in finding any new potential sources that could become qualified. No responses were received.

This effort will be synopsized in accordance with FAR 5.201 citing conditions which preclude full and open competition. Any sources that subsequently respond to the Government as a result of the synopsis will be identified to potentially become a qualified source.

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. Price analysis will be utilized if possible. If not, the contractor will be required to provide other than cost or pricing data to support the Government’s evaluation of the proposed cost IAW FAR 15.403-3.

The proposed cost elements will be negotiated by the Government based on recommendations from the Defense Contract Audit Agency (DCAA)/Defense Contract Management Agency (DCMA), and local pricing personnel supporting the program. The contract price will be negotiated in accordance with the procedures in FAR Part 12 (because this is a commercial acquisition) 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

A market research using Google and email conducted by the WIUED shows that there are no other manufacturers that repair the original ESCADU without the additional cost of reverse-engineering hardware and software, test and certification.

An internet search in Google using “Air Data Computer” provided suppliers and other air data computers, but no authorized repair sources and/or facilities for the TH-1H ESCADU.

Accessing the Penny & Giles website revealed that Penny and Giles air data computers were now available from Curtiss-Wright Defense Solutions division. An email link for repair was utilized to gather information. The response was that Curtiss-Wright is the repair facility.

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 U.S. Government does not have the technical data required for repairing this item. The Government's request to buy this technical data was declined via telephone discussion with the OEM’s Technical Support Engineer on 12 Dec 17.

Reverse-engineering options have been assessed and the IPT concluded that such efforts would not be cost-beneficial to the Government (see Section V). This helicopter platform is anticipated to fly until 2040; therefore, any efforts made to establish data ownership with the goal of qualifying new sources to leverage cost-savings from competition would need to recoup the financial investment within the next 22 years. The analysis showed it would take over 98 years to recoup a reverse-engineering investment; therefore, it was determined to be not feasible based on the projected life of the program.

There were no actions in the previous J&A to break barriers to competition; therefore, this J&A does not require higher-level approval under condition stated in DFARS PGI 206.304(a) (S-70) (ii). Nonetheless, every 18 months, the Government will (1) review current technical literature,

(2) explore alternative product support strategies with the pertinent engineering organizations,

(3) inquiry with industry for potential sources of supply and/or opportunities to purchase the needed intellectual property to qualify additional sources, and (4) conduct future requests for purchasing data rights, possibly elevating these within the OEM's leadership. Should the OEM respond favorably to selling the technical data to the Government, the Logistics Manager in AFSC will work with the System Program Office (SPO) in AFLCMC to budget for the funds to procure data where it makes sound economic sense to do so.

XII. CONTRACTING OFFICER’S CERTIFICATION

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

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