JUSTAPPR_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 10

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: < $700K > $700K and < $13.5M > $13.5M and < $93M > $93M

Contracting Activity: AFSC/PZAAA

Purchase Request / Local ID Number: FD2060-19-00027

Program / Project (and PE, if applicable): AN/ASN-175 Cargo Utility Global Positioning System Receiver

Program Type (PEO or Other Contracting): Other Contracting

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

15 Oct 2018

Project Lead / Program Mgr / Requiring Activity

Signature

Date

Contracting Officer

Date

Local Legal Reviewer

APPROVAL (AFFARS 5306.304(a) )

Date

Competition Advocate

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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). The contracting activity for this requirement is AFSC/PZAAA at Robins AFB, GA. The Purchase Request (PR) number supporting this contracting action is FD2060-19-00027.

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

Due to the circumstances described herein, the activity requests authority to acquire repair services described herein 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 follow-on Requirements Indefinite Delivery Firm-Fixed Price (FFP) contract with a one-year basic plus four ordering periods of performance. The ordering validty of this acquisition will be from July 2019 through July 2024.

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

FreeFlight Acquisition Corporation 3700 Interstate 35 S Waco, TX 76706-3756 CAGE code: 1WAN0 Small Business

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

The purpose of this requirement is to acquire repair services for the AN/ASN-175 Cargo Utility Global Positioning System (GPS) Receiver (CUGR), NSN 5826-01-441-9797GA, PN 82128-00 in support of the UH-1N Helicopter Program. The agency's need is to support and ensure that the operational mission of the UH-1N helicopter program is successfully accomplished as a result of acquiring the repair services identified in this document.

The UH-1N helicopter functions primarily as a light-lift utility platform. It performs missions including airlift of emergency, security and disaster response forces, emergency evacuation of government officials, support for school training and testing, airlift for distinguished visitors, and transport/security for Intercontinental Ballistic Missile (ICBM) support personnel. Other roles include airborne cable inspections, security surveillance of off-base nuclear weapons convoys, response to search and rescue operations, and medical evacuation and transport. The UH-1N has the ability to easily change mission packages to support this diverse set of functions. The capability of flight during inclement weather or nighttime conditions allows it to operate in most situations.

The AN/ASN-175 is an airborne navigational system that operates in conjunction with the Global Positioning System (GPS). GPS is a three dimensional (3-D) precision position and navigation system.

The AN/ASN-175 receives data from four sources: GPS via satellite; an information database loaded by an inserted database card; user defined data; and the aircraft via existing aircraft avionics. The CUGR system, or B kit, is comprised of a radio receiver, a servo amplifier and a remote antenna.

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Originally manufactured by Trimble Navigation, the technical data for repair was later transferred to FreeFlight Acquisition Corporation.

The CUGR's advanced GPS receiver allows it to calculate aircraft position to within less than 16 meters Root Mean Square (RMS) when operating in P(Y) mode. Along with reporting a new position every second, the CUGR's GPS receiver also measures speed to better than a tenth of a knot. Using this GPS feature, pilots can receive position and speed information anytime, anywhere, in any weather. In addition to being a high precision GPS receiver, the CUGR is also a complete navigation management system, providing pilots with instant access to detailed flight information. After fixing a position, the CUGR instantaneously calculates and displays bearing and distance. The CUGR also provides a destination name, ground speed, ground track, and ETA. To help pilots stay on course, the CUGR is equipped with a built-in Course Deviation Indicator (CDI). To maintain system accuracy, the CUGR continuously monitors itself via Receiver Autonomous Integrity Monitoring (RAIM). It also predicts RAIM conditions for approach arrival times. A system option allows pilots to insert a specific course for any waypoint, either inbound or outbound, into the navigation solution which enables the CUGR to display the appropriate course deviation on its built-in CDI. Also visible on the display is a pilot-selectable Track Angle Error graphic. Located directly above the CDI, this graphic provides pilots with a visual representation of desired course intercept. Along with its many other features, the CUGR provides selectable Lat/Long, MGRS, UTM, and UPS coordinate systems with 123 worldwide datums, user units (nautical miles, kilometers, statute miles, etc.), and a quick access search to the 20 nearest airports. In addition, the CUGR automatically sequences through 20 flight plans with up to 20 waypoints each, plans vertical descents or climbs, displays minimum safe altitude, calculates winds aloft, and provides E6B calculation functions.

The CUGR is a complete GPS Precise Positioning System (PPS) navigation receiver.

This contracting effort will fill the need for replenishment of broken GPSs on the aircraft decreasing mission capability. The estimated repair cost of the best estimated quantities (BEQs) per Ordering Period, and aggregated totals for the entire requirement are illustrated in the below table:

Basic:

NSN Noun Unit Price BEQ Cost 5826-01-441-9797GA Cargo Utility GPS Receiver 40

Ordering Period 1:

NSN Noun Unit Price BEQ Cost 5826-01-441-9797GA Cargo Utility GPS Receiver 40

Ordering Period 2:

NSN Noun Unit Price BEQ Cost 5826-01-441-9797GA Cargo Utility GPS Receiver 40

Ordering Period 3:

NSN Noun Unit Price BEQ Cost 5826-01-441-9797GA Cargo Utility GPS Receiver 40

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Ordering Period 4:

NSN Noun Unit Price BEQ Cost 5826-01-441-9797GA Cargo Utility GPS Receiver 40

Grand Total:

The total estimated cost for this acquisition is as displayed in the table above. Each ordering period will contain quantity ranges to include the Best Estimated Quantity (BEQ). The basis of this requirement is derived from the March 2018 D200A summary computation, which identifies the specific parts that need to be purchased and also calculates (1) the Forecast Unit Price and (2) the quantities that are needed by the Warfighter. The type of funding utilized for this requirement is Consolidated Sustainment Activity Group (CSAG) FY 19-FY23 funding (Appropriation 4930).

The nominal Contract Line Item Numbers (CLINs) are as follows:

CLIN DESCRIPTION COST TYPE

CLIN 0001 Repair FFP

CLIN 0002 BER/NFF FFP

CLIN 0003 DATA NSP

The validity period of the Requirements contract will be five years after contract award and through to completion of each order. The delivery schedule is 60 days after receipt of order (ARO).

Through the Screening Analysis Worksheet process, the Cargo Utility GPS Receiver was assigned the Repair Method Code/ Repair Method Suffix Code (RMC/RMSC) R3/R.

RMC: R3; Repair, for the second or subsequent time, directly from the actual manufacturer. RMSC:

R, The Government does not own the data or the rights to be contract repair of this part from additional sources. It has been determined to be uneconomical to buy the data or rights to the data. It is uneconomical to reverse engineer the part.

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, required by FAR 6.303-2(b)(4).

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 agency's minimum needs can only be satisfied by the unique supplies or services available from FreeFlight Acquisition Corporation, which possesses the unique capabilities demonstrated as follows:

The drawings, maintenance manuals, and acceptance test procedures for the GPS are proprietary to the manufacturer, FreeFlight, which was formed through the acquisition of assets associated with the Business & Commuter Avionics Division of Trimble Navigation, to include all applicable technical drawings and data required for continued manufacture, support and repair of the products. The CUGR system was originally manufactured by Trimble Navigation, the technical data for repair was later

March 2018 FOR OFFICIAL USE ONLY Page 5 of 10 transferred to FreeFlight Acquisition Corporation. The contemplated contract will be solicited under “Other than Full and Open Competition” to FreeFlight Acquisition Corporation as they are the only viable source who possesses the proprietary data. The following paragraphs summarize the respective conclusions, all of which support a sole source requirement to FreeFlight Acquisition Corporation.

The Cargo Utility GPS Receiver (CUGR) is a highly specialized item developed for military aircraft operations. The CUGR is a complete GPS Precise Positioning System (PPS) navigation receiver that communicates with satellites in geo-synchronous orbit. It meets the performance standards for instrument flight rules (IFR) for enroute, terminal, and nonprecision approach phases of flight as specified in the U.S. Army and U.S. Air Force Aircraft GPS Integration Guide (GIG). The CUGR is used on Air Force UH-1N aircraft that perform for various missions. The AN/ASN-175 utilizes a six channel P(Y) code continuous tracking, dual frequency (L1/L2) compatible receiver, an omnidirectional flat L1/L2 antenna with an integral preamplifier, and a 2-channel synchro driver. It also accepts Navigation database Cards with information compiled by the Jeppesen NavData Services.

This database provides access to world-wide data on airports, approaches, standard instrument departures (SIDs), standard terminal arrivals (STARs), very high frequency (VHF) omnidirectional range transmitters (VORs), non-directional beacons (NDBs), intersections, and airspace boundaries.

The Government previously awarded an urgent sole source purchase order, FA8524-17-P-0008 to FreeFlight Acquisition Corporation on 18 September 2017. The contract will expire on 17 September 2018.

The Government contacted Free Flight Systems, Inc. on 22 January 2018, via e-mail to determine if they would be willing to sell the data and data rights. FreeFlight has offered to sell the technical data to the USAF, for However, the development and qualification process will be very expensive and exceed the useable lifetime of the units. If UH-1N is still in use after CUGR repair efforts are exhausted, then solution would likely be to consider replacing CUGR with an M-Code type system, and not try to extend the CUGR life on an aircraft that is identified for retirement.

On 23 February 2018, AFSZ/FZC-R conducted a breakeven analysis which yielded the following results:

1. A breakeven analysis was performed on the subject NSN using the following alternatives: Sole

Source and Reverse Engineering. Below are the assumptions used within the analysis:

a. All costs within the analysis are in basic year (BY) 2018$. Costs provided are considered total year (TY) costs and were converted to BY2018$ using 2017 USAF Raw and Weighted Indices for 3400 Operations and Maintenance, Non-Pay.

b. The analysis period is 10 years, FY2018-2027, based on the expected service life of the subject

NSN.

c. Annual buy costs are based on the current 2018 repair price adjusted for inflation.

d. Repair quantities are based on Cargo Utility Global Positioning System, NSN 5826-01-441-9797GA used for the duration of the period of analysis (FY2018-2027).

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e. Reverse engineering effort requires 5 years. Investment costs are based on one contractor engineer working for 4 years to develop the technical data package and approve the prototype.

These costs are based on a FY2018 effort (Benz contract FA8524-17-D-0004), were adjusted for inflation, and spread evenly across the 4 year effort (FY2018-2021).

f. Total reverse engineering costs of includes the cost of one contractor engineer for total cost of supplies needed is certification for reverse engineering costs and the cost for the data package is

g. While the reverse engineering effort is being accomplished, analysis assumes repairs are sole source (FY2018-2021).

2. The Savings/Investment Ratio (SIR) and Payback Period are provided below. A desired SIR is 1 or greater, indicating that for every dollar invested, a dollar or more is earned as a return on investment. The Payback Period indicates how many years it takes to recoup dollars invested.

a.

b. Payback Period = >40 years

3. Based on the analysis, the savings gained through competition do not offset the costs of reverse engineering within the 40 year analysis. Overall, the analysis indicates sole source procurement is the least costly alternative. See J&A Attachment Format A-1.

Considering the quantities required to support up to 66 aircraft, combined with the level of complexity of this GPS Receiver, which has to communicate with satellites in geo-synchronous orbit, this makes any effort to reverse engineer this item not even remotely cost effective. FreeFlight maintains the configuration of this GPS, including its software version, by part number.

Any attempts by the Government to reverse-engineer the Cargo Utility GPS Receivers would result in a significant duplication of costs that would not be recouped by the AF within the timeframe that this part is anticipated to be utilized on the UH-1N aircraft.

AFGSC received congressional authorization to pursue the immediate replacement of approximately 41 each UH-1N aircraft. AFGSC is pursuing the purchase of the Army's HH-60M version which is currently in production. AFGSC estimates within 4 to 5 years, HH-60Ms will be replacing UH-1Ns.

The Agency estimates that this is not a 1 for 1 replacement; therefore, future UH-1N AN/ASN-175 Cargo Utility GPS Receiver will be subject to Reclamation Efforts prior to the Agency seeking any future repair action.

The only identified manufacture source through which Operations, Safety, Suitability and Effectiveness (OSS&E), and Configuration Control can be successfully maintained is FreeFlight Acquisition Corporation.

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Accordingly, FreeFlight Acquisition Corporation is the only company capable of providing the supplies described in Section III above without the U.S. Air Force experiencing substantial duplication of cost that could not be expected to be recovered through competition.

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 Federal Business Opportunities (FedBizOpps) on 02 February 2018 with a response date of 19 February 2018 under Solicitation Number FD20601900027. The SS/RFI requested responses from interested vendors that possess the repair data, capabilities, and experience to meet qualification requirements to repair the AN/ASN-175 Cargo Utility GPS Receiver which is applicable to the UH-1N Helicopter. No vendors responded to the SS/RFI.

The requirement will be synopsized in FedBizOpps 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.

The overall cost of this acquisition will be negotiated in accordance with procedures in FAR Part 12 and FAR Part 15.405, and a statement of price reasonableness ensuring the ultimate price to the Government is fair and reasonable. Additional pricing methodologies to negotiate fair and reasonable pricing may include reviewing publicly offered catalogs, comparison to historical contractor sales, and/or analysis of limited cost and pricing information provided by the contractor.

In the event that limited cost and pricing information is made available, the Government's negotiation objective will be developed using local technical analysis and direct and indirect rate factors recommended by the Defense Contract Management Agency (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 10.001 and 10.002. The market research was completed on 10 April 2018. Market research techniques used are as follows:

The market research was conducted using search engines such as Google, and Information Handling Services (IHS) (Haystack). The website addresses for each search engine are listed below:

https://www.sam.gov/portal/SAM/#1 www.smallbusinessadvocate.com https://www.google.com/?gws_rd=ssl

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An internet search using Google on the NSN, “5826-01-441-9797,” yielded five aftermarket dealers claiming to offer this part.

UH-1N engineers thoroughly assessed the availability (and/or Government ownership) of the required technical data via the Joint Engineering Data Management Information and Control System (JEDMICS) at https://jedmics.af.mil/webjedmics/index.jsp, but for this item, the needed information was clearly proprietary to FreeFlight Acquisition Corporation. Also, a Federal Logistics Information search was conducted at the IHS Haystack website at http://www.ihs.com/products/supply-chain/ defense/haystack.aspx to determine if the item was available from a different vendor who could serve as an alternate source of supply. Helicopter-related periodicals were searched for potential supply sources. The commercial market was searched using the Small Business Dynamic Search Engine and Google. The NAICS code 334511, Search, Detection, Navigation, Guidance, Aeronautical and Nautical System and Instrument Manufacturing, and noun drive shaft was used in both search engines.

None of these efforts identified additional sources for the manufacture of this item.

Information Handling Services (IHS) (Haystack) shows FreeFlight as the manufacturer of this item.

As described in Section VI above, a SS/RFI was posted to FedBizOpps advising industry of the pending acquisition and soliciting inquiries from interested vendors. The SS/RFI was posted on 02 February 2018 with a response date of 19 February 2018 under Solicitation Number FD20601900027.

The SS/RFI requested responses from interested vendors that possess the repair data, capabilities, and experience to meet qualification requirements to repair the AN/ASN-175 Cargo Utility GPS Receiver which is applicable to the UH-1N Helicopter. No vendors responded to the SS/RFI.

The System for Award Management (SAM) shows FreeFlight is a small company for its one NAICS code, 334511 - Search, Detection, Navigation, Guidance, Aeronautical and Nautical System and Instrument Manufacturing.

Vendor Survey The manufacturer and technical data ownership belongs to FreeFlight Acquisition Corporation.

The Cargo Utility GPS Receivers are not commercial off the shelf items. There are no commercial or non-developmental items that meet the requirements. The items being repaired under this effort are utilized by military only. Original usage goes far beyond UH-1; this is a military version of the commercial FreeFlight 2101 receiver, the additional “military” capability is not available on the commercial units, this is why it is not COTS. CUGR is commercially overhauled/repaired IAW FAR 12 and meets the definition of a commercial item for repair services in accordance with FAR 2.101.

The market research concluded FreeFlight is the only vendor capable of fulfilling the Government's requirement. The capabilities to fill this particular requirement are only available from FreeFlight because no other source has the data to properly build the asset currently installed on the UH-1N.

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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.

The U.S. Government does not have the technical data required for manufacturing these items. This data would have enabled other companies to fulfill the Government's requirements, thus fostering competition. The Government contacted Free Flight Systems, Inc. on 22 January 2018 regarding the purchase of data and data rights. The contractor quoted a cost of for technical data. Due to the AF not owning the required technical data for these parts, it is not possible to approve any additional sources of manufacture because of the inability to verify and validate another source's capabilities for meeting this agency need.

The Government conducted a breakeven analysis to compare sole source procurement to a reverse engineering alternative. The breakeven analysis concluded that the savings gained through competition do not offset the costs of reverse engineering within the 40 year analysis period. The analysis also indicated that sole source procurement is the least costly alternative.

The fleet of 68 each UH-1N Helicopters are retiring and will be replaced by a new aircraft through competition. Retirement of the UH-1N fleet is estimated to begin in CY2018 and will continue drawing down until completely out of AF inventory by CY2030. By CY2025, 36 of Air Force Global Strike Command's fleet of 41 UH-1N Helicopters are scheduled to retire. This will result in a rapid and steady increase in asset availability with more Cargo Utility GPS Receiver (CUGR) supporting fewer helicopters (minimizing or eliminating the need for future production). The remaining 32 UH-1N Helicopters are scheduled to retire by CY2030. This will be the final acquisition of the aircraft.

XII. Certification by the Contracting Officer.

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

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