J&A_Redacted.pdf

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

FOR OFFICIAL USE ONLY

25 May 2018 FOR OFFICIAL USE ONLY Page 1 of 8

NOTE: If a Justification was approved for the preceding acquisition, a copy of the approved Justification for the predecessor action must be included in the staff package for approval of the instant Justification. This applies to Justification staff packages that are submitted for review and approval at a level above the contracting officer. The predecessor Justification 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: >SAT and < $700K > $700K and < $13.5M

Contracting Activity: AFSC/PZAAA

Purchase Request / Local ID Number: FD2060-19-00011

Program / Project (and PE, if applicable): HH-60G Remote Data Concentrator (RDC)

Program Type (PEO or Other Contracting): Other Contracting

Authority: AFFARS 5313.501 - 10 U.S.C. 2302b, Implementation of Simplified Acquisition Procedures (41 U.S.C. 1901)

AFFARS 5313.501 - 10 U.S.C. 2304a, Special Emergency Procurement Authority (41 U.S.C. 1903)

Estimated Contract Cost (including options): $ Justification Type: Class Individual

COORDINATION (AFFARS 5306.304(a) )

Date Logistics Manager Chris Boarman

411 SCMS/GULAB, 468-2730

Signature

Date Contracting Officer Troy Winebarger

AFSC/PZAAA, 468-0059

Signature

Date

10 Oct 2018

Local Legal Reviewer

Bradley Adams

78 ABW/JAQ, 472-0569

Signature

APPROVAL (AFFARS 5306.304(a) )

Date

16 Oct 2018

Competition Advocate Elizabeth F. Kennedy

AFSC/PZCA, 472-1102

Signature

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

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I. Contracting Activity.

This Sole Source Justification (SSJ) requests authority for Other Than Full and Open Competition to support 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 AFSC/PZAAA. The purchase request number supporting this contracting action is FD2060-19-00011.

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

Due to the circumstances described herein, this activity requests authority to contract repair using Other Than Full and Open Competition in accordance with 10 U.S.C. 2302b, Implementation of Simplified Acquisition Procedures as prescribed by FAR 13.5, Simplified Procedures for Certain Commercial Items. This action will result in the award of a follow-on Requirements Indefinite Delivery Contract (IDC), which will be firm-fixed price contract with a basic year plus four (4) Option Years.

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

Simmonds Precision Products Inc.

100 Panton Rd Vergennes, VT 05491-1008

CAGE: 89305

Large Business

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

This is a commercial requirement to acquire contractor depot level repair for the HH-60G Remote Data Concentrator (RDC), National Stock Number (NSN) 1680-01-500-6388GC, Part Number 30201-050. The RDC is a component of the Integrated Vehicle Health Management System (IVHMS) on board the HH-60G Pave Hawk Helicopter.

The repair will require the contractor to restore the unserviceable assets to serviceable condition using contractor developed repair acceptance test procedures. The extent of repair required to ensure a serviceable end item shall be determined by the induction inspection, test, and required disassembly, and shall conform to the Original Equipment Manufacturer (OEM) data and specifications. Under the contemplated Requirements IDC contract, the contractor will provide the following estimated repairs to support the HH-60G Pave Hawk Helicopter in sustainment of the USAF Special Operation Forces program. The nomimal contact line item numbers will be X001 and X002. The total estimated contract value for this effort is $ .

Basic Year

NSN BEQ Unit Price Extended Price

1680-01-500-6388 NFF/BER 4 $ $

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1680-01-500-6388 Repair 30 $ $

TOTAL $

1st Option Year

NSN BEQ Unit Price Extended Price

1680-01-500-6388 NFF/BER 4 $ $

1680-01-500-6388 Repair 30 $ $

TOTAL $

2nd Option Year

NSN BEQ Unit Price Extended Price

1680-01-500-6388 NFF/BER 4 $ $

1680-01-500-6388 Repair 30 $ $

TOTAL $

3rd Option Year

NSN BEQ Unit Price Extended Price

1680-01-500-6388 NFF/BER 4 $ $

1680-01-500-6388 Repair 30 $ $

TOTAL $

4th Option Year

NSN BEQ Unit Price Extended Price

1680-01-500-6388 NFF/BER 4 $ $

1680-01-500-6388 Repair 30 $ $

TOTAL $

GRAND TOTAL = $

The estimated unit repair cost is based on the current repair cost in contract FA8524-16-D-0016. A 4% inflation factor was added to each Option Year. This requirement will be funded with 4930 Working Capital funds. The validity period of the Requirement IDC is estimated to be 26 Aug 2019 through 25 Aug 2024, if all out-year options are exercised. This SSJ is applicable to all in scope task orders issued under the Requirement IDC though completion of the task orders.

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The NSN was screened and assigned a Repair Method Code/ Repair Method Suffix Code (RMC/ RMSC) of R3/R. The RMC R3 means to repair, for the second or subsequent time, directly from the actual manufacturer. The RMSC “R” means the Government does not own the data or rights to the data needed to 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. 2302b, Implementation of Simplified Acquisition Procedures. This acquisition will follow procedures of FAR 13.5, Simplified Acquisition Procedures in accordance with 41 U.S.C. 1901.

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 Simmonds Precision. The RDC uses technology that is proprietary to Simmonds Precision.

Simmonds Precision possesses unique capabilities demonstrated as the OEM having proprietary rights and is currently the Government's source of repair. As such, Simmonds Precision is the only authorized and capable repair source for the HH-60G RDC.

The repair of the RDC is considered highly specialized. The RDC converts aircraft signal information from junction boxes into a data stream that is sent to the Integrated Vehicle Health Management Unit via an ARINC-429 bus interface (single line cable). The RDC performs analog-to-digital voltage conversions, determines the state of discrete inputs, measures time between zero crossing for Alternating Current (AC) signals, determines synchronic positions, and measures root means square (RMS) voltage from AC waveforms. It provides integrated health and usage management information that will enhance aircraft safety by identifying and precluding premature component failure.

The current repair contract for the RDC is FA8524-16-D-0016. The requirement was sole source to Simmonds Precision. The contract was awarded on 26 Aug 2016 and expires 25 Aug 2019.

The Government engaged the OEM on 15 Nov 2017 by e-mail to inquire if they would be willing to sell the technical data. They responded that they were not willing to release control of their intellectual property.

The estimated end of life cycle for the RDC is CY2029 based on the projected year to retire the HH-60G fleet (96 Helicopters). One RDC was sent to Robins AFB Depot EMXG team on 17 Aug 2017 to evaluate cost and schedule to develop Organic Depot Level Repair capability. On 29 Nov 2017, the 402 EMXG Project Manager responded with the estimates for cost and schedule. The estimated cost and schedule was 83 months at a cost of $ . The 402nd Depot at Robins AFB estimated to stand up Organic Depot Repair would take approximately seven years. This estimated cost and timeline is based on expert opinion of the 402 EMXG/MXDEK Reverse Engineering Department to disassemble a Remote Data Concentrator and research the components to determine the requirements for testing and availability of the components. By CY2025, half the HH-60G fleet is estimated to be retired, resulting in a rapid and steady increase in RDC asset availability. Based on

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

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402 EMXG cost and schedule analysis, a Return on Investment (ROI) of the initial $ Non- Recurring Engineering investment is not expected by the time the system is projected to retire in CY2029. The 83 months delay in meeting our repair requirements is unacceptable as it would impact the sustainability of the HH-60G Pave Hawk Helicopter.

The capabilities to fill this requirement are only available from Simmonds Precision. No other company has the technical data to repair and test this asset. Simmonds Precision has sole proprietary rights to the technical data. In order to maintain Operations, Safety, Suitability and Effectiveness (OSS&E) and Configuration Control, the Government's need can only be met by Simmonds Precision.

Accordingly, Simmonds Precision is the only firm capable of providing the supplies and services 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 and unacceptable delays in fulfilling its requirements.

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 on the Federal Business Opportunities (FedBizOpps) web site on 17 Oct 2017 under Solicitation number FA8524-18-R-0002 with responses due by 16 Nov 2017 to further survey the market for any interested, potentially capable repair sources for these assets. Results from the SS/RFI did not produce any responses at the close out on 16 Nov 2017.

The requirement will be synopsized in FedBizOpps in accordance with FAR 5.201. Although the Government does not own data to support the repair effort from any other source, any source that expresses interest 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 13.106-3(a) (2), 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 16 Jul 2018. The following market research tools were utilized by the Government

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

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A review of the Government's technical data dispository (JEDMICS) was searched and showed the Government has only limited rights to technical data and the information in the available drawings are proprietary, Company Confidential and incomplete https://jedmics.af.mil/webjedmics/index.jsp .

Team members searched FEDLOG, the internet Haystack Database, which details history of design for the items. HAYSTACK product: https://tdweb.robins.mil/congruity/

An internet search was conducted using ThomasNet web site. Part Numbers were used as search criteria and no sources were identified.

The Dynamic Small Business Search (DSBS) http://.sba.gov/ was searched using North American Industry Classification System code “811219” and keyword “Remote Data Concentrator.” No small businesses were found that had capability, data, and expertise to repair this asset.

As described in Section VI above, a SS/ RFI synopsis was posted to FedBizOpps on 17 Oct 2017 under Solicitation Number FA8524-18-R-0002. Results from the SS/RFI did not produce any responses at the close out on 16 Nov 2017.

Additionally, the Government Integrated Product Team (IPT) participated in an Industry Day conference on 28 Sep 2017 held at Robins AFB hosted by the 429 SCMS, Strategic Alternate Sourcing Program Office (SASPO). As a result of Industry Day participation, two companies, Torch Technologies and Alion Science and Technology, contacted our team through the SASPO Office to express their interest in developing depot level repair capability for this NSN through an Engineering Services contract with the Government. However only one company, Torch Technologies, a small business, submitted a White Paper, as required, to the SASPO Office describing their capabilities and potential to support an engineering effort to develop Depot Level Repair capability as described in our requirement. Torch Technologies and Alion Science and Technology are not interested in contracting to repair these assets. They are interested in contracting with the Government to reverse engineer the assets to develop Depot Level Repair capability for the Government. As a result, funding is being sought through the SASPO office and a Sustaining Engineering Project (Project # 4187) is being planned for additional multi-year effort through the Sustaining Engineering Program Office for a sustaining engineering effort to develop depot level repair data and capability in an effort to acquire Government ownership of full technical data and a competitive environment for repair of this asset.

The IVHMS RDC meets the definition of FAR Part 2 in terms of commercial items or non-developmental items which can be acquired using the streamlined acquisition procedures under FAR Part 12 and 13.

In conclusion, there is currently only one source who is capable, equipped, and qualified to successfully accomplish the objectives of this requirement. Based on proprietary technical data and engineering knowledge of the item, Simmonds Precision is the only capable source to support repair of the HH-60G RDC.

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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 fleet of 96 HH-60G Helicopters are scheduled to begin retiring in CY2021and will be replaced by the new HH-60W weapon system. The HH-60G fleet is estimated to continue draw down to zero Air Force inventory by CY2029. This asset will not be installed in the HH-60W.

The Government does not possess the technical data for the HH-60G RDC to support full and open competition. An inquiry for sell of the technical data was sent to the OEM on 15 Nov 2017. The OEM responded that they were not willing to release control of their intellectual property.

Approval for FY19 funding is now in final coordination for approval through the SASPO office to develop depot level repair data and capability to qualify additional repair sources for competitive environment. The deliverable will be a complete and full Technical Data Package (TDP), and will contain the details of functional diagrams, schematics, mechanical drawings, and parts lists. This TDP can be used to qualify additional repair sources for competing future depot level efforts for this asset.

A Sustaining Engineering Project (Project # 4187) for a sustaining engineering effort to develop depot level repair data and capability in an effort to acquire Government ownership of full technical data and allow a competitive environment for repair of this asset in two years following project approval.

In an effort to foster competition for this effort, the Government's solicitation will allow for submission of proposal utilizing the Source Approval Request (SAR) package process. If a vendor submits a SAR package and the cognizant Government engineering office reviews and qualifies the new vendor prior to contract award, the J&A will be amended and acquisition strategy revised under the basis of a limited competition. If qualification of the new vendor does not occur prior to contract award, they will be considered for future follow-on repair contracts for this item.

The plan to break barriers to competition in the prior J&A was to continue to survey the market for commercial vendors and allow vendors to submit SAR packages in an effort to qualify new vendor(s) as a source of repair for the HH-60G RDC. The IPT completed the actions of the prior plan, therefore the requirement to obtain higher level approval for this instant J&A in accordance with DFARS PGI 206.304(a) (S-70) (ii) is not applicable.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

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XIII. Certification by the technical/requirements personnel.

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