IETM_RTOC_FOE_-_Redacted.pdf

APPENDIX B

FAIR OPPORTUNITY EXCEPTION (FOE) DETERMINATION AND APPROVAL CAD

Contracting Activity: _AFLCMC/WIUKA_________________ Purchase Request/Local Identification Number: __FD2060-14-31420__________ Program Name (and Program Element, if applicable): C-130 Interactive Electronic Technical Manual (IETM) and Integrated Maintenance Information System (IMIS) Reduction of Total Ownership Cost (RTOC) Estimated Cost/Price of the Order (including options): $9.4M______ Type Program: PEO Authority: FAR 16.505(b)(2)(i)(B) Type Determination: _Individual______________

Program Manager: July 9, 2014_

Thomas C. Stretch AFLCMC/WIUEG Date Signed

DSN: 497-4026 COM: (478) 327 4026

Contracting Officer:

Erin B. Taylor AFLCMC/WIUKA Date Signed

DSN: 468-7270 COM: (478) 926-7270

Local Legal

Reviewer:

Charles R. Epperson 78 ABW/JA Date Signed

DSN: 472-0578, COM: (478) 222 0578

Competition

Advocate:

Kimberly McDonald AFSC/PZC Date Signed

DSN: 472-1088, COM: (478) 222 1088

9 Jul 2014

FAIR OPPORTUNITY EXCEPTION (FOE) JUSTIFICATION

I. Contracting Activity

The contracting activity responsible for this action is AFLCMC/WIUKA, Robins AFB, GA. The Contracting Officer is Erin B. Taylor, AFLCMC/WIUKA, DSN 468-7270.

Buyer is Cindy Foster, AFLCMC/WIUKA, and 468-2477.

This is an Exception to Fair Opportunity Justification.

Purchase Request number: FD2060-14-31420

II. Nature and/or Description of the Action being processed

This effort will be a new order utilizing the F2AST contract FA8530-08-D-0004 with Boeing FT. Walton Beach, FL CAGE 022T1. The Period of Performance (PoP) will consist of a twelve

(12) month basic, two (2) twelve (12) month options, and a ten (10) month option estimated at approximately $9.4M including options. Pricing is mixed, Cost Plus Fixed Fee (CPFF), Firm Fixed Price (FFP), and Cost Reimbursable No-Fee (CRNF).

This order supports Reduction of Total Ownership Cost (RTOC) and is intended to be a companion order to the C-130 Interactive Electronic Technical Manual (IETM) and C-130 Integrated Maintenance Information System (IMIS) Sustainment order. Since C-130 IMIS is software driven, the Sustaining Engineering branch and users have identified numerous opportunities to improve IMIS capability at the point of maintenance. These improvements will contribute to RTOC by reducing the amount of time a maintainer has to leave a job site as well as allow the maintainer to more efficiently return an aircraft to service. Additionally, technological advancements allow the capture and sharing of more accurate repair procedures which can be utilized by other DoD information systems to improve reliability. Also, the Air Force (AF) continues to purchase additional C-130J variants that deliver with paper based technical orders that must be integrated into the IETM. C-130 IMIS currently supports 25 plus different Mission Design Series (MDS) consisting of approximately 600 AF aircraft. AF C-130 aircraft undergo constant modifications and upgrades to ensure safety and/or reduce cost of ownership. This order allows for IETM data integration resulting from major modifications/upgrades that change the end item performance. The C-130 IETM contains all data for all variations of C-130 currently used by the AF. Common data is shared and variant difference data is added.

III. Description of the Supplies/Services Required to Meet the Agency’s Needs

Under this task order Boeing FT. Walton Beach Corporation will provide the following services in support of the C-130 IETM/IMIS RTOC order: Below is a breakdown of tasks to be performed throughout the life of this order:

A Integration (Integrating source data from Sustaining Engineering upgrades and modifications)

B Integration for C-130J Variants (Integrating paper based source data into IETM) C Integration of Source Data Packages (Retaining expertise to sustain Gov organic authoring) D Familiarization/orientation (USAF and contractor personnel) E Travel F Material

The following are options that will be available for exercise within the basic and each option period:

A Foreign Military IETM data currency B Sustaining Engineering Support (finding better ways to utilize capability) C Enhance Electronic Technical Data Improvement Process (AFTO 22/252 Process) D IETM / IMIS Data and Software Improvements for Depot Usage

The period of performance for this requirement is as specified below:

Basic 12 month PoP is expected 29 Sep 2014 thru 28 Sep 2015 Option 1 29 Sep 15 thru 28 Sep 16 Option 2 29 Sep 16 thru 20 Jul 17 * Option 3 21 Jul 17 thru 20 Jul 18 *The F2AST contract PoP ends July 2018, therefore utilizing a ten month option allows us to maximize use of the contract.

F2AST

Fund Type Basic Option I Option 2 Option 3

FY 14

(12 month)

FY15

(12 month)

FY 16

(10 month)

FY 17

(12 month)

Amount Required $2.5M $2.5M $1.9M $2.5M Amount Appropriated $2.5M $0 $0 $0

Delta $0 $2.5M $1.9M $2.5M

Appropriations will be 3400 with an estimated 46 month PoP valued at $9.4M if all options are exercised.

IV. Authority Permitting a Fair Opportunity Exception

FAR 16.505(b)(1)(i) requires the Contracting Officer to provide each awardee under a multiple award contract a fair opportunity to be considered for each order exceeding $3,000, unless a statutory exception applies. The specific exception that precludes the fair opportunity process for this acquisition is FAR 16.505(b)(2)(i)(B).

V. Demonstration of the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above to Provide the Required Supply/Service (Applicability of Authority)

FAR 16.505(b)(2)(i)(B)“Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.”

The AF mandated digital technical data usage in the AF by 2012 without providing any guidance or standards for digital technical data. The C-130 IETM conversion effort resulted in development of a Type II IETM specification which was approved by the AF as MIL-DTL- 87269C but not made mandatory. The authoring tool is commercially available off-the-shelf (COTS); however, the contractor owns the intellectual properties. Since there is no mandatory DoD/AF specification for a Type II IETM, Boeing, in coordination with the Government, designed the C-130 IETM specification for the C-130 IETM conversion effort. The specification was later approved by the AF but many of the existing authoring techniques (business rules) used for the C-130 IETM were not enforced as mandatory. Therefore another contractor could interpret the Business Rules differently and deliver incompatible data. The AF still has no universal IETM specification for conversion of legacy technical data which leaves no reasonable alternative other than to retain Boeing for this effort. AFLCMC/WIU System Program Office (SPO) believes that 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 unacceptable delays in fulfilling the AF’s C-130 IETM/IMIS RTOC requirements. Estimates are based on the initial conversion effort, showing it would cost the Government, at a minimum, an additional $30M and an additional five (5) years for another contractor to develop a Type II IETM.

Mission would be impacted as some technical data only resides within IETM. This means there are no procedures for mechanics to repair systems or order parts. Additionally, without an IETM RTOC contract, we would lose the ability to maintain the data matching current aircraft configuration. We would also lose our current capability of developing and delivering new data resulting from TCTOs/Mods (changes from engineering).

Without utilizing Boeing’s intellectual properties, processes and techniques there is significant risk the new IETM data will not be compatible with the existing C-130 IETM. Boeing is not willing to give up those intellectual properties, processes and techniques without significant cost.

The Government is transitioning to primarily organic sustainment of the data through partnering which does not require the Government to purchase the authoring tool or annual licenses.

VI. Description of Efforts Made To Ensure Competition Between All Awardees

In accordance with FAR 16.505(a)(1) orders under indefinite-delivery contracts do not have pre-award synopsis. IAW FAR 5.301(d)(3) post award posting of the justification is required for task or delivery orders greater than the simplified acquisition threshold and awarded without providing for fair opportunity in accordance with 16.505(b)(2)(ii)(B)(D).

The Government has pursued purchasing the software code from Boeing and determined that purchasing the software code would increase the risk of the system becoming inoperable as a result of Government software upgrades. The Government updates Information Technology (IT) software on a regular basis. Some of these software updates affect C-130 IMIS operations. If a software push from the Government renders C-130 IMIS inoperable the Government would have to re-contract with Boeing, the OEM, for an upgrade. This could take a significant amount of time and could affect and/or halt AF C-130 operations due to unavailability of technical data for several hours, days or weeks depending on the significance of the software update. Retaining the OEM has already proven to be beneficial to the Government as the contractor has prevented disruption of services thus far. Purchasing the software would also require the Government to purchase annual software licenses to continue Government organic sustainment of the data. Since the Government has partnered with the OEM annual licensing costs have not been required. This partnering has resulted in cost avoidance for the varying licensing fees of approximately $1M annually for the Government.

VII. Determination by the Contracting Officer That The Anticipated Cost to the

Government Will Be Fair and Reasonable

A fair and reasonable price will be obtained through comparison of the proposed labor rates with the pre-negotiated labor rates established on the F2AST contract. The proposed labor hours will be evaluated by the government technical team and the resulting technical evaluation will be used as the basis of negotiations for labor hours. Previous F2AST orders FA8530-08-D-0004- 0016/0018 are available for historical comparison. A certificate of current cost or pricing data will be obtained IAW FAR 15.406-2 upon completion of negotiations.

VIII. Description of Market Research Conducted Among All Awardees and the Results or a Statement of the Reason Market Research Was Not Conducted

A market research report was completed 20 May 2014 for this effort. Research consisted of visiting vendor Web Sites and witnessing actual demonstrations of other IETM products. The results of the market research confirmed there was no other economically feasible vendor capable of performing this order satisfactorily without significant cost and schedule impacts to the Government. This effort will be a companion order to a sole source order for IETM/IMIS Sustainment with the OEM that currently owns the software and intellectual properties.

IX. Other Facts Supporting the Justification

NONE

X. List of Any Awardee That Expressed Interest in the Acquisition

NONE

XI. Actions the Agency May Take to Remove or Overcome Any Barriers To Increasing

Fair Opportunity Before Any Subsequent Acquisition For the Supplies or Services

The Government can purchase the software for approximately $3M and annual licenses for $1.6M. It is estimated it would take approximately three to five years for another vendor to achieve the same level of quality assuming Boeing provides them with the intellectual properties. However, there is far too much risk purchasing the software because the system operates on the AF Global Information Grid (GRID). The AF IT/SC community is constantly upgrading numerous software programs and security. This will require the Government to have full time software support to be able to adapt the IMIS software upgrades and changes that will be required to restore operational capability. If the Government purchases the software the Government would be forced to re-contract with Boeing for any upgrades or changes to the software. This will result in disruption of services to C-130 maintainers. Based on the annual cost avoidance the Government is benefitting from, it doesn’t appear to be economically feasible, or advantageous to purchase the software at this time.

Without full time Government software support C-130 IMIS/IETM may become inoperable and USAF technicians would not have access to the most current technical data. Partnering with the contractor and retaining limited authors and software support that can react to AF IT security updates has thus far ensured uninterrupted availability to IMIS/IETM. It is anticipated this effort may go on beyond FY 2025. As the OEM owns the software and Intellectual Properties (IPs) and is unwilling to sell IPs, therefore the Government does not currently plan to pursue full organic capability.

Future efforts will be reviewed to determine if the Government can pursue further in house capability or if it becomes economically feasible to purchase IPs and sustain IETMS competitively.

XII. Contracting Officer’s Certification

The contracting officer’s signature on the signature page 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 signature page, the technical and/or requirements personnel have certified that any supporting data contained herein which is their responsibility is both accurate and complete.