GPM_JA_(400_Hz_Power_Cable_Assembly)_Redacted.pdf

CUI

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

I. Agency and Contracting Activity.

This Justification and Approval is to request authority for Other Than Full and Open

Competition supporting requirements generated for the Air Force Life Cycle Management

Center (AFLCMC)/Support Equipment and Vehicles Division/WNZ. The contracting activity for this requirement is AFLCMC/WNKAA. The purchase request number supporting this contracting action is FD2060-21-31511.

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

Due to the circumstances described below, this activity requests authority to specify Brand Name

Or Equal (BNOE) components in acquisition for Ground Power Modernization (GPM). The

BNOE authority for use of Other Than Full and Open Competition is as prescribed by FAR

6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency

Requirements and DFARS 206.302-1(c).

The brand name manufacturer is specified below:

ITW GSE INC.

HOBART GROUND SYSTEMS

11001 US Highway 41 N

Palmetto, FL 34221-7700

CAGE: 0SMN2

Large Business

III. Description of supplies/services required to meet agency needs (including the estimated value).

The GPM solicitation (FA8532-22-R-0001) will specify a requirement for BNOE JB8817-60

(with Remote Voltage Sensing (RVS) or JB8816-60NJ (without RVS); 115/200 Volt Alternating

Current (VAC), 400 Hertz (Hz), 260 amp rated, single jacket style, replaceable wear nose, aircraft external power cable assemblies. BNOE for this activity means form, fit, and function interchangeable at the end item cable assembly and component level. These brand name components can be obtained by vendors from ITW GSE. If a vendor chooses to submit for evaluation an “Equal” equivalent power cable assembly, the government will evaluate the proposed alternate part(s) to determine if it is an acceptable substitute. This BNOE specification will result in the procurement of approximately 3,428 power cable assemblies that are components of the overall GPM requirement. These power cable assemblies are utilized on both the 72 kilowatt (kW) ground power units (GPUs) (1 cable assembly each) and the 144kW GPUs

(two cable assemblies each).

The current commercial pricing is approximately per power cable assembly, which equates to an estimated cost to the overall GPM requirement. The overall GPM competitive requirement is estimated at . The BNOE specification represents approximately of the total estimated value.

The overall GPM contract is expected to result in the award of a new Firm Fixed Price Indefinite

Delivery Contract with a three (3) year basic contract period and seven (7) 12-month ordering periods.

IV. Statutory authority permitting other than full and open competition.

10 U.S.C. 3204 (a)(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 the nature of the acquisition requires use of the authority cited above (applicability of authority).

There are multiple methods to wire, or construct, a 115/200 VAC single jacket style 400 Hz power cable assembly. The power quality originating at the power generation/power conversion equipment must be maintained at the aircraft, normally 60 feet away (although in some instances, the distance can be much further away). Each commercial 400 Hz power cable assembly manufacturer markets their own unique replaceable wear nose that is not interchangeable or interconnecting with other commercial manufacturers wear nose. Several questions regarding this wear nose topic were asked in a recent Sources Sought (SS) / Request for Information (RFI) and all respondents indicated non-interchangeability with one another's products.

Time and attrition has lead Air Force GPUs, solid state frequency converters, and motor generator sets, along with United States Navy shipboard applications to standardize to the

ITW/GSE specific replaceable wear nose. For the Air Force, this is primarily due to some equipment coming with them attached via the equipment manufacturer, some multi-strand aircraft external power cable assemblies being replaced over attrition with the newer commercial style, and some end item generator set production contracts being modified during the design review process to include them. In summation, there are in the order of 5,500 to 7,000 plus

ITW/GSE aircraft external power cable assemblies in use by Air Force today, across the globe, affording Air Force a small logistics footprint.

The most critical requirement is the ability to form, fit, function interchange at both the consumable end-item power cable assembly level but also the consumable piece part level, which is the replaceable wear nose. For the entire aircraft external power cable assembly to be form, fit, function interchangeable when connected to the GPUs delivered as part of the GPM acquisition, not only must all the purchase description (PD) requirements of environmental, power quality, etc. be met, but also the replaceable wear nose must be compatible with what is currently in Air Force inventory, as well as each GPM awardee’s solution. Due to funding constraints, it will take quite a few years for GPM to replace legacy GPUs and in the Logistics

Under Attack concept of Agile Combat Employment, the small logistics footprint of the aircraft external power cable assembly is critical to launching and recovering aircraft. Unfortunately, as noted earlier, each aircraft external power cable manufacturers wear nose is not currently form, fit, and function interchangeable with another manufacturers wear nose.

The Government requires a specific cable assembly that is only made by ITW/GSE. This ensures form, fit, and function interchange with existing aircraft external power cable assemblies and replaceable bolt on/bolt off spare parts, however the competitive GPM solicitation will allow for vendors to propose an “equal” equivalent cable assembly for consideration. To accommodate this requirement, two specific part number choices described as BNOE are explicitly required to be delivered in the GPUs PDs.

If the Government were to remove the BNOE requirement for these power cable assemblies, a substantial duplication of cost could likely be incurred. A non-BNOE procurement strategy would force the Government supply chain agencies to procure the current brand name power cable assemblies and their peculiar replaceable wear-nose components, plus any non-BNOE power cable assemblies and their peculiar replaceable wear-nose components. This would effectively double the supply chain costs, to include replacement follow-on power cable assemblies and power cable wear nose components.

A conservative estimated value is if a non-BNOE is utilized. This estimated value is based on the current per cable assembly price, multiplied by the 4,128 power cable assemblies (3,428 anticipated as a part of the GPM procurement plus 700 power cable assemblies that would be needed to set up an inventory for logistical and supply chain purposes).

Additionally, as many as 12 Air Force technical orders would require modification and would incur development costs. As such, the cost associated with the technical order modifications is estimated at . When added to the estimated cost of a non-BNOE cable assembly procurement and bench stock creation, the Government’s estimated value of a non-BNOE strategy is conservatively valued at .

Finally, the Air Force will incur mission impacts to having non-interchangeable parts on two different power cable assemblies and power cable assembly wear-nose components. During any deployment, the inability to procure any non-BNOE power cable assemblies or wear nose components, will neutralize the Air Force’s capability to meet deployment requirements.

Based on the above, BNOE requirement to fulfill the GPM power cable assembly requirement is in the best economical approach for the Government.

Accordingly, ITW/ GSE INC.’s or Equal BNOE cable assemblies described in Section III above are required to ensure the Air Force avoids experiencing substantial duplication of cost that could not expected to be recovered through competition.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under FAR 5.202 applies.

A SS/RFI synopsis was posted to Sam.gov on 25 Apr 2022 with a response date of 10 May 2022 under Notice ID FA8532-22-R-CABLE. This SS/RFI sought to identify sources that manufacture 115/200 VAC 400 Hz power cable assemblies and also ascertain whether any of the sources offered a form, fit, function interchangeable wear nose for the 115/200 VAC 400 Hz power cable assemblies currently in use by United States Air Force (USAF) and currently specified in the GPM solicitation. Three companies responded:

. The respondents were evaluated and conclusion reached that ITW/GSE was the only vendor capable of providing a form, fit, function interchangeable 115/200 VAC 400 Hz power cable assembly that is currently being utilized by USAF. However, the Government encourages competition and desires for the GPM awardees to be able to collaborate with power cable assembly manufacturers, such as those identified in the SS/RFI to provide form, fit, and function interchangeable power cable assemblies at the piece part level and is therefore specifying a BNOE for the power cable assemblies.

The overall GPM requirement was synopsized in accordance with requirement of FAR 5.201.

VII. Determination by the Contracting Officer that the anticipated cost to the

Government will be fair and reasonable.

For the overall GPM acquisition, the Government anticipates fair and reasonable prices will be determined based on adequate competition in accordance with FAR 15.103-3(b). In the event competition is not achieved, the Contracting Officer will require the submission of other than certified cost or pricing data in accordance with FAR Part 15.403-3. Price analysis or cost analysis based on “information other than certified cost or pricing data” will be used to examine and evaluate the proposed prices to determine fair and reasonable pricing. Price analysis techniques include comparison of proposed prices to historical prices paid for a same or similar item; comparison with published price lists, offered catalog prices and prices obtained through market research for a same or similar item; comparison of proposed prices with independent

Government estimate; or analysis of data other than certified cost or pricing information.

The contract price will be negotiated in accordance with the procedures in FAR Part 15 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.

Market research was conducted 24 Mar 22 through 07 Jun 22 in accordance with FAR Part

10.001 and 10.002. The Market Research Report was completed on 07 Jun 2022. Market research techniques used are as follows:

As described in Section VI above, a SS/RFI was posted to Sam.gov advising industry of the pending acquisition and soliciting inquiries from interested vendors. The SS/RFI was posted on

25 Apr 2022 under Notice ID FA8532-22-R-CABLE. Three companies responded:

. Respondents were evaluated and ITW/GSE cables were determined the only acceptable form, fit, function interchangeable 115/200 VAC 400 Hz power cable assembly. However, in light of this, the Government will allow vendor(s) to propose

“Equal” equivalent power cable assembly for evaluation and approval in meeting this GPM solicitation component part requirement.

AbilityOne is not able to provide 115/200 VAC 400 Hz power cable assemblies.

A dynamic small business search was conducted using North American Industry Classification

System code 334419 on 26 May 2022 and no further sources of 115/200 VAC 400 Hz power cable assemblies were identified.

The 115/200 VAC 400 Hz power cable is considered a commercial item as defined in FAR

2.101. The 115/200 VAC 400 Hz power cable is used by both the military and the commercial aviation industry.

The market research concluded that currently only cable assembly is capable of meeting the

Government’s requirement. This cable assembly is manufactured by ITW/GSE.

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 Government considers the allowance of BNOE to be a means of breaking barriers to competition. The Government will continue to conduct market research and review information from industry regarding form, fit, function interchangeable wear nose for the 115/200 VAC 400

Hz power cable assemblies currently in use by the USAF.

There was no prior J&A, therefore higher level approval per DFARS PGI 206.304(a) (S-70) (ii) does not apply.

XII. Certification by the Contracting Officer.

As evidenced by my signature on the Coordination and Approval Document (CAD), 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 (our) signature(s) on the CAD, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.