JUSTAPPR_redacted.pdf

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

I. CONTRACTING ACTIVITY

This Justification and Approval (J&A) to request auth01ity for Other Than Full and Open Competition suppo1is requirements generated for the Air Force Sustainment Center (AFSC), 638 Supply Chain Management Group (SCMG), 409 Supply Chain Management Squadron (SCMS) I GUMAB). The contracting authority for this requirement is 638 SCMG/PKAB. The purchase request number supporting this contracting action is FD2060- l 7-00002.

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

Due to the circumstances described herein, the activity requests autho1ity to acquire the repair listed in this document 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 contract, which will be a firm-fixed price requirements contract with a basic year and four annual options in which addition quantities may be ordered. This sole source requirement will be purchased from the following company:

Innovative Solutions and Support Inc 720 Pennsylvania Drive Exton, PA 19341-1129 Cage Code: OEUWO Small Business

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

AGENCY'S NEEDS

Under the contemplated repair contract, Innovative Solutions and Support Inc. will provide the following services which are required to support the repair of three Federal Stock Classification numbered C-130H Aircraft Avionic Components. Maintenance to be performed includes teardown, analysis, overhaul, repair, testing and procurement of spare components, packaging handling, storage, transportation, as well as data collection, engineering support and services.

Requirements listed in this document will be funded by the Material Suppo1i Division (MSD) appropriation. Estimated unit repair costs and Beyond Economical Repair (BER) costs are from last contract FA8538-12-D-0003 and were prorated for 3% inflation for option periods. This contract requires delivery to begin in 30 days ARO at quantities indicated for Basic and Ordering Periods. The RMC/RMSC codes for listed items are R3D, which means repair for the first or second/subsequent time directly from the actual manufacturer. The data needed to compete contract repair is not physically available, it cannot be obtained economically, nor is it possible to draft adequate specifications or any other adequate, economical description of the repair for competitive solicitation.

NSN 6340-01-445-0138LG

ALTITUDE ALERTER

TOTAL POTENTIAL CONTRACT VALUE

EST. QTY EST. REPAIR

UNIT PRICE

TOTAL

PRICE

BASIC 6

BER FOR BASIC 1

OPTION 1 6

BER FOR OPTION 1 1

OPTION 2 6

BER FOR OPTION 2 1

OPTION 3 6

BER FOR OPTION 3 l

OPTION 4 6

BER FOR OPTION 4 1

TOTAL

NSN 6610-01-443-8396LG

AIR DATA COMPUTER

EST. QTY EST. REPAIR

UNIT PRICE

TOTAL

PRICE

BASIC 2

BER FOR BASIC 1

OPTION 1 2

BER FOR OPTION 1 1

OPTION 2 2

BER FOR OPTION 2 1

OPTION 3 2

BER FOR OPTION 3 1

OPTION 4 2

BER FOR OPTION 4 1

TOTAL

NSN 6610-0l -444-0169LG

AIR SPEED INDICATOR

EST. QTY EST. REPAIR

UNIT PRICE

TOTAL

PRICE

BASIC 2

BER FOR BASIC 1

OPTION 1 2

BER FOR OPTION 1 1

OPTION 2 2

BER FOR OPTION 2 1

OPTION 3 2

BER FOR OPTION 3 1

OPTION 4 2

BER FOR OPTION 4 1

TOTAL

IV. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION

10 USC 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

This agency's requirements can only be satisfied by the unique supplies or services available from only Innovative Solutions and Support Inc. Innovative Solutions and Support Inc., is the only known approved repair source at this time for these C-13OH Aircraft Avionic Components.

Innovative Solutions and Support Inc., possesses the test equipment and data to test and repair these components to meet the required military specifications. Sufficient justification does not exist to obtain funding for reverse engineering the following components, which is necessary for qualifying additional source(s), and which has been determined to be cost prohibitive.

Reverse engineering costs are based on similar Engineering Projects

AI' r Data Computer (6610-01-443-8396LG)

The Air Data Computer has a current monthly demand rate (MDR) of 0.33 with a repair cost of $. Average annual repair cost is MDR (0.33) X Months (12) X Repair Cost ($=

Assuming a reverse engineering effort would result in a 10% reduction in repair cost the new annual repair cost would be, Current Repair Cost $ X 90% = $ per repair X MDR (0.33) X Months (12) = $

The annual savings for repair of the Air Data Computer would The initial $ investment in reverse engineering divided by annual savings $ , it would take more than 806 years to get a return on investment (ROI).

Ai'rspeed Indicator (6610-01-444-0169LG)

Task Time to Perform Task (months)

Cost to Perform Task ($)

Reverse Engineering, Prototypes & Data Development

18 - 24

Airworthiness Qualification/ Certification and Flight Testing

8 -12

Totals 36

Task Time to Perform Task (months)

Cost to Perform Task ($)

Reverse Engineering, Prototypes & 18 - 24

Data Development Airworthiness Qualification/

Certification and Flight Testing 8-12

Total 36

The Airspeed Indicator has a current monthly demand rate (MDR) of 0.58 with a repair cost of $. Average annual repair cost is MDR (0.58) X Months (12) X Repair Cost = annual repair cost would be, Current Repair Cost ($ X 90% = per repair X MDR (0.58) X Months (12) =

The annual savings for repair of the Air Data Computer would be $ - $ = $. The initial $ investment in reverse engineering divided by annual savings $

Altitude Alerter (6340-01-445-0138LG)

The Air Data Computer has a current monthly demand rate (MDR) of 0.2 with a repair cost of $. Average annual repair cost is MDR (0.2) X Months (12) X Repair Cost $ = annual repair cost would be, Current Repair Cost $ X 90% = $ per repair X MDR (0.2) X Months (12) = $.

The annual savings for repair of the Air Data Computer would be $. The initial $investment in reverse engineering divided by annual savings, it would take more than 2,078 years to get a return ROI.

The current estimated life of the C-130H aircraft is 2030, approximately 15 more years.

Since the Government does not own data rights and reverse engineering of these 1980 vintage items is cost prohibitive and impedes competition from other sources, therefore, directs the solicitation be made to the approved source only. Accordingly, Innovative Solutions and Support Inc., is the only firm capable of providing the supplies and services described in Section III above without the U.S. Air Force, Air National Guard and Air Force Reserve experiencing substantial delays, approximately 36 months for data, prototype development and testing and 4

Task Time to Perform Task (months)

Cost to Perform Task ($)

Reverse Engineering, Prototypes & Data Development

18- 24 $

Ahw01thiness Qualification/ Certification and Flight Testing

8 -12 $

Total 36 $ months for first article evaluation to qualify a new repair source, follow by another 6 month for repairs to start fulfilling requirements.

VI. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE

SOLICITED FROM AS MANY POTENTIAL SOURCES AS DEEJ\1ED PRACTICABLE

This requirement was posted on the Federal Business Opportunities (FedBizOps) web page on 23 September 2015 citing conditions which precluded Full and Open Competition. No sources expressed an interest as a result of the posting. Although the Government does not own data to support acquisition of these C-130H Aircraft Avionic Components from any other source, any source who response to the Government as a result of this synopsis will be identified to the prime contractor as a potential for subcontracting possibilities. This is a pre-award contract action as required by FAR 5.201 in advance of issuance of the solicitation.

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 based upon FAR 15 negotiation procedures. The Contractor will be. required to submit data other than ce1iified cost or pricing data in accordance with FAR 15.403-3. Thorough price analysis will be conducted using available information and approved pricing teclu1iques that will support the contracting office in making a determination that the price paid to the contractor is fair and reasonable to the Government.

VIII. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AND THE

RESULTS, OR A STATEMENT OF THE REASONS MARKET RESEARCH WAS NOT

CONDUCTED

A detailed market research was conducted by the System Engineer in accordance with FAR

10.001 and 10.002 and was completed 18 March 2015. The engineer conducted research using internet searches, such as Central Contractor Registration, Thomas Registry, HIS Haystack, ILSmart, ai1d Google for part/national stock numbers and by manufactures. Also qualified individuals within the appropriate Government sections were contacted for assistance gathering product background information. A search for HUB zone and service disabled veteran owned businesses was also conducted using the Dynamic Small Business Search Engine. The subject National Stock Numbers (NSNs) on this repair contract are used exclusively on C-130H aircraft.

The items as used by the U.S. Air Force, Air National Guard and Air Force Reserve Command are not commercial items due to special military specifications. The data rights to the drawings are proprietary and are owed by Im10vative Solutions and Support Inc and they are not willing to release the data rights or sell the data. Im10vative Solutions and Support Inc was contacted by the 409 SCMS/GUEA Engineering Office via e-mail on 11 March 2015 about purchasing the data and Innovative Solutions ai1d Support Inc response was, "they have no desire to sell, lease, or loan the data". Research identified no sources, other than Innovative Solutions and Support Inc that are currently qualified to satisfy this requirement. Therefore, these items should be repaired by I1111ovative Solutions and Support Inc, because they retain proprietary rights to the data packages. No other contractual vehicles are in place to repair these items, and it's not a feasible option to reverse engineer and qualify another source at this time.

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

Innovative Solutions and Support Inc., is the only known source that can provide supplies and services described herein within the timeframe required. As of 11 March 2015, Innovative Solution and Support Inc., is not willing to sell, lease, or loan the data.

Reverse engineering is a desirable and viable avenue whenever applicable and practical.

However, because of the low repair quantities, low MDRs and the length of time to recover investment from reverse engineering, it is not a feasible option at this time.

While the current Market Research indicates a sole source environment for these NSNs, there are steps the Government will take to overcome barriers to competition for future acquisitions.

1. Depending on the designated Repair Method Code/Repair Method Suffix Code screening will be revisited every 1-5 years.

2. Elevate to Innovative Solutions and Supp01i Inc. upper management, the request to purchase essential data/drawings/technical manuals necessary for competition.

3. Work with 429 Supply Chain Management Squadron/ Strategic Alternate Sourcing

Program Office to request funding to acquire data/drawings/ repair technical manuals, through reverse engineering, during the appropriate fiscal cycle for data sufficient for competition.

Once the data/drawings/repair technical manuals are available the Government will compete future requirements or establish organic repair.

XII. CONTRACTING OFFICER'S CERTIFICATION

The contracting officer's signature on the Coordination and Approval Document evidences that he/she has determined this document to be both accurate and complete to the best of his/her knowledge and belief. (FAR 6.303-2(b)(l 2))

XIII. TECHNICAL/REQUIREMENTS PERSONNEL'S CERTIFICATION

As evidenced by their signatures on the Coordination and Approval Document, the technical and/or requirements personnel have certified that any supporting data contained herein, which is their responsibility, is both accurate and complete. (FAR 6.303-2(c))