Redacted-JA-Redacted.pdf

Justification and Approval (J&A) for Other Than Full and Open Competition

CONTROLLED UNCLASSIFIED INFORMATION

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I. Agency and Contracting Activity.

This Class Justification and Approval is to request authority for Other Than Full and Open Competition supporting requirements generated for the Air Force Sustainment Center (AFSC), 638 Supply Chain Management Group (SCMG), 409th Supply Chain Management Squadron (SCMS)/GUMA. The contracting activity for this requirement is AFSC/PZAAB. The purchase request number supporting this contracting action is FD2060-23-00027.

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

Due to the circumstances described herein, the activity requests authority to acquire the overhaul services of the C-5 trailing edge flap gearbox assemblies using Other Than Full and Open Competition as prescribed by FAR 6.302-1, Only One or a Limited Number of Responsible Sources and no Other Supplies or Services Will Satisfy Agency Requirements

This action will result in the award of a new overflow overhaul 2-year contract, which will be a Firm-Fixed Price (FFP), Requirements Indefinite Delivery Contract (IDC) contract. The contract will be structured with a 1-year Basic Ordering Period plus a 1-year Outyear Ordering Period. Based on the projected contract award date, orders can be issued between April 2025 and April 2027.

The vendor below is the only one qualified due to being on the Source Qualification Statement (SQS):

Thomas Instrument, Incorporated 3440 1st St.

Brookshire, TX 77423-9525

CAGE: 5H860

Large Business

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

The Air Force has a requirement for the overhaul services of the C-5 trailing edge flap gearbox assemblies.

The C-5 flap system makes it possible for the aircraft to operate at relatively slow speeds for takeoff or landing, and high speeds for cruise. These individual Flap gearboxes are part of the C-5 flap system that transmit rotational input from the flap power package to the flap actuators to physically drive the positioning their respective flaps.

C-5 flap gearbox repair requires strict control of processes to ensure adherence to very close tolerances when machining specified material. Special equipment is required to repair the precisely manufactured part surfaces.

Consistent repair processes are needed to ensure that the gearbox is manufactured such that the gearbox drives appropriately in flight.

Failure of C-5 Flap gearboxes could place the aircraft and crew in an extremely hazardous situation due to potential loss of appropriate flap actuation. This could lead to asymmetrical conditions between flaps.

Flight safety histories indicate that aircrew task saturation as a result of component failures dramatically

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These items are coded as ERRC T, meaning that the items are repairable. The NAICS code 811210 is the code that is used for aircraft parts and auxiliary equipment repair and overhaul.

The overall program acquisition strategy for future sustainment is to promote competition to the maximum extent possible by providing opportunities for additional vendors to become qualified sources. It is expected that Ogden CMXG will have resolved all repair and overhaul issues affecting the gearbox assembly repair line, by the end of this overhaul contract lifetime. The Air Force will not seek further opportunities for contract overhaul, as this effort is meant to be an overflow contract. This J&A conclusion supports that strategy by being limited to a period of two years. It is anticipated that additional vendors will become qualified by acquiring the tooling, test equipment and trained personnel by the expiration date of this current effort.

IV. Demonstration that the contractor's unique qualifications or the nature of the acquisition requires use of the authority cited above.

The agency's minimum needs can only be satisfied by the unique supplies or services available from Thomas Instrument, Inc. as identified on the design requirements and source qualification statement (SQS).

These items were designed specifically for the C-5 aircraft when the C-5 was built in the 1960s. They were built per a Lockheed Martin envelope drawing and specification. These items are unique to the C-5, designed, qualified, and manufactured exclusively for the C-5 aircraft.

Government engineering has determined that, due to the non-standard C-5 specific design and the Government's lack of information on the interior configuration and the particulars of the assembly component parts, no other commercial or non-developmental items can meet its needs. Therefore, a commercial item is not suitable for procurement contracts.

This acquisition is subject to FAR Part 9 compliant qualification requirements and as such, any contract award is limited to suppliers that have been qualified as an approved source through the Source Approval Request (SAR) process prescribed in AFMCI 23-113. Thomas Instrument, Inc., as the Original Equipment Manufacturer (OEM) is currently the only approved source. The Small Business Office (SBO) has confirmed as of 8 February 2024 that no other companies have submitted a SAR package, nor is there any SAR package in the evaluation process. Consistent with regulation and guidance, no vendor is a viable source until such time as they submit a source qualification package, are evaluated, and receive approval, thus becoming a qualified and approved source. Currently, Thomas Instrument, Inc. is the only approved source for this acquisition.

The subject trailing edge flap gearbox assemblies have been deemed organic repair for Ogden CMXG.

However, Ogden CMXG is currently at a complete work stoppage due to issues such as the technical order (T.O.) overhaul and the lack of component parts. Ogden CMXG cannot repair additional gearboxes until all constraints have been resolved. Ogden CMXG has determined that the estimated completion date for these issues to be resolved is in FY27.

The subject gearboxes are currently replaced at 100% for the production depot maintenance (PDM) and are critical to the operation of the C-5 galaxy aircraft. If the gearboxes are not repaired in a timely manner, August 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 11 of 13 mission incapable (MICAPs) backorders and surges will continue to accumulate, which will lead to aircraft grounding and will ultimately jeopardize the mission. The C-5 cannot undergo a lapse in repair of these items for any period of time. Due to the complexity of the trailing edge flap gearboxes, the tooling required and the criticality of this item for the C-5 aircraft only vendors that have been approved by AFLCMC/ WLSEAB C-5 Galaxy division engineering and are on the source qualification statement (SQS) may compete for this effort.

The 638 SCMG believes that award to any other source would result in unacceptable delays in fulfilling the Air Force's requirement. All other vendors wanting to become qualified would need to submit a source qualification package to the engineer. This would require the vendor to acquire the required tooling and the test equipment. It is estimated that it will take a vendor between 2-3 years in order to acquire the tooling, test equipment and to train qualified personnel.

The Government cannot afford to wait for additional vendors to acquire the required tooling and test equipment, otherwise additional MICAPs and surges would accrue leading to aircraft grounding. It is in the Government's best interest to award this contract to Thomas Instrument, Inc. Due to the sincere need of these items, and the fact that Thomas Instrument Inc. is the only approved vendor, the Government has no other options than to go sole source to Thomas Instrument, Inc. If the Government were to wait for other vendors to become qualified it would cause unacceptable delays and would significantly harm the Government. As recently stated, MICAPs would continue to accrue causing aircraft grounding and ultimately jeopardizing the mission of the United States Air Force. None of the vendors identified on the market research report have expressed interest in this effort when contacted.

Accordingly, Thomas Instrument, Inc. is the only vendor capable of providing the requirements described in Section III above without the United States Air Force (USAF) experiencing unacceptable delays in fulfilling its requirements.

V. 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 Request for Information (RFI), including a source qualification statement (SQS), Solicitation Number FD2060-23-00027 was posted to SAM.gov on 27 November 2023 for the repair of the C-5 trailing edge flap gearboxes. All responses were due by 28 December 2023. Thomas Instrument Inc. is the only vendor that has expressed interest and is listed on the source qualification package.

The requirement will be synopsized in SAM.gov 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.

VI. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will require the submission of certified cost or pricing data in accordance with FAR Part 15.403-3. Price analysis and cost analysis will be used to examine and evaluate the proposed prices to determine fair and reasonable pricing.

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VII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

Market Research was conducted on 23 December 2023 in accordance with FAR part 10.001 and 10.002.

The Market Research Report was completed on 8 February 2024. The market research techniques used are as follows:

As stated in Section V above, an RFI, including a source qualification statement (SQS), Solicitation Number FD2060-23-00027 was posted to SAM.gov on 23 December 2023 for the overhaul of the C-5 trailing edge flap gearboxes. All responses to the RFI were due by 8 February 2024. Thomas Instrument Inc. is the only vendor that is listed on the source qualification statement. Air Quality Aviation has expressed interest in this effort. However, they did not submit all of the required documentation that was necessary to complete their source qualification package. Therefore, they were not deemed capable.

Performed a Dynamic Small Business Search 17 April 2024 at http://dsbs.sba.gov/dsbs/search/ dsp_dsbs.cfm/ using NAICS code 811210 (other aircraft parts and auxiliary equipment manufacturing) and keyword “gearbox.” The search did not return any results.

An internet search at https://www.thomasnet.com/ using the following search criteria:

- C-5 Gearbox

- Manufacturers

- Quality Certifications - ISO 9001:2015

Search resulted in 3 suppliers: Interface Air Repair Inc, Avion USA LLC and Skytronics Inc. None of these vendors are qualified due to not being on the source qualification list.

The C-5 trailing edge flap gearbox does not fit the definition of a commercial item as defined in FAR Part

2.101. This item is defined as military unique and is not customarily used by the general public or by non- Governmental entities. The Government requires parts that meet an exact form, fit, and function as determined by the specific mission. There are no aircraft in the commercial market with the same or similar components.

The market research concluded that the acquisition can only be made to Thomas Instrument Inc.

VIII. Any other facts supporting the use of Other Than Full and Open Competition.

The current items designs have successfully operated on the aircraft since deployment, and there are no known obsolescence or diminishing manufacturing issues to be resolved. Additionally, there are no new technologies, applicable to these items that provide affordable best value alternatives to the current design.

Based on the reasons stated in section IV of this document, the only viable source for manufacture of these parts is Thomas Instrument Inc.

IX. List of any sources that expressed, in writing, an interest in the acquisition.

See Section V above.

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X. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisitions for the supplies or services required.

The only available action to make this effort more competitive would be for additional vendors to submit source qualification packages, and for them to be approved by AFLCMC/WLSEAB C-5 Galaxy division engineering. Opportunities to respond to the source qualification inquiry will be provided every two years, prior to any follow-on contract.

XI. Certification by the Contracting Officer.

As evidenced by my signature above, I certify that this justification is accurate and complete to the best of my knowledge and belief.

XII. 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.