PCMCIA_DTD_-_JA__redacted.pdf

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

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I. Contracting Activity.

United States Air Force (USAF), Air Force Life Cycle Management Center (AFLCMC), Air Force Program Execution Office (AFPEO)Digital (AFLCMC/HB), Airspace Mission Planning Division (AMPD)(AFLCMC/HBM) Contracting Office (AFLCMC/HBMK), 11 Barksdale Street, Bldg. 1614, Hanscom AFB MA, 01731-2100. Procuring Contracting Officer (PCO) is John F. McGowan, (781) 225-9603 or DSN 845-9603.

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

The purpose of this Justification and Approval is for issuance of a Firm Fixed Price purchase order to acquire 3,500 PCMCIA Micro USB Data Transfer Devices (DTDs). There is only one manufacturer who produces this unique device: Printed Circuits Corporation of Lilburn, Georgia. This device will be used at various Mission Planning locations for a variety of different aircraft (F-22, C-5, C-130, HC-130 etc.). This will be a sole source contract to Printed Circuits Corp using FAR Part 12 procedures.

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

PCMCIA is an acronym for Personal Computer Memory Card International Association (PCMCIA).

PCMCIA was an organization consisting of some 500 companies. Companies included Poqet, Fujitsu, Intel, Mitsubishi, IBM, Lotus, Microsoft and SCM Microsystems. In 1990, PCMCIA developed a standard for small, credit card-sized devices, called PC Cards. PC Cards are hot-pluggable flash memory devices originally designed to support 16-bit interfaces and are used to expand memory for laptop device; and can also be used to store and transfer data between computer systems.

In the early 2000s, several USAF Aircraft platforms adopted a 32MB, PC Card Type II device to store and transfer critical data to aircraft avionics and weapon systems.

In 2006, PCMCIA adopted a new variation called ExpressCard that provided support for PC Cards and allowed another set of newer devices. However in 2009, the PCMCIA disbanded and by 2011 less than half a per cent of laptops were actually using the ExpressCard slot. Today, the PC CARD/ ExpressCard slot is considered to be mostly obsolete.

In 2008, the Department of Defense (DoD) banned the use of flash media devices, except for devices deemed to be mission essential. Movement of data to Air Force avionics and weapons fell into that category but use of these devices was not permitted on USAF networks.

In 2010, the USAF began to relax the ban on flash media with significant limitations but, due to the now unchanging design of the PC Card, these devices were still not fit to be placed on the government networks.

In 2012, AFLCMC/EZAS and Defense Microelectronics Activity (DMEA) began an effort with Printed Circuits Corporation (PCC) to design and manufacture a PCMCIA Type II device to resolve issues that many weapons systems were having with the then current supply of PCMCIA PC devices.

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These issues primarily dealt with compatibility with older weapons systems as well as with providing design enhancements to bring these devices into compliance with updated security requirements.

In 2016, AFLCMC/EZAS, through DMEA, created NSN 7025-01-659-7874. The DTD is a PCMCIA Type II device with a built-in micro USB port. This allows aircraft avionics mass memory systems to access data stored on the DTD device via the typical PCMCIA peripheral reader interface and allows connection to any modern desktop or laptop without an adaptor via the micro USB interface. The card supports a variety of data formats and is configurable from 32 MB to 32 GB. Individual device behaviors or protocol timing characteristics are configurable based on expected aircraft avionics read write systems. This device supports a wide variety of data formats and has been successfully tested with several aircraft avionics systems. It is also approved by the National Security Agency (NSA) for cryptological support.

Air Space Mission Planning Division requires 3,500 PCMCIA Micro USB Data Transfer Devices (DTD). This device is a PCMCIA Type II form-factor DTD with an integrated micro USB 2.0 port on the side. Data accessible on the PCMCIA port of the device is also accessible via the USB port from a standard PC. There are no drivers necessary to access data from the device. It can be connected to any PC (Windows, Unix, Linux, or Mac). There are many characteristics that make this device truly unique. Each device has a particular serial number assigned during manufacturing which enables the device to be "white listed" or "black listed" on a network. White listing is based on a "zero trust" principle which essentially denies all entities, and allows only what is necessary. Black listing prevents known malicious or suspicious entities that should not be allowed access or execution rights in a system or network.

The PCMCIA Micro USB DTD is already approved or can be approved for use on any Air Force Network. The capacity of the device is configurable from 32MB to 32GB with the same hardware.

The individual device behaviors or protocol timing characteristics (read/write speeds) are configurable to support each specific platform requirement which is crucial when supporting a plethora of aircraft platforms.

This action is sole source because Printed Circuits Corporation (PCC), the small business that re-designed the PCMCIA devices, is the only manufacturer of the PCMCIA Micro USB DTD. The card will be ordered with machined Aluminum case rather than a stainless steel case. The devices shall be delivered in minimum batches of 500 units, beginning with an initial batch16-weeks ARO and continuing in similar size batches every ten weeks thereafter until the 3,500 quantity is met.

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

The statutory authority that permits other than Full and Open Competition for this acquisition is 10 U.S.C. 2304(c)(1), as implemented by FAR 6.302-1(a)(2)(iii)

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V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

Award to any other source would result in unacceptable delays in fulfilling the Air Force's requirements. It took the current vendor over two years to obtain the knowledge and expertise to manufacture this this DTD successfully. Presumably a new company would take just as long if not longer to gain the in-depth knowledge of how this DTD functions and how it is to be manufactured.

The next challenge for a new company would be having the capability and capacity to provide a large quantity of extremely unique cards in an efficient, timely manner. With the delivery schedule of the experienced manufacturer being just over 1-year, it would take an inexperienced manufacture at least double that time to deliver this product. Therefore, it would be at least a three year delay for receiving these crucial DTD's which is unacceptable for the warfighter and the Air Force. Daily requests are being made by the warfighter for these cards as they are essential for them to perform their mission.

Accordingly, PCC is the only firm capable of providing the supplies and services described in Section III above without the U.S. Air Force experiencing unacceptable delays in fulfilling its requirements.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

Given the unique characteristics of this Data Transfer Device (Ref Section III), no other sources are currently available to provide it.

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

Printed Circuits Corp. will be required to submit a proposal that will undergo a thorough technical evaluation. The pricing will be evaluated and compared to an Independent Government Price estimate and prices paid for prior technology. The contractor will be required to provide evidence of pricing charged to other organizations.

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

On 20 Mar 2019, AFLCMC/HBMK posted two Requests for Information (RFI) to both the AFWay/ NETCENTS-2 Products IDIQ and the NASA SEWP IDIQ requesting sources and a market research quote for the 3,500 of the unique PCMCIA DTDs that the Air Force requires. Both RFIs was posted to all 24 NETCENTS-2 Products vendors and to all 128 NASA SEWP IDIQ vendors. The due date for responses was 5 April 2019.

The NASA SEWP RFI resulted in one response from a NASA SEWP vendor which was a request for more information. However, the vendor did not indicate that they had the capability to produce the unique PCMCIA DTDs required by the Government.

The NETCENTS-2 RFI also resulted in one response from an AFWay/NETCENTS-2 Products IDIQ vendor which was also a request for more information. However, the vendor did not indicate that they had the capability to produce the unique PCMCIA DTDs required by the Government.

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Further market research via Google searches and phone calls with IT products re-sellers demonstrated that there are many companies that still produce and sell different versions of obsolete PCMCIA devices. Market research was discontinued when the procuring activity realized that none of the sources that were identified are able to deliver the unique configurable PCMCIA devices with switchable memory capacity from 32MB to 32GB, adjustable protocol timing characteristics configurable to a plethora of aircraft, the integrated micro USB 2.0 connectivity port and all of the other unique characteristics outlined in previous sections above that are crucial mission critical capabilities for USAF aircraft.

There is no company other than Printed Circuits Corporation with the unique capability to produce the required particular mission-critical PCMCIA DTDs.

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

N/A

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

The RFIs yielded two interested parties, but as mentioned in Section VIII, the procuring activity did not initially understand the uniqueness of the card being procured. As mentioned in Section III, this device provides unique features that are essential for the card; namely, the devices ability to be "white" and "black" listed on all Air Force Networks and the individual card behaviors and protocol timing characteristics to adapt to a plethora of aircraft platforms.

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.

Currently a re-design of the PCMCIA DTD is on-going. Once an updated drawing package becomes available and has been qualified by the appropriate government entities, the Government will be able to make future procurements using full and open competition.

XII. Certification by the Contracting Officer.

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

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