Fire Reporting System Upgrade Justification - Final dated 17DEC2021(Award Notice).pdf
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- Fire Reporting System Upgrade
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- FA468626PC006
About this file
This is a Justification and Approval (J&A) document for Other Than Full and Open Competition authorizing the Air Force to procure facility fire alarm panels on a non-competitive basis.
The Air Force Installation Contracting Center (AFICC) seeks to standardize facility fire alarm panel purchases across all CONUS and OCONUS installations through a Class J&A effective through September 30, 2026. The estimated total contract value is $14,800,000, covering approximately 20,864 units expected to reach end-of-service life over the five-year period. The contracting authority is 10 U.S.C. 2304(c)(1) (FAR 6.302-1), which permits non-competitive acquisition when supplies are available from a limited number of responsible sources and no other type will satisfy agency requirements. The Air Force justifies this approach based on standardization benefits including: training cost reductions of approximately $22 million and 375,000 duty hours over a five-year training cycle; increased mission performance through specialized technician expertise; reduced system downtime; and improved lifecycle maintenance planning. Currently, the Air Force inventory includes 28 different fire alarm panel manufacturers, with 86% of installations operating multiple brands, requiring technicians to obtain separate manufacturer-specific training at costs ranging from $8,400 to $9,300 per person. A Notice of Proposed Contract Action was posted on SAM.gov on June 1, 2021, for 15 days, with zero vendors expressing interest. The J&A received final approval on November 30, 2021, from all required coordination parties including the Chief of the Contracting Office, local legal counsel, the Competition Advocate, and acquisition support directors.
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Justification and Approval (J&A) for Other Than Full and Open Competition
CONTROLLED UNCLASSIFIED INFORMATION CONTROLLED UNCLASSIFIED INFORMATION
March 2020 CONTROLLED UNCLASSIFIED INFORMATION Page 1 of 6March 2020 CONTROLLED UNCLASSIFIED INFORMATION Page 1 of 6
Was a J&A approved for the preceding acquisition? Yes No
Is this a new or amended J&A Document? New Amended ( Prior to Award Only! )
Is this a Bridge Action as defined at AFFARS 5302.101? Yes No
Dollar Value of this Acquisition: < $750K > $750K and < $15M > $15M and < $100M > $100M
Contracting Activity: Air Force Installation Contracting Center (AFICC)
Purchase Request (if available): TBD
Program / Project (and PE, if applicable): Facility Fire Alarm Replacement Standardization
Program Type (PEO, Enterprise, of Operational): Operational
Authority: 6.302-1 – 10 USC 2304(c)(1), Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements
Estimated Contract Cost (including options): $ 14,800,000 J&A Type: Class Individual
! ! Provide estimated cost of all contracts.
COORDINATION ( AFFARS 5306.304(a)) Sign and Save Procedure
** The text in the signature blocks below is editable, including the title.
** To remove a row, click the "X" next to the signature block. CAUTION: Once removed, it can only be restored by downloading the BLANK FORM again.
Date
22 Sep 2021
Project Lead / Program Mgr / Requiring Activity Major Patrick J. Grandsaert
AFCEC/COOM / DSN 523-6931
Signature
X
Date
04 Oct 2021
Contracting Officer Major Anthony S. Percy
AFICC 772 ESS/PKD / DSN 523-6482
Signature
X
Date
12 Oct 2021
Local Legal Reviewer Ms. Karen White
AFIMSC/JAQ / DSN 523-6575
Signature
X
Date
19 Oct 2021
Chief of the Contracting Office (COCO) Lt Col Michael E. Corrigan
772 ESS/CC / DSN 969-8776
Signature
X
Date
29 Nov 2021
Director, Acquisition Support (AFICC/KP) Robert A. Hixenbaugh/DSN 787-5529
Signature
X
Date 30 Nov 2021
Director, Enterprise Solutions Support (AFICC/KA) Roger H. Westermeyer/DSN 787-5217
Signature X
Date Signature X
GRANDSAERT.PATRICK.
JOSEPH.1283426889
Digitally signed by
GRANDSAERT.PATRICK.JOSEPH.1283426889
Date: 2021.09.22 21:55:55 -05'00'
PERCY.ANTHONY.S.101
1007097
Digitally signed by
PERCY.ANTHONY.S.1011007097
Date: 2021.10.04 13:47:04 -05'00'
WHITE.KAREN.SUE.1157
422550
Digitally signed by
WHITE.KAREN.SUE.1157422550
Date: 2021.10.12 10:09:47 -05'00'
CORRIGAN.MICHAEL.E.
1084070757
Digitally signed by
CORRIGAN.MICHAEL.E.1084070757
Date: 2021.10.19 09:57:30 -05'00'
HIXENBAUGH.ROBERT.
ALLEN.1080487998
Digitally signed by
HIXENBAUGH.ROBERT.ALLEN.1080487998
Date: 2021.11.29 15:26:42 -05'00'
WESTERMEYER.ROGER.H.1102036324 Digitally signed by WESTERMEYER.ROGER.H.1102036324 Date: 2021.11.30 14:47:52 -05'00'
March 2020 CONTROLLED UNCLASSIFIED INFORMATION Page 2 of 6March 2020 CONTROLLED UNCLASSIFIED INFORMATION Page 2 of 6
APPROVAL ( AFFARS 5306.304(a))
Date
17 Dec 2021
Competition Advocate Mr. Anthony W. Everidge, SES
AFICC/CA / DSN 787-1900
Signature
EVERIDGE.ANTHONY.W.
1230167814
Digitally signed by
EVERIDGE.ANTHONY.W.1230167814
Date: 2021.12.17 12:14:16 -05'00'
March 2020 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 6March 2020 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 6
I. Agency and Contracting Activity.
Department of the Air Force, Air Force Installation Contracting Center, 772 Enterprise Sourcing Squadron, Bldg 1, Port San Antonio, 3515 S. General McMullen, Ste 200, San Antonio, TX 78226-1865.
II. Nature and/or description of the action being approved.
The United States Air Force (USAF) has a brand name requirement to procure facility fire alarm panels from a limited selection of manufacturers specified by location to support new fire alarm panel purchases for the remainder of this Fiscal Year (FY) through 30 Sep 2026. This Class J&A will support multiple contracts (new) throughout CONUS and OCONUS locations.
III. Description of supplies/services required to meet agency needs (including the estimated value).
This Class J&A covers all USAF facility fire alarm panel purchases from the effective date of this Class J&A through 30 Sep 2026. Fire alarm panel purchases during the next 5 years are expected to number 20864 units (the number of units expected to reach the end of service life). The total spend necessary for replacement of these units has been estimated at approximately $14.8M. Approval of this Class J&A will reduce the total cost of ownership to the Air Force by eliminating inefficiencies and duplication in cost by reducing the need to train USAF fire alarm panel technicians on multiple manufacturers' systems, eventually reducing training requirement by an estimated $22M and 375K hours per 5 year training cycle. Standardization under this class J&A also allows, over time, fire alarm panel repair and programming to be done in-house as the primary option versus contracting out these services. Approval will also increase mission performance efficiencies by streamlining and specializing Civil Engineering (CE) maintainer's schoolhouse training and more importantly additional training at the maintainer's duty location on base-specific manufactures' generators, increasing expertise of organic technicians thereby reducing downtime of fire alarm panels for repair and replacement due to increasing expertise of organic technicians. The increased availability of trained technicians also improves the sustainment of the Air Force's equipment, machinery, and communications systems. Approval will also increase process efficiencies by allowing CE pre-planning for building design, will improve life-cycle maintenance and replacement of expensive and critical equipment, and will leverage spending on spare parts inventory.
IV. Statutory authority permitting other than full and open competition.
The Competition in Contracting Act (CICA) at 10 U.S.C. 2304(c)(1), as implemented by FAR 6.302-1(a)(2) and required by FAR 6.303-2(b)(4), states when supplies or services required by the agency are available from a limited number of responsible sources and no other type of supplies or services will satisfy agency requirements, full and open competition need not be provided for.
V. Demonstration that the contractor's unique qualifications or the nature of the acquisition requires use of the authority cited above (applicability of authority).
The Air Force is required to use the “brand name exception” to CICA because the nature of the acquisition as a strategic vehicle for Category Management (CM) requires a pre-planned brand name approach to acquiring facility fire alarm panels. This brand name acquisition is integral to avoiding estimated costs in training expenses and efficiency improvements in mission performance not otherwise available under full and open competition.
The training requirements of Air Force maintenance personnel would be greatly reduced under the standardization of fire alarm panels as described in paragraph II. There are two aspects of training for Air Force maintenance personnel. Similar to other Air Force assets, additional training beyond initial skills training is required to maintain proficiency in the system's maintenance. Initial training for Air Force personnel maintaining fire alarm panels is conducted at Sheppard AFB (the “school house”) and includes basic instruction for common maintenance and operations across the inventory of Air Force fire alarm panels. However, there is no detailed instruction on fault diagnosis and repair because the Air Force inventory of fire alarm panels has 28 different manufacturers, the unique difference in the manufacturers' processes cannot be trained to ensure trainees master all manufacturers at initial skills training. Therefore Air Force personnel require additional training at the maintainer's duty location on base-specific manufactures' fire alarm panels. At every Air Force base, there are between 1 and 15 unique manufactures' fire alarm panels requiring the local training to stretch across all different types of fire alarm panels The Air Force Civil Engineering Center (AFCEC) Force Development Manager for electricians reviewed the Career Field Education and Training Plan (CFETP) to capture the costs for minimal training to operate and maintain multiple
March 2020 CONTROLLED UNCLASSIFIED INFORMATION Page 4 of 6March 2020 CONTROLLED UNCLASSIFIED INFORMATION Page 4 of 6 systems. Of the 16 fire alarm panel related tasks on the CFETP, 16 tasks would have to be re-learned or accomplished with each new manufacturer bought and installed. Thus, 100% of the advanced fire alarm panel training costs is repeated at the duty station for each new manufacturer installed at a base. This level of effort is not practical, and cannot occur while still meeting the basic mission needs. The result is an under-trained workforce burdened to train-as-you go, which ends in failed attempts to maintain and repair critical infrastructure equipment.
Additional training must also be provided to ensure advanced troubleshooting and repair of specific systems. Advanced training requires the manufacturer to be involved in order to certify that the maintainer can use proprietary systems for fault diagnosis, program fire alarms, or have access to proprietary code for digital faults. The cost of this training is high and is specific to each manufacturer. Currently, the Air Force funds this training for only the top manufacturer used at the base, on a case by case basis, and any repairs required on other complex systems are contracted out.
The training is currently conducted by the manufacturers at their location resulting in Temporary Duty (TDY) costs for all technicians requiring training. Each manufacturer has different courses that must all be completed to be fully trained. The majority of installations, 86%, have more than one fire alarm panels manufacturer represented, with a mean value of 7.13, and a maximum of 15. This represents a significant duplication of training costs and time in having technicians obtain required training from each manufacturer.
Manufacturer-specific training for CFETP requirements for fire alarm panels has been priced from actual expenses for OEM systems. The total cost to train one technician on one of the three main OEM fire alarm panels in the Air Force ranges from $8400 to $9300 per person, or an average cost of $8,566. If we take the 381 technicians, assume 33% need training annually due to turn over, apply the average cost to 126 technicians to 7.13 brands, consolidating to up to 3 brands would reduce our training requirements by $22M over a 5 year period. These TDYs also take 144 duty hours away from the mission, thus, using the same calculation, consolidating to up to 3 brands would return 375K hours to the mission.
The biggest requirement reductions would result by the Air Force establishing local specialized training, once the installation's standardized fire alarm panel manufacturer is designated. However, even if the Air Force paid full vendor prices and were trained at the bases instead of sending technicians TDY, any mix of training reform aided by standardization results in millions in cost requirement reductions.
The Category Management process identified the Air Force did not have an established TCO model for real property installed equipment. The CIR team sponsored a master's student at the Air Force Institute of Technology (AFIT) to develop a Total Cost of Ownership (TCO) model template for RPIE systems that includes sustainment costs. A major finding of this thesis is the enterprise lacks data to properly complete a TCO model. Therefore, the model was used for this effort was derived from existing operations and maintenance and contract spending data associated with fire alarm panels. The TCO model provides USAF acquisition, contracting, and civil engineering professionals a tool with which to project life-cycle costs, negotiate prices, and justify spending decisions. Furthermore, the model provides a proof of concept to the CE enterprise that will allow for the expansion of TCO modeling to other categories of spending.
Implementation of this Class J&A will (1) standardize the USAF on a limited number of facility fire alarm panel manufacturers which reduces training requirements by an estimated $22M and training hours by 375K per 5 year training cycle, (2) will ensure training will be more defined, (3) will increase the responsiveness and effectiveness of in-house technicians resulting in fewer and shorter downtimes for facility fire alarm panels, (4) will lead to a more cost effective delivery of mission capability by ensuring Air Force technicians are fully trained, and (5) reduce cyber security requirements across the CE enterprise. Therefore, award to any other sources than those specified brand names for specified Air Force bases would result in continued substantial duplication of cost and lowered mission performance to the Government that is not expected to be recovered through competition. Finally, approval will generate demand efficiencies by reducing the equipment and parts inventories for CE and the personnel required to sustain them.
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.
IAW FAR 5.201 a Notice of Proposed Contract Action/Special Notice, 772_Fire_Alarm_Panel_Brand_Namewas posted on SAM.gov (Government Point of Entry "GPE") 01 June 2021; the posting remained open for 15 days.
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A brief description of the requirement was included in the GPE notice. The notice advised that any interested responsible party that believed it was equally or otherwise uniquely capable of meeting the requirements should submit a capability statement. The notice also stated that supporting evidence must be furnished in sufficient detail to not only demonstrate the ability to fulfill the requirement but also demonstrate that competition would be advantageous to the government and would not create a break in service or degradation of performance quality. Zero vendors expressed interest in the published Special Notice/Synopsis that was posted on the GPE.
In addition, a survey of small business companies from GSA listings was conducted in March 2021. A minimum of 17 GSA defined small business in different zones across the United States were found to be capable of performing fire alarm panel removal and install. This list of small business supports the idea of competition among the manufacturers being maintained at the distributor level, where possible small business awards can be made. The cost and efficiency benefits to the Air Force through standardization and interoperability, with sunk costs of existing and highly reliable infrastructure, greatly outweighs the expected benefits of competition of differing OEM brands.
Ultimately, full and open competition is what led the Air Force to the current state of costly training but still less than fully trained technicians, multiple systems per base requiring contracting out advanced repairs, and preventing the efficiencies of less system down-time. The Air Force owns and operates large infrastructure systems, however installing disparate systems has led to a lack of operations and maintenance proficiency. The market research and the subject matter expert analysis captured in the CIR documents that training effectiveness and system knowledge diminish as manufacturer diversity increased. Inversely, costs to train go up to pay for diverse training programs over all the systems. Lack of expertise with complexity across multiple fire alarm panel systems coming from a multitude of vendors all lead to gaps in training, and inability to operate and maintain systems effectively. Finally, the CE schoolhouse training dollars as well as local base O&M funds for training are not being effectively applied when the result is less than a fully qualified organic maintenance function.
The efficiencies gained by standardization on selected brand name systems per base will allow the unspent O&M funds to be applied to unmet training needs.
VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.
Contracting Activities will be required to make an individual determination of price fair and reasonableness IAW FAR 13.106-3(a) (simplified acquisitions) or FAR 15.403-3(c)(1) (commercial acquisitions) prior to award. AFCEC and local bases have a large data base of historical prices based on competitive acquisitions, which should be used for comparisons and the government's estimate. While there would not be competition among manufacturers for a local base buy of the assigned name brand fire alarm panel under this J&A, there can still be competition between distributors and most decentralized purchases will include installation and minimal training when needed. These costs will be competed, most likely among small business installers.
At this time, the Air Force CE community needs the immediate J&A authority to limit acquisitions to assigned brand name fire alarm panels because it is estimated that approximately $14.8M of the estimated $126M in fire alarm panels have either reached their end of life or will reach their end of service life over the next five years. Procuring under this class J&A will replace the anticipated repeated requests from local contracting units for brand name J&As to ensure equipment interoperability which were not consistently processed and approved and often stalled procurements by roughly 12 weeks on average for similar RPIE requirements. Under this class J&A, contracting units will not process separate J&As, creating more agile acquisition cycles, as well as cost avoidance in demand and process.
VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.
A joint CIR between Air Force Installation and Mission Support (AFIMSC), AFCEC, and AFICC was accomplished in 2018 to gain practical knowledge and experience in how the Air Force manages RPIE. Supporting facts in this Class J&A were drawn from this CIR and current BUILDER inventory data. Fire alarm panel specific input was gathered from AFCEC and base level subject-matter experts and market analysis. Additionally, IAW FAR 5.201 a Notice of Proposed Contract Action/Special Notice, 772_Fire_Alarm_Panel_Brand_Namewas posted on SAM.gov (Government Point of Entry "GPE") 01 June 2021; the posting remained open for 15 days. Zero vendors expressed interest or concerns in the published Special Notice/Synopsis that was posted on the GPE.
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IX. Any other facts supporting the use of Other Than Full and Open Competition.
In order to increase mission performance, requirement reductions, and innovation in business methods, facility fire alarm panels standardization supports the National Defense Strategy objective to innovate business decisions for saving taxpayer dollars. In order to implement this acquisition strategy, the Air Force must pre-plan the brand name facility fire alarm panels per installation.
X. List of any sources that expressed, in writing, an interest in the acquisition.
This class J&A does not have a specific acquisition attached to this request. No sources that expressed interest in this effort. The underlying analysis of the need for standardization accounted for as many different manufacturer's brands as would be practical to achieve the maximum amount of requirement reduction and efficiencies. An “or equal” manufacturer to those specified by location is an oxymoron in that other brands may be able to generate fire alarm codes and alerts equally. However, those “or equals” could not produce the requirement reductions and efficiencies determined by the extensive business analysis found in the CIR because they could not provide the standardized training on proprietary information and designs, and could change the fact that multiple manufacturers would still be procured using the status quo procedures. The efficiencies of maintaining a limited number of fire alarm panel brands over time could not be achieved.
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 only barriers to competition under this class J&A have been generated by historical purchases. This class J&A action only recognizes that past competitive awards have established the number and mix of fire alarm panels on each base. The Category Management analysis and action only recognizes these facts and maximizes efficiencies based on what the Air Force has in its current inventory across the enterprise and at local levels. The Air Force will continue to perform data driven analysis over time to look for market changes that may increase competition amongst fire alarm panel manufacturers. Additionally, as standard industry practice involves manufacturers, selling through vendors, competition will be maintained at the Dealer/ Distributor level. As noted earlier, the Air Force may pursue negotiations for best customer pricing directly with selected brand name manufacturers to pre-price the fire alarm panels
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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