H65_CAAS_AFCS_Component_2.0_J-and-A (Public Copy).pdf

Commandant, US Coast Guard (CG-9127) 2703 Martin Luther King Jr. Ave SE, Stop 7828

Washington, DC 20593-7828

Source Selection Information – See FAR 2.101 and FAR 3.104

Justification for Other Than Full and Open Competition Under 10 U.S.C. 2304 (c)(1)

Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) Subpart 6.3 and in accordance with the requirements of FAR 6.303-1, the justification for the use of the statutory authority under FAR Subpart 6.3 is supported by the following facts and rationale as required by FAR 6.303-2:

(1) Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Coast Guard (USCG) Headquarters, Office of Contract Operations – Formal Contracts Division VII (CG-9127), Washington, D.C., proposes to enter into a contract on the basis of other than full and open competition.

(2) Nature and/or Description of the Action being Approved.

This Justification and Approval (J&A) authorizes and approves, on a sole source basis, the procurement, production, and delivery, of Common Avionics Architecture System (CAAS) components, Very High Frequency Omnidirectional Range (VOR) / Airborne Radio Navigation (ARN) radios and mounts, and Automatic Flight Control System (AFCS) components. This includes hardware/software upgrades that will improve capabilities and extend the service life of the CAAS and AFCS components. The CAAS components, VOR radios and mounts, and AFCS components are Original Equipment Manufacturer (OEM) products from Rockwell Collins, whose address is below:

Rockwell Collins, Incorporated 440 Collins Road NE Cedar Rapids IA 52498-0505 Data Universal Numbering System (DUNS): 081306302

Historically, USCG procured these supplies and related service updates via a sole-source contract (HSCG23-17- C-AHH001) with Rockwell Collins. The contract expired on 31 January 2018.

USCG intends to execute these requirements under a sole-source, Indefinite-Delivery Indefinite-Quantity (IDIQ), Firm-Fixed-Priced (FFP), commercial contract to Rockwell Collins. The IDIQ format provides for greater flexibility in placing orders and funding considerations.

The type of funding used will be Fiscal Year 2020 USCG Procurement, Construction, and Improvement (PC&I), which is available for obligation up to five (5) years after appropriation.

The guaranteed minimum for the IDIQ will be satisfied with award of the first delivery order, which the USCG will award simultaneously with the IDIQ award. If additional PC&I funding becomes available, the USCG will execute orders up to the IDIQ ceiling value of $45 million.

The estimated total value of the contract is $45 million detailed as follows:

Justification and Approval (J&A) New H-65 CAAS/AFCS Components APFS Record #F2020048906

Source Selection Information – See FAR 2.101 and FAR 3.104 Page 2

Period Dates Estimated Total

Base

01 September 2020 to 31 August 2021 $20,000,000.00

01 September 2021 to 31 August 2022 $14,000,000.00

01 September 2022 to 31 August 2023 $10,000,000.00

01 September 2023 to 31 August 2024 $1,000,000.00

Total $45,000,000.00

The solicitation number will be 70Z02320RAHH00600.

(3) Description of Supplies/Services.

Under this proposed contract action, Rockwell Collins will deliver the components and component upgrades, which will be installed into the USCG MH-65E helicopter(s) as they undergo Programmed Depot Maintenance (PDM) and airframe service life extension activities. These activities will take place at the USCG Aviation Logistics Center (ALC) in Elizabeth City, North Carolina.

Specifically, the proposed contract will include the following components and service bulletin updates to improve and overhaul obsolete components and improve or replace components:

Item Description Part #/National Stock # Total Estimated Quantity

Multi-Function Display (MFD-268C3A) 822-2796-001/5820-01-HS2-3149 258

Data Transfer Unit (DTU) 7100 822-2429-001/5999-01-HS2-0880 65

Processor Switch Module (PSM-8600A) 822-2487-001/5895-01-HS2-3152 111

MT-8600 Mount Assembly/Fan (GPPU) 822-1852-001/4140-01-HS1-7504 194

Video Processing Module (VPM-8600A) (GPPU) 822-2017-002/5836-01-591-1755 37

CAAS Control Panel (CP-255K) 822-1059-112/6610-01-HS2-5774 121

VOR/ARN-147 / REC-2594, Radio Navigation 622-6376-015/5826-01-467-6215 3

VOR/ARN-147 MT Base, Electrical (MT-6313) 622-6380-001/5975-01-235-5111 65

AFCS Control Panel (FPC-100) 822-3362-001/5998-01-HS3-0904 65

AFCS Yaw Parallel Servo 622-4585-003/6615-01-HS3-4157 15

AFCS Collective Parallel Servo 622-4586-003/6615-01-HS3-4155 25

Digital Voice Privacy Processor 822-2506-003/5895-01-HS2-3872 1

BELOW ARE SERVICE BULLETIN UPDATES TO THE SERVOS

AFCS Yaw Parallel Servo Service Bulletin Update 141

AFCS Collective Parallel Servo Service Bulletin Update 135

AFCS Computer Service Bulletin Update 153

The Rockwell Collins CAAS is a manufacturer-integrated group of components used to provide cockpit indications to pilots and to interface with installed helicopter systems on the MH-65E. This specific system has been tested and integrated into the MH-65E prototype over a seven-year period, from 2012 to 2019.

Additionally, USCG installed Rockwell Collins CAAS in the MH-60T upgrade and the USCG benefits from continued commonality between airframes as an objective to reduce costs and improve logistics.

Source Selection Information – See FAR 2.101 and FAR 3.104 Page 3

The AFCS parallel servos and collective servos are in use currently on the MH-65. They provide stabilization to flight controls inputs. A reliability and improvement study contract (HSCG23-16-C-AHH001) completed by Rockwell Collins, identified technical enhancements that could be applied to the USCG’s existing inventory of AFCS components as service bulletins. Furthermore, additional inventory levels are required for these components due to the USCG decision to extend the useful mission life of the USCG MH-65E from 2030 to 2039.

The VOR/ARN-147 Receiver and Mount provides the pilot’s direction to the selected navigational aids or stations, and airports. The parts are critical to aircraft flight performance, safety of flight, and essential to avoid grounding of aircraft.

(4) Identification of Statutory Authority Permitting Other than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 United States Code (USC) 2304(c)

(1) as implemented by FAR Subpart 6.302-1, “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

(5) Identification of Exception to the Buy American Statute.

This section is not applicable, as the USCG does not anticipate an applicable exception to the Buy American statute. The Buy American statute will apply to this acquisition.

(6) Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited.

The USCG does not possess the data rights for the components required under this proposed IDIQ contract;

Rockwell Collins is the OEM and owns all data rights for production of the various components required under the proposed contract action.

The MH-65E aircraft design is at a physically mature state that has completed rigorous developmental and operational testing.

Deviation from the Rockwell Collins CAAS now would be detrimental to the H-65’s program cost and schedule, and introduce unacceptable risk that would affect planned delivery of the MH-65E aircraft. The additional cost to integrate non-OEM architecture into the Rockwell Collins system and tying it into the Operational Flight Program software would be cost prohibitive, with an order of magnitude exceeding $200 million, and cause production stoppage estimated at eighteen (18) to twenty-four (24) months. This would also cause the program to breach its Acquisition Program baseline schedule that USCG reports to both DHS and the U.S. Congress.

Initially, the USCG selected the Rockwell Collins CAAS to meet its mission needs due to the commonality with the Department of Defense (DoD) and the USCG MH-60T. Development of the MH-65E began in 2012. At that time, USCG expected full-rate production of the MH-65E to begin in 2017. In May 2016, the USCG approved a justification for other than full and open competition for the requirements discussed in this J&A. In January 2017, the USCG awarded a FFP contract (HSCG23-17-C-AHH001) for the procurement of CAAS, VOR, and AFCS, components. The quantity of components procured in the base year, in addition to components procured through other purchase orders and interagency agreements, accounted for almost two years’ worth of required production components. Shortly after award of HSCG23-17-C-AHH001, the MH-65E program incurred a schedule breach due to technical complexities between the CAAS software and the MH-65 flight director. The USCG did not award the remaining option years for that contract, which resulted in the contract ending. USCG restructured the MH-65E program to be back in compliance in early 2018 and received permission from DHS to

Source Selection Information – See FAR 2.101 and FAR 3.104 Page 4 enter Full-Rate Production (FRP) in November 2019. Full Rate Production (FRP) activities are currently on going, utilizing Rockwell Collins components procured from the aforementioned HSCG23-17-C-AHH001 and various purchase orders.

(7) Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as is Practicable.

On 31 January 2020, the USCG contracting staff posted this requirement in the Acquisition Planning Forecast System (APFS) under APFS Record # F2020048906. To date, the USCG has not received any responses related to this posting.

In addition, on 12 February 2020, the USCG contracting staff posted a sources sought notice (70Z02320SSNAHH007) on beta.SAM.gov. The response deadline was Wednesday, 04 March 2020. To date, USCG has not received any responses related to the posting.

(8) Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The USCG Contracting Officer anticipates that the price to the USCG for the supplies and services for this acquisition will be determined fair and reasonable based on a pricing comparison to the USCG’s Independent Government Cost Estimate (IGCE). The MH-65E program office built the IGCE using the historical pricing data from the previous contract (HSCG23-17-C-AHH001) with an applicable escalation rate to approximate price increases. Moreover, the USCG Contracting Officer will use the techniques found in FAR Subpart 15.404-1, “Proposal Analysis Techniques”, to help determine a fair and reasonable price, such as by comparing Rockwell Collins’ proposed prices to its commercial prices (15.404-1(b)(2)(iv)) and comparing the prices paid for similar Rockwell Collins components on recent purchase orders. As a part of this analysis, the USCG will also request other than certified cost and pricing data (such as Rockwell Collins’ commercial price list) to be submitted as a part of Rockwell Collins’ proposal.

Additionally, as the USCG places more orders, it will use the historical pricing information available from prior orders to help determine the fair and reasonable pricing of future orders.

(9) Description of Market Research.

Aside from the market outreach previously noted in Section (7), the USCG Integrated Procurement Team (IPT) conducted market research from October 2019 through March 2020. The IPT reviewed the DHS Strategic Sourcing Vehicles (SSVs), but could not find any other company who could potentially meet this requirement.

In looking for potential supplies, the IPT also used the Defense Logistics Agency (DLA) Logistics Information Services (FEDLOG), the Federal Logistics Information System Web Search (WEBFLIS), the General Services Administration (GSA) Advantage website, and the North Atlantic Treaty Organization (NATO) Support and Procurement Agency (NSPA). These sources did not provide any additional suppliers who could meet these requirements besides Rockwell Collins.

Additionally, the USCG used the Inventory Locator Service (ILS), a website used to locate difficult to find parts, to see if other distributors had the part numbers available and were authorized to distribute said parts. The USCG could not find any available inventory at the time of the search to indicate that other distributors are able to provide the referenced components.

Source Selection Information – See FAR 2.101 and FAR 3.104 Page 5

In light of the above information, the USCG intends to proceed with a sole-source IDIQ award to Rockwell Collins.

(10) Any Other Facts Supporting the Use of Other Than Full and Open Competition:

The USCG has a substantial investment tied to the MH-65 conversion/sustainment program. Ongoing development efforts and other contracts (such as for software integration and avionics rack modification) will be affected unnecessarily in cost and schedule should the USCG not be given approval to purchase the components referenced herein from Rockwell Collins. The MH-65E program’s need to purchase these Rockwell Collins components is based on system availability, integration with the test aircraft, and the USCG’s decision to keep alignment with the MH-60T CAAS components.

A competitive effort to acquire these components from another source will result in the need to develop additional specifications separate and distinct from those specific to the current prototype and other maturely developed specifications. The solicitation and selection of any other system would result in an estimated ten (10) year minimum delay comprised of essentially starting a new program from the Acquisition Lifecycle Framework’s Analyze/Select phase. This would also include procuring all applicable data rights from Rockwell Collins, which has not shown any interest in selling these rights and wishes to remain a sole-source in this marketplace. This would also eliminate the commonality of parts with the Department of Defense, which would impede maintenance and reduce similarity between the military branches.

Monetarily, the estimated cost to restart essentially the program from the Acquisition Lifecycle Framework’s Analyze/Select phase and to re-test and integrate brand new components throughout the lifecycle would be approximately $200 million. This figure comes from the total dollars spent on the initial certification and then escalated to the present time.

The ongoing conversion/sustainment of the MH 65E CAAS components is the best value to the USCG and is only possible through the OEM, Rockwell Collins.

(11) A Listing of the Sources, if Any that Expressed, in Writing, an Interest in the Acquisition:

No sources have expressed a written interest in this acquisition.

(12) A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome any Barriers to Competition Before any Subsequent Acquisition for Supplies or Services Required.

The USCG will continue to try to remove competitive barriers. USCG will remain up-to-date on technological innovations and information that may prompt the testing and usage of new materials as the MH-65E program ages. The Aviation Logistics Center’s (ALC’s) Spare Parts Breakout (SPBO) Manager will be involved with any companies who want to qualify to manufacture or repair parts for USCG aircraft and the USCG contracting and program staffs will be in close consultation with the SPBO office. The SPBO manager will continue to monitor the sustainment parts and identify if alternate sources of supply can satisfy all form, fit, and functional requirements.

Moreover, the USCG will explore its options with Rockwell Collins in procuring the data rights for these components so the work may be competed among different vendors.

Source Selection Information – See FAR 2.101 and FAR 3.104 Page 6

(13) Contracting Officer’s Certification. I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

XXXXXXXXX Date Contracting Officer (CG-9127)

(14) Technical / Requirements Personnel Certification. I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

XXXXXXXXXX Date Deputy Program Manager (CG-9315)

(15) Legal Counsel Review. I have reviewed this Justification and Approval for Other Than Full and Open Competition in accordance with HSAM 3006.304-70 and find it legally sufficient.

Legal Counsel (CG-0949)

APPROVAL:

Procuring Activity Advocate for Competition

(PAAC) (CG-9D)