H65_AFCS_JA_Approved_20150403_REDACTED.pdf

PROCUREMENT SENSITIVE

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

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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 justified by the following facts and rationale required under FAR 6.303-2 as follows:

(1) Agency and Contracting Activity.

The Office of Contract Operations Formal Contracts Division VII (CG-9127), the United States Coast Guard (USCG) Headquarters, Department of Homeland Security, Washington, DC, 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.

The USCG has a requirement for the upgrade and service life extension for the H-65 helicopter Automatic Flight Control System (AFCS). The AFCS Original Equipment Manufacturers (OEMs) are Rockwell Collins Inc. (RCI) and Sagem. The contract will include non-recurring engineering and logistics efforts to improve capabilities and extend the service life of the AFCS and procurement of AFCS hardware/software upgrades. This Justification and Approval (J&A) addresses contract actions for AFCS for RCI components only.

(3) Description of Supplies/Services.

The contract requested will include:

Non-recurring engineering (NRE) and logistics efforts to improve and overhaul obsolete components and improve or replace components with high failure rates for service life extension.

Component buys – Improved AFCS components in the AFCS computer, AFCS control panels and AFCS servo components with Diminishing Manufacturing Sources (DMS).

An AFCS Line Replaceable Unit (LRU) status detection capability integrated with the aircraft’s Common Avionics Architecture System (CAAS).

Production Ground Support Equipment (GSE) – maintenance break-out boxes, unit level production testing equipment and others as determined by engineering analysis.

Transition of AFCS components to the updated fault isolation platform at the RCI repair facility.

OEM technical support to verify AFCS proper installs, procedures and assess improved capability.

The AFCS system includes the following components:

a. AFCS Computer. The AFCS computer, according to initial technical discussions is planned to remain a useable component with only surgical replacements of sub-component hardware to increase reliability and combat obsolescence issues. The computer itself would then require appropriate qualification testing. The analog computer contains no software.

b. Parallel Servos. The collective parallel servo and yaw parallel servo are planned to be retained following over-haul of high failure and obsolete sub-components. Modifications to the original internal error thresholds of the parallel servos will significantly reduce intermittent failures. Additionally, LRU level fault isolation will significantly reduce unnecessary maintenance and increase the useful service life of components.

c. Control/Engage Panel. The AFCS engage panel has long been identified as a top mission degrader for the H-

65. It is of analog design (no software) and contains both electrical and electro- mechanical components. The OEM is currently under contract to build a replacement AFCS Engage Panel. The contracting effort, considered in this J&A, will complete the NRE of this panel and allow for production quantity component buys.

d. Component level diagnostics and failure detection. CAAS has the capacity to manage and display component level conditions in order to improve maintainability of the AFCS system.

e. Ground Support Equipment (GSE). Fault isolation and maintenance equipment for the AFCS is outdated and will require replacement and/or upgrades to effectively extend the systems service life. This includes a transition to the OEM’s new depot level test equipment – ACES.

Estimated Period(s) Total Description of Efforts

Base and four options (Firm Fixed Price )

Non-recurring engineering and logistics efforts, hardware/software modifications, hardware/software acquisitions for complete AFCS improvements

(4) Identification of statutory authority permitting other than full and open competition.

The statutory authority permitting other than full and open competition is Title 10, United States Code §2304(c)(1) (10 U.S.C. § 2304(c)(1)) as implemented by the Federal Acquisition Regulation (FAR) §6.302-1 “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

(5) Demonstration That the Nature of the Acquisition Requires Use of the Authority Cited.

Through a competitive acquisition, the USCG selected the RCI AFCS to meet mission requirements as part of the original acquisition of the asset. RCI owns all data rights for the H-65 AFCS. In accordance with FAR 6.302- 1(a)(2)(iii), award to any other source would result in --

(A) Substantial duplication of cost to the Government that is not expected to be recovered through competition, (and)

(B) Unacceptable delays in fulfilling the agency’s requirements. (See 10 U.S.C. 2304(d)(1)(B) or 41 U.S.C.

253 (d)(1)(B).)

The service provided by RCI is highly specialized and they are the only vendor with access to the requisite drawings and technical data rights for the AFCS. Further, RCI provided notification on July 22, 2014 that they do not intend to provide such drawings and information to other sources. The USCG did not purchase the data rights for these components in the original AFCS procurement. As this is the last planned upgrade and service life extension of the AFCS, the purchase of data rights is not practicable or economical.

All AFCS components currently produced, with capabilities equivalent to the H-65’s system, use digital technology.

No other vendor produces form, fit, function components.

The H-65 is currently undergoing a significant upgrade (the MH-65E) to its avionics which is integrated with the legacy AFCS. To date, has been obligated to this upgrade. A change in the avionics architecture (to include software and navigational hardware) to allow for competition at this point would carry significant technical risk as the AFCS must operate seamlessly with the CAAS for proper operation of the aircraft. Further, the design changes and testing required, in the case of a redesign to accommodate a new AFCS system, would have significant schedule consequences (up to 2 years delay). Based on market research and the Independent Govt. Cost Estimate, the cost of a new avionics architecture (hardware and software changes) to accommodate a new AFCS combined with the cost of a new AFCS system would exceed when the required redesign of the nearly complete MH-65E avionics upgrade is fully considered. The aforementioned duplicated costs are not expected to be recovered via a competition, and the delay in filling the requirement would lead to decreased aircraft reliability, increased maintenance costs and mission failures.

The upgrade and service life extension of the current system through the OEM allows for significant cost savings in that it does not require replacement of the entire system. All components (except for the replacement AFCS control panel) will be re-used after repair or modification. The technology and engineering development process required to improve the reliability of the AFCS components originally manufactured by RCI is readily available. Therefore, in

(10) A Listing of the Sources, if Any That Expressed, in Writing, an Interest in the Acquisition.

Listed in item (6): RCI, .

(11) 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.

Per ALC instruction 4200.3A and the Spare Parts Breakout (SPBO) Program COMDTINST M4408.8, all flight critical items may only be procured through an OEM approved source or a vendor acceptable to ALC’s aircraft product line engineering cells. The SPBO Manager, located at the ALC, is the primary contact for companies that want to qualify to manufacture and/or repair parts for USCG aircrafts. 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.