J_and_A_for_Additional_3_Month_Extension_P00038_(Redacted).pdf

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

Integrated Maintenance, Operation, and Modification Support

Contract Number: HSCG38-12-C-410001

Pursuant to the requirements of the Competition in Contracting Act as implemented by Federal

Acquisition Regulation (FAR) 6.3 and in accordance with the requirements of FAR 6.303-1, the justification for the use of the statutory authority under FAR 6.3 is supported by the following facts and rationale required under FAR 6.303-2 as follows:

(1) Agency and Contracting Activity:

The United States Coast Guard (USCG), Aviation Logistics Center (ALC), Aviation Logistics

Division (ALD), Elizabeth City, North Carolina in support of the USCG Aviation Training

Center (ATC) located in Mobile, Alabama, proposes to enter into a modification to extend contract HSCG38-12-C-410001 on the basis of other than full and open competition.

(2) Nature and/or description of the action being approved:

The USCG, ALC, ALD seeks approval to award a contract based on other than full and open competition for the procurement of Integrated Maintenance, Operation, and Modification

Support (IMOMS) of flight simulators. Specifically, ATC utilizes operational flight trainers, cockpit procedure trainers, desktop part-task trainers, and an interoperable weapons trainer in order to qualify student aviators and aircrew annually through transition, qualification, re-qualification, and proficiency courses. These training devices, most of which employ stimulated aircraft avionics and cockpit components, require services outside the typical scope of a contractor operation and maintenance support contract. The IMOMS contract unifies operations, maintenance, supply management, in-service engineering, and modifications under a single contractor with experienced site personnel who are cross trained and supported by reach-back engineering, management and technical support capabilities.

The USCG intends to modify contract HSCG38-12-C-410001 by an extension in the period of performance by three (3) months. The USCG has been working on a follow-on contract and fully anticipated award prior to the expiration of the current contract extension. However, there have been delays due to unforeseeable circumstances. There have been inadequate personnel resources and numerous revisions to the technical requirements.

The modification value is estimated at $321K. FY 2019 Operating Expense funds will be utilized. These services are considered commercial in nature and will be procured using the procedures listed in FAR Part 12 and FAR Part 15.

The proposed contractor is:

Aero Simulation, Inc

4450 East Adamo Drive, Suite 501

Tampa, FL 33605-5941

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

Agency Requirements

(3) Description of supplies/services:

The ATC operates the largest virtual training center in the Department of Homeland Security with over $100M in virtual flight training infrastructure. ATC currently utilizes operational flight trainers, cockpit procedure trainers, desktop part-task trainers, and an interoperable weapons trainer in order to qualify over 700 student aviators and aircrew annually through transition, qualification, re-qualification, and proficiency courses. This requirement is for flight simulator operations, maintenance, supply management, engineering, and modification support at the fixed prices and hourly rates established in the contract. Operations include daily readiness tests, training event setup, and post event inspections. Maintenance includes preventive and unscheduled maintenance. Engineering modification support includes correction of discrepancy/deficiency reports and latent defects, cockpit configuration currency upgrades, technical refreshment, and service life extension upgrades. Engineering reach-back capabilities include design, development, integration, test, and support of aircraft cockpit components, aircraft systems, aircraft avionics (communications, navigation, and flight management), flight control systems, motion systems, visual display systems, visual database management, aerodynamic and ground reaction modeling, hardware and software engineering, technical documentation creation and modification, and cyber security. Services also include program management. ATC’s centralized flight training systems are vital to the USCG’s ability to execute its national security responsibilities. With a limited number of training devices and dedicated training aircraft, training system performance can have an immediate and adverse impact on student certifications and a deleterious effect on operational readiness. IMOMS ensures a high state of trainer readiness through agile, full-service contractor support.

The estimated total of this modification is $321K.

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

The statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c) (1) as implemented by the Federal Acquisition Regulation (FAR) 6.302-1 entitled “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:

In accordance with the authority cited, Aero Simulation, Inc. is the only responsible source and no other supplies or services will satisfy agency requirements because it will cause a disruption or lapse in flight simulator support services. Any disruption or lapse in services will cause a significant cost impact to the Government. The USCG has been working on a follow-on contract and fully anticipated award prior to the expiration of the current contract 3 month extension.

Due to inadequate personnel, resources, and numerous revisions to the technical requirements the follow-on package was delayed. The contract extension expires in October 2018, therefore the additional three (3) month extension is to support the timeframe needed to complete the follow-

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

Agency Requirements on contract. This extension is to ensure continued IMOMS support of flight simulators through the contract award period for the follow-on requirement based on the normal Procurement

Action Lead Time (PALT).

A lapse in contractual coverage will result in a significant cost impact to the Government as flight simulators are essential to qualifying student aviators and aircrew. A lapse in coverage, even for a brief period of time, would result in the following:

a) The USCG would revert to issuing a purchase order for on-site maintenance and modification tasking only. Having only on-site maintenance and modification tasking, ATC would not have hours to use if behind schedule or in need of off-site expertise which is essential to ensuring the flight trainers remain available for training purposes;

b) Low flight trainer readiness rates have the potential to create multi-year student backlogs, reduced pilot staffing at operational units and degrade aviation support capabilities to operational Commanders. To prevent a backlog in student aviator and aircrew training

ATC would have to pull operational aircraft out of service to be used at ATC for training purposes. This would require ATC Mobile to utilize one (1) HC-144, six (6) MH-65, and two (2) MH-60 operational aircraft to maintain current student training schedule. ATC would have to transition to an aircraft based training program which would require doubling the instructors at ATC;

c) ATC’s centralized flight training systems are vital to the USCG’s ability to execute its national security responsibilities. With a limited number of training devices and dedicated training aircraft, training system performance can have an immediate and adverse impact on student certifications and a deleterious effect on operational readiness. IMOMS ensures a high state of trainer readiness through agile, full-service contractor support.

ATC’s flight training systems represents the USCG’s most significant investment in flight safety and standardization;

d) Per Commandant Instruction COMDINST 3710, mandated annual proficiency courses required for every USCG aviator would be terminated. Annual burden for the instrument proficiency check would transfer to the operational Air Stations; and

e) All required IMOMS support would have to be negotiated under a purchase order or other contracts resulting in a lengthy award process.

The benefits to the Government are:

(1) The IMOMS contract unifies operations, maintenance, supply management, in-service engineering, and modifications under a single contractor with experienced site personnel who are cross trained and supported by reach-back engineering, management and technical support capabilities;

(2) If the USCG uses the operational aircraft to complete the trainings, it is estimated to cost three (3) times that of the current simulation based training;

(3) Simulators facilitate a two (2) to one (1) student to instructor ratio that minimizes ATC staffing and aircraft requirements;

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

Agency Requirements

(4) More importantly, flight trainers enable aircrews to practice maneuvers and emergencies otherwise deemed too risky to conduct in aircraft; and

(5) Continuity of mission readiness by having trained, qualified aviators and aircrew.

(6) A description of the efforts made to ensure that offers are solicited from as many potential sources as is practicable:

It is not practicable to solicit from any source other than Aero Simulation, Inc. The USCG, ALC, ALD is currently in the final stages of negotiating the IMOMS follow-on contract. This extension is to ensure continued IMOMS support of flight simulators through the contract award period for the follow-on requirement without disruption or lapse in services. Any disruption or lapse in contractual coverage will result in a significant cost impact to the Government.

(7) Determination by the Contracting Officer that the anticipated cost will be fair and reasonable:

The Contracting Officer anticipates that the prices for this procurement will be fair and reasonable based on a price analysis (FAR 15.404-1 (b)) utilizing a combination of price analysis techniques to include: comparison of proposed prices to historical prices paid (FAR 15.404-1

(b)(2)(ii)), comparison of proposed prices with government cost estimates (FAR 15.404-1

(b)(2)(v)), comparison of proposed prices with prices obtained through market research for similar items (FAR 15.404-1 (b)(2)(vi)).

(8) Description of the Market Research:

Market research was conducted in accordance with FAR Part 10 from November 2015 through

November 2016 for the follow-on requirement. Three small businesses with capabilities to fulfill the requirement were identified. A Special Notice was posted on the Federal Business

Opportunities (FBO) website on August 23, 2016 for an Industry Day which was conducted

September 20, 2016. Industry Day had five (5) participants. As such, the follow-on requirement is expected to be competitive.

(9) Any other facts supporting the use of other than full and open competition:

Although the industry shows adequate competition, it is in the best interest of the Government to issue a three (3) month extension to contract HSCG38-12-C-410001 to ensure that there is continuity for mission readiness.

(10) A listing of sources, if any that expressed, in writing, an interest in the acquisition:

None

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

Agency Requirements

(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 Required Supplies or

Services:

As stated in Paragraph five (5), a lapse in coverage, even for a brief period of time, would result in costly downtime of the training devices. The benefits to the Government to exercise the proposed three (3) month extension are:

(6) The IMOMS contract unifies operations, maintenance, supply management, in-service engineering, and modifications under a single contractor with experienced site personnel who are multi-disciplined, cross trained and supported by reach-back engineering, management and technical support capabilities;

(7) If the USCG uses the operational aircraft to complete the trainings, it is estimated to cost three (3) times that of the current simulation based training;

(8) Simulators facilitate a two (2) to one (1) student to instructor ratio that minimizes ATC staffing and aircraft requirements;

(9) More importantly, flight trainers enable aircrews to practice maneuvers and emergencies otherwise deemed too risky to conduct in aircraft; and

(10) Continuity of mission readiness by having trained, qualified aviators and aircrew.

The USCG, ALC, ALD solicited the follow-on IMOMS requirement through the government-wide point of entry Federal Business Opportunities website on a total small business set-aside basis. More than one offeror submitted a proposal in response to the solicitation and the USCG, ALC, ALD is currently in the final stages of negotiating the follow-on contract. This sole source contract extension is needed to provide continued uninterrupted support services until the follow-on contract is awarded.

Remainder of the Page Intentionally Left Blank

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

Agency Requirements

(12) 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.

Christian Broxterman Date

Program Manager

(13) Legal Review and Concurrence

I have reviewed this justification and deem it legally sufficient.

Legal Service Command CG-LSC-9E Date

Approval:

Catrina M. McDonald Date

Contracting Officer