ID08200037 -Limited Source Justification for Bridge Signed.pdf

LIMITED SOURCE JUSTIFICATION

FOR BRIDGE CONTRACT TO SUPPORT COMPETTIVE EFFORT

PROJECT ID08200037

1) Identification of Agency :

Agency:

General Services Administration (GSA) Region 08, Federal Acquisition Service Acting in support of: United States Marine Corp (USMC) New River MCAS

2) Nature and/or Description of Action Being Approved:

GSA FAS requests approval to award a bridge contract for Contractor Maintenance Support (CMS). The USMC’s current contract for the MV-22 Contractor Maintenance Support (CMS) services at New River, NC is under an automatic stay in response to Government Accountability Office (GAO) protest, effective May 12, 2020. Due to time constraints that could not be overcome, GSA is unable to responsibly award a competitive action at this time. A bridge contract needs to be awarded in order to prevent further lapse in service. The previous contract has since expired and a new bridge contract to the currently performing contractor is the only way to ensure continuity of services.

The bridge contract will be a limited source task order award to GSA Schedule contractor LOGMET LLC., a Service- Disabled Veteran-Owned Small Business (SDVOSB). It will be a time and material (T&M) contract.

3) A Description of Supplies/Services Required to Meet Agency’s Need:

The USMC VMMT-204 squadron is the only military unit providing support aircraft readiness for the training of Department of Defense (DoD) and Foreign Military Sales (FMS) pilots on the V-22 Osprey tiltrotor aircraft. The V-22 is the basic aircraft model. Service specific variances account for the different nomenclature, such as, MV-22 (Marine Corps) and CMV-22B (Navy). The only way to provide the necessary level of readiness for the training program is through Contractor Maintenance Support (CMS) services. Specifically, the CMS provides maintenance for 31 MV-22 aircraft, which are used by not only the USMC, but all of the other services, as well, for pilot training.

The 31 MV-22 aircraft being maintained account for approximately three MV-22 squadrons, requiring significant maintenance man-hours. (The only day when there is not 24 hours of on-going maintenance work is Sunday.) Government maintainers cover some of the manpower for a 12 hour daily shift during the week, all other shifts are covered exclusively by CMS. Aircraft maintenance support for the MV-22 Osprey at MCAS requires highly skilled and certified maintainers to ensure aircraft availability for pilot training hours. This contract sustains a single point of failure for all V-22 aircraft pilot training for the Marine Corps, the Air Force, the Navy, and Japan Defense Force personnel. The scope of supported entities spans across the globe and facilitates pilot replenishment to support real world operations across the DoD and to establish a pilot training and maintenance effort for Japan FMS aircraft. Short term delays in pilot production will have multi-year effects on pilot population sustainment if CMS production is stopped, even for a brief period of time.

The USMC itself does not have enough trained airframe mechanics, flight-line mechanics, electrical/avionics mechanics, system support specialists, supply technicians, and logs and records technicians to support O-Level scheduled and unscheduled maintenance on aircraft. The government needs this CMS support to perform troubleshooting, inspections, corrosion prevention/treatment, servicing, lubricating, adjusting and the removal and replacement of aeronautical components. Since the Government does not have enough personnel of its own the government needs CMS personnel to augment USMC maintenance personnel at the squadron in order to keep maintenance activities going at satisfactory performance levels.

The period of performance for the bridge contract will consist of a one month base period commencing May 19, 2020, followed by two optional one month periods should the government need the full 100 days that the GAO receives to issue a recommendation.

This performance term is the minimal amount of time needed in order to minimize any lapse in service and allow for the responsible completion of a competitive contract action.

The estimated price for each 1 month period is $825,252.92 for a total estimated price of $2,556,758.76.

4) Authority and supporting rationale and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service:

This limited source justification is using the authority at FAR 8.405-6(a)(1)(A) an urgent and compelling need exists, and following the procedures would result in unacceptable delays.

While this contract is specifically for the USMC, the impact of a lapse in service is much broader than just the USMC. Specifically, as stated above, the MV-22 aircraft located at the VMMT-204 training location are used for all DoD pilot training required to operate the V-22 or its variances. The V-22 is a joint service, multi-mission aircraft with vertical take-off and landing (VTOL) capability. It performs VTOL missions as effectively as a conventional helicopter while also having the long-range cruise abilities of a twin turboprop aircraft. The versatility of the V-22 makes it equipped for a number of critical mission areas for the military, specifically, as an assault transport for troops, equipment and supply being deployed from ships, or for expeditionary airfields ashore. Specific impacts are as follows:

For the MV-22, the USMC relies on these versatile aircraft to allow for the forward deployment of multiple squadrons, upon a moment’s notice. The Marine Corps’ MV- 22 community supports Marine Expeditionary Units (MEUs) that cover various regions around the globe, as well as deployments providing various support in the US- CENTCOM region, Africa, Japan, and Australia. Marine Corps pilots trained at VMMT- 204 will be sent around the world to fill a myriad of positions, attaching the pilots to specific units scheduled to support deployments in various theaters during this fiscal year.

The Air Force CV-22 community provides the main foundation in US Special Operation assignments across the globe. A much smaller community than the Marine Corps, Air Force CV-22 pilot training delays will be felt immediately and support shortfalls to US Special Operations assault support deployments will result. Pilots trained at VMMT-204 this fiscal year are needed to deploy in support of these assignments within the next 12 months.

The Navy is currently standing up their initial CMV-22 squadron with pilots trained at VMMT-204. Their deadline for training completion is August 2020 and the Navy’s first CMV-22 deployment is scheduled for early 2021. The CMV-22B for the Navy provides combat search and rescue, delivery and retrieval of special warfare teams, along with fleet logistic support transport. If the MV-22 aircraft are not continuously maintained, the ability of the Navy to satisfy its mission will be negatively impacted.

Specifically, a stay of performance in CMS to support maintaining squadron aircraft will irrefutably delay squadron stand-up and subsequent initial deployments in Navy V-22 operations.

The full requirement to meet operational need is to provide 96 Marine pilots, 26 Air Force pilots, 22 Navy pilots, and 10 Japanese Defense Force pilots this fiscal year. If the aircraft are not continuously maintained, provision of the required number of pilots will be impossible.

VMMT-204 heavily relies on CMS to support the squadron’s mission. The USMC relies on the CMS support to train incoming military maintainers as part of the requirement.

The Marine Corps generally sends qualified military maintenance personnel to deploying units to support Strategic Objectives; the strength of the CMS contract is that they retain a core amount of qualifications to support the bulk of the maintenance effort at home.

Accordingly, the CMS mission is even more vital in maintaining the required aircraft because of the lack of available military maintenance personnel. The loss of CMS personnel for any amount of time will cause VMMT-204 to be limited to 12 hours of maintenance capability per day. With CMS, the maintenance crew functions 24 hours/day, 6 days a week, with an additional 8 hours Saturday. Depending on the length of the delay, this reduction in capability would eventually cripple the MV-22 community and negatively impact their ability to provide assault support to the Marine Corps and Joint operations community as a whole. Estimated minimum impacts are identified below:

-Reduced maintenance capability will reduce flight events by 60 each week (half of required production).

-Any delay in CMS production will be increased by a minimum of 3 weeks, as new personnel, after the work stoppage, must go through the required training pursuant to the Commander, Naval Aviation Instruction (COMNAVAIRINST) 4790.2C Naval Aviation Maintenance Program (NAMP) (4790.2C) because of the turnover and loss of personnel expected.

-In two weeks without CMS, reduced production will cut the trained pilots for this Fiscal Year (FY) by 3.

-At one month (4 weeks) with a halt in production, the estimate is that trained pilots needed for this FY will be reduced by 12 (half of what is required by a single squadron).

-By 3 months (12 weeks), FY trained pilots would be reduced by 36 (nearly two entire squadrons).

The training that VMMT-204 provides to MV-22 pilots directly relates to supporting troops in the field across the globe. The failure to provide replacement pilots for squadrons going through deployment cycles and natural attrition of personnel would cause impacts after only two weeks of lost support. At 12 weeks, nearly 25% of the necessary pilots for this FY would be impacted and the mission would be severely undermined for upwards of two years to recover the lost schedule of pilot training. The effect on national security would be acute.

Additionally, the squadron’s FY 22 requirement for CMS FTE is anticipated to increase.

It has historically proven difficult to recover a deficit of more than 10 contractor employees, usually taking roughly a month with hiring and training new personnel, plus simultaneously encountering general company workforce attrition. By stopping production and affecting the current work force, the CMS for VMMT-204 would, as a best guess, lose approximately 25 percent of its current work force by the time the stay was lifted. This severe personnel shortage will place both the contractor and the squadron severely behind schedule with it taking upwards of 6-9 months to stabilize and recover from the negative impact. All of this, in turn, would ultimately negatively affect the mission and necessary support to troops in the field across the Joint DoD community, as well as limit the ability of the MV-22 pilots to accomplish their missions.

5) A Determination by the ordering activity contracting officer that the order represents the best value consistent with 8.404(d):

A competitive best value award determination has recently been made for this requirement with competitive pricing and past performance. Best value was determined in accordance with the solicitation, per the RFQ, “Award will be made upon the basis of best value, utilizing trade-offs of non-price factors and price" and that "Past Performance is significantly more important than price." LOGMET, the currently performing contractor was determined to be the best value to the Government. LOGMET will honor their recently competed rates for the work described in this bridge contract. The rates quoted did not exceed the rates on schedule that have been determined to be fair and reasonable. Based on the above facts, the order is determined to be the best value to the Government.

6) A Description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted:

This bridge contract will maintain continuity of operations until the GAO is able to issue a recommendation.

Based on Market Research, no source other than the currently performing contractor will be able to meet the Government’s requirement for performance of these services beginning on May 19, 2020.

This bridge contract is being put in place only for the shortest amount of time necessary in order for the government to responsibly respond to the GAO recommendation.

Competition has already been provided for and if the GAO recommendation is to continue performance a contract is in place to provide performance. If GAO recommends reevaluation or a new solicitation competition will be provided for in this way as well.

Market Research included an initial Request For Information (RFI) which received seven responses from small businesses. Therefore, it was determined that two or more quotes would be and were received. The Request for Quotation (RFQ) for the competitive action was released March 13, 2020 via the GSA LOGWORLD schedule. Order was awarded to LOGMET on April 30, 2020 with performance starting on May 2, 2020.

7) Any other facts supporting the justificaiton:

The currently performing contractor is determined to be the only responsible source that is able to maintain organizational maintenance responsibilities within the required timeframe, preventing further lapse in service. The currently performing contractor has the expertise, installation access and current staffing capability with no transition time needed to continue operation until the GAO issues a recommendation. If the operation experiences any further lapse in service there will be unacceptable delays in the pilot training program causing pilot training quotas to be missed. This leaves the customer with an insufficient number of mission trained pilots.

8) A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers that led to the restricted consideration before any subsequent acquisition of the supplies or services is made:

For this bridge effort, limited market research has been conducted. Based on the acquisition team’s experience with previously awarded contracts for aircraft maintenance in support of the USMC, they are aware that even a fully qualified company could not hire staff and obtain base access before May 19, 2020.

Market research has been conducted for the awarded contract that is currently under protest. Market research has shown aircraft maintenance services are a commercial service. Seven vendors replied to a Request for Information with two having MV22 related experience indicating competition for this requirement. This was confirmed with a competitive award being made on April 30, 2020. Based on the market research only the currently performing contractor would be able to responsibly perform on May 19, 2020 which would cause unacceptable delays in meeting the Government’s requirement.

There are no barriers to competition as this action was released March 13, 2020 via the GSA LOGWORLD schedule providing fair opportunity to all schedule holders. This limit source justification is only necessary due to the stay of performance in response to a timely GAO protest.

9) Contracting Officer Certification that the Justification is Accurate and Complete to the Best of the Contracting Officer’s Knowledge and Belief:

I certify that this justification is accurate and complete to the best of my knowledge and belief, and I determine on the basis of the findings above that a sole source approach is in accordance with the requirements and is in the best interest of the Government.

David Shamburger

__05/18/20________ Date

Contracting Officer

GSA/FAS/R8

10) Certification by the technical requirements personnel that supporting data and rationale which form a basis for the justification have been certified as complete and accurate I certify that this justification is accurate and complete to the best of my knowledge and belief.

Captain Gary Boggs Date Assistant Aircraft Maintenance Officer

USMC VMMT-204

11) Final Approval

I determine that circumstances under FAR 8.405(a)(1)(A) apply to this justification.

Penny Grout Date Competition Advocate

GSA/FAS/R8

DAVID SHAMBURGER Digitally signed by DAVID SHAMBURGER Date: 2020.05.18 15:12:18 -06'00'

5/18/20