ID09180060-J&A-Approved-Redacted.pdf

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FOR OFFICIAL USE ONLY

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL & OPEN COMPETITION

CLIENT ORDER ID: ID09180060

The U.S. General Services Administration (GSA) hereby makes this Justification and Approval (J&A) for Other Than Full and Open Competition pursuant to Federal Acquisition Regulation (FAR)

6.302 and in accordance with the format prescribed at FAR 6.303-2.

1. Identification of Agency and Contracting Activity:

Requiring Agency:

U.S. General Services Administration (GSA) Federal Acquisition Service (FAS) Assisted Acquisition Services (AAS)

Acting in support of:

Air National Guard Air Force Reserve Command Test Center (AATC) 1600 E Super Sabre Drive, Building 10 Tucson, AZ 85706-6081

Contracting Activity:

U.S. General Services Administration Federal Acquisition Service Contracting Division 50 United Nations Plaza 2nd Floor Suite 2430 San Francisco, CA 94102

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

This Justification and Approval (J&A) for other than full and open competition is made for the solicitation and award of a Cost Plus Fixed Fee (CPFF) bridge contract to support the Air National Guard Air Force Reserve Command Test Center (AATC). The bridge contract will provide the continuity of mission critical administrative, test and evaluation, and engineering services rendered under the current contract, which was competitively awarded under the Design Engineering Support Program (DESP) III contract. The period of performance will be one (1) year and will include FAR clause 52.217-8, Option to Extend Services, to allow up to an additional six (6) months of optional performance.

The effort will support test planning, test execution, test reporting, test logistics and studies/analysis for installations and integration on the following aircraft: A-10C, C-130H/J, F-15C/D, F-16C/D, C-17, KC-135, HH-60G, HC/MC-130, RC-26, MQ-9, Battlefield Airman (BA), as well as multiple cross-platform logistics and Electronic Warfare capabilities. In addition, support is required for program management, integration engineering, engineering liaison, and technology insertion to assist AATC and National Guard Bureau (NGB)/A5-8 with modernization of Air Reserve Component (ARC) weapons systems to include but not limited to Aircraft, Joint Terminal Area Controller (JTAC) and BA, Command, Control, Communications, Computers, Intelligence, Surveillance and Reconnaissance, Domestic Operations (DOMOPS), and Logistics programs. ARC modernization efforts require avionics, mechanical, and structural modifications to include, but not limited to, technical requirements definition, avionics integration, systems engineering, design engineering, test support, cost assessment and control, integrated logistics engineering, logistics, studies and analyses, prototype installations, program engineering coordination, test equipment, and technical documentation.

The current contract was awarded by the Department of Air Force, Directorate of Contracting. The procurement was a small business set-aside under the DESP III contract. Services are currently provided under Contract Number FA8222-12-D-0010, Delivery Order Number 0002, awarded to Gauss

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Management Research and Engineering, Inc. (GMRE) as a CPFF contract, with a period of performance from June 16, 2014 – January 9, 2019. In accordance with the terms and conditions of the DESP III contract, all DESP orders’ period of performance cannot go beyond the DESP III contract end date of January 10, 2019.

AATC is currently working with GSA to procure a long-term, competitive follow-on acquisition. However, the long-term effort requires additional market research to determine the most suitable contract vehicle and acquisition strategy for the follow-on acquisition. Continued support must be procured as a sole-source contract to meet mission requirements while allowing adequate time to award the follow-on acquisition. There is not sufficient time to conduct necessary market research and solicit, negotiate, and award the follow-on acquisition with an adequate phase-in period. Tentative milestones for the follow-on acquisition that justify the need for this interim sole-source contract are as follows:

Market Research Completed: March 26, 2019 Solicitation Issuance: June 24, 2019 Proposals Due: July 24, 2019 Evaluation: September 22, 2019 Award: November 21, 2019 Phase-in Period: November 22, 2019 – January 9, 2020

3. Description of Supplies/Services Required to Meet Agency’s Needs (Including Estimated Value):

This bridge contract will provide ongoing support for administrative, test and evaluation, and engineering services rendered under the current contract that is necessary to meet AATC’s mission requirements of providing test support of potential modifications or modernizations to ANG and AFRC weapon systems.

This sole source action is not for the direct acquisition of weapon systems and is authorized under GSAM 507.7001(a).

The following support is required:

- Program Management

- Administrative, Contract, Test Documentation, and Meeting Support

- Technical Test and Evaluation (T&E) Support to Integrate A-10C, C-130H/J, F-15C/D, F-16C/D, C-17, KC-135, HH-60G, HC/MC-130, RC-26, MQ-9 and BA Hardware and Software Avionics, Mechanical, and Structural Modifications

- Battlefield Airmen Tactics Development, Test Support, Operations, and Training

- Aircraft Maintenance Pro-Super Expertise

- System Administrators for computer systems supporting test and daily operations at AATC

- Data-Link and Advanced Communications Systems Expertise and Training Support

- KC-135 Simulator Certification Support

- Air Force Research Laboratory (AFRL) Liaison Support at Wright-Patterson Air Force Base (AFB), OH.

- Information Systems Security Officer (ISSO) Support

- Integration and Installation Support

Primary performance will take place at AATC in Tucson, Arizona. F-15 efforts will be conducted out of AATC’s F-15 detachment at Eglin Air Force Base (AFB), Florida. A-10C support will be at AATC facilities at Davis-Monthan AFB, AZ. KC-135 efforts will be managed at AATC facilities at Davis-Monthan AFB, AZ with testing conducted with the unit in Phoenix, AZ. C-130 efforts will be conducted at Little Rock, AR.

Performance will require the contractor to support testing on temporary bases when conducting test on ranges such as Edwards AFB, Eglin AFB, Point Mugu, Tyndall AFB, and land ranges near Nellis AFB and Hill AFB, and other locations as required to accomplish test activities.

The period of performance of the bridge contract is one (1) year and will include FAR clause 52.217-8, Option to Extend Services, to allow up to an additional six (6) months of optional performance. This extension clause would only be utilized in the event there are unanticipated delays during the procurement of the long-term follow-on acquisition.

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The total potential estimated value, including the 1-year period of performance and option to extend the services for up to 6 months (FAR 52.217-8), is Calculated separately, the estimated value of the 1-year period is and the 6-month period is

4. Identification of the Statutory Authority Permitting Other Than Full and Open Competition:

This acquisition will be conducted pursuant to the authority of 10 United States Code (U.S.C.) 2304(c)(1), as implemented by FAR 6.302-1, only one responsible source and no other supplies or services will satisfy agency requirements.

Pursuant to FAR 6.302-1(a)(2)(iii), for Department of Defense (DoD), National Aerospace National Aeronautics and Space Administration (NASA), and the Coast Guard, services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in unacceptable delays in fulfilling the agency requirements. (See 10 U.S.C. 2304(d)(1)(B))

5. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Requires Use of the Authority Cited:

Pursuant to FAR 6.302-1(a)(2)(iii)(B), the services described above are available only from the incumbent contractor. Award to any other source would result in unacceptable delays in fulfilling the AATC testing requirements. These services are available only from the original source that has the experience, technical and operational knowledge and resources immediately available to allow for continuation of highly specialized technical support services.

AATC testing demands have increased over the course of performance of the current contract and GMRE’s services are required to continue in order to ensure the ARC systems are updated and operationally ready for any and all contingencies as part of the Total Force (Air Force (AF) and ARC).

Over the past four (4) years, AATC has experienced a significant yearly growth rate. In the 4th Quarter of 2014, AATC had 19 active tests; 45 in 2016; and currently AATC has 109 approved projects with another 11 going through final approval. Current National Strategy relies heavily on ARC systems and personnel.

As a result, the demand on AATC by the National Guard Bureau and Major Commands (MAJCOMs) for modernization programs is consistently increasing and necessary for the defense of the nation. It is expected future demands will continue to increase as the ARC systems continue to age with only a few major system replacements in the pipeline. The mission of AATC is to test and provide recommendations on modernization/modification projects as directed by higher headquarters. With more projects being assigned to AATC, manpower must also increase to accomplish the tasks. Military, Civilian, and contractor manpower are all increasing each year to reflect this increase in workload.

AATC does not have capacity and manpower to provide ongoing support for the services provided under the current contract. The anticipated bridge contract will ensure uninterrupted test activity and operations impacting all AATC test responsibilities and activities and provide continued support for administrative, test and evaluation, and engineering services rendered under the current contract. A one-year bridge contract is the minimum amount time required to complete current testing requirements, adequately transition any incomplete testing requirements, and complete a competitive follow-on acquisition.

The current GMRE contract provides key technical and unique support to all AATC test projects by providing technical test and administrative support in all areas of AATC testing for all aircraft and systems that AATC supports. GMRE provides unique testing expertise to several projects associated with the C- 130 (all variants), KC-135, RC-26, HH-60, Battlefield Airman, F-15 and A-10 aircraft/systems. These aircraft/systems are currently used in threat environments around the world and require continuous upgrades to be mission ready and provide a safe platform for aircrews and personnel. Key test activities where only GMRE has the expertise, knowledge, and capacity to immediately support ANG’s requirements include:

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- C-130 Hard Mount upgrade and technical order finalization on the second test aircraft. One (1) of two (2) test aircraft are now complete through GMRE technical and engineering delivery. The second installation and technical finalization would take years by another contractor and delay C-130 Single Pass Precision Airdrop (SPPAD) delivery.

- Completion of the C-130 3.5 Series Engines, NP2000 Propellers, Electronic Propeller Control System (EPCS) and Tactical Airlift Mission Software Suite (TAMSS) version 3.0 test completion and final report.

GMRE is providing test conduct, and analysis at this time. Delivery of these key capabilities will be delayed if GMRE support is interrupted.

- C-130 Improved Modular Airborne Fire Fighting System (I-MAFFS), the C-130J Aerial Reconnaissance Weather Officer hardware/software upgrade, the C-130 TAMSS v4.0, and the KC-135 aircraft & aircrew ground cooling are all in the test planning phase. Interruption of these projects will cause the C-130 critical program modernizations projects to be delayed resulting in less capable aircraft in the operational field.

- GMRE is providing key personnel with expertise in standing up the C-130 AATC Operating Location at Little Rock, AR in 2019. The lack of this support will cause delays in standup and potential delays in all C- 130 test operations.

- KC-135 Large Aircraft Infrared Countermeasures (LAIRCM), and LED Landing/Taxi Lights modernization fielding will be delayed without GMRE engineering and reporting expertise since these two

(2) projects are in the analysis and reporting stage but will not be done by the end of the current contract.

- GMRE personnel have been leading the RC-26 aircraft upgrade. This key Intelligence, Surveillance, and Reconnaissance (ISR) aircraft upgrade will be set back if the engineering and acquisition support provided by GMRE is lost.

- Combat Search and Rescue (CSAR) projects including HH-60/HC-130J Joint Mission Planning System (JMPS), EC/HC-130J Link 16 Multi-functional Information Distribution System – Joint Tactical Radio System (MIDS-JTRS), and HH-60 Personnel Recovery Situational Awareness (PRSA) efforts will be delayed without key GMRE subject matter expertise.

- A-10 test maintenance, project management, and flight testing activities for the Jam-Resistant Global Positioning System (GPS), 3D Audio, Hybrid Optical-based Inertial Tracker (HObIT), and parking brake projects will be at risk without the GMRE support.

GMRE is the only source capable of providing these services without unacceptable delays in satisfying AATC’s requirements. GMRE project managers, test maintenance personnel, network system administrators, liaison, and test executors, are critical for AATC success. GMRE provides a unique capability and niche in testing any other companies could not immediately fill given the engineering, test experience, aircraft knowledge and current project immersion that GMRE uniquely possesses. GMRE is a small business that has focused on these capabilities creating a unique dependence by AATC on their expertise to accomplish the assigned projects in the tight timelines demanded by ANG and Air Force Reserve Command (AFRC) and the threat environment. The current GMRE staff is qualified to immediately provide the AATC required ongoing services as they are already performing all the current task areas. They have specialized knowledge and expertise on the discrete nuances of current existing testing efforts, due to their extensive prior experience as the incumbent providing support and services on the current 4.5 year contract effort.

Using any other source without an adequate transition period would cause an unacceptable delay in modernization efforts, affecting nearly half of all Total Force aircraft, which could put aircrews and platforms at risk in the ever changing threat environment and potentially create unacceptable safety risk and hazard to human life. It would also cause significant delays to efforts already in progress that enable key capabilities that increase the overall effectiveness of the Total Force, as noted in all the projects listed above. These are some of, but not the only, critical requirements of the ANG and AFRC, as dictated by the staff organizations. Additionally, the current contract provides critical administrative support to the overall mission of AATC, and the loss of this support would create significant shortfalls in manpower to complete the core test mission of AATC, which ensures the previously stated requirements are met.

The proposed bridge contract will allow for the continuity of mission critical services that is absolutely necessary to fulfill AATC’s mission, while the Government conducts a competition for a longer term solution. The bridge contract will allow for an adequate transition period so that another vendor can

ID09180060- J&A Page 5 of 7 become proficient on existing developments. Due to their extensive knowledge and prior experience working on AATC requirements, it is in the Government’s best interest to continue services from the incumbent.

6. Description of Efforts Made to Ensure that Offers are Solicited From as Many Potential Sources as Practicable, Including Whether a Notice Was Publicized as required by FAR Subpart 5.2:

As required by FAR Part 5.201, on September 25, 2018, the Contracting Officer published a synopsis on the FedBizOpps (FBO) website stating the Government’s intent to solicit, negotiate, and award a sole source acquisition. The notice included a statement that all interested responsible sources may submit a capability statement which shall be considered by the agency. To date, the Contracting Officer has not received any statements of interest regarding the proposed sole source effort.

7. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable:

In accordance with FAR 15.402, the Contracting Officer shall ensure that all services and supplies provided under this contract are procured at a fair and reasonable price. The cognizant Defense Contract Audit Agency/Defense Contract Management Agency (DCMA) offices will be contacted for rate recommendation, adequacy of accounting systems, and any other information required. The contractor will submit a formal cost proposal with certified cost and pricing data and sufficient information to support the accuracy and reliability of the proposed costs. To ensure that the proposed costs to the Government will be fair and reasonable, the Contracting Officer will evaluate the cost elements and fixed fee of GMRE’s proposed costs to ensure that the costs are fair and reasonable. An Independent Government Cost Estimate (IGCE) has been developed for this effort and is based upon the labor categories and hours of the current contract. The IGCE will also be used as a factor for the price analysis.

8. Description of the Market Research Conducted and the Results or a Statement of the Reason Market Research was not Conducted:

Market research was conducted to determine small business capability under the open market for the required services. A Request for Information (RFI) was issued with two (2) attempts to determine small business capability under North American Industry Classification System (NAICS) code 541330, Engineering Services, Exception A, Military and Aerospace Equipment and Military Weapons. A total of 10 responses were received from both attempts. The RFI results revealed that the incumbent contractor is the only fully qualified respondent. As a result, an interim bridge contract is required for continued performance of mission critical services to allow the Government sufficient time to conduct additional market research to determine the most suitable contract vehicle and acquisition strategy for the competitive follow-on acquisition, and solicit, negotiate, and award the competitive follow-on acquisition with an adequate phase-in period.

9. Other Facts Supporting the Use of Other Than Full and Open Competition:

AATC supports full and open competition but initial responses from small businesses did not identify additional potential sources that would meet the minimum requirements. Additional market research is necessary to ensure a proper full and open competition can be conducted with the best interest of the Government in mind. The current contractor providing this support (GMRE) is extremely capable and has filled these requirements successfully over the past four and a half years with outstanding expertise.

During future market research efforts, AATC may need to increase the breadth of competition and consider medium or large companies to ensure qualified companies are included.

10. Listing of the Sources, if any, That Expressed, In Writing, An Interest in the Acquisition

As indicated in Section 6 above, the proposed sole source effort was synopsized on the FBO website as required by FAR 5.201. To date, the Contracting Officer has not received any statements of interest regarding the proposed sole source effort.

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11. Statement of the Actions, if Any, the Agency May Take to Remove or Overcome Any Barriers to Competition Before Any Subsequent Acquisition for the Supplies or Services Required:

This sole source action serves as an interim solution in order to provide the continuity of mission critical services until a new procurement can be properly competed and awarded with an adequate transition period. The performance period is limited to one (1) year, which is the minimum amount of time required to complete a competitive, long term contract based on the dollar value and complexity of the requirement. The interim bridge contract will include FAR clause 52.217-8, Option to Extend Services, to allow up to an additional six (6) months of services in the event there are unanticipated delays during the procurement of the competitive long-term follow-on acquisition.

The Government intends to fully compete the new procurement under the most suitable contract vehicle based on the results of the additional market research that will be performed.

Actions that the Government may take to remove or overcome barriers to competition include the following: holding an industry day, issuing a RFI for unrestricted competition (the RFI will include a Question and Answer (Q&A) period), and contacting DESP III contract holders.

12. Contracting Officer’s Certification

I hereby certify that the facts and representation under my cognizance which are included in this justification document and which form a basis for this justification are accurate and complete to the best of my knowledge and belief.

LYNDA LUO Date Contract Specialist Contracting Division Federal Acquisition Service U.S. General Services Administration

KARINA R. LEVITAS Date Contracting Officer Contracting Division Federal Acquisition Service U.S. General Services Administration