J_A - 30mm SRDT Kits_Redacted (3).pdf

Control Number: 2025-062

JUNE 2025

JUSTIFICATION REVIEW DOCUMENT

FAR Part 6 Justification and Approval for Other than Full and Open Competition

Program/Equipment: 30mm Stryker Reconfigurable Desktop Trainer (SRDT) Kits in support of Program Executive Office Ground Combat Systems Project Manager (PM) Stryker Brigade Combat Team (SBCT).

Authority: Title 10 United States Code §3204(a)(1) as implemented in Federal Acquisition Regulation (FAR) 6.302-1(a)(2)(iii)(B), Unacceptable delays in fulfilling the agency’s requirements.

Amount: $754,000

Prepared by: Katie Ordakowski Phone: 571 588-8928

Contract Specialist Date: 10 JUL 2025 E-mail: katie.e.ordakowski.civ2army.mil

Contracting Officer: Marta Furman Phone: 571 588-9101

Contracting Officer Date: 14 JUL 2025 E-mail: marta.furman.civ2army.mil

Technical: Michael J Gammon Phone: 586 215-7359

Stryker Fielding and Fleet Management Date: 14 JUL 2025 E-mail: michael.j.gammon2.civ@army.mil

Requirements: Lawrence Shell Phone: 520 673-9245

Program Officer (Acquisition) Date: 14 JUL 2025 E-mail: lawrence.r.shell2.civ@army.mil

FAR Part 6 Justification and Approval

OPSEC

TOTAL: $753,602.14

5. Authority Cited: The statutory authority permitting other than full and open competition is 10 United States Code Section 3204(a)(1) as implemented by Federal Acquisition Regulation (FAR) 6.302-1(a)(2)(ii)(B), “Only one responsible source and no other supplies or services will satisfy agency requirements.” Specifically, FAR 6.302- 1(a)(2)(ii)(B) which states “Supplies may be deemed to be available only from the original source in the case of a follow-on contract for the continued development or production of a major system or highly specialized equipment, including major components thereof, when it is likely that award to any other source would result in- (B) Unacceptable delays in fulfilling the agency’s requirements.”

Following a competitive acquisition process, the delay would be approximately 24 months.

6. Reason for Authority Cited: Award of this action on a sole source basis is necessary as the requirement cannot be procured from sources other than InVeris without unacceptable delays. The United States Government (USG) does not have the necessary intellectual property data rights to the pertinent 30mm SRDT Kit Technical Data Package (TDP) and SRDT software to enable competitive re-procurement. As of 17 June 2025, InVeris retains exclusive ownership of the SRDT software data rights.

The USG reached out to InVeris on 10 June 2025 with a request to procure or license the TDP for the 30mm SRDT Kits, which contains the intellectual property and technical data required for competitive sourcing. InVeris declined the USG’s request on 17 June 2025. As such, InVeris is the only source capable of providing the 30mm SRDT Kits described herein without unacceptable delays affecting the immediate training needs of the Stryker Brigades.

a. Background: Initially, the intention of the United States Army was to integrate and deploy the Stryker embedded training system in all Stryker platforms. The embedded training system (or embedded software) directly interacts with vehicle hardware to enable specific training tasks and will become the sole method for “Gate to Live Fire” training. To ensure NET instructors’ proficiency in operating the embedded training systems within the DVH and DVHA1 Stryker platforms, it was determined that embedded training systems must include emerging weapons capabilities such as the CROWS-J and 30mm training software. Initial assessments indicated the CROWS-J embedded training system was fully functional. However, post-delivery of the embedded software, integration efforts revealed deficiencies within the software itself that impeded successful implementation within the Stryker platform. Further analysis indicated these shortfalls required remediation to achieve full system compatibility. These shortfalls not only affected full functionality of the CROWS-J embedded software, but also impacted as the 30mm embedded software.

OPSEC

c. Impact if not approved: Disapproval of this justification is not a viable option due to schedule risks associated with a competitive acquisition. Specifically, the unacceptable delay and resulting harm to operational readiness far outweigh any perceived benefits resulting from a competitive acquisition. Approving this sole-source justification ensures the timely delivery of this critical capability and maintains the combat effectiveness of our forces.

7. Efforts to Obtain Competition: Market research revealed that only InVeris possesses the unique expertise, proprietary knowledge of the SRDT’s software, and established integration necessary to provide the required follow-on kits without unacceptable disruption to critical PM SBCT operations.

a. Effective competition: The Government will not compete this effort for the reasons stated Section 6 above. Notices required by FAR 5.201 shall be published, and any bids or proposals received shall be considered

b. Subcontracting competition: In accordance with FAR 19.702, a Small Business Subcontracting Plan is required. The solicitation will include FAR clauses 52.219-8, Utilization of Small Business Concerns and FAR 52.219-9, Small Business Subcontracting Plan. The Small Business Plan will be subject to Department of Defense small business subcontracting goals.

8. Actions to Increase Competition: If an additional requirement for 30mm SRDT kits arises, the USG will continue to survey the marketplace along with continuing efforts to obtain a Specifically Negotiated License to the 30mm SRDT kits TDP and SRDT software with rights sufficient for competitive procurement. Any information received will be considered to determine if a competitive acquisition should be conducted for potential future requirements.

A transition to a competed embedded training system remains the planned path to increased competition. However, an embedded training system will not be ready for competition until at least Fiscal Year 2032. Recognizing the continued sole-source reliance for the follow-on kits, the USG is actively conducting Market surveillance to mitigate barriers to future competition. This includes exploring emerging technologies and potential alternative vendors capable of providing similar capabilities.

9. Market Research: In accordance with Defense Federal Acquisition Regulation Supplement Procedures, Guidance, and Information 206.303-2, PM-SBCT and ACC- DTA issued a Source Sought Notice through Sam.gov on 7 May 2025, with a response date of 23 May 2025. The Sources Sought intent was to solicit interest, acquire, and assess the capabilities of interested vendors. The Sources Sought Notice included questions related to development and/or manufacturing experience, monthly production rate, quality control measures, and other relevant experience. At the closing date, five

(5) responses were received from the following vendors:

InVeris: A response was received from the current manufacturer, InVeris, on 12 May 2025. InVeris confirmed full production capability of the 30mm SRDT Kit, indicating a strong fit as this directly addresses a critical requirement for interim training support.

Rafael Advanced Defense Systems (Rafael): A response was received from Rafael on 22 May 2025. The respondent indicated capacity solely for the manufacture of the MCWS Control Grips, a component of the overall system, demonstrating a lack of capability to deliver a complete and integrated solution.

ADS, Inc.: A response was received from ADS Inc. on 22 May 2025. The respondent expressed the ability to manufacture a comparable system, but did not offer a solution independent of access to the SRDT TDP, highlighting a critical dependency on InVeris-owned technical data in order to produce the 30mm SRDT extension kits.

Even with the full SRDT TDP, ADS still could not make the deadline.

OT Training Solutions: A response was received from OT Training Solutions on 22 May 2025. The respondent expressed the ability to manufacture a comparable system, but did not offer a solution independent of access to the SRDT TDP, highlighting a critical dependency on InVeris-owned technical data, given their existing partnership with InVeris for system production. Although they have an existing partnership, this vendor could not make the critical deadline on their own.

BHPE LLC: A response was received from BHPE LLC on 20 May 2025. The respondent provided an incomplete response, directing respondents to their website without addressing the specific RFI questions, and therefore failed to provide the necessary information for a proper evaluation.

A thorough market assessment identified multiple vendors with related production capabilities. However, all responses except the current manufacturer’s indicated significant schedule delays would be incurred due to requirements for additional technical data, collaborative partnerships, or access to proprietary information. While not explicitly stating a dependency on the SRDT TDP and software, these responses collectively highlight the substantial delays associated with competing this 30mm SRDT Kit requirement. The inability to immediately produce the kits without the TDP underscores the critical risk to program schedule. Additionally, FAR subpart 10.002 recommends researching if the existing need can be met by a commercial item. Thus, between 5 May 2025 and 5 June 2025, the Contract Specialist performed several internet searches to evaluate the possibility of a commercial marketplace equivalent for the 30mm SRDT Kits. After thorough inquiries using the part number, National Stock Number, and nomenclature, no conclusive results were obtained through websites such as GSA Advantage, UNICOR, FedLog, and Ability One. Through a Google search, the Contract Specialist did not find any accurately matching results to the part numbers provided by the original vendor.

10. Interested Sources: To date, besides the sources mentioned above in Section 9, no other sources have written to express an interest in, or are believed to be capable of, supplying the 30mm SRDT kits to suitable fit, form, and function.

11. Other Facts:

a. Procurement history:

1. InVeris supplied SRDTs under an Undefinitized Contractual Action (UCA)

W56HZV-22-C-0054 awarded on 6 September, 2022. This UCA initially required a quantity of 53 EA, but was definitized on 18 January 2023 for a quantity of 26 EA at total value of $591,731.75.

2. Sole source

3. This acquisition of the SRDT was justified under the authority of Federal

Acquisition Regulation (FAR) 6.302-1(a)(2)(ii)(B), unacceptable delays in fulfilling the agency’s requirements.

4. Not applicable, previous action was sole source.

5. Not applicable, no unusual patterns revealed.

6. Not applicable, no protests.

b. Other facts: Not applicable.