J-A C-5 NLG Shift Clutch Assy-REDACTED_FINAL.pdf

Justification and Approval (J&A) for Other Than Full and Open Competition

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I. Contracting Activity.

United States Air Force

OL:H/PZABB

6050 Gum Lane, Bldg 1215 Hill AFB, UT 84056-5825

PR Number: FD20201800612

II. Nature and/or description of the action being processed.

A. Upon approval to use other than full and open competition procedures, the Air Force will issue a new, non-commercial, requirements repair contract to procure the repair of the C-5 Nose Landing Gear (NLG) Shift Clutch Assembly.

Contract will be awarded to: TRIUMPH GEAR SYSTEMS 6125 Silver Creek Dr Park City, UT 84098 Cage: 82402

B. The estimated dollar value is A Firm Fixed Price (FFP) pricing arrangement is anticipated. The estimated award date is 18 Mar 2019. The ordering period for this requirement contract will be 18 Mar 2019 through 31 Mar 2024 with an estimated delivery schedule that extends through 31 Dec 2024.

C. Individual

III. Description of supplies/services required to meet agency needs.

A. This is a new requirements repair contract for the repair of the C-5 NLG Shift Clutch Assembly, NSN 1620-01-036-4315 (PN 42292E8). These assets are used for the C-5 program by the US Air Force. This assembly functions as the speed control shifting device during NLG kneeling and retraction. The clutch assembly consists of a clutch, pressure shaft, plate, clutch plate retainer and stationary and rotating discs. The repair will follow the processes and procedures outlined in Technical Order 16G1-158-3.

B. The Air Force estimated unit repair and obsolescence cost and quantities for five years are shown below:

Line Item NSN 5 Yr Qty Cost Est (EA) Total

0001 NLG Shift Clutch Assy 1620-01-036-4315 25 ea

C. Total Estimated Cost is The estimated price is based on quote for 9ea from Triumph from 02 Feb 2018.

The contracting action will use 4930 CSAG-S Working Capital funds.

D. Approval is requested for more than one fiscal year. The government will annually request to purchase data rights necessary to repair this asset from the OEM during the period of performance.

IV. Statutory authority permitting other than full and open competition.

10 USC 2304(c)(1), as implemented by the Federal Acquisition Regulation FAR 6.302-1(a)(2)(iii), Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

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V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

A. The above authority was selected because the requirement is for repair of highly specialized assets whose design data is currently limited to the OEM (Triumph Gear Systems). The C-5 NLG Shift Clutch Assembly is considered highly specialized because the geometry, materials, function and processing requirements are specific to the C-5 landing gear system. If incorrect materials or processes are used for repair, the assets will become ineffective and unreliable causing potential safety hazards on the aircraft. Therefore this is for the repair of highly specialized assets.

B. The Air Force does not control the design nor possess the data required to repair the C-5 NLG Shift Clutch Assembly.

The 417 SCMS/GUMC team contacted Triumph Gear Systems on 02 Feb 2018 regarding the purchase of data rights on NSN 1620-01-036-4315, P/N 42292E8. Triumph is the OEM and owns the technical data to repair the Clutch Assy and is unwilling to sell or provide data rights for government use in organic repair, or give the government the use of the data for competitive purposes.

C. The C-5 Actuating Mechanism Design Specification (DS) DS41051 requires the entire NLG actuating system to be redesigned and qualified as an entire system which excludes a singular component of the mechanism such as the C-5 NLG Shift Clutch Assembly from reverse engineering possibilities. The DS also requires the NLG actuation system to complete a full environmental qualification with a corresponding flight test program. The cost of the redesign including a flight test is expected to exceed . Therefore, the time and cost associated with seeking another source is prohibitive.

D. Accordingly, Triumph Gear is the only firm capable of providing the repair services described in Section III above without the U.S. Air Force experiencing substantial duplication of cost that could not be expected to be recovered through competition and unacceptable delays in fulfilling its requirements.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

A. A Sources Sought Synopsis (SSS) FA8203-18-R-C5SCA was posted to FedBizOpps.gov on 18 Oct 2018 and closed on 02 Nov 2018. No responses were received. The 417 SCMS EN contacted Triumph Gear Systems who said they didn't respond to the SSS because they knew they controlled the design documents and were the only qualified source of repair.

B. Synopsis - this requirement will be synopsized in http://www.FedBizOpps.gov as a notice of proposed contract action IAW

FAR 5.201.

C. Other Actions - None

D. Qualifying Country Sources - None

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The following steps will be taken to ensure that the anticipated cost of this acquisition will be fair and reasonable. The Contracting Officer will comply with the procedures and criteria contained in Federal Acquisition Regulation (FAR) under Part 30 - Cost Accounting Standards, Part 31 - Contract Cost Principles and Procedures, Subparts 15.4 - Contract Pricing; to include technical evaluations and audits, as appropriate. Additional steps to ensure price reasonableness will be under the guidance of the Contract Pricing Reference Guides, jointly developed by the Federal Acquisition Institute and the Air Force Institute of Technology. The Final Step is to include the Price Negotiation Memorandum (PNM). This detailed documentation and justification of price reasonableness will be disclosed in the official PNM, to be prepared upon completion of negotiations.

VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

A. As described in Section VI above, market research IAW FAR Part 10 has been conducted through SSS FA8203-18-R-

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C5SCA and the synopsis of the proposed acquisitions, advising industry of the pending acquisition, and soliciting inquiries from interested parties.

B. In accordance with FAR part 10, the 417th SCMS/GUMB IPT conducted market research that yielded the following results:

1. Commercial catalogs, company literature on file, proprietary data rights and individual experiences from the C-5 IPT and other weapon system IPTs were reviewed. Reviews indicated no other repair sources possess the data and capabilities except for Triumph Gear Systems.

2. Organic repair capabilities were explored. An Opportunities Review Board (ORB) questionnaire ID# NW-16-017 was submitted 6 Apr 2016. The workload was declined by OO-ALC/DV on 9 Sept 2016. The decision was based on significant concerns brought forth during evaluation, specifically on technical data, materials, tooling and equipment.

3. A review of the procurement history for Clutch Assembly was conducted. The history identified Triumph Gear Systems, cage 82402, as being the only manufacturer utilized for procurement.

4. The Government's Purchase Request Process System (PRPS) was also searched in which the results showed the only viable source as the OEM, Triumph Gear Systems, cage 82402.

C. Market research concluded that there are no alternate/additional sources capable of meeting the government's requirement at this time and Triumph Gear Systems, cage 82402, is the only known company capable of satisfying the government requirements.

D. The C-5 NLG Clutch Assembly is unique to the C-5 aircraft and does not have commercial off-the shelf sources of manufacture. No commercial or non-developmental items are available with similar form, fit, or function parameters that can be used or modified to satisfy the agency's need.

E. The C-5 NLG Clutch Assembly is currently not a candidate for organic repair because the government does not possess data rights sufficient for organic stand-up.

IX. Any other facts supporting the use of Other Than Full and Open Competition.

No further information.

X. List of any sources that expressed, in writing, an interest in the acquisition.

See Section VI above.

XI. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before making subsequent acquisitions for the supplies or services required.

The Air Force regularly inquires with industry about sharing or selling the proprietary data rights for use in free and open solicitations and will do so annually with Triumph Gear Systems before each option period. Triumph Gear Systems is the only source that owns the data required to repair these items.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

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XIII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.