J-A FCTS 05072018 REDACTED.docx

DEPARTMENT OF THE NAVY

NAVAL AIR WARFARE CENTER AIRCRAFT DIVISION

IN REPLY REFER TO:

J&A_18_1206

J&A_18_0207 JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity.

Naval Air Warfare Center Aircraft Division (NAWC-AD) Lakehurst, NJ

1. Description of the Action Being Approved.

This Justification and Approval, establishes authority for the procurement of 543 Engineering Change Proposal (ECP) kits to overcome parts obsolescence issues and to make the Fuel Control Test Set (FCTS), TTU-597/E, I-level maintainable on a sole source basis with Flightline Electronics, Inc., 7625 Omnitech Place, Victor, NY (CAGE: 50027). The current TTU-597/E test set must be returned to the Original Equipment Manufacturer (OEM), Flightline Electronics, Inc., for repair.

1. Description of Supplies/Services.

This procurement is for the manufacture and delivery of 488 United States Navy TTU-597/E ECP kits and 55 Foreign Military Sales TTU-597/E ECP kits at a rate of fourteen (14) kits per month to address parts obsolescence and availability issues by moving the current FCTS to a modular design and making the test set I-level maintainable. The legacy TTU-597/E was originally procured as a Commercial Off the Shelf (COTS) piece of equipment and though fielding began in 2008, the current design is 14 years old. In addition to the kits, logistics support documents (technical manual updates and provisioning data) and the Interim Support Items List for the subassemblies and components changed by the FCTS ECP will be acquired. The current FCTS is used to test the fuel quantity probes and indicators of various Navy and Marine Corps aircraft by measuring the capacitance of the fuel probes under known fuel levels and simulating capacitances into the fuel quantity gages and to verify correct indicated fuel levels. The ECP will replace obsolete parts, upgrade the operating system, and add I-level maintenance capability. The ability to maintain the equipment at I-level will significantly increase fleet availability.

BCF Designs Ltd the OEM and designer of the TTU-597/E FCTS (part number BC849A6010-000) was acquired by Flightline Electronics, Inc. in late 2007. As the OEM, Flightline Electronics, Inc. is the only authorized source of the ECP kit and kit contents. The Estimated Dollar Value is $14,650,000 of APN7 funds.

Estimated Dollar Value in Millions

FMS Quantities

FMS Procurement

$14.65 M

1. Statutory Authority Permitting Other Than Full and Open Competition.

10 U.S.C. 2304(c)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.

1. Rationale Justifying Use of Cited Statutory Authority.

The TTU-597/E is COTS equipment whose design is proprietary and drawings owned by the OEM. Due to parts obsolescence issues with components such as the display, keyboard, and some internal electronics the current configuration is difficult to support. Upgrading the electronics will also require updating the operating system. The current test set operates on FreeDos, which is an outdated operating system incompatible with modern technology and electronics. Modifying the test set to a COTS supported configuration requires change to the proprietary design and drawings. The operation of this modified test set is identical to the current test set, minimizing training and changes to operational manuals.

The total cost of competitively procuring a brand new FCTS is approximately $4.5M greater than the total cost of the proposed ECP, as presented in the Analysis of Alternatives (AoA) brief prepared by NAWCAD 4.2 Cost personnel. These costs do not include those associated with increasing the schedule another 18-24 months in order to competitively procure a brand new test set. Interfaces and procedures would need to be identified for each platform supported with a new procurement, whereas integration for these platforms has already been accomplished for the TTU-597. Operator training will not need to be done since operating procedures will remain the same. Reliability testing is also not required as we can use reliability prediction methods based on the existing equipment. These are some tasks that are not required when replacing obsolete parts but would be required for a new procurement. Also, logistics for the ECP can be leveraged off of the existing logistics, whereas logistics support would need to be established for a new procurement.

1. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

In preparation for this acquisition, market research and internet searches by the Instrumentation IPT Lead (NAWCAD 1.3.1.8) and Lakehurst engineering personnel were not able to identify a second source of supply for the ECP kit. In accordance with FAR 6.303, Solicitation Number, N68335-17-R-0376, Request for Information (RFI) was posted on 27 July 2017 and ended on 28 August 2017. This original RFI yielded no responses. A synopsis with intent to sole source was posted for this procurement as required by FAR 5.201 on the FEDBIZOPS website on 30 August through 14 September 2017.

Due to this procurement description being changed to a modification of equipment, an RFI was again posted on 18 October, which closed 17 Nov 2017. This RFI yielded responses from two contractors; Ki Ho Military Acquisition Consulting, Inc. and SAIC which were sent to the Program Office and Technical personnel for review. On 31 January 2018, the Contract Specialist was informed that although both companies have appropriate expertise, a third party would not be able to develop the ECP on a proprietary test set to which Flightline Electronics, Inc. owns the drawings. While the Navy owns the drawings for the interface adapter sets, as the OEM, Flightline Electronics, Inc., is the only authorized source for the ECP kit and kit contents. For this reason, Flightline Electronics, Inc. is the only viable solution to procure and install the ECP kits.

A synopsis was posted for this procurement as required by FAR 5.201 on the FEDBIZOPS website on 01 February 2018 through 16 February 2018. Within this period, two responses were received from contractors that are interested in the opportunity to support the Navy with an ECP for the FCTS. The two contractors that responded to the synopsis were from Parts Life, Inc. and Flightline Electronics, Inc. A response letter was sent to Parts Life, Inc. on March 27, 2018 to explain that as the OEM, Flightline Electronics, Inc. is the only authorized source of the ECP kit and kit contents. For this reason, Flightline Electronics, Inc. is the only viable method to procure and install ECP kits. The letter further explained that the Government has performed extensive market research and an AoA concluding that the most cost effective and efficient acquisition strategy is an ECP that replaces the obsolete parts from the OEM, whose design is proprietary.

1. Determination of Fair and Reasonable Cost.

In accordance with FAR 15.402, the Contracting Officer shall ensure that all supplies and services provided under this contract are procured at a fair and reasonable price. The contractor will submit a formal price proposal with data other than certified cost or pricing data and sufficient information to support the accuracy and reliability of the proposal estimate. The proposal will be reviewed by experienced technical analysts, cost analysts, and contract specialists with the aid of necessary field pricing support, as required. The Contracting Officer will utilize data other than certified cost or pricing data for analysis and historical pricing information as the basis for negotiating a fair and reasonable price.

1. Actions to Remove Barriers to Future Competition.

The existing units being replaced have been in the Fleet for nine years but the design is over 14 years old. NAVAIR expects installation of ECP kits to address obsolete parts and allow for organic I-level maintenance. This procurement will be a one time/life-of-type buy for the offeror’s product. Therefore, at this time the Government does not anticipate any additional buys for this equipment beyond this single procurement. The Government will continue to monitor the availability of alternate products and sources that could meet the capabilities.

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