JA-00975 SPRDL125R0001-FOIA_CSRedacted.pdf

JA-00975 - SPRDL1-25-R-0001

Previous J&A not available.

4. Authority Cited: The statutory authority permitting other than full and open competition for this effort is 10 United States Code (U.S.C.) 3204(a)(1) as implemented by the Federal Acquisition Regulation (FAR) 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

5. Reason for Authority Cited:

The Government does not have the pertinent technical data to enable competitive re-procurement.

The HMMWV differential was originally designed and developed by Dana / AMG. The original HMMWV program acquisition strategy incorporated a combination of off-the shelf commercial parts, existing ordinance parts, and contractor developed parts to speed up the acquisition process and allow the Government to own some portions of the HMMWV, but not the full technical data package (TDP) of the vehicle system. This strategy reduced research and development time as well as overall program cost. Thus, while the HMMWV has a TDP, it is not all inclusive of every component of the vehicle system. Further, the TDP does not include vendor-developed components that were considered the intellectual property of the developer. Since this differential was developed by Dana / AMG at their expense, the technical information for this item is proprietary to both firms. As such, the use of such descriptions in the acquisition is essential to the Government’s requirement thereby precluding consideration of a product manufactured by another company.

There are no known funding efforts in progress at this time to acquire the commercially owned and controlled data necessary to make NSN 2520-01-521-0572 fully competitive.

Further, because this is a major system component of the ECV HMMWV FoV, the time, cost and schedule impact associated with a competitive action on every single differential purchase would result in a full qualification test for each awarded vendor to validate form, fit and function of the differential. This would add unnecessary cost and schedule time to the acquisition of each differential of the ECV HMMWV FoV, which is a program that is currently in sustainment. If the Government attempted a fully competitive procurement for the differential, the Government would have three choices to obtain the necessary information to enable full competition: Research and Development of our own differential design; Reverse Engineering of the existing system; or simply ask the vendors, in this case Dana / AMG, for a price to purchase the full TDP and rights to use the item competitively. The Government has tried to obtain the TDP for the differential, but Dana / AMG’s response was it was not for sale. The Government has two remaining methods to acquire the data required and execute a competitive differential purchase. The remaining options are:

(1) Research and Development (R&D): To develop a competitive data package through an R&D effort would involve procuring proprietary data for research, generating a requirements document and any associated technical drawings.

Based on past experience with similar efforts, the estimated cost for R&D to develop a compatible product and qualify additional sources exceeds $5,500,000 with a setback of 42 months. Required funding would include $3,900,000 for personnel to support research and redevelopment of a differential that would perform the same task as this NSN. Included in this cost would be funding for staff to develop the computer-aided design (CAD) models and drawings that would be required for any potential vendor for manufacturing purposes, and an additional $1,675,000 - $2,230,000 required to develop prototypes to test and validate the Government design that functions identically to the original. If funding for a new-start research and development effort became available, the 42-month process would consist of the following: 12 months to develop requirements; 6 to 12 months in design and prototyping; 12 months to test compatibility and function; and an additional 12 months to write the technical data package and provision the parts. A timeline of the estimated R&D process is shown for clarity:

Requirements development 12 Months Design and prototype development 6 Months Component, safety and system level testing 12 Months Write TDP, technical bulletins and provision parts 12 Months Estimated Time to research and develop 42 Months

(2) Reverse Engineering (RE): To reverse engineer, validate the design, procure prototypes for testing and ultimately release a competitive data package would cost an estimated $5,025,000, with an estimated delay of no less than 36 months. Required funding would include $3,350,000 for personnel to support reverse engineering and validation of the design as well as staff to develop the CAD models and drawings, with an additional $1,675,000 - $2,230,000 to develop prototypes, test and finalize the product to verify that the newly created differential provides equivalent performance when compared against the original. If funding for reverse engineering became available, the 36 month process would consist of the following:

3 months to obtain existing parts;

3 months to tear down and understand the design;

6 months to iteratively develop drawings, prototypes and bench test;

12 months to perform system and vehicle level testing;

12 months to write the technical data package and provision the parts.

To complete the reverse engineering process successfully, the Government would have to obtain a sufficient sample size of existing parts to provide a 95% probability and 90% confidence level in the actual size of the existing item to be studied. Once a large enough sample has been collected, the Government would then tear down and understand the design, conduct prototype development and produce the final TDP and associated provisioning documents at an estimated cost of $5,000,000. In addition to the cost and delay for an R&D action or an RE effort, the Government estimates that it would take approximately one additional year to establish another source and procure

7. Actions to Increase Competition: There are no plans to increase competition for future procurements due to the reasons cited above.

8. Market Research: A Sources Sought Notice was posted to SAM.gov on 18 December 2024 and was open for 15 days. No responses were received.

Product Director Light Tactical Vehicle Engineering conducted a computer-based online search on 07 November 2024, searching for companies with published material on a new built differential specifically for ECV HMMWVs.

Keyword(s): Differential, HMMWV, ECV, differential assembly.

Links used to conduct market research are listed below:

https://www.eaton.com/Eaton/ProductsbyMarket/Government/Vehicles/MilitaryVehicles/ HMMWV/index.htm https://predatorinc.com/shop/hmmwv-differential-centering-kit/ https://www.jasperengines.com/differentials http://www.g2axle.com/pages/view/core_locker https://www.axletech.com/en/products/components

Findings: The results of this search did not produce any new companies that would provide a direct replacement front differential for the ECV HMMWV FoV that is 100% new and not rebuilt that could be installed in the HMMWV without considerable time and effort to adapt the new components. The HMMWV is in sustainment at this time so substantial vehicle system changes to accommodate competition are not funded and are unable to be fielded.

Summary: As a result of the Market Research, it was concluded that the Government does not have enough detailed information to consider similar parts for this specific application on the HMMWV. This front differential cannot be identified as a Commercial Off-The-Shelf item.

9. Interested Sources: To date no additional sources have expressed interest in this item.

10. Other Facts: Procurement History: There is no procurement history for NSN 2520- 01-521-0572.

11. Technical Certification: I certify that the supporting data under my cognizance which is included in the justification is accurate and complete to the best of my knowledge and belief.

Name:

Title: Engineering Branch Chief, PD Light Tactical Vehicles