JA for Other Than Full Open_Signed1_Redacted.pdf

Department of the Air Force: Justification for Other Than Full and Open Competition

CUI

March 2026 Page 2 of 3

I. Agency and Contracting Activity (RFO 6.104-1(a)(1)):

Agency: AETC, 12th Maintenance Group, JBSA Randolph TX 78150-4513 Contracting Activity: 502d Contracting Squadron, Bldg. 224, 395 B Street West, JBSA Randolph TX 78150-4525

II. Nature and/or description of the action being approved (RFO 6.104-1(a)(2)):

12th Maintenance Group is purchasing and installing one (1) row and one (1) Bay of T-7A aircraft sunshades. Each bay will house two (2) aircraft. One (1) of the new bays will be added to a row of sunshade shelters that is already scheduled for installation. The other two (2) new bays will be erected as a standalone row. All bays will be in support of the T-7A's initial operational deployment.

III. Description of supplies/services required to meet agency needs (RFO 6.104-1(a)(3)):

This acquisition is for the purchase, manufacture, and installation of one row and one additional bay of T-7A aircraft sunshades, providing protective shelter for a total of six aircraft, with a total estimated value of The work shall be performed in accordance with the designs and drawings specified in the Government-furnished

IV. Statutory Authority Permitting Other Than Full and Open Competition (RFO 6.104-1(a)(4)):

10 U.S.C. 3204(a)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.

V. Rationale for Use of Authority (RFO 6.104-1(a)(5)):

The contract will be awarded as a sole source award to for the procurement and installation of three T-7A aircraft sunshade shelters. This acquisition is a follow-on to a contract currently in progress for T-7A aircraft sunshades. These circumstances meet the criteria for other than full and open competition under the authority of 10 U.S.C. 3204(a)(1), as only one responsible source can meet the agency's needs without unacceptable delays and substantial duplication of cost. The scope requires adding a new sunshade bay directly onto a shelter row presently under construction by the incumbent contractor, Awarding this to any other firm would be impractical, as it would require them to attach their structure to the end of the existing row, which would violate the warranty of the work currently underway and create unacceptable risk for the government. To mitigate the risk of future vendor lock and ensure long-term sustainment competition, the government is acquiring the necessary intellectual property and data rights, specifically the designs and drawings under which will allow for competitive procurement of future maintenance or additional construction. However, for this specific action, only the incumbent contractor can provide the required services in time to meet the urgent need to protect incoming T-7A aircraft, without causing price escalation and significant schedule delays associated with a new competitive procurement.

VI. Integrated Market Analysis and Efforts to Solicit Competition (RFO 6.104-1(a)(6), (8), and (10)):

Market research for this requirement consisted of analyzing historical cost data from the current contract price analysis. Developing a detailed Independent Government Cost Estimate (IGCE) was already established from the current contract. This analysis confirms that the contractor’s proposed price was fair and reasonable. The primary and insurmountable barrier to compete the physical nature of the work: the new sunshade bay must be directly attached to a structure currently being built by the incumbent. This creates a unique circumstance where only the incumbent can perform the work without voiding the government's warranty on the original structure and introducing unacceptable risks to the project's integrity.

A synopsis will be published to the Government Point of Entry (GPE) in accordance with public notification requirements.

Department of the Air Force: Justification for Other Than Full and Open Competition

CUI

March 2026 Page 3 of 3

However, due to the unique and restrictive nature of the work, it is anticipated that no other sources will submit a responsive proposal, as no other contractor can overcome the warranty and integration barriers. Therefore, the market analysis concludes that only the incumbent contractor, can meet the government's minimum requirements without the government assuming unacceptable risks and incurring substantial cost and schedule impacts that would jeopardize the timely bed down of the T-7A aircraft.

VII. Determination of Fair and Reasonable Cost (RFO 6.104-1(a)(7)):

The Contracting Officer is responsible for evaluating, determining, and documenting the anticipated contract cost/price is fair and reasonable in accordance with RFO Subpart 15.4, Contract Pricing.

VIII. Any Other Facts Supporting the Justification (RFO 6.104-1(a)(9)):

This acquisition must be awarded to the incumbent contractor to avoid substantial duplication of costs that would not be recovered through competition. Based on the IGCE, the estimated cost for this 3-bay addition is $ this work were awarded to a new contractor, the government would incur significant, non-scalable costs associated with separate mobilization, project management, and complex design integration.

The estimated cost to the Government that would be duplicated is approximately This estimate is derived as follows and represents costs that would be incurred by any new contractor but are largely avoided by using the mobilized incumbent:

Contractor Mobilization & Demobilization: A new contractor would have to mobilize equipment and personnel to an active, ongoing construction site, representing an estimated cost of (approx. 5% of project total).

Duplicative Project Management & Startup Overhead: While the incumbent is already managing the site, a new contractor would need to establish entirely new project management, safety, and administrative functions from scratch. This duplicative effort is estimated at $ (approx. half of the IGCE's 20% overhead calculation).

New Design, Engineering, and Submittals: A new contractor would have to perform complex design and engineering work to ensure their structure could safely and effectively integrate with another company's in-progress construction, estimated at (approx. 5% of project total).

Increased Government Project Oversight: The government would need to expend significant additional man-hours to oversee and coordinate between two separate contractors working on attached structures, estimated at

This estimated in duplicated costs represents approximately 20% of the Independent Government Cost Estimate. This figure is derived from standard industry costs for mobilization, project management, and duplicative engineering required for a new contractor to integrate with an in-progress construction project. This estimate does not and cannot include the unquantifiable financial risk the government would incur from voided warranties on the original structure, which represents a significant and unacceptable liability.

IX. Actions to Overcome Barriers to Competition (RFO 6.104-1(a)(11):

For this specific action, the primary barrier to competition—the fact that this is a logical follow-on to an in-progress construction project requiring physical integration—cannot be overcome. However, the agency is taking definitive action to ensure competition for all subsequent acquisitions for the same supplies or services. The government is acquiring the necessary intellectual property and a complete technical data package, including all designs and drawings under This data will be used to support future requirements, enabling full and open competition for any follow-on maintenance, modifications, or new construction of T-7A sunshades. This action directly mitigates the risk of long-term vendor lock and ensures a competitive environment for the sustainment of this capability.