JA Joint Inspection Group (JIG)_Redacted.pdf

DEFENSE LOGISTICS AGENCY

ENERGY

8725 JOHN J. KINGMAN ROAD

FORT BELVOIR, VIRGINIA 22060-6222

November 16, 2021 JA Tracking Number: 22-0006

Justification for Other than Full and Open Competition

1. Summary/Introduction:

The Defense Logistics Agency (DLA) Energy, a component of DLA, is the contracting activity and DLA Energy Quality (DLA Energy- ) is the requiring activity. The purpose of Solicitation SP0604-22-Q-0401 is to renew membership with the Joint Inspection Group (JIG) to keep up with industry standards for DLA Energy Into-Plane contracts. The statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c)(1). This requirement is for a twelve (12) month membership from January 1, 2022 to December 31, 2022. The estimated value for the membership is £7,600 ($10,400.60). Please note that currency exchange rate from British Pound to U.S. Dollar at the time of the approved Purchase Request for this solicitation is $10,400.60.

2. Nature and/or description of the action being approved (FAR 6.303-2(b)(2)):

The action is to renew DLA Energy’s JIG membership. DLA Energy has been a member since 2006; however, JIG and its guidance documents have been in existence for approximately 30-40 years, as used by DLA Energy/DESC/DFSC and prior organization titles. The Associate membership provides DLA Energy with a copy of “Guideline for Aviation Fuel Quality Control & Operating Procedures for Joint Into-plane Fueling Services” and JIG’s standards are incorporated into DLA Energy into-plane contracts. For example, JIG 1 is mandated in OCONUS DLA Energy into-plane contracts and JIG 2 or EI/JIG 1530 is also required on some contract line item numbers (CLINs) as auxiliary support. The Associate membership also extends an opportunity for DLA Energy to participate in JIG Technical Forum meetings and JIG Training Workshops.

The resultant contract will cover a twelve month period from January 1, 2022 to December 31, 2022. This firm-fixed price contract will use funds from fiscal year 2022.

3. Description of supplies or services required to meet the agency’s need (including estimated value) (FAR 6.303-2(b) (3)):

JIG’s primary objective is to promote safe and cost-effective best practices for aviation equipment and aviation fuel quality control and handling by developing, compiling, printing, publishing, and distributing guidelines for aviation fuel quality control and operating procedures. DLA Energy is an Associate member of the JIG. The benefits of this membership include access to and use of JIG’s “Guideline for Aviation Fuel Quality Control & Operating Procedures for Joint Into-plane Fueling Services” in DLA Energy Into-plane contracts, participation in JIG meetings, and invitations to JIG Training Workshops.

Justification for Other Than Full and Open Competition (Cont’d)

(SP0604-22-Q-0401 – JIG)

4. Identification of the statutory authority permitting other than full and open competition (FAR 6.303-2(b)(4)):

This J&A is based upon the authority of 10 U.S.C. § 2304(c)(1), as implemented by FAR 6.302- 1(a)(2). The membership is exclusive to JIG, thus JIG is the only source able to provide the information and benefits DLA Energy requires. Therefore, in accordance with FAR 6.302-1(a)(2), JIG is the only responsible source that will satisfy agency requirements.

5. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited (FAR 6.303-2(b)(5)):

JIG is uniquely qualified as it is the only source for the required guidelines for aviation fuel quality control and operating procedures. The membership and guidelines are proprietary to JIG, and no other source can provide these requirements for DLA Energy.

6. Description of the efforts made to ensure that offers are/were solicited from as many potential sources as is/was practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies (FAR 6.303- 2(b)(6)):

DLA Energy-FEA posted an intent to sole source notice on SAM.Gov (SP0604-22-Q-0401) on October 29, 2021 and the notice closed on November 15, 2021. No vendors responded to the notice, resulting in no additional competition to meet this requirement. Therefore, JIG is still the only source available to meet DLA Energy’s needs at this time. The information and benefits that JIG provides have been shown to fit DLA Energy’s requirements.

7. Determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable (FAR 6.303-2(b)(7)):

The Contracting Officer determines the price offered by JIG to be fair and reasonable in accordance with FAR 15.404-1(b)(2)(vii), analysis of data other than certified cost and pricing data provided by the offeror. JIG charged members £7,250 for an annual membership in 2021.

JIG increased the fee by £350 to £7,600 to help fund additional improvements and investment that JIG are implementing. The JIG website will continue to be developed, with an integrated Events platform due before the end of this year, and some planned Learning Modules (starting with some elements of Inspector Training) planned for 2022. The Contracting Officer sought to verify the price increase independently but public sources of verification were not available. As a result, the Contracting Officer requested for “Other Than Certified Data” from JIG to support the price is similar (or advantageous) to what another customer may be charged. JIG submitted a redacted invoice that satisfied the Contracting Officer’s request. The Contracting Officer determines £7,600 ($10,400.60) a fair and reasonable price because it represents the fee that all members will be charged for an annual membership in 2022.

(SP0604-22-Q-0401 – JIG)

8. Description of the market research conducted and the results or a statement of the reason market research was not conducted (FAR 6.303-2(b)(8)):

Due to the proprietary nature of the membership and required guidelines, JIG is the only source available for the required membership. DLA Energy has no expectation that market research or other efforts will result in future competition.

9. Any other facts supporting the use of other than full and open competition, such as (FAR 6.303-2(b)(9):

DLA Energy-FEA posted an intent-to-sole source notice on SAM.Gov (SP0604-22-Q-0401). No vendors responded to the notice resulting in no additional competition to meet this requirement.

Therefore, JIG is the only source available to meet DLA Energy’s needs at this time.

(i) Explanation of why technical data packages, specifications, engineering descriptions, statements of work, or purchase descriptions suitable for full and open competition have not been developed or are not available.

Not applicable.

(ii) When 6.302-1 is cited for follow-on acquisitions as described in 6.302-1(a) (2) (ii), an estimate of the cost to the Government that would be duplicated and how the estimate was derived.

Not applicable.

(iii) When 6.302-2 is cited, data, estimated cost, or other rationale as to the extent and nature of the harm to the Government.

Not applicable.

10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition (FAR 6.303-2(b) (10):

No sources replied to the Intent-to-Sole Source Notice posted to SAM.Gov.

11. Actions that may be taken to remove or overcome barriers to competition before any subsequent acquisition for the supplies or services are required (FAR 6.303-2(b) (11)):

There are no known actions that will allow DLA Energy to overcome the competition barriers for this requirement.

(SP0604-22-Q-0401 – JIG)

I hereby certify that the data, which forms the basis for this justification, is accurate and complete to the best of my knowledge and belief.

I hereby certify that the data, which forms the basis for this justification, is accurate and complete and that the purchase request covers only the minimum requirements to satisfy the needs of the Government.

Approved:

JOSEPH KNUDSON

Contracting Officer

KNUDSON.JOSEP

H.D.1042229926

Digitally signed by

KNUDSON.JOSEPH.D.1042229926

Date: 2021.11.22 11:25:09 -05'00'