JA (Redacted).pdf

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

I. CONTRACTING ACTIVITY

United States Air Force

AFSC/PZA

3001 Staff Drive Tinker AFB, OK 73145

Purchase Request # FD2030-18-01841

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING PROCESSED

This individual Justification and Approval (J&A) authorizes the use of other than full and open competition procedures to obtain a new firm-fixed price (FFP), sole source indefinite delivery indefinite quantity contract. The contemplated contract is for remanufacture of F-16 aircraft Demand Oxygen Test Stand (here after referred to as field testers). The Original Equipment Manufacturer (OEM) is Carleton Life Support Systems Inc. DBA Cobham Mission System (Cobham) Commercial and Government Entity (CAGE) code 99251. In accordance with (IAW) FAR Part 16, a 5-year indefinite delivery indefinite quantity contract with a 1-year basic contract, and four 1-year options is considered to be appropriate for this acquisition. The previous acquisition under contract FA811815D0054 was considered Overhaul and acquisition under FA8118-16-D- 0038 was a remanufacture. Both of these acquisitions accomplished the same effort, and are now considered a Remanufacture/Supply. This contract will consolidate the requirement to remanufacture two national stock numbers (NSNs) under one single contract whereas these NSNs were previously performed under two separate contracts.

The acquisition is not a Bridge Action as defined in AF Bridge Action Reduction Plan.

This is a non-commercial acquisition. The estimated total value of this contract action is $3,333,949.50 with an estimated award date of Dec 19.

Previous Contract Number: FA8118-15-D-0054 Contractor Name: Carlton Life Support Systems Inc.

Date of Award: 10 Sep 15 Completion Date: 09 Sep 18 Basis of Award: Sole Source FA8118-15-D-0054 was the previous contract for National Stock Number (NSN): 4920-

01-321-1839BO

Previous Contract Number: FA8118-16-D-0038 Contractor Name: Carlton Life Support Systems Inc.

Date of Award: 22 Dec 16 Completion Date: 21 Dec 19 Basis of Award: Sole Source FA8118-16-D-0038 was the previous contract for NSN: 4920-01-521-3685BO

III. DESCRIPTION OF THE SUPPLIES/SERVICES REQUIRED TO MEET THE

AGENCY’S NEEDS

Under the contemplated contract, Cobham will remanufacture the field testers. Field testers functionally tests CRU (Crew Regulator Unit)-73, CRU-98, CRU-93 and CRU- 120 oxygen regulators for serviceability of oxygen life support equipment. The Contractor will provide the disassembly, cleaning, inspection, maintenance, re-assembly, testing, and finishing actions required to return the end item to a like new condition. This is a supply effort. Dollar values below reflect the estimated anticipated contract value.

Contract Summary Year Estimated Dates Estimated Dollars Basic Dec 19 – Dec 20 $666,789.90 Option I Dec 20 – Dec 21 $666,789.90 Option II Dec 21 – Dec 22 $666,789.90 Option III Dec 22 – Dec 23 $666,789.90 Option IV Dec 23 – Dec 24 $666,789.90 Total Contract Dec 19 – Dec 24 $3,333,949.50

PR Line Item 0001

Remanufacture, to include remanufacture of the case assembly, of

NSN: 4920-01-321-1839BO

Part Number (P/N): 3300223-6002 Noun: Test Stand, Demand Oxygen Application: F-16 Item description and function: Used to test oxygen regulators and connectors Type of Appropriation: 3400 Total estimated dollars for PR Line Item 0001: $2,611,892.50

Year MIN Qty

BEQ MAX

Qty

Unit Price Estimated Dollars

Period of Performance

Basic 10 25 50 $10,447.57 $522,378.50 Dec 19 – Dec 20 Option I 10 25 50 $10,447.57 $522,378.50 Dec 20 – Dec 21 Option II 10 25 50 $10,447.57 $522,378.50 Dec 21 – Dec 22 Option III 10 25 50 $10,447.57 $522,378.50 Dec 22 – Dec 23 Option IV 10 25 50 $10,447.57 $522,378.50 Dec 23 – Dec 24

Note: All assets shall be initiated into the remanufacture program at the highest level (PR Line Item 0001), to include the case remanufacture. Should it be determined that an asset does not need a case remanufacture, the government shall be notified, and the contract modified accordingly to de-obligate funds and move the asset to the test stand remanufacture only Line Item 0002 below.

PR Line Item 0002

Remanufacture of Test Stand only, excluding remanufacture of the case assembly of

NSN: 4920-01-321-1839BO

P/N: 3300223-6002 Noun: Test Stand, Demand Oxygen Application: F-16 Item description and function: Used to test oxygen regulators and connectors

Total estimated dollars for PR Line Item 0002: N/A

Year Qty Unit Price Estimated Dollars

Period of Performance

Basic 1ea $0 $0 Dec 19 – Dec 20 Option I 1ea $0 $0 Dec 20 – Dec 21 Option II 1ea $0 $0 Dec 21 – Dec 22 Option III 1ea $0 $0 Dec 22 – Dec 23 Option IV 1ea $0 $0 Dec 23 – Dec 24

PR Line Item 0003

Remanufacture of NSN: 4920-01-521-3685BO P/N: 3300223-6003 Noun: Test Stand, Demand Oxygen Application: F-16 Item description and function: Used to test oxygen regulators and connectors

Total estimated dollars for PR Line Item 0003: $717,057.00

Year MIN Qty

BEQ MAX

Qty

Unit Price

Estimated Dollars

Period of Performance

Basic 3 10 20 $7,170.57 $143,411.40 Dec 19 – Dec 20 Option I 3 10 20 $7,170.57 $143,411.40 Dec 20 – Dec 21 Option II 3 10 20 $7,170.57 $143,411.40 Dec 21 – Dec 22 Option III 3 10 20 $7,170.57 $143,411.40 Dec 22 – Dec 23 Option IV 3 10 20 $7,170.57 $143,411.40 Dec 23 – Dec 24

PR Line Item 0004

Description: Over and Above

Total estimated dollars for PR Line Item 0004: $5,000.00

Period of Performance

Basic 1 LT $1,000 $1,000 Dec 19 – Dec 20

Option I 1 LT $1,000 $1,000 Dec 20 – Dec 21 Option II 1 LT $1,000 $1,000 Dec 21 – Dec 22

Option III 1 LT $1,000 $1,000 Dec 22 – Dec 23

Option IV 1 LT $1,000 $1,000 Dec 23 – Dec 24

PR Line Item 0005

Description: Data Not Separately Priced (NSP), IAW CAVAF SOR and CDRLs Type of Appropriation: N/A Total estimated dollars for PR Line Item 0005: N/A

Period of Performance

Basic 1 LT NSP NSP Dec 19 – Dec 20

Option I 1 LT NSP NSP Dec 20 – Dec 21 Option II 1 LT NSP NSP Dec 21 – Dec 22

Option III 1 LT NSP NSP Dec 22 – Dec 23

Option IV 1 LT NSP NSP Dec 23 – Dec 24

Due to the circumstances described below in Sections V, VIII, and XI, there are no immediate actions that could be taken to develop competition. Therefore, it is considered appropriate to seek approval for more than one fiscal year’s requirements. If other qualified or approved sources become known during the life of this contract, full and open completion will be considered and utilized to the maximum extent practicable.

IV. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION

10 U.S.C. 2304(c) (1), as implemented by FAR 6.302-1(a) (2) (ii)

V. DEMONSTRATION THAT THE CONTRACTOR’S UNIQUE

QUALIFICATIONS OR NATURE OF THE ACQUISITION REQUIRES THE

USE OF THE AUTHORITY CITED ABOVE (APPLICABILITY OF

AUTHORITY)

The anticipated acquisition is a follow-on contract that is for the remanufacture of the field testers, NSNs 4920-01-321-1839BO and 4920-01-521-3685BO for the F-16 aircraft.

The intended action is a follow-on contract with the OEM, Cobham. The two items are now combined under one single contract for administrative purposes. The field testers are critical application items, as defined in the Aviation Critical Safety Item Management handbook, and are used to provide field test capability for the oxygen regulator on the CRU-73, CRU-98, CRU-120 and CRU-93. These field testers are considered vitally important to provide flow test capacities, test oxygen concentration, and pressure characteristics at the desired altitudes. These items are specially designed for maintenance of aircraft components, and are imperative to allow the Government to be mission ready at all times. Therefore, this acquisition will be a follow-on contract for the continued development of highly specialized support equipment.

Cobham is the only known source that has the necessary detailed remanufacturing and process data, and parts needed to remanufacture these testers. The Government has limited form, fit and function (FFF) data, this data is not sufficient to remanufacture the items described in section III. The Government does not possess complete technical data, drawings or parts lists necessary to complete a competitive packages. Existing technical orders only cover calibration and minor repair, not remanufacture. The Government has established Qualification Requirements (QR) for the field testers.

Prospective sources must meet these requirements prior to being identified as an approved source. This item requires engineering source approval in order to maintain its quality and technical baseline. The 423rd Supply Chain Management Squadron has determined that Cobham, the OEM, is the only source that has met the defined QR at this time and thus has been listed as the only source.

The 423rd SCMS believes that award to any other source would result in unacceptable delays in fulfilling the Air Force’s requirement. Development of additional sources to remanufacture this item is not feasible within allowable timeframes. The Government does not expect that any other source could become qualified in time to avoid unacceptable delays. Any interested sources would be required to submit a Source Approval Request (SAR) for review by the cognizant engineering authority. Interested vendors would need to submit a SAR package demonstrating capacity to access the necessary data, independently develop maintenance/remanufacture procedures or other proof of capability. As of 21 May 2019, there have been no SAR packages submitted for approval even though there are sources that indicate interest in this acquisition, discussed in Sections VI and VIII. Once a source has been identified and has submitted a SAR package, it can take in excess of one year to qualify the potential source. During this time the Government must review and approve the SAR package, complete any potential site visits, and validate/verify any developed technical requirements. Delays in procurement will disrupt the availability of parts to the CRU-73, CRU-98, CRU-120 and CRU-93, thereby leaving the Air Force unable to meet critical mission requirements and hampering the Air Force. If deliveries do not begin by Jan 20, the 848 SCMG would be unable to provide an adequate supply of testers to support the F-16 fleet. The Operations Tempo for item consideration includes flying schedules, Mobility Readiness Spares Packages in readiness base levels, future pilot production and absorption as per HQ/AFMC/A4 Campaign Plan.

Accordingly, Cobham is the only firm capable of providing the supplies described in Section III above without the Air Force experiencing unacceptable delays in fulfilling its requirements.

VI. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERS ARE

SOLICITED FROM AS MANY POTENTIAL SOURCES AS DEEMED

PRACTICABLE

A Sources Sought Synopsis (F-15, F-16) Field Testers - FD2030-18-01841 (NSN’s 4920- 01-321-1839BO and 4920-01-521-3685BO) was posted to the Federal Business Opportunities, https://www.fbo.gov, on 07 May 18 with a close date of 07 Jun 18. There were three vendors that showed interest by the response date (see Section X) but only Carleton is identified as an approved source for this remanufacture. Government defined pre-award qualification requirements of potential sources has been identified and apply to these items, potential sources will be required to obtain the necessary data independently or otherwise provide proof demonstrating capability via the SAR process. All SAR package submissions submitted prior to contract award will be evaluated in accordance with the process outlined, to ensure the highest level of competition possible. The QRs were synopsized on https://www.fbo.gov June 2017 and can be found by searching for keyword “RQR-848”. There are currently no SAR package submittals for either NSN.

This requirement will be synopsized in https://www.fbo.gov as a notice of proposed contract action IAW FAR 5.201.

VII. DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND

REASONABLE

The Contracting Officer will ensure that the items described herein are negotiated at a fair and reasonable price to the Government. IAW FAR as supplemented, the contractor will be required to submit Certified Cost and Pricing Data a detailed cost analysis and a price analysis will be performed. The Contracting Officer will request a technical evaluation from the Defense Contract Management Agency (DCMA) to aid in the evaluation of the contractor’s proposal. The Contracting Officer will seek audit assistance from the Defense Contract Audit Agency (DCAA) if necessary.

VIII. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AND THE

RESULTS, OR A STATEMENT OF THE REASONS MARKET RESEARCH

WAS NOT CONDUCTED

In accordance with FAR 10.001(a) (2), market research conducted on the field testers was conducted 7 May 2018 to 22 Jun 18,. Market research included inquiries into internet sites including Google, the Thomas Register, Haystack, and similar item manufacturer’s websites. Inquiries were also conducted using FedBizOpps, Government Databases (FPDS-NG, FAPISS, PPIRS, CPS, GSA, SBA Databases etc.), Government Contacts (SME in specific Markets, other People with experience with this product/service) and contacting known source of products or services. Searches included part number and nomenclature as well as similar items. A Sources Sought Synopsis as discussed in Section VI above was also conducted. This market research was conducted from 07 May 2018 to 22 June 2018 and while it did reveal that other sources manufacture similar items, none have sought qualification through the SAR process.

Market research identified four previous delivery orders on the Contract Repair Screening Analysis Worksheet that were not Carlton Life Support Systems. Further research revealed three of these delivery orders were contracted with Lockheed Martin and one was contracted with BAE Systems Information and Electronics, through the Foreign Military Sales (FMS) office at Hill Air Force Base. To the best of the acquisition team’s knowledge, Lockheed and BAE acted as a supply/requirement integrator for FMS requirements and did not actually perform remanufacture of these field testers.

Based on the market research, the OEM, Cobham, was found to be the only qualified source able to fulfill the requirement described in Section III. Further, the market research revealed that there is not a commercial process available to meet this requirement.

IX. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND

OPEN COMPETITION

No further information.

X. LIST OF SOURCES, IF ANY, THAT EXPRESSED INTEREST IN THE

ACQUISITION

See Section VI for more detail.

ATEQ Corporation. CAGE: 5WTAO 35980 Industrial Rd.

Livonia, MI 48150-1274 Phone: 734-838-3116

Carleton Life Support Systems, Inc. CAGE: 99251 2734 Hickory Grove Rd.

Davenport, IA 52804-1203 Phone: 563-383-6146

ARMCOR.COM Contractor Capital L.L.C CAGE: 3CK69 5203 Leesburg Pike Ste 61 Falls Church, VA 22041-3401 Phone: 800-873-4161

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 Government has specified requirements a potential source must satisfy in order to become qualified and listed as an approved source for future acquisition. These requirements will be communicated to industry through periodic synopsis of the QRs themselves and through SSS associated with any future acquisitions.

Per DFARS PGI 206.304 (a) (S-70), as indicated by the signature on the Coordination Approval Document, a review of the previous J&A’s were completed and all efforts to remove barriers have been accomplished.

XII. CONTRACTING OFFICER’S CERTIFICATION

As evidenced by his/her signature on the Coordination and Approval Document, the Contracting Officer has determined this document to be both accurate and complete to the best of the Contracting Officer’s knowledge and belief.

XIII. TECHNICAL/REQUIREMENTS PERSONNEL’S CERTIFICATION

As evidenced by their signatures on the Coordination and Approval Document, the technical and/or requirements personnel have certified that any supporting data contained herein, which is their responsibility, is both accurate and complete.