JA_Redacted_FA852414D0018___30SEP14.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPTEITION

I. CONTRACTING ACTIVITY:

This Justification and Approval to request authority for Other Than Full And Open Competition supports requirements generated for the Air Force Sustainment Center (AFSC), 638th Supply Chain Management Group (SCMG), 409th Supply Chain Management Squadron (SCMS) GUMAA. The contracting authority for this requirement is AFSC/PZAAA, C-5 Aircraft Support, Robins Air Force Base, GA. The purchase request number supporting this contracting action is FD2060-13-01050.

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

Due to the circumstances described herein, the activity requests authority to obtain depot level maintenance for the items listed in this document using Other Than Full and Open Competition as prescribed by FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. This action will result in the award of a follow-on contract, which will be a firm-fixed price, requirements contract with a basic year plus one-year option period. This sole source requirement will be purchased from the following company:

GE Aviation Systems, LLC 1000 MacArthur Memorial Hwy Bohemia, N.Y. 11716

CAGE: 19623

Large Business

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

AGENCY’S NEEDS:

The items listed below are the C-5 Battery Control Electronics Module (BECM) and Regulated Transformer Rectifier Unit (RTRU). The BCEM and RTRU are aircraft components that are part of the Emergency Power System (EPS) on all models of C-5 aircraft and are additionally used in conjunction with the auxiliary power unit (APU) system on C-5M model aircraft.

This is a requirement for depot level repair. MSD revolving funds will be used and will be in support of the C-5 Avionics Section.

BCEM, NSN

6130015357275UC

P/N 716110-2 Basic Option 1

Estimated Repair Qty 54 54 Estimated Repair Unit Price (U/P)

Estimated Total Repair

Estimated Test/No Repair Qty 20 20

Estimated Test/No Repair U/P Estimated Total Test/No Repair Estimated Beyond Economical Repair (BER) Qty 6 6

Estimated BER U/P

Estimated Total BER

Annual totals (80 ea qty)

Total Estimate for all years:

RTRU, NSN

6120014933059UC

P/N 715080-1 or -100 Basic Option 1

Estimated Repair Qty 2 2

Estimated Repair U/P

Estimated Total Repair

Estimated Test/No Repair Qty 1 1

Estimated Test/No Repair U/P Estimated Total Test/No Repair Estimated Beyond Economical Repair (BER) Qty 1 1

Estimated BER U/P

Estimated Total BER

Annual totals (4 ea qty)

Total Estimate for all years:

Over & Above Entire Period of

Performance

Total Estimate for all years:

The total estimated cost of this acquisition, including options, is Estimated unit repair prices were computed by escalating current prices by 10 percent in the first year, then 3 percent in the option year. Estimated unit prices for no fault found were computed by escalating current prices by 10 percent in the first year, and then straight lined for the option year. The estimated unit prices for BER was computed by escalating current prices by 10 percent in the first year, then 3 percent in the option year. The estimate for over and above is based upon per unit for up to 100 units to do any reliability improvements or modifications or other Over & Above repairs.

IV. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION:

10 U.S.C. 2304(c)(1) as implemented by FAR 6.302-1, Only One or a Limited Number of Responsible Sources, and No Other Supplies or Services Will Satisfy Agency Requirements.

V. DEMONSTRATION THAT THE CONTRACTOR’S UNIQUE QUALIFICATIONS

OR NATURE OF THE ACQUISITION REQUIRES THE USE OF THEAUTHORITY

CITED ABOVE:

The agency's minimum needs can only be satisfied by the unique supplies or services available from only the above cited source whom possesses unique capabilities demonstrated as follows:

GE Aviation Systems, LLC is the only source that possesses the complete engineering data package that includes assembly, schematic and test procedures for these items. Solicitation must be made to this source as complete engineering data packages are not available for competitive solicitation. Repair Method Suffix Code (RMSC) of 3H is assigned for the BCEM and RTRU.

RMSC of 3H means the Government physically does not have in its possession sufficient accurate or legible data to contract repair with other than the current source. As the manufacture of the BCEM and RTRU, GE Aviation is the only source that possesses the complete data package, skills, expertise, and specialized test equipment necessary to successfully repair these items.

VI. DESCRIPTION OF EFFORTS TAKEN TO ENSURE THAT OFFERS ARE

SOLICITED FROM AS MANY POTENTIAL SOURCES AS DEEMED PRACTICABLE:

Due to reliability issues with the BCEM since installation causing higher than anticipated failures and condemnations, no attempts have been made to acquire the data for the BCEM AFLCMC Engineering is currently investigating another part (emergency power BUS relay) that is causing the damage and high BCEM failures. Until the cause(s) of the failures is resolved, we cannot consider the item as design stable. Estimated time for resolution is Feb 2018. Once a solution is approved that will allow the BCEM to be considered design stable, attempt will be made to acquire the logistics support needed to establish organic depot repair at Warner Robins Air Logistics Center (WR-ALC). This includes acquisition of logistics elements (data, hardware, test program sets, etc.) to be identified through a Depot Maintenance Activation Working Group

(DMAWG).

The data on the other item, the RTRU, was not acquired due to the item being identified as non-core, low demand/high reliability and as such the item was approved for contract repair on the Source of Repair Assignment Process (SORAP) decision.

VII. DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND REASONABLE:

The overall cost of this acquisition will be fair and reasonable to the Government. In accordance with FAR 15.403-4, the contractor will be required to provide certified cost and pricing data to be used in supporting the Government’s evaluation of the proposed cost. The proposed skill mix of labor, labor hours, types and quantities of material, other direct costs, and direct and indirect rates will be negotiated by the Government based on recommendations from the Defense Contract Audit Agency (DCAA) and expert technical personnel supporting the program. The contract price will be negotiated in accordance with the procedures in FAR Part 15 ensuring the ultimate cost to the Government is fair and reasonable.

VIII. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED AND THE

RESULTS, OR A STATEMENT OF THE REASONS MARKET RESEARCH WAS NOT

CONDUCTED:

The BCEM and RTRU are aircraft components that are part of the Emergency Power System (EPS) on all models of C-5 aircraft and the BCEM is additionally used in conjunction with the auxiliary power unit (APU) system on C-5M model aircraft. The current repair contract was awarded for a period of two (2) years with firm fixed priced line items for repair and test with no faults found, an over and above line item for in scope work to be negotiated as identified, and “not separately priced” data line items. Also, a Beyond Economical Repair (BER) line was added to cover any potential condemnations that might incur costs for testing or other work done prior to determining that they are beyond economical repair. Contract was awarded sole source.

The current repair source is:

GE Aviation Systems, LLC (CAGE for award 19623, CAGE for Performance/Repair Facility is 1VBY9) 1000 MacArthur Memorial Hwy Bohemia, NY 11716

NAICS: 336413

PSC/FSC: J016

System design problems with the EPS necessitated changes and redesign of the BCEM twice and there are still reliability issues that are being worked on the BCEM. Because of these issues, the item is not considered design stable. Plan is that once the item is determined to be design stable, logistics support will be acquired to enable organic repair. Until then the repair will be sole source to the OEM.

The other item, the RTRU, is considered a developmental item that is qualified for form, fit, and function for application in the C-5 Emergency Power Generation System. The Air Force determined that it would not acquire the original equipment manufacturer (OEM) acceptance test procedures, manufacturing practices, repair procedures, parts list, and drawings due to the high reliability/low demand for the RTRU.

A reverse engineering (RE) effort would require additional funding, engineering manpower (government or contract), and time. Based on engineering experience and past RE efforts, it is anticipated that a RE effort could cost approximately $2,000,000-$5,000,000 and would require 5-7 years to complete. Furthermore, there would be no guarantee of success because reliability issues with the BCEM since installation have included higher than anticipated failures and condemnations causing the current BCEM to be an unstable design. At this point, a RE effort cannot be economically justified nor could the C-5 Engineering Office successfully complete such a project within the timeframe required to support current demands.

The BCEM & RTRU are not offered for sale, lease, or license to the general public. These are not commercial items and cannot be acquired using the streamlined acquisition procedures under FAR Part 12.

Market research techniques used included internet searches for the part numbers using GOOGLE with no results. Two aviation repair stations that are qualified by the FAA for electrical and electronic accessory service were also contacted. Both confirmed that without the data they could not accomplished repairs and testing of these items.

Acquisition strategy for repair for the BCEM and RTRU should be pursued as sole source due to lack of parts data, parts assessment, repair procedures, and test procedures. Competitive acquisition of repair services from other than the OEM without the necessary data is not possible.

Based upon research done by the commodity council, there are no other existing contract vehicles that may be used to satisfy these repair requirements.

IX. ANY OTHER FACTS OTHER PERTINENT FACTS SUPPORTING USE OF THE

EXCEPTION:

None

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

ACQUISITION:

See Section VI above.

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 TH SUPPLIES:

The BCEM and RTRU which are part of the C-5 Emergency Power System (EPS) were installed as a required upgrade/modification to all C-5 aircraft prior to induction for the Avionics Modernization Program (AMP) modification. The original recommendation by the program manager on the SORAP was for contract repair on both items. The final decision on the RTRU was for contract repair, but on the BCEM it was changed to organic repair at WR-ALC. The estimated date on the transition plan for the BCEM workload to be established as organic repair is Feb 2018 which is the reason a repair contract is required.

XII. CONTRACTING OFFICER’S CERTIFICATION

The contracting officer’s signature on the Coordination and Approval Document evidences that he/she has determined this document to be both accurate and complete to the best of his/her 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.