JA_Short_Gage Block Comparator Upgrade Redacted.pdf

Justification and Approval (J&A) for Other Than Full and Open Competition

FOR OFFICIAL USE ONLY

March 2018 FOR OFFICIAL USE ONLY Page 2 of 4

I. Contracting Activity.

AFMETCAL/WNMK, 813 Irving Wick Drive West, Heath Ohio 43056-1199.

II. Nature and/or description of the action being processed.

This J&A is for a new sole source, firm-fixed-price commercial contract to upgrade the Short Gage Block Comparators. The proposed contractor is Mahr Federal Inc. (Mahr).

Based on Market Research and the Sources Sought Synopsis, the Original Equipment Manufacturer (OEM), Mahr, is the only manufacturer that can supply this upgrade. Mahr's responses to the Market Survey indicate the components, data, and specialized training required to accomplish the upgrade are not available through other vendors. Further, the Mahr software and source code needed for the upgrades is proprietary to Mahr.

The purpose of this requirement is to upgrade 20 Air Force P/N 130B-24 Short Gage Block Comparators currently in use at Precision Measurement Equipment Labs (PMELs) around the world. The units are over 10 years old and critical to support the Air Force mission. The upgrade will include replacement of the amplifier, gage heads, controller, and software. The acquisition will include on-site installation and one day of training by an applications engineer or technician. The risk of this contract should be minimal because the Mahr130B-24 Short Gage Block Comparator Upgrade controller and associated components are currently commercial-off-the-shelf (COTS) products.

As Mahr does not authorize other contractors to support its equipment nor does it share the detailed data required to do so, there would be a substantial duplication of costs to the Air Force that is not expected to be recovered through competition. Therefore, the Government will pursue a sole source acquisition, utilizing FAR 6.302-1: Only One Responsible Source and No Other Supplies or Services will Satisfy Agency Requirements.

III. Description of supplies/services required to meet agency needs.

The current short gage block comparators used by the United States Air Force (USAF) PMELs are becoming unreliable, and in the current configuration, they are not able to be supported by the OEM. Short gage blocks are used to support the calibration of many aircraft fixtures such as the F-16 Aft Reference Boresight Calibration Fixture Assembly (33K6-4-3669-1) and the F-16 Diameter Exhaust Nozzle Diameter Gage (33K6-4-1488-1). To maintain calibration support, it is recommended the current short gage block comparators be upgraded.

The upgrade will make the Air Force 130B-24 Short Gage Block Comparators identical to the new ones currently being sold by Mahr. The upgraded unit is expected to have a life-cycle of 15 to 20 years, including anticipated supportability of at least 10 years.

It is anticipated 20 units will be upgraded from FY21-FY23 using 3080/Investment funds at a total estimated price of

IV. Statutory authority permitting other than full and open competition.

10 USC 2304(c)(1), as implemented by Federal Acquisition Regulation (FAR) Part 6.302-1(a)(1) Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements, and required by FAR 6.303-2(b)(4).

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

Only One Responsible Source FAR 6.302-1 - This acquisition is to procure replacements for outdated system components, update the system control software, and extend the working life of the system for 15 to 20 years. The 15 to 20 year life expectancy is the same as the life expectancy of a new unit. The control system contains proprietary software and proprietary hardware interfaces, and only the OEM has the proprietary data required to accomplish full system integration, functionality, control, and communication. Award to any other source would result in substantial

March 2018 FOR OFFICIAL USE ONLY Page 3 of 4 duplication of cost to the government that is not expected to be recovered through competition.

These upgrades will preserve and expand the currently used automated calibration programs and procedures, whereas the procurement of a new system would require development of a new set of programs and procedures. The development of a new set of programs and procedures would cause an extra delay of three to six months. This delay is unacceptable as this is a large and critical PMEL workload. The total estimated price for the upgrade is per unit multiplied by 20 units for a total of Based on market research, the estimated cost of a new system is per unit or a total of o replace 20 systems. The AFMETCAL Technical Team determined the proposed system upgrade would save and provide superior capability to the full replacement option.

Without this acquisition, AFMETCAL risks significant down time and increased calibration costs because future calibrations will have to be obtained from commercial calibration sources. Due to the proprietary nature associated with the short gage block comparator and software, Mahr would not sell the rights. Thus another company would not be able to upgrade the comparator.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

AFMETCAL Contracting and Small Business Representative issued a Sources Sought Synopsis with draft purchase description on November 4, 2020, and no responses were received. AFMETCAL reached out to Mahr directly, in which Mahr stated it is not possible for another vendor to buy all the parts needed to complete the upgrade. These gages have to be rebuilt by trained technicians using proprietary methods and procedures. Mahr's software source code is also proprietary. To obtain competition, new short gage block comparators would need to be purchased.

As required by FAR 5.2, the proposed contract action will be synopsized on Beta.Sam.gov. We intend on posting this proposed contract action on, or around, 26 February 2021.

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

A price analysis will be used to verify the overall price offered is fair and reasonable. Price Analysis will be based on comparison to the Government estimate per FAR 13.106-3(a)(2)(vi).

VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

As described in Section VI of this document, market research, IAW FAR Part 10, was conducted by synopsis to advise industry of the proposed acquisition and to solicit inquiries from interested parties. No responses were received and engineering reached out to Mahr directly. Based on the results of this market research, the AFMETCAL Technical Team determined a system upgrade provides the best value to the government, and there is no vendor, other than Mahr, able to perform the upgrade as required for this acquisition.

IX. Any other facts supporting the use of Other Than Full and Open Competition.

The required software necessary to operate the upgraded short gage block comparator is proprietary to Mahr.

The upgrade to the 130B-16 by Mahr will be able to satisfy customer requirements based upon the market research performed and the engineer's knowledge of the items to be procured. The component items are COTS items, so delays in delivery are not expected. There is no expectation that administration of this contract will be difficult.

X. List of any sources that expressed, in writing, an interest in the acquisition.

Mahr Federal Inc.

1144 Eddy Street Providence, RI 02905-4511 POC: George Schuetz

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Phone: (401) 784-3274 E-mail: george.schuetz@mahr.com

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.

Mahr is the manufacturer of the original systems, and this procurement is for the upgrade of AFMETCAL's 20 original systems. The upgrade requires replacement components and specialized training that is not available through other vendors. It also involves proprietary software source code, which the OEM is unwilling to release to other vendors. For this requirement, there is no other action that can be accomplished to generate competition without a substantial duplication of costs. This procurement will provide the best value to the Government at this time. A sole source effort is required for the base quantities and option years to prevent significant downtime and increased calibration costs due to the proprietary data involved with the upgrade. AFMETCAL will continue to monitor the market place to see if other viable vendors become available for future acquisitions.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.