JA SPRDL1-19-R-0335_Redacted.pdf

J&A SPRDL1-19-R-0335

No previous J&A is available

J&A SPRDL1-19-R-0335 1

Justification and Approval for Other than Full and Open Competition

1. Contracting Activity: The procuring activity for this action is the Defense Logistics Agency Land – Warren (DLA Land – Warren).

2. Description of Action: The proposed action is to award a contract on a sole source basis to Vetronix Research Corporation, CAGE Code 0LUC0, for the procurement of the new Automatic Data Processing Interface Unit (aka Utility Bus Interface Module Assembly (UBIM)). DLA Land - Warren proposes to negotiate a 5 year, long term, firm-fixed-price, IDIQ contract, using AWCF funding.

3. Description of Supplies/Services: This award is for the procurement of a new Automatic Data Processing Interface Unit, NSN: 7025-01-494-9652, in support of the Abrams tank. This item is a key component of Abram’s data communication system, as it enables the transfer of data and control signals within the tank’s data bus.

The total estimated contract value is for up to 1,664 units. For this contract, the deliverables are as follows:

a. NOUN: Interface Unit, Automatic Data Processing

b. NSN: 7025-01-494-9652

c. TACOM P/N: 12467380

d. MFR: Vetronix Research Corporation, CAGE Code 0LUC0

e. MFR P/N: UBIM-543 REV (A)

f. MINIMUM QUANTITY: 227 Ea.

g. MAXIMUM QUANTITY: 1664 Ea.

h. UNIT PRICE:

i. ESTIMATED MINIMUM VALUE:

j. ESTIMATED TOTAL VALUE:

k. PRON: EH9L0554EH

Acquisition Method Code (AMC): 3. Acquire, for the second or subsequent time, directly from the actual manufacturer.

Acquisition Method Suffix Code (AMSC): B. This part must be acquired from a manufacturing source(s) specified on a source control or selected item drawing as defined by the current version of DoD-STD-100. Suitable technical data, Government data rights, or manufacturing knowledge are not available to permit acquisition from other sources, nor qualification testing of another part, nor use of a second source part in the intended application. Although, by DoD-STD-100 definition, altered and selected items shall have an adequate technical data package, data review discloses that required data or data rights are not in Government possession and cannot be economically obtained.

4. Authority Cited: The statutory authority permitting other than full and open competition is Title 10 United States Code (U.S.C.) Section 2304(c)(1), as implemented by FAR 6.302-1, J&A SPRDL1-19-R-0335 2

“Only one responsible source and no other supplies or services will satisfy agency requirements.”

5. Reason for Authority Cited: The Automatic Data Processing Interface Unit is a critical item of the data bus system of the M1 Abrams tank. This item is source controlled by Vetronix Research Corporation, CAGE Code 0LUC0 and must meet the requirements specific to its intended function in accordance with Source Control Drawing 12467380. Only the Automatic Data Processing Interface Unit produced by the manufacturer identified above is approved for use in the Abrams tank by The United States Army TACOM Life Cycle Management Command (TACOM LCMC). A substitute item cannot not be used without prior approval by TACOM. It is imperative that this product meets and demonstrates compliance to established performance, design, test, manufacture, and acceptance requirements as specified in spec SC-SA15153 --including testing for compliance with EMI and EMR shielding and nuclear hardening. This product is a survivability item and is critical for the soldiers’ safety.

Vetronix Research Corporation has developed, tested, and obtained Government approval for this item for application in the Abrams tanks at their own cost. Only this source has the capability to manufacture the Automatic Data Processing Interface Unit, to perform failure analysis, develop inspection and acceptance criteria for components, and to repair/rebuild and test this item. Installing hardware that has not undergone similar verifications, to ensure proper interfaces between the utility data bus and the discrete data and controls signals, could cause extensive damage to its mating components and to Abrams electrical power system. Under battlefield conditions, such a failure will render the tank unable to proceed with its mission function.

Currently, Vetronix Research Corporation is the only approved source to make this item for the US Government (USG). This manufacturer is the sole owner of the build-to-print technical data package (TDP). Reverse Engineering is the only option for the USG to develop a competitive TDP – which is needed for full and open competition. Reverse Engineering is a multi-layered process; it requires the procurement and testing of prototypes to understand current function, the design of the new product, prototyping and testing the new product to ensure functionality, and the release of the design into the Army supply system. These efforts involve a significant amount of time and money. The USG does not have the funding required to develop and qualify additional sources for this product. Even if a reverse-engineering effort was affordable, this process would incur excessive lead-time delay. A new manufacturer’s prototypes need to be tested in conjunction with the overall electrical system of the Abrams tank. The cost to reverse-engineer this unique component is estimated at $2.45M and 53 months to complete. Reverse Engineering the TDP includes, but is not limited to the following:

Reverse Engineering Activity Delay Costs Obtain existing part samples 4 months $ 2,194 Hardware design, integration and fabrication/install 20 month $ 750,000 Component and vehicle system testing 20 months $1,500,000 Documentation (drawings/ECP/Tech Manuals) 9 months $200,000 Total Estimated Time to Reverse Engineer 53 months $2,452,194M

J&A SPRDL1-19-R-0335 3

The Government would not be able to recover, through subsequent competition, the additional costs involved in either procuring the proprietary data or reverse engineering the item to create a competitive package. At the current usage rate of 156 units per year, at the current unit cost of ea, and assuming the 25% saving achieved through competition, the annual savings would take years to offset the estimated $2.25M cost of reverse engineering the item and qualifying another source.

6. Efforts to Obtain Competition: No vendors are in the process of being qualified at this time, nor will be prior to the contract award.

The Government intends to solicit only from Vetronix Research Corporation based on the rationale provided in paragraph 5 above. The notices required by FAR 5.201 shall be published for this effort, and any bids or proposals received will be considered. There has not been any expressed interest by any known contractors to become a qualified source to produce this Interface Unit, Automatic Data Processing.

To ensure the contractor competitively awards subcontracts to the maximum extent possible, the contract will contain FAR Clauses 52.244-5, “Competition in Subcontracting,” and 52.244-2, “Subcontracts.” Vetronix Research Corporation will also be required to submit subcontracting plans for review and approval.

Any new vendor who decides to pursue the qualification process will be directed to the Competition Advocate’s Source Approval Program. The Competition Management Office (CMP) will encourage interested parties to submit a Source Approval Request (SAR) for future buys.

There has not been any expressed interest by any known contractors to become a qualified source to produce this Interface Unit, Automatic Data Processing.

7. Actions to Increase Competition: As stated in section 5 above, there is no build to print TDP available to support a competitive procurement. This item is source controlled to Vetronix Research Corporation, CAGE Code 0LUC0. This manufacturer owns the technical data and is the only approved source of supply for this item. Because a significant amount of time and money would be necessary to reverse engineer, procure and test prototypes, and release the design (also stated in section 5), the Government is not actively pursuing the development of a competitive TDP for future procurements.

8. Market Research:

The Automatic Data Processing Interface Unit (NSN: 7025-01-494-9652) does not appear on either the Competition Advocate Shopping List (CASL) or the Advance Procurement Planning List (APPL), dated 15 February 2019. Market research was performed by GVSC Engineering by reviewing vendor catalogs and available product literature, published online, to determine if commercial items or non-developmental items are available or could be modified to meet

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Approval Authority for Acquisitions Equal to or Greater Than $700,000.

APPROVAL OF JUSTIFICATION

FOR OTHER THAN FULL AND OPEN COMPETITION

Based on the foregoing Justification, I hereby approve the procurement of the following:

a. Noun: Automatic Data Processing Interface Unit

b. NSN: 7025-01-494-9652

c. LTC Minimum Quantity: 227Ea.

d. Minimum Qty. Estimated Value:

e. LTC maximum Qty.: 1664 Ea.

f. Quantity with Option: N/A

g. Maximum Qty. Estimated Value:

This action will be awarded under other than full and open competition pursuant to the authority of 10 USC 2304(c)(1) and subject to the availability of funds. This approval is subject to the provision that the property herein described has otherwise been authorized for acquisition.

Signature:

Date: SHEARER.MARY.E.125070

Digitally signed by

SHEARER.MARY.E.1250702449

Date: 2019.08.23 07:28:05 -04'00'