JA_SPRDL1-22-R-0041_Redacted.pdf

SPRDL1-22-R-0041 (JA-00358)

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JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN

COMPETITION SPRDL1-22-R-0041

1. Contracting Agency: Defense Logistics Agency (DLA) - DLA Land Warren.

2. Description of Action: DLA Land Warren proposes to award a new Firm-Fixed- Price contract to Data Device Corporation, Commercial and Government Entity (CAGE) 19645, for National Stock Number (NSN) 5998-01-681-9858, Circuit Card Assembly, 32 Channel Solid State Power Controller (SSPC), using Army Working Capital Funds (AWCF) under Purchase Request Order Number (PRON) EH0C0693EH.

3. Description of Supplies/Services: The NSN 5998-01-681-9858, part number RP-26611000N0-600 / 12571090, Circuit Card Assembly, 32 Channel SSPC, is used on the M2A4/M7A4 Bradley and Armored Multi-Purpose Vehicle (AMPV). The deliverables for this contract are for a base quantity of 100 each, with an option quantity of 200 each, for a total quantity of 300 each. The estimated unit price is each for a total contract maximum value, with option, of .

This item is a subcomponent of the SSPC Line Replaceable Unit (LRU) used on the Bradley and AMPV platforms. The Circuit Card Assembly, 32 Channel SSPC, function is to determine the amount of power to be delivered depending on the load being requested from a component in the vehicle.

Acquisition Method Code (AMC):

4 – Acquire, for the first 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 (STD), 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 (TDP), data review discloses that required data or data rights are not in Government possession and cannot be economically obtained. If one source is available, AMCs 3, 4, or 5 are valid. If at least two sources exist, AMCs 1 or 2 are valid.

4. Authority Cited: The statutory authority permitting other than full and open competition for this effort is 10 United States Code (U.S.C.) 2304(c)(1) as implemented by the Federal Acquisition Regulation (FAR) 6.302-1, “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Reason for Authority Cited: This item is a subcomponent of the SSPC LRU used on the Bradley and AMPV vehicles. The purpose of the Circuit Card Assembly, 32

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Channel SSPC, is to determine the amount of power to be delivered depending on the load being requested from a component in the vehicle.

Only Data Device Corporation has the requisite technical and engineering expertise to perform all efforts required to provide the Circuit Card Assembly, 32 Channel SSPC.

Data Device Corporation has demonstrated the unique and proven manufacturing capabilities to establish and maintain the processing control required to repetitively produce this item. Additionally, the Government did not fund the contractor to prepare a fully detailed TDP. As such, Data Device Corporation is the sole owner of the documents and technical data rights, and the Government does not own proprietary rights to the documents that would be required to produce a competitive TDP. The item required is mission critical. A failure of this item during operation in a Bradley or AMPV vehicle could cause extensive and costly damage.

Due to the lack of performance and technical data available on the Circuit Card Assembly, 32 Channel SSPC, Reverse Engineering is the only recourse the Government could entertain to increase competition through development of a competitive TDP. A significant amount of time and money would be necessary to reverse engineer, procure and test prototypes, and release the design. Engineering utilized a Subject Matter Expert (SME) to determine the reverse engineering costs by reviewing the costs for a previous design effort for a circuit card similar to the Circuit Card Assembly, 32 Channel SSPC. The estimated cost and time to reverse engineer the Circuit Card Assembly is $6.5 M and 60 months to perform the various reverse engineering tasks such requirement development & hardware design, integration & fabrication/installation, Reliability Assessment & Monitoring (RAM) vehicle testing and development & validation of TDP. The nature of this hardware requires significant qualification testing and system level testing.

Reverse Engineering Activity Delay (Months)

Cost

Requirement development & Hardware Design 8 $1,000,000

Integration & Fabrication/Installation 10 $2,760,000

RAM Vehicle Testing – 3 Vehicles 12 $2,250,000

Develop & Validate TDP 30 $490,000

Total Time & Cost for Reverse Engineering 60 $6,500,000

The Government would not be able to recover within a reasonable time, through subsequent competition, the duplicate costs involved in reverse engineering the item to create a new and competitive Circuit Card Assembly, 32 Channel SSPC TDP. At the current average usage rate of 20 units each year (using the demand for a similar product), average unit price of , and assuming 25% savings achieved through competition, the in annual savings would take approximate years to offset the estimated $6,500,000 cost of reverse engineering the item and qualifying another source.

SPRDL1-22-R-0041(JA-00358)

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A Cost Estimate breakdown is as follows:

Cost to Reverse Engineer $6,500,000 / ((Unit Cost x 20 each Circuit Card Assembly, 32 Channel SSPC yearly demand = ) x 25% assumed savings =

) = years.

6. Efforts to Obtain Competition:

a. Effective competition: Due to the reasons cited in section 5 above, competition will not be pursued for this item.

b. Subcontracting competition: Subcontracting competition: Unless the contract is awarded to a small business, the solicitation and resulting contract will include FAR clauses 52.219-8, "Utilization of Small Business Concerns"; 52.244-5, "Competition in Subcontracting"; 52.219-16, "Liquidated Damages- Subcontracting Plan" and Defense Federal Acquisition Regulation Supplement (DFARS) 252.219-7003, "Small Business Subcontracting Plan (Department of Defense Contracts)," to maximize small business opportunities and utilization.

Due to the reasons cited in section 5 above, competition will be limited to the source cited in section 2 above.

c. Sole Source: Notices required by FAR 5.201 will be posted.

7. Actions to Increase Competition: There are no plans to increase competition for future procurements due to the reasons cited above in Section 5.

8. Market Research: A Sources Sought Notice was posted to beta.SAM.gov on 05 October 2021 and was open for 14 days. The Ground Vehicle Systems Center (GVSC) provided an assessment of the only response received from Addon Services. The documentation sent from Addon Services was generic and didn’t demonstrate their ability to produce a SSPC that could be considered for use by the Government.

On 10 September 2020 and 21 September 2021, GVSC conducted market research by utilizing the internet with the search of ‘Solid State Circuit Card’. GVSC identified several companies that produce circuit card assemblies but due to a lack of performance requirements, at this time the Government cannot identify one that could be qualified as a source of supply for this SSPC.

9. Interested Sources: To date, no additional sources have expressed interest in this item.

10. Other Facts: No procurement history is available.

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APPROVAL OF JUSTIFICATION

FOR OTHER THAN FULL AND OPEN COMPETITION

Approval Authority for Acquisitions Equal to or Greater Than $750,000

But Less Than $15M

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

a. NOUN: Circuit Card Assembly

b. NSN: 5998-01-681-9895

c. Basic Quantity: 100 each

d. Option Quantity: 200 each

e. Maximum Quantity (with full exercise of option): 300 each

f. Minimum Estimated Base Total Value:

g. Maximum Estimated Total 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:

Competition Advocate

SHEARER.MA

RY.E.12507024

Digitally signed by

SHEARER.MARY.E.12507

02449 Date: 2022.02.02 08:49:20 -05'00'