JA-SPRDL1-24-R-0016_Redacted..pdf

SPRDL1-24-R-0016 (J&A 00749)

No Previous J&A

Pelican Products, Inc. (CAGE 65442) is the approved manufacturer of the shipping and storage container.

The Keypad 12999084 is part of the Paladin Digital Computer Unit (PDCU) system, which performs computations and weapon control, and provides the interface between the Paladin Digital Fire Control System computer and the radios. Data entered at the keypad are stored in the PDCU and are displayed on the Paladin Display Unit.

The Government does not have the pertinent technical data to enable competitive re-procurement. The Government does not own the necessary intellectual property data rights to the pertinent technical data to enable competitive re-procurement.

The Government does not have the specs or the complete build to print TDP.

Additionally, the Government does not have proprietary rights.

The keypad 12999084 is a critical item for the M109 Howitzer Family of Vehicles (FOV).

The Government has a top-level drawing which is not fully defined and has no access to the approved source's detailed Level III TDP. In addition, the source-controlled drawing 12999084 does not disclose all the information necessary to produce this keypad. In fact, the technical data available to the Government is not adequate for competitive procurement of this item.

Sechan Electronics Inc. (7Z941) has developed this item at their own expense, therefore owns the technical data and all the associated performance specifications needed to produce this kit. Engaging in a competitive TDP development effort would potentially result in prohibitive costs and time delays for the Government. No contractor other than Sechan Electronics has the capability to manufacture or produce this item.

Sechan has invested their resources in the development, design, and establishment of the manufacturing practices, therefore retains the rights to the technical data. Sechan Electronics' keypad is the only part to date that has met the M109 program's requirements. This manufacturer possesses the unique technical qualifications and experience to satisfy the Government need to manufacture this keypad. To competitively procure the keypad, the Government would have to acquire the rights to access and use Sechan Electronics’ detailed TDP needed for a new contractor to manufacture the part and conduct all the required acceptance testing. Sechan Electronics is the only contractor who has the required technical and engineering knowledge, production facility capability and expertise, internal configuration control, quality testing capability, and the overall management capability necessary to produce this item and is not willing to make the detailed TDP available to the Government.

Engaging in the process of acquiring this part from a source other than the sole source other than the sole source Sechan Electronics would result in a substantial duplication of cost, which would not be recovered through subsequent competition. Even if the Government has access to Sechan Electronics’ technical data, any new source will have to spend considerable long periods of time to gain extensive experience with the keypad before being able to manufacture it. This will not only result in unplanned cost, but also a prohibited delivery delay.

As stated above, competitive procurement is not an option at this time. The table “Duplication of Cost through Reverse Engineering” below gives the details of the estimated reverse engineering and associated costs if the Government would like to pursue competitive TDP acquisition. These estimates, as discussed below in Paragraphs a through e, are based on engineering experience and similar items costs.

Duplication of Cost through Reverse Engineering:

Army Combat Capabilities Development Command (DEVCOM) - Armaments Center (AC) engineering estimates the cost to develop a competitive package for this keyboard through reverse engineering, could run as high as $900,000. This includes fabrication and testing of the prototype hardware and releasing a validated TDP. The subtasks involved in this task would include the following: identify all deficiencies, conduct market research on available parts and components, work in conjunction with BAE Systems Land and Armaments, identify the system’s components and their interrelationships;

obtain existing parts; tear down and understand the design; create representations of the system in another form or a higher level of abstraction; create the physical representation of that system, fully define functional parameters, generate Bill of Materials document, build prototypes, and then create a new TDP which would include component drawings, performance specifications, and qualification procedures.

Since there are no procedures in place to determine whether other sources are qualified to meet the Government’s requirements, it would take approximately an additional $700,000 for the U.S. Army, DEVCOM AC engineers to develop the requirements and qualification procedures for the prospective contractors to manufacture and qualify the new keypad.

It would cost at least $500,000 to conduct the actual engineering testing/analysis in collaboration between the United States Government engineers and BAE Systems Land and Armaments, including the cost for any additional test equipment or fixtures;

component, safety and system level/ higher level assemblies testing, or end item systems required to test the item. Plus, any costs for test facilities and testing on the end item, to ensure proper field operation. The analysis includes conducting the actual verification testing, reviewing the engineering data, and preparing a technical report to determine whether a newly designed kit has successfully met the qualification process.

Paragraph Task Cost Estimate a.

b.

c.

d.

e.

Reverse Engineering of Application Specific Design Development of Qualification Procedures/Requirements Testing/Analysis of Application Specific Design Logistical Development System Support Package (SSP)

$900,000 $700,000 $500,000 $350,000 $300,000

Total $2,750,000 the overall estimated schedule delay to (see “Scheduling Delay Concern Table” above). A delay of this extent is not acceptable.

6. Efforts to Obtain Competition:

a. Effective competition: Due to the reasons cited in section 5 above, the Government is not pursuing competition for this item.

b. 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 (DoD Contracts)," to maximize small business opportunities and utilization.

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.

Due to the costs associated with developing a competitive TDP that cannot be recovered, the Government is not actively pursuing the development of a competitive TDP for future procurements.

8. Market Research: A Sources Sought Notice was posted to SAM.gov on 16 November 2023, and was open for 16 days. No responses were received.

DEVCOM-AC engineer conducted market research on 14 December 2023, by performing an internet search which included searching NSN Now, and Ability One, for the kit 12999112. The searches revealed that this customized military part is not available from any other sources.

The search results are described below:

Keyword(s): 12999112 Website: NSN-NOW (https://nsn-now.com/Indexing/PublicSearch.aspx) Findings: Manufacturers CAGE Part Number Company 19200 12999112 US Army ARDEC RDECOM

Keyword(s): 12999112 Website: Ability One (https://www.abilityone.gov ) Findings: No Results