JA_TruLogic_CA Signed_Redacted.pdf

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

CONTROLLED UNCLASSIFIED INFORMATION

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The USAF through the Air Force Life Cycle Management Center and the Propulsion Sustainment Contracting Office (AFLCMC/LPK), requests approval to procure non-commercial services for the sustainment of the General Electric (GE) Engine Interactive Electronic Technical Manuals (IETMS) support for the USAF under the Justification and Approval (J&A) for Other Than Full and Open Competition detailed in this document. This is a class J&A, which a class J&A is appropriate based on the expectation that there will be multiple task/delivery orders generated from the basic contract and the inclusion of FAR 52.217-8. The task/delivery orders and the six month extension of services allowed under FAR 52.217-8 will be for the same work that is in the basic contract and therefore will be in-scope work.

This action will be a follow-on non-commercial, firm-fixed price Indefinite Delivery Indefinite Quantity (IDIQ) contract. The contemplated contract is for the preparation and sustainment of specialized USAF format technical orders to support the USAF GE Engine Models F101-102, F110-100/-129, F118-100, F118-101 and any additional variants as applicable. Interactive Electronic Technical Manuals (IETMS) intermediate, depot level, and special purpose technical procedures and equipment from TruLogic Inc., 1430 Oak Ct., Suite 311, Beavercreek, OH 45430. Cage Code: 1J7H7.

The resulting contract is not a Bridge Action as defined in AF Bridge Action Reduction Plan. This procurement is to satisfy a bona fide need to support the sustainment of the GE Engine Models F101-102, F110-100/-129, F118-100, F118-101 and any additional variants to these engine models as applicable. The contemplated follow-on contract action will be in accordance with (IAW) FAR Part 15. A one-year basic contract with four one-year options plus the 6-month Option to Extend Services under FAR 52.217-8 is appropriate for this acquisition. A class J&A is appropriate due to the inclusion of FAR 52.217-8, Option to Extend Services. The six-month extension of services allowed under FAR 52.217-8, will be for the same work in the basic contract and will therefore be in-scope work. The estimated total value of this contract is with an estimated award date of April 2024. The Ordering Period (OP) for the anticipated contract is estimated to begin on 11 April 2024 and extend through 10 September 2029. The Period of Performance (PoP) will be cited on individual orders as they occur. A class J&A is appropriate based on the expectation that there will be multiple task/delivery orders generated from the basic contract. Because the task/delivery orders will be authorized by the basic contract, the orders will be for in-scope work.

Previous Contract History:

Contract Number: FA8124-19-D-0003 Award Date: 19 August 2019 Completion Date: 10 April 2024 Contract Value:

Basis of Award: Sole Source Period of Performance: 11 April 2019 thru 10 April 2024

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TruLogic is the only source capable of providing the expertise, knowledge, and exclusive data rights to meet the USAF IETMS requirements. TruLogic designed the digital viewer and developed the highly specialized software to read the IETMS.

This acquisition is to obtain technical publication services for the GE Engine Models F101-102, F110-100/-129, F118-100, F118-101 and any additional variants to these engine models as applicable, as well as, Intermediate, Depot, and special purpose manuals. Specific tasks include: technical writing, illustrating, research (ensuring accuracy, adequacy, compatibility and suitability for Air Force use to maintain technical integrity), analysis of modification data, evaluation of Air Force Technical Order Recommend Change Publication Change Request, and all requirements necessary to develop new technical orders or changed/revised technical orders to support the GE Engine Models F101-102, F110-100/-129, F118-100, F118-101 and any additional variants to these engine models as applicable. All technical data will be viewable on Standard Desktop Core Configuration (SDCC) approved Air Force Viewer. The services shall also include technical order status and schedules, conference attendance/support, and any potential IETMS enhancements or conversions that will be negotiated at the time requirements are identified/priced under the scope of this J&A. This data shall address all configurations of the engines listed above. The services include maintaining a common and unique database for the engine manuals. All the technical orders produced will be maintained and distributed in a paperless environment. The data will be delivered as Web Application (WA-1) via DoD Safe, CD or DVD ROM in an IETMS's System format up to four times (quarterly) every calendar year.

CONTRACT SUMMARY

Year Estimated Dollars Estimated OP's BASIC April 2024 - March 2025 OPTION I April 2025 - March 2026 OPTION II April 2026 -March 2027 OPTION III April 2027 - March 2028 OPTION IV April 2028 - March 2029 -8 OPTION April 2029 - September 2029

ESTIMATED TOTAL

CONTRACT VALUE April 2024 - September 2029

CLIN Description Max Qty Unit Price BASIC YEAR COST

0001 Type II Build/Delivery of Block Cycle Updates (BCU) 34

0002 Sustainment/Delivery of Change Pages (Non-Mod) 4127

0003 Sustainment/Delivery of ECP/MOD Pages 616

0004 Development/Delivery of Rapid Action Changes (RAC) 16

0005 Travel (Cost Reimbursement) 1

0006 Data NSP

0007 Delivery of Converted IETMS Work Packages 2316

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0008 Master Support Equip/Consumable Tbl Auto-Generation 1

0009 Process and Delivery of Generated Reports 34

0010 Graphic Navigation Interface (GNI) 1

0011 Engine Automated Work Package (EAWP) Enhancement

0011AA Server Environment Definition 1

0011AB Form Modifications 1

0011AC Client-Side Mod &Integration w/Server-Side 1

0011AD PPR Delivery and PPR Comment Resolution 1

0012 Calculations Sheet or EAWP Form Generation

0012AA Calculations Sheet or EAWP Form Generation 1

0012AB Editorial Change Existing Page 1

0012AC Programming Changes Existing Sheet or Form 1

0013 Portable IETM Reference Library 1

0014 IETM Enhancements 1

0015 GFE Workstation Support 1

TOTAL

* Option CLINs will be numbered as follows:

Option Year 1 - CLIN 1001

Option Year 2 - CLIN 2001

Option Year 3 - CLIN 3001

Option Year 4 - CLIN 4001

IDIQ Minimum Order Requirements are as follows:

CLIN MIN QTY UNIT PRICE ESTIMATED DOLLARS

0001 17 0002 2064 0003 308 0004 8 0008 1 0009 17 0010 1

0011AA 1

0011AB 1

0011AC 1

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0011AD 1

0012AA 1

0012AB 1

0012AC 1

0013 1 0015 1

TOTAL

Operation & Maintenance 3400 appropriations will be used for the task orders issued under the IDIQ. The estimated unit prices were calculated utilizing a average inflation rate over the past few years of the current contract found via the Bureau of Labor Statistics and growth IAW the 2023 North America Short Term Forecast table (found at https://usaf.dps.mil/sites/TMCA19327/PKC/ PKCF/North%20American%20Forecast%20Tables/Forms/AllItems.aspx?viewid=8e0ad112%2D37aa% 2D4106%2D8068%2D03e941fd609c). The relevant data was found under the "Aerospace & Defense" and furthermore in the aircraft engines and engine parts category. The was applied to the basic year and ( ) was applied for every option year. No intellectual property (IP) CLINs will be included, as the data rights are not available for purchase from TruLogic. There will be no CLINs for intellectual property rights, which is consistent with the approved acquisition strategy. This J&A covers all contract actions including options, and task orders for all CLINs detailed in the CLIN table above. Estimated total contract value is the maximum IDIQ dollar value.

Due to the circumstances described in Section V, IX and XI, there are no feasible actions that could develop future competition within the performance period of this contract. Therefore, it is considered appropriate to seek approval for more than one year. Should an additional source(s) become known, any remaining options will not be exercised, and this J&A will not be used to support any buys using other than full & open competition.

This is a follow-on contract for the acquisition of technical publications of the engine programs for the GE Engine Models F101-102, F110-100/-129, F118-100, F118-101 and any additional variants to these engine models as applicable. The required services are unique and are provided by only one responsible source.

TruLogic owns the exclusive rights to the technical data conversion software and commonality database for General Electric (GE) Engine Models F101-102, F110-100/-129, F118-100, F118-101 and any additional variants as applicable engine interactive electronic technical manuals. Due to the proprietary and customized nature of the software program and the associated services TruLogic is the only responsible/ capable source. TruLogic has the expertise and experience to maximize compliance and accuracy of the associated technical orders, as well as minimize the time necessary to integrate any necessary changes to these publications which directly support the war fighter. Currently, the USAF does not possess the required expertise to re-engineer or to program a replacement software platform for maintaining the IETMS's databases that are currently in use.

TruLogic's software uses the commonality tags as the way to change one tech order and have it mirrored in the other common tech orders. Therefore, this acquisition will be a

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TruLogic's software is the only known software available to be able to provide this functionality. This provides a reduction in cost, time, and effort for the Government. Failure to procure this service support will adversely affect the USAF mission, creating a work stoppage resulting from a lack of support and services. The TruLogic software used by the USAF for the IETMS for the GE Engine Models F101-102, F110-100/-129, F118-100, F118-101 and any additional variants to these engine models as applicable.

These engines have been highly modified to support the GE Engine Common Core/Common Data concept.

TruLogic's Common Data programming allows the USAF to re-utilize massive amounts of common core engine data which is shared among nine different IETM programs. If a portion of technical data is changed or added which is part of those common areas, that data is only authored once but updated in all applicable technical orders. TruLogic's programming and proprietary system allows for the USAF to benefit from this process which reduces time and cost during the IETMs publication process. The USAF benefits as there is a single cost for incorporation of the data one time for all applicable technical orders. This process increases the consistency and accuracy of the technical manuals as a large portion of the information included in the nine different databases are common. TruLogic has identified that they will not provide the Government with data rights to the proprietary software per letter dated 23 June 2023. The IETMs are issued to the Government with a non-exclusive license for Commercial Computer Software-Restricted Rights. The End User License Agreement (EULA) has been provided to the Government and was developed in concert with TruLogic, GE Aviation and the USAF (Tinker). This EULA identifies that TruLogic's software is identified as commercial computer software IAW DFARs 227.7202 but is not currently available on the commercial market. Per DFARs 227.7202-1(c)(2), TruLogic is not required to relinquish to, or otherwise provide, the Government rights to use, modify, reproduce, release, perform, display, or disclose commercial computer software or commercial computer software documentation except for a transfer of rights mutually agreed upon. Market research has determined that there is not another software system which provides the necessary functionality of the common data concept. With the lack of necessary data rights, there are no immediate actions that could be taken to develop future competition.

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The rough order magnitude estimate for the Government to acquire the licensed software tools, documented procedures, setup, testing, training and materials, a two-phase migration process and an initial period of on-line and telephone technical support is as follows. The period of performance from start to a turn-key operation (provided no delays in Government acquisition, setup and continual support of the required hardware and network environment) is estimated at 24 - 30 months. Modifications to our current factory software would be required at the start to incorporate �ease of use interfaces� to the authoring and publication process to minimize the level of training required, an important factor to consider in a moderate-level personnel turnover environment. The two-phase migration consists of the initial phase-one programming and setup of the authoring environment at Tinker and training of Government personnel on the aspects of SGML authoring, QA, and maintenance of the Government-owned technical data in the common data environment. Initial IETM publication would remain at TruLogic during phase one. Phase two consists of the initial programming and setup of the IETM publishing environment at Tinker and the training of Government personnel on the tasks related to publishing, QA and distribution of the IETM system. An initial period of technical support is included to round out the transfer of management and responsibility period. Estimated cost is for the tasks and materials required to support this initial two-phase migration for the maintenance and publication of the IETM system to a Tinker-based organic operation. Follow-on technical support and a software licensing and maintenance program would be an on-going process needed to monitor and provide routine software updates, system improvements and upgrades, additional training, travel, and technical support as needed. As there is a current lack of data rights for the current system, re-engineering would be required to be conducted by the USAF which would be a duplication of costs already spent on the initial development and long-term sustainment services that have been provided by TruLogic. No IP or Data rights were acquired in the previous contracts with TruLogic and the possiblity of acquiring these rights were denied again by TruLogic in a letter dated 23 June 2023.

Costs include but are not limited to Non-Recurring Engineering for redesign and extensive re-engineering efforts required to establish a sustainable baseline for the technical publication support needed to fulfill the requirement. Re-engineering with an alternate technical publication support system would also create unacceptable schedule delays that would result in a lapse of depot maintenance and the loss of trained personnel. This would also require the organic capability of the USAF to support and sustain this new system. Neither of these options are currently viable, nor are they expected to become viable in the foreseeable future. Therefore, it is considered appropriate to seek approval for more than one fiscal year's requirements and options have been included in this acquisition. This J&A also requests approval for a duration longer than one year to ensure continuity of service from the software developer, who is the only source capable of providing the expertise, knowledge, and exclusive data rights to meet the USAF IETMS requirements. Accordingly, TruLogic is the only firm capable of providing the services described in Section III above without the USAF experiencing substantial duplication of cost that could not be expected to be recovered through competition and unacceptable delays in fulfilling its requirements.

Pursuant to FAR Part 10, market research was concluded on 20 June 2023 through SSS FA8124-23-SS- IETMS posted on 18 May 2023 and ending on 2 June 2023 in conjunction with internet searches using search engines. There were three respondents to the sources sought. The research revealed no other potential sources possess Trulogic's proprietary software/database. Therefore, all respondents outside of TruLogic were not able to fulfill the Government's requirement. The future contract actions such as the Request for Proposal (RFP), and post-award synopsis will be posted IAW FAR 5.203. There will also be a synopsis pre-RFP IAW FAR 5.201.

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The Contracting Officer will ensure that the items described herein are negotiated at a fair and reasonable price to the Government. IAW FAR as supplemented, the contractor will be required to submit Certified Cost or Pricing Data and/or Other Than Certified Cost or Pricing Data. A detailed cost analysis and price analysis will be performed. The Contracting Officer will request a technical evaluation from the Defense Contract Management Agency (DCMA) to aid in the evaluation of the contractor's proposal. The Contracting Officer will seek audit assistance from the Defense Contract Audit Agency (DCAA) if necessary.

Pursuant to FAR Part 10, market research was concluded on 20 June 2023, signed by the contracting officer and program manager, through SSS posted on 18 May 2023 and ending on 2 June 2023 in conjunction with internet searches using search engines. Market research revealed no other potential sources, neither military nor commercial, with the ability to obtain TruLogic's proprietary software package to view the TOs or provide engine manuals sufficient to meet the USAF's IETMS requirements. No other market research was conducted. The software required to provide necessary services is only available from the OEM. Commercial services are not available, nor can a commercial service be modified to meet the government's requirement in a timely and economical manner. There is no commercial or non-developmental service available to meet the Government's requirements. The current Air Force data resides in a data use rights structure married to a modified version of a Trulogic-owned document management and IETM publication system to develop technical data and convert this data into engine manuals.

No further information.

This acquisition is currently sole source due to proprietary software and the commonality tag database that was developed solely for USAF IETMs efforts for these engine technical orders.

As a result of continued refusal by the sole source contractor to provide or license data as well as the duplication of cost and unacceptable delay of developing additional sources per Sections IV and X, there are no known additional actions which can be taken to remove barriers to competition and therefore, specific actions and milestones cannot be established.

Per PGI 206.304(a)(S-70)- As indicated by signature on the Coordination and Approval Document, the previous J&A has been reviewed and the Approval Authority determines that all stated actions to remove

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As evidenced by their signature, the contracting officer certifies that this justification is accurate and complete to the best of their knowledge and belief.

As evidenced by their signatures, the technical and/or requirements personnel have certified that any supporting data contained herein, which is their responsibility, is both accurate and complete.