JA W58RGZ20R0161 Redacted.pdf

Control Number:ALB-J&A20-0311 SolicitationNumber: W58RGZ-20-R-0161

FOR OFFICAL USE ONLY

JUSTIFICATION REVIEW DOCUMENT

FAR PART 6 JUSTIFICATION ANDAPPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

WEAPON SYSTEM: T700 Engine

RISK LEVEL: LOW

Program/Equipment: Upgrade/Repair of the Enhanced Digital Electronic Control Unit (EDECU), for T700 engine, utilized on UH-60 Blackhawk and AH-64 Apache on behalf of the U.S. Army Aviation and Missile Command AMCOM logistics Center (ALC)

Authority: 10 U.S.C. 2304(c)(2) as implemented by paragraph 6.302-2(b) of the Federal Acquisition Regulation (FAR) entitled, “Unusual and Compelling Urgency.”

Amount:

Prepared by:

Typed Name:

Title: Contract Specialist

E-mail:

DSN:

Date: 14 May 2020

Contracting Officer:

Typed Name: DSN:

Title: Contracting Officer Date: 14 May 2020

E-Mail:

Technical Representative:

Title: Director, Cargo/T700 Sustainment Date: 19 May 2020

E-mail:

Requirements Representative:

Title: Director, Cargo/T700 Sustainment Date: 19 May 2020

E-mail:

Solicitation Number: WSSRGZ-20-R-0161

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager:

Typed Name:

Signature:

AMCOM Legal Designee:

DSN:

Date: 15 May 2020

Signature: Date: 21 May 2020

JUSTIFICATION AND APPROVAL

FAR PART 6 JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

WEAPON SYSTEM: T-700 Engine

1. Contracting Activity: Department of the Army Contracting Command-Redstone (ACC-RSA), ATTN: CCAM-ALB, Redstone Arsenal, AL 35898-5000.

2. Description of Action: The U.S Army Aviation and Missile Command (AMCOM) Logistics Center (ALC) requests the approval to utilize a modification to an existing Firm-Fixed (FFP), Maintenance & Overhaul (M&O) contract W58RGZ-18-D-0076, and issue a new delivery order under the unusual and compelling provision, for the item listed below with Triumph Engine Control Systems, LLC, 1 Charter Oak BLVD, West Hartford, CT 06133-1328 (CAGE Code 11599) large business. Army Working Capital Funds, Reparable will be used. The quantity added via the modification 200 each which does not include Foreign Military Sales (FMS) quantities. The Government projects award for June 2020.

3. Description of Supplies/Services: ALC has an urgent requirement for contractor support to provide overhaul of the Enhanced Digital Electronic Control Unit (EDECU),in order to return the items as specified by the statement of work for the National Stock Number (NSN) identified below, to condition code A as defined by Army Regulation AR 725-50, Appendix C (Table C-38). The contractor shall furnish all services, facilities, labor, parts, materials, equipment, tools, and data necessary to complete the inspection and overhaul. The following information is provided for the

EDECU:

Weapon System: T-700 Engines Procurement Request Identification (PRID): UT401 Procurement Request Order Number (PRON): AX0MY079AX Noun: EDECU Input NSNs: 2995-01-641-8045

2995-01-572-1860 Output NSN: 2995-01-641-8045 Input Part Numbers (P/N): 4155T12P08

4155T12P07 Output Part Number (P/N): 4155T12P08 Quantity: 200

Estimated Dollar Value:

The total estimated dollar value of the proposed procurement is based on the current Ordering Period 2 unit price of

This calculation is for Contract Line Item Number

(CLIN) 0002AA and for CLIN 0002AB negotiated on M&O contract W58RGZ-18-D- 0076. CLIN 0002AA multiplied by the one-time buy quantity of 30 each, and CLIN 0002AB multiplied by the one-time buy quantity of 170 each. The total dollar value is for United States (US) effort only and does not include Foreign Military Sales (FMS) requirements. The M&O contract W58RGZ-18-D-0076 was awarded on 26 Jun 2018 and expires on 14 May 2023. The current quantity on contract W58RGZ-18-D-0076 is exhausted. The Independent Government Cost

Unit Price Total Price

200 TOTAL

170 CLIN 0002AB

30 CLIN 0002AA

Quantity US

Estimate (IGCE) supports these prices.

The United States (US) and FMS requirements, by year, are as follows:

FMS Quantity Unit Price Total Price

Base Year 0 N/A $0.00

TOTAL 0 $0.00

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)(2), as implemented by paragraph 6.302-2(b) of the FAR entitled, “Unusual and Compelling Urgency.”

5. Reason for Authority Cited: The proposed acquisition requires the use of the cited statutory authority because this is an urgent requirement to acquire assets as expeditiously as possible to obtain the earliest contract award, accelerated delivery and additional quantity. This modification will provide contract coverage while a follow on five-year IDIQ is being awarded. The maximum quantity for the EDECU has been exhausted and due-ins will not bridge the gap until a follow on contract is awarded resulting in Aircraft on the Ground (AOG’s). This action will increases the maximum quantity for the EDECU on existing contract W58RGZ-18-D-0076 with Triumph Engine Control Systems, LLC (Triumph) (CAGE Code 11599) from 270 to 470. Triumph is the only SRD approved source for this requirement and have demonstrated via contract history that they have the available capacity and material supportability to perform the repairs necessary at the required production schedule and turn-around-time for this urgent requirement. These units support Field, CCAD, FMS demand of 55 per month. This effort has been sustained with new spares and commercial repair. Triumph’s Sub-Tier suppliers of capacitors and PF connectors has severely degraded Triumph’s ability to produce new spare assets to all its customers. The urgent repair order will aid in regaining a positive supply posture supporting urgent requirements, filling backorders, and augmenting new spares due in. Without award of the urgent contract action backorders will continue to accrue monthly, potentially grounding 3 aircraft permonth.

Any delays of the acquisition for the EDECU will negatively impact the Government’s recap production lines for both fleets by increasing the shortage of EDECUs, causing the UH-60 and AH- 64 aircraft fleets to fall below the Army readiness standards and be unable to perform required missions. Triumph is qualified to perform the required work as the OEM in accordance with their blueprints, engineering drawings, and commercial best practices. Triumph possesses the technical expertise, required machinery, and personnel to perform the actions required by this acquisition. The required delivery of the EDECU is 20 each per month starting 60 days after the vendor receives assets. The Period of performance is from 15 June 2020 to 15 June 2021 for the 200 units.

Due to the urgency of this requirement and the impact it can have on the readiness to the UH-60 and AH-64 fleets the Government does not have any alternatives at this time to satisfy this requirement. Triumph is the only approved source that has demonstrated that they have the capabilities to meet this urgent need. Waiting for a new IDIQ contract will increase the backorders impacting line maintenance, the Blackhawk RECAP production line at CCAD, and the Apache REMAN production line at Boeing potentially grounding of aircraft.

6. Efforts to Obtain Competition:

a. Effective Competition: A Sources Sought announcement was publicized in beta.SAM.gov on 2 April 2020. No sources other than the approved sources identified in section 5 of this J&A have expressed interest in this acquisition to date. The known quantities identified in paragraph three above will not be synopsized in the beta.SAM.gov since this requirement falls within FAR 5.202 (a)(2) exception to synopsize requirements. The Army Aviation Sustainment Gateway (ARISE) CSI database, Source Management module, was queried on 11 May 2020, and there are no pending SAR packages awaiting processing.

b. Subcontracting Competition: Per FAR 19.702 and FAR 19.704, a Subcontracting Plan is required for large businesses on acquisitions that exceed $700,000. According to FAR 19.704, the contractor must include FAR 52.219-8, entitled “Utilization of Small Business Concerns”, in all subcontracts that offer further subcontracting opportunities and shall require all subcontracts that offer further subcontracting opportunities, except small businesses, to adopt a plan that complies with the requirements of the clause at FAR 52.219-9, “Small Business Subcontracting Plan”. Per FAR 44.204(c), the solicitation and resulting contract will include the FAR clause 52.244-5 entitled “Competition in Subcontracting” and DFARS clause 252.219-7004, entitled “Small Business Subcontracting Plan (Test Program)” to ensure that all subcontracts are awarded on a competitive basis to the maximum extent possible. Triumph, a large business firm, will be required to comply with these requirements.

7. Actions to Increase Competition: There is not a DMWR currently available to support a competitive solicitation. However, the PM is currently working to develop and approve repair procedures for the new configuration of EDECU. At this time, Triumph is the only approved contractor for the EDECU. Due to the unusual and compelling urgency considerations outlined in the attached Statement of Urgency, (Statement of Urgency 8045 Qty 200_Dec 2019 (signed) which is located in the VCE-PFC File), this acquisition must be restricted to the OEM Triumph. Follow-on routine acquisitions for the EDECU will be competitive to each vendor that has become qualified through the SAR process.

8. Market Research: As documented in the Market Research Report and Commerciality Determination (MRR/CD), concurred with by the Contracting Officer on 3 April 2020, market research has been conducted in accordance with FAR 10.002(b) by the Logistics Management Specialist, T700 Engine Division, AMCOM Logistics Center, in the last 12 months (with specific dates for each step listed below). Research methods included the following: a.

Personal knowledge in procuring supplies/services of this type; b. Contacting knowledgeable persons in Government during September 2019 (to include a Supply Team Lead Logistics Management Specialist); d. Publication of a formal request for information in the form of a sources sought notice issued on 2 April 2020; e. Review of Government and/or commercial databases for relevant information during September 2019 – January 2020 (Interactive Configuration Management and Procurement Program (ICAPP), Logistics Modernization Program (LMP),Army Aviation Sustainment Gateway (ARISE), The System for Award Management (SAM), and Electronic Document Access (EDA)). As previously noted, the sources sought notice was published 2 April 2020; no responses were received. Based upon this market research, it has been determined that the Government’s needs can be satisfied with commercial items, commercial items with customary or reasonable modifications, or non-developmental items. Based upon the above, the basic clauses and provisions prescribed in FAR Part 12 are sufficient for use in this acquisition and will be utilized. As determined by the market research, the only acceptable source for this urgent requirement is Triumph.

9. Interested Sources: A Sources Sought announcement was publicized in beta.SAM.gov on 2 April 2020. The known quantities identified in paragraph three above will not be synopsized in the beta.SAM.gov since this requirement falls within FAR 5.202 (a)(2) exception to synopsize requirements. The ARISE database was queried on 11 May 2020 and there are no pending SAR packages waiting processing. To date no other sources have expressed an interest in this acquisition. There is a reasonable basis to conclude at this time, that the agency’s minimum needs can only be satisfied by the approved source.

10. Other Facts: Other factors affecting this effort are as follows:

a. Procurement History (Maintenance and Overhaul):

(1) The applicable history for this action is as follows:

Contract Number Award Date Quantity Unit Price Contractor

W58RGZ18D0076

W58RGZ19F0267 0002AA

02/28/2019 191 $14,689.00 Triumph Engine Control Systems

W58RGZ18D0076

W58RGZ19F0267 0002AB

06/26/2018 19 $13,690.00 Triumph Engine Control Systems

W58RGZ18D0076 0001

0002AA

06/26/2018 23 14,689.00 Triumph Engine Control Systems

(2) The statutory authority referencing the current contract (W58RGZ-18-D-0076) for other than full and open competition is 10 U.S.C. 2304(c)(1), as implemented by paragraph 6.302-1(a)(2) of the Federal Acquisition Regulation (FAR) entitled, Only one or limited responsible sources, and no other supplies or services will satisfy agency requirements.” The historical contract is reflected in the Technical Justification and Certification and in the history as stated above. This item is not a CSI, the Government does not possess the technical data package. The only known source with a SAR necessary to perform this requirement is Triumph Engine Control Systems, LLC (CAGE Code 11599), is the only source that is authorized by Systems Readiness Directorate (SRD) to perform the overhaul. As of 11 May 2020, there have been no new SAR’s submitted for this item. In preparation for this acquisition, the Government has complied with the requirements of these sections.

Co ntr o l N umb er:A LB-J&A2 0 -0311

SolicitationNu mbe r: WSSRGZ-20-R-0161

FOR OFFICIAL USE ONLY

11. Te chni ca l Certifi cation: I cert ify that the supporting data under my cognizance that are included in this justification are accurate and complete to the best of my knowledge and belief.

Title: Director, Cargo/T?00 Sustainment

Date:

Signature:

12. Requirement s Certification: I certify that the supporting data under my cognizance that are included in this justification are accurate and complete to thebest of my knowledge and belief.

Title: Director, Cargo/T?00 Sustainment

Date:

Signature:

13. Fair and Reasonable Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable. The determi nation of fair and reasonable cost will comply with the policies, regulation, and procedures in FAR Part 12

"Acquisition of Commercial Items." Analysis techniques will include cost/price analysis, use of

Independent Government Estimates, comparison to commercial catalog prices, and comparison to prices.

Title: Contracting Officer

Date: 14 May2020

Signature:

14. Pro curing Contracting Officer Certification: I certify that this justifications accurate and complete to the best of my knowledge andbelief.

Title: Contracting Officer Signature

FOR OFFICIAL USE ONLY

Approval

Based on the foregoing justification, I hereby approve to Upgrade/Repair of the Enhanced Digital Electronic Control Unit (EDECU), for T700 engine on an other than full and open competition is Title 10, United States Code (U.S.C.), Section 2304(c)(2), as implemented by paragraph 6.302-2(b) of the FAR entitled, “Unusual and Compelling Urgency” subject to availability of funds, and provided that the services/supplies and properties herein described have otherwise been authorized for acquisition.

Weapon System: T-700 Engines Procurement Request Identification (PRID): UT401 Procurement Request Order Number (PRON): AX0MY079AX Noun: EDECU Input NSNs: 2995-01-641-8045

2995-01-572-1860

Output NSN: 2995-01-641-8045 Input Part Numbers (P/N): 4155T12P08

4155T12P07 Output Part Number (P/N): 4155T12P08 Quantity: 200

Estimated Dollar Value:

Approved Source:

Triumph Engine Control Systems, LLC

1 Charter Oak BLVD

West Hartford, CT 06133-1325

(CAGE Code 11599)

Large business

6/9/2020

Date Advocate for Competition