JandA_PMA 290_Air Seperator Modules_updated 20220510 Signed.pdf

General Services Administration

JUSTIFICATION AND APPROVAL FOR SOLE SOURCE ACQUISITION (J&A)

FAR 13.501(a)

1. IDENTIFICATION OF THE AGENCY AND CONTRACTING ACTIVITY

Contracting Activity: General Services Administration (GSA) Federal Acquisition Service (FAS) Southwest Supply Acquisition Center, Large SOP 819 Taylor St., Fort Worth, TX 76102

Requiring Activity: United States Naval Air Systems Command – PMA 290 (NAVAIR) 22347 Cedar Point Rd Patuxent River, MD 20670

Description of Requirement: P-8 Poseidon Air Separation Module P/N 2170105-101 Manufacturer: Parker Hannifin GSA’s Acquisition PIID # 47QSWC22K0071 Period of Performance (POP): 5 months ARO Contract Value: $5,544,000.00

2. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED

This action is to request the approval of a sole source Purchase Order for the supply of Parker Hannifin Corporation Air Separation Modules to support the sustainment of the PMA 290 for the P-8 Poseidon surveillance aircraft.

This Justification and Approval serves to support the procurement as a one-source award for deliverables manufactured by Parker Hannifin Corporation and are limited in accordance with FAR 13.501, Sole source acquisitions.

3. DESCRIPTION OF SUPPLIES REQUIRED TO MEET THE AGENCY’S NEEDS

CLIN Part Number DESCRIPTION

0001 2170105-101 Parker Hannifin Air Separation Module (Qty 147)

The total contract value of the Purchase Order is $5,544,000.00 for 147 Air Separation Modules

4. IDENTIFICATION OF STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION

This acquisition will be conducted under the authority of FAR 13.5 Simplified Procedures for Certain Commercial Items which allows the use of simplified acquisition procedures for the purchase of Air Separation in amounts greater than the simplified acquisition threshold but not exceeding $7,500,000.00. The Parker Hannifin Air Separation Module meets the definition of commercial products in accordance with FAR 2.101 as these items are generally available for public use with a minor modification not customarily available in the commercial marketplace made to meet Federal Government requirements.

For sole source purchases exceeding the simplified acquisition threshold, the requirements at FAR 13.501(a) apply.

The need for a sole source requirement is justified in writing utilizing the format at FAR 6.303-2 properly modified to reflect that the procedures at FAR 13.5 were used in accordance with 41 U.S.C. 1901. This justification will be approved at the levels specified in accordance with FAR 13.501(a)(2)(ii) and posted to SAM.gov within fourteen (14) days of contract award in accordance with FAR 13.501(a)(1)(iii).

5. DEMONSTRATION OF THE PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS TO PROVIDE

THE REQUIREMENT

The P-8A Poseidon aircraft, modified from the commercial aircraft Boeing 737-800ERX, is the latest maritime, patrol and reconnaissance aircraft designed to secure the Navy’s future in long-range maritime patrol capability. NAVAIR’s PMA 290 team holds the responsibility of maintaining, repairing and implementing new aircraft capabilities to the P- 8A fleet for operational use. The Boeing 737-800ERX is equipped with one of many available fuel tank inerting systems called On Board Inert Generating System (OBIGGS).

The air separation module (ASM) uses semi-permeable, hollow fiber membranes, packaged in a cylindrical canister that removes oxygen from a compressed air stream to generate a nitrogen enriched air (NEA) stream. Parker Aerospace's air separation modules are used in a variety of inerting systems designed and manufactured for Military, commercial, and business aircraft. Parker Hannifin air separation modules benefit from proprietary, higher-performance Parker fibers not available to other companies, resulting in a smaller, lighter, and less-costly system.

Parker's air separation module (ASM) keeps fuel tanks safer, utilizing semi-permeable hollow fiber membrane technology. The Parker fiber also has the highest performance of all available aerospace ASMs, enabling the smallest total ASM weight and package volume on the market today.

Parker provides the only vendor parts that have been analyzed, tested, and certified to provide the proper level of protection and survivability in a threat environment and is compatible with OBIGGS. Standard MIL 810 environmental quality procedures were used. As for performance, the P-8A aircraft has more stringent needs than commercial aircraft, which were more difficult to achieve. Due to potential direct fire possibilities in hostile areas, P-8A aircraft require ASMs that can provide a 9% O2 concentration that only the Parker AMS can provide. All other open market ASMs currently available are only certified to 12%. The 3% reduction in O2 concentration provides the maximum safety to P-8A on board personnel and drastically limits the possibility of an explosion due to excess fuel vapors.

Their design is proprietary and not based on any generic specification design of separation modules. Any other supplier would need to have their parts certified via standard MIL 810 environmental quality procedures to 9%, which requires multi-million dollar testing and analysis. The Parker ASM is the only currently available ASM that meets those more stringent performance requirements. Even if another supplier was able to be certified to meet the 9% requirement, the P-8A aircraft would require multi-million dollar modifications to establish compatibility with the already installed OBIGGS.

6. DESCRIPTION OF EFFORTS MADE TO ENSURE THAT OFFERORS ARE SOLICITED FROM AS MANY

POTENTIAL SOURCES AS PRACTICABLE, INCLUDING WHETHER A NOTICE WAS OR WILL BE

PUBLICIZED AS REQUIRED BY SUBPART 5.2 OR IF AN EXCEPTION UNDER 5.202 APPLIES

The market research conducted by the Contracting Officer and information submitted by the customer for review indicates that only one (1) source is available. Additionally, the Contracting Officer posted a notice of proposed contract action in which the Government intends to solicit and negotiate with only one source five (5) days prior to the issuance of the solicitation; no industry inquiries or capability statements were received.

7. DETERMINATION ANTICIPATED COST WILL BE FAIR AND REASONABLE TO THE GOVERNMENT

Because this requirement is one-source, the Government will be utilizing at least two (2) price analysis techniques outlined in FAR 15.404-1 by which to determine pricing submitted by Parker Hannifin to be fair and reasonable.

These techniques include, but not limited to the following:

● Requesting recent commercial and Government sales history

● Making indirect pricing comparisons to:

o the same or similar items in the marketplace, o competitive published price lists, and

Independent Government Estimates.

8. DESCRIPTION OF MARKET RESEARCH CONDUCTED

Market research was conducted in accordance with FAR Part 10 to determine the availability of products capable of meeting the Government’s requirement. A review of schedule contract vendors listed under the GSA Schedule program did not reveal any other items of similar intended functionality, specifications and customizable design features as outlined in this document that are critical to meeting the customer’s need. Also, a Sources Sought was posted with the notice of intent to negotiate with one source for five (5) days. No industry inquiries or capability statements were received. As such, the results of the market research determined that only Parker Hannifin was interested and capable of meeting the Government’s requirements.

The Contracting Officer also contacted Parker Hannifin to determine if other authorized distributors were available. A representative of Parker Hannifin confirmed that they had attempted to partner with a GSA Schedule contract holder to add this item to the Schedule program, but that effort was unsuccessful. At this time, they do not have any authorized dealers.

9. ANY OTHER FACTS SUPPORT THE USE OF OTHER THAN FULL AND OPEN COMPETITION

Parker Hannifin’s design is proprietary and not based on any generic specification design of separation modules. Any other supplier would need to have their parts certified, which requires multi-million dollar testing and analysis.

10. LIST ANY OTHER SOURCES THAT EXPRESSED INTEREST IN WRITINGIST OF SOURCES THAT

EXPRESSED AN INTEREST IN THE ACQUISITION

No other sources expressed interest for this requirement

11. STATEMENT OF ACTIONS, IF ANY, THE AGENCY MAY TAKE TO REMOVE BARRIERS TO

COMPETITION

Parker Hannifin is currently the only source capable of meeting the Government’s needs. Prior to any subsequent procurement, the Government will once again review the market using various methods to assess whether any other qualified sources are available and are able to meet the Government’s requirements.

TECHNICAL REQUIREMENTS CERTIFICATION

I certify that this support data under my cognizance, which forms a basis for this justification, are accurate and complete to the best of my knowledge.

Dustin Wimpee Date US Navy, PMA 290 Supply Chain Manager Approved By:

CONTRACTING OFFICER CERTIFICATION AND APPROVAL

The Contracting Officer has determined that the appropriate actions were taken under this acquisition meet the conditions described in FAR Subpart 13.501, Sole source acquisitions. The information contained in this justification is accurate and complete to the best of the Contracting Officer's knowledge and belief.

Phil Cleveland Date Contracting Officer, Large SOP (7QFAD)

Reviewed by:

Tammy Mattox Date One Level Above, Large SOP (7QFAD)

Assistant Regional Counsel (LD7) Date

Director, Assisted Acquisition Services (7QFA) Date

COMPETITION ADVOCATE CERTIFICATION

I, the approving authority, determine that the circumstances identified in this document are accurate; therefore, limiting competition to one source under FAR 13.501 is justified. The signature below also represents approval of this Limited Sources Justification.

Mike McDaniel Date Competition Advocate FAS Regional Commissioner’s Officer