JandA_Redacted.pdf

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

CONTROLLED UNCLASSIFIED INFORMATION

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I. Agency and Contracting Activity.

This Justification and Approval is to request authority for Other Than Full and Open Competition supporting requirements generated for the Air Force Sustainment Center (AFSC), 638 Supply Chain Management Group (SCMG), 409 Supply Chain Management Squadron (SCMS/GUMB). The Contracting Office responsible for this proposed contracting action is the Air Force Sustainment Center (AFSC/ PZAAB). The Purchase Request Number for this contracting action is FD2060-24-00010.

II. Nature and/or description of the action being approved.

Due to the circumstances described herein, the activity requests authority to acquire the repairs listed in this document using Other Than Full and Open Competition as prescribed by FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. This action will result in the award of a follow-on contract, which will be a Firm Fixed Price Requirement Indefinite Delivery Contract (IDC) with a basic one-year plus four (4) one-year Ordering Periods. Based on the projected contract award of 19 December 2024, orders can be issued 19 December 2024 - 18 December 2029.

This sole source requirement will be purchased from the following vendor:

Simmonds Precision Products Inc.

100 Panton Rd Vergennes, VT 05491-1008

CAGE: 89305

Size: Large

III. Description of supplies/services required to meet agency needs.

This requirement is for the repair of the C-130 Aircraft Digital Fuel Quantity Indicator (DFQI) and the Digital Fuel Quantity Totalizer (DFQT), National Stock Numbers (NSNs) 6620-01-394-4018LG, Part Numbers (P/N) 10095-0101 and NSN 6680-01-394-2555LG, P/N 10097-0101. The DFQI and DFQT provides fuel levels of the C-130 aircraft. The DFQI is a set of 8 displays, one for each of the fuel tanks, mounted on the flight station control panel. The indicators operate in response to signals from the tank probes. Each of the indicators is contained in an environmentally sealed case. The digital display consists of 3 numbers and a single decimal point, which shows fuel to the ten-pound level. The DFQT is 1 indicator that totalizes the fuel quantity in each tank and displays the results on a single unit. For this contract, services shall include maintenance services and repair of recoverable items, packaging, handling, storage, transportation and data collection while meeting required performance thresholds. The contractor shall provide management organization, systems and processes to effectively and efficiently accomplish component repair. Contractor shall furnish all material, support equipment, tools, test equipment, and services. The contractor is responsible for providing, maintaining, and calibrating all support equipment required at their facility or a subcontractor's facility. Contractor furnished material or parts used for replacement shall equal or exceed the quality of the original material or parts. The contractor shall repair and test the DFQI and DFQT to Original Equipment Manufacturer (OEM) specifications, returning the assets to the Air Force in serviceable condition. Contractor knowledge of the C-130 aircraft platform is pertinent in order to provide analysis, offer recommendations, and comply with timelines established by the

August 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 5 of 9 is one indicator that totalizes the fuel quantity in each tank and displays the results on a single unit on the C-130 aircraft. Historical data reflects that the USAF has a long history of repair of the DFQI and DFQI with the OEM. Simmonds most recently was awarded a sole source IDC five (5) year repair contract FA8538-20-D-0001 on 19 December 2019. This contract is set to expire 18 December 2024.

The Government contacted Simmonds Precision Products Inc via email on 6 June 2023 to inquiry on their interest in selling the Technical Data Package (TDP) to the Government. In response, Simmonds stated their TDP is proprietary, and they are not currently interested in selling the TDP or authorizing Government purpose rights to the Government.

Simmonds Precision Products Inc is the OEM of the DFQI and DFQT. They possess the proprietary rights to the TDP. A complete TDP is required in order to repair these items. The Government does not possess any commercial product sheets, test data, qualification data, support manuals or related data that defines the performance and manufacturing characteristics of these items. There is no repair data on these items in its Joint Engineering Data Management Information and Control System (JEDMICS) repository or Technical Order Library to facilitate competition. Simmonds Precision Products Inc possesses the proprietary test equipment and data to test and repair these items to meet the required military specifications.

Simmonds Precision Products Inc is the only qualified source capable of repairing the DFQI and DFQT due to the proprietary rights. Simmonds has previously provided DFQI and DFQT repair services in the form of testing, repair and functional check and certification of items. The repair service sustainment of the DFQI and DFQT is required to ensure availability of the assets necessary to support mission requirements of the C-130 aircraft. The repair effort will support backorders, Mission Impaired Capability Awaiting Parts (MICAPs) and Surge requirements in support of the C-130 critical aircraft missions. Therefore, this acquisition will be a follow-on contract for the continued production of highly specialized equipment in support of the C-130 aircraft.

The 409th SCMS/GUMB has determined that award to any other source would result in substantial duplication of cost to the Government that is not expected to be recovered through competition and unacceptable delays in fulfilling the agency's requirements. The items complexity and lack of adequate data for the repair, certification and validation testing has resulted in the determination that undertaking a reverse engineering (RE) effort is not economical or beneficial to the Government. Repair capability and capacity by Simmonds adequately address sustainment requirements.

A Cost Breakeven Analysis (CBA) for NSNs 6620-01-394-4018LG and 6680-01-394-2555LG was conducted in September 2023. The alternatives used were Sole Source and Reverse Engineering (RE). The following are the assumptions that were used while conducting the analysis.

• Analysis period is 15 years, FY25-FY40, based on the expected service life of the aircraft which uses these items/NSNs.

• Annual repair cost were based on the FY24 repair price adjusted by . Repair quantities were based on 2 separate NSNs used for the duration of the period of analysis (FY25-

FY40).

• Reverse engineering effort requires 18-24 months and the investment costs are based on engineers working for 18-24 months to develop the technical data package and approve the prototype. The RE, prototype and data development is based on the similar Caution Advisory Panel reverse engineering project.

• The Savings/Investment Ratio (SIR), Payback Period and Total Present Value of new Investment

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The requirement will be synopsized in SAM.gov in accordance with FAR 5.201. It is anticipated that sources having an interest in subcontracting may be identified through synopsis. Any source who responds to the Government as a result of this synopsis will be identified to the prime contractor as a potential subcontracting possibility.

VI. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The overall cost of this acquisition will be fair and reasonable to the Government. In accordance with FAR 15.403-3, the Contracting Officer will require the submission of other than certified cost or pricing data.

Price analysis or cost analysis based on “information other than certified cost or pricing data” will be used to examine and evaluate the proposed prices to determine fair and reasonable pricing. Price analysis techniques include comparison of proposed prices to historical prices paid for a same or similar item;

comparison with published price lists, offered catalog prices and prices obtained through market research for a same or similar item; comparison of proposed prices with independent Government estimate; or analysis of data other than certified cost or pricing information.

VII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

Market research was conducted 8 May 2023 to 5 Oct 2023 in accordance with FAR Part 10.001 and

10.002. The Market Research Report was completed on 5 Oct 2023. The market research techniques used are as follows:

As described in Section V above, a SS/RFI was posted to SAM.gov advising industry of the pending acquisition and soliciting inquiries from interested vendors. The SS/RFI was posted on 2 Mar 2023 under Notice ID FD2060-24-00010. No interested vendors responded to the SS/RFI.

Queries were conducted within Government databases and various internet searches were conducted within Government databases, combined with various Internet searches (Thomas Registry, IHS Haystack, Google, etc.) using the following key words: “Fuel Quantity Indicator for Avionics”, “10095-0101”, “6620-01-394-4018”, “Fuel Quantity Totalizer”, “6680-01-394-2555”, 10097-0101”. Searches resulted in more than 20 potential vendors. An assessment to determine the capabilities of individual vendors identified through Internet searches was performed. Qualified individuals within the appropriate Government sections were contacted and assisted with the gathering of product background information. A search for HUB zone and service-disabled veteran owned businesses was conducted using the Dynamic Small Business Search Engine (http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm), using criteria consisting of keywords: “Fuel Quantity Indicator for Avionics”, “10095-0101”, “6620-01-394-4018”, “Fuel Quantity Totalizer”, “6680-01-394-2555”, 10097-0101.” However, the DSBS did not return any vendors. A search for Small Business, Small/Disadvantaged Business, Section 8A business, HUBZone, Service-Disabled Veteran Owned Small Business (SDVOSB), and Woman-Owned Business/Economically Disadvantaged Women Owned Small Business (EDWOSB) was conducted using the Dynamic Small Business Search Engine (http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm). Criteria pertaining to the item description for Noun, Part# and NSN [Fuel Quantity Indicator, 10095-0101/6620-01-394-4018] [Fuel Quantity Totalizer,10097-0101/6680-01-394-2555] were used under NAICS code 811210, Aerospace product and parts manufacturing. Results show there are no potential opportunities for small business set asides and/or direct awards in support of this requirement. These services are not eligible to be provided by the

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AbilityOne program ( www.abilityone.gov).

The DFQI and DFQT do not fit the definition of a commercial item as defined in FAR Part 2.101. This item is defined as military unique and is not customarily used by the general public or by non- Governmental entities. The Government requires parts that meet an exact form, fit, and function as determined by the specific mission. There are no aircraft in the commercial market with the same or similar components.

The market research concluded Simmonds Precision Products Inc is the only vendor capable of fulfilling the Government's requirement.

VIII. Any other facts supporting the use of Other Than Full and Open Competition.

None.

IX. List of any sources that expressed, in writing, an interest in the acquisition.

See Section V above.

X. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisitions for the supplies or services required.

The DFQI and DFQT are used on the C-130 aircraft with an excepted lifecycle through 2040.

The plan to break barriers to competition in the prior J&A was to rescreen the NSNs, continue engaging the OEM on selling the TDP to the Government and work with the Consolidated Sustainment Activity Group- Supply/General Support Division Sustaining Engineering Program Office to request funding to acquire data, drawings, repair technical manuals through reverse engineering. The NSNs were rescreened and the RMC/RMSC code remains a R3/R. The most recent communication with Simmonds was on 6 June 2023.

Simmonds stated their TDP is proprietary, and they are not currently interested in selling the TDP or authorizing Government purpose rights to the Government. Cost and time to reverse engineer was determined as uneconomical due to ROI would not occur until after the end of the life cycle of the aircraft.

Based on fulfillment of the prior plan, the current J&A does not require higher level approval in accordance with DFARS PGI 206.304(a) (S-70) (ii).

The plan to remove or overcome barriers to competition in the future is to inquire with the OEM their interest in selling the technical data package to the Government. The OEM will be contacted annually.

XI. Certification by the Contracting Officer.

As evidenced by my signature above, I certify that this justification is accurate and complete to the best of my knowledge and belief.

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XII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.