CUI // SP-PROCURE // DL ONLY

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UNITED STATES MARINE CORPS

REGIONAL CONTRACTING OFFICE

MARINE CORPS INSTALLATIONS

WEST– MARINE CORPS BASE

BOX 55010

CAMP PENDLETON, CA 92055-5010

IN REPLY REFER TO:

J&A No.26-0004

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity.

Regional Contracting Office, Marine Corps Installation West (RCO MCIWEST)

2. Description of the Action Being Approved.

Award of a sole source firm-fixed-price (FFP) purchase order to VTS Aviation LLC for foreign adversary air support.

3. Description of Supplies/Services.

This contract provides high-fidelity foreign adversary rotary-wing and surrogate unmanned aerial system threat replication support for the first iteration of the FY27 semi-annual Weapons and Tactics Instructor (WTI 1-27) course at Marine Corps Air Station (MCAS) Yuma, Arizona in support of Marine Aviation Weapons and Tactics Squadron One (MAWTS-1). The WTI Course is a Service-led tactical training evolution emphasizing integrated operations across all Marine Air-Ground Task Force (MAGTF) aviation and ground combat elements.

The period of performance for this sole source action is strictly limited to the duration required to execute the WTI 1-27 evolution: 23 September 2026 – 24 October 2026 (approximately four weeks).

The estimated dollar value of the contract is $527,834.44, funded using FY26 Operations and Maintenance, Marine Corps (O&M, MC) appropriations.

4. Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. 3204(a)(2), as implemented by the Federal Acquisition Regulation (FAR) (Revolutionary FAR Overhaul (RFO)) 6.103-2, unusual and compelling urgency.

5. Rationale Justifying Use of Cited Statutory Authority.

The rationale for this justification is 10 U.S.C. 3204(a)(2), as implemented by the FAR (RFO) 6.103- 2, “Agencies may contract without providing for full and open competition when the agency's need for the supplies or services is of such an unusual and compelling urgency that the Government would

Controlled by: USMC, I&L HCA Controlled by: MCIWEST RCO MCFCS CUI Category(ies): PROCURE Limited Dissemination Control: DL ONLY

POC: MCIWEST RCO

be seriously injured, financially or otherwise, unless the agency is permitted to limit the number of sources from which it solicits bids or proposals.”

Background: RCO MCIWEST conducted advanced planning to competitively solicit and award contract M00681-26-P-0050 to VTS Aviation LLC (VTSA) on 24 July 2026, as detailed in the chronological timeline below:

(a) August 2025 – March 2026: MAWTS-1 and RCO MCIWEST initiated procurement planning a full year prior to execution, conducting requirements development and market research across regional stakeholders.

(b) April 14, 2026: A Sources Sought notice was posted to SAM.gov, identifying commercial capabilities.

(c) July 16, 2026: A competitive 100% small business set-aside solicitation was posted to SAM.gov, yielding two proposals (VSC and VTSA).

(d) July 24, 2026: RCO MCIWEST awarded contract M00681-26-P-0050 to VTSA. VTSA mobilized and participated in the mandatory WTI 1-27 Mid-Planning Conference (MPC) from 27–31 July 2026.

(e) August 3, 2026: Unsuccessful offeror VSC filed a formal bid protest with the GAO (B-424711.1), triggering an automatic stay of performance pursuant to RFO 33.105-3(b).

(f) August 28, 2026: The Government elected to take voluntary corrective action to amend solicitation terms, re-request proposals and re-evaluate proposals.

As stated above, after reviewing the necessary records related to this procurement, on August 28, 2026 the Government elected to take voluntary corrective action to amend solicitation requirements and re-evaluate proposals. Because the lead time to execute corrective action (solicitation amendment, proposal submission, re-evaluation, and re-award) requires an estimated 60-75 days, a competitive re-award cannot occur before WTI 1-27 begins. The stay occurred 49 days prior to the live-flight phase, creating an unexpected, immediate gap in contracted threat replication that could not have been prevented through advance planning.

Limitation of Urgent Action: The Government pared down this sole-source action to the absolute minimum required to prevent catastrophic mission injury:

Scope De-escalation: The Government removed all non-critical requirements from the original competitive scope, including Fixed-Wing (FW) adversary aircraft and classroom academic instruction. This sole source procurement is restricted exclusively to the irreplaceable live-threat elements: Rotary-Wing (Mi-24 HIND) and surrogate Unmanned Aerial Systems (UAS).

Period of Performance Minimization: While the comprehensive WTI course spans seven weeks, which was included in the original competitive scope, this action is limited strictly to the approximate 4-week high-intensity live-flight execution window, terminating immediately upon completion of the flight phase.

Mission Impact and Quantifiable Harm: MAWTS-1’s semi-annual, Weapons and Tactics Instructor (WTI 1-27) course is the Marine Corps’ premier graduate-level tactical aviation program. Operating on a “train-the-trainer” model, WTI produces elite instructor graduates who return to Fleet Marine Force (FMF) squadrons to qualify aircrews for Global Force Management (GFM) deployments. This is a highly synchronized, Service-led exercise across the Department of War (DoW) integrating 80+ aircraft, 4,000 military, civilian, and contractor personnel, and over 120 military vehicles from the FMF. The USMC invests approximately $4.5M per WTI class on specialized exercise support services separate from the adversary air support contract towards the staging of joint-force troops, aircraft operations, fuel, and ammunition.

The loss of contracted foreign adversary rotary-wing (RW) and surrogate Unmanned Aerial System (UAS) threat replication during WTI 1-27 introduces immediate, severe operational harm:

Aircrew Qualification Deficit: Causes an immediate 50% reduction in Defensive Air Combat Maneuvering–Instructor (DACM-I) designations for AH-1Z/UH-1Y aircrews and a 50% reduction in Defensive Maneuvering–Instructor (DM-I) designations for CH-53E aircrews.

Because unqualified graduates cannot certify subsequent fleet aircrews, this generates a compounding, systemic two-year readiness deficit across the FMF.

Ground-Based Air Defense (GBAD) Degradation: The absence of the Mi-24 HIND attack helicopter directly undermines the WTI certification pipeline, creating immediate Risk to Force and Risk to Mission across the Ground-Based Air Defense (GBAD), Low-Altitude Air Defense (LAAD), and Command and Control (C3) communities. Denying this primary threat platform eliminates 33% of threat RW sorties for Base Defense Zone and GBAD evolutions and prevents LAAD Enhancement Training Instructor (LETI) students from validating live-threat platoon engagements. Substituting friendly USMC surrogates requires late-stage External Air Support (EAS) requests and reliance on EAS assets that suffer a historical 50% attrition rate, and fail to replicate HIND flight profiles.

Direct Deployment Vulnerabilities: These readiness deficits will manifest immediately in active theaters of operation, directly degrading units deploying immediately post-course, including upcoming deployments of units to the U.S. CENTCOM AOR, the forward-deployed 31st MEU in INDOPACOM, and the 15th and 26th Marine Expeditionary Units (MEUs) entering spring deployments.

Counter-UAS Mandates: Eliminating surrogate UAS flights directly violates MAGTFTC counter-drone training directives, leaving Marines unprepared for asymmetric drone threats.

"Negative Training Scars": Diverting friendly USMC "Blue" H-1 aircraft to simulate "Red" threats removes ~10 hours of friendly RW control training, also preventing pilots from coordinating with Command, Control, & Communications (C3) professionals and depriving C3 and Ground Combat Department students of the unique, face-to-face opportunity to learn the capabilities, limitations, and planning factors of the threat aircraft during dedicated pilot debriefs and tours. Ultimately, the lack of a live HIND degrades realistic Positive Identification training, and develops flawed tactical responses, leaving LAAD gunners less prepared to make live-or-death decisions, and is compounded further as these WTI graduates pass their training deficiencies onto future students they teach.

In addition to the operational and readiness risks, failure to provide threat replication directly jeopardizes the Marine Corps’ approximate $4.5M dedicated investment in specialized exercise support services. Executing these high-cost live-fire evolutions without realistic adversary threat profiles drastically dilutes the return on investment of these taxpayer funds and severely degrades the training value of the entire exercise.

Technical Infeasibility of Alternative Sources: The Government has identified two vendors that are reasonably capable of providing this service: VTSA and VSC. However, conducting a limited competition between these sources for this 4-week long action is technically and operationally unfeasible due to critical integration milestones already completed. After the contract award, but prior to the protest, VTSA attended the mandatory MPC for WTI 1-27 (27–31 July 2026). During this critical planning conference, VTSA was able to complete the detailed coordination with MAWTS-1 personnel that will ensure safe and effective air-to-air and air-to-ground training. Re-executing an MPC with another vendor is schedule-prohibitive. Transitioning to another vendor at this juncture introduces unacceptable flight safety hazards. Due to the constraints of the exercise life cycle, it is not possible to schedule another planning conference and re-create this coordination with a different vendor prior to the start of WTI 1-27, therefore, at this point, VTSA is the only vendor that can successfully complete this iteration of WTI.

Impossibility of Deferral or Organic Asset Substitution: Deferring or rescheduling the WTI 1-27 course is operationally impossible. As discussed above, this is a massive, multi-service endeavor synchronized with joint-force troop deployments, ammunition allocations, specific range windows, and Fleet Marine Force deployment schedules. MAWTS-1 and RCO MCIWEST evaluated both organic military assets and existing DoW contract vehicles; no alternative assets or contract mechanisms are available to provide the required threat profiles within the required operational window. Initiating a brand new, competitive procurement is not attainable prior to the WTI 1-27 course dates, and as described above, the critical planning conference already took place that cannot be replicated prior to the WTI 1-27 course start dates.

Based on the severe fleet readiness deficits resulting from a gap in service and an administrative timeline that precludes a competitive re-award prior to exercise execution, only VTSA—having completed mandatory safety and tactical integration at the Mid-Planning Conference—can safely perform within the required operational window. Accordingly, an urgent and compelling four-week sole-source bridge contract is required to provide mission-essential adversary air support for WTI 1- 27, ensuring the uninterrupted qualification and survivability of deploying Marine Corps aircrews.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

The underlying requirement was competitively solicited under full and open competition (small business set-aside). Following the protest of contract M00681-26-P-0050, the Contracting Activity initiated corrective action to amend solicitation terms and conduct a thorough re-evaluation. A competitive award will be finalized to support the second iteration of the course (WTI 2-27 in Spring 2027). For this immediate 4-week requirement, soliciting additional sources was determined impracticable. This action was not synopsized, per FAR RFO 5.101(b)(2). Given the strict timeline between the live-flight phase and ability to reprocure, coupled with the pre-requisite planning milestones completed exclusively by VTSA, VTSA is the sole commercial vendor capable of deploying and executing the requirement without causing severe operational disruption and safety risks.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer has determined that the anticipated cost to the Government of the services covered by this Justification will be fair and reasonable. The fair and reasonableness of the prices will be based on an analysis of the contractor’s price proposal using the price analysis techniques pursuant to FAR 15.404-1(b)(2)(ii) comparison of the proposed prices to historical prices paid and FAR 15.404-1(b)(2)(v) comparison of proposed prices with independent Government cost estimates.

In addition, other than certified cost and pricing data may be requested from the contractor in order to ascertain fair and reasonable pricing in a sole source environment. It is also anticipated that the analysis will be conducted using one or more experienced technical representatives and contract specialists.

8. Actions to Remove Barriers to Future Competition.

In accordance with RFO 6.103-2(c), the period of performance does not exceed the unusual and compelling requirements of the work to be performed under the contract, does not exceed one year, and the following contract for the required services will be obtained through competitive procedures.

This requirement was competitively solicited prior to receiving the post-award protest. This sole source contract is strictly limited to the first WTI 1-27 training session required, and even further to only the rotary wing aircraft and the surrogate UAS, (the irreplaceable live-threat elements). It also only includes the approximate 4-week live-flight execution window, not the entirety of the planned WTI 1-27 training event. There are no options included in this sole source award beyond this approximate 4-week window. It does not include the second iteration of training currently planned for spring 2027 (WTI-2-27), and does not include the elements of the requirement deemed not vital to the mission (i.e., the fixed-wing aircraft and the academic portion), all of which will be competitively awarded after the Government concludes corrective action. All future iterations of this training requirement, beyond the spring WTI-2-27 event will be competed as well.

DISTRIBUTION: DoW COMMUNITY ONLY

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.

Technical/Requirements Cognizance:

Signature Dustin Ralph Phone No. 928-269-3403 Date

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

Signature Phone No. Date

CONTRACTING OFFICER APPROVAL

I certify that this Justification is accurate and complete to the best of my knowledge and belief.

Upon the basis of the above justification, I hereby approve, as the Contracting Officer, the solicitation of the proposed procurement described herein using other than full and open competition, pursuant to the authority of 10 U.S.C. 3204(a)(2).

GySgt Duong, John

Date

Distribution List for DL ONLY Limited Dissemination Control

Digitally signed by RALPH.DUSTIN.MATTHEW.1367622756 Date: 2026.09.17 17:14:51 -07'00'

TORRESALA.JOHN.WILLIAM.1

265412358

Digitally signed by

TORRESALA.JOHN.WILLIAM.1265412358

Date: 2026.09.18 11:03:08 -07'00'

DUONG.JO

HN.145765

Digitally signed by

DUONG.JOHN.

1457657028 1 Oct 2026

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