JEFO 20-0190 Redacted.pdf

D E P A R T M E N T O F T H E N A V Y

N A VA L A I R S Y S T E MS C O MMA N D

N A V AL A I R S YS T E MS C O MMA N D H E A D Q U A R T E R S

4 7 1 2 3 B U S E R O A D , UN I T # I P T

P A TU XE N T R I V E R , MD 2 0 6 70 -1 5 4 7

JEFO Number: 20-0190

JUSTIFICATION FOR AN

EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity.

Naval Air Systems Command (NAVAIR) Headquarters

2. Nature and/or Description of Action being Approved.

Pursuant to FAR 16.505(b)(2)(i)(C), this Justification for an Exception to Fair Opportunity (JEFO) authorizes and approves the award of an order modification as a logical follow-on to existing Order N0001920F0474 under Indefinite Delivery Indefinite Quantity Contract (IDIQ) N0001918D0110 awarded to Standard Aero on 5 December 2019 for the induction of P-8A Poseidon aircraft engine with Engine Serial Number (ESN) 362142. The instant modification will procure repair of the engine’s seized High Pressure Compressor (HPC) variable stator vanes, replacement of the 3rd stage Booster Vane, as well as the implementation of CFM Service Bulletins to bring the engine to the latest approved configuration. Repair of the HPC variable stator vanes includes the tear down and refurbishment of the HPC Rotor and Stator modules. In addition, Service Bulletins (which are classified as Technical Directives) are required to be incorporated to correct known engine component reliability issues and the replacement of the 3rd Stage Booster Vane Assembly is required to ensure the engine is returned to Ready-For-Issue (RFI) status.

3. Description of the Supplies or Services Required to Meet the Agency’s Needs (including the estimated value).

The Maritime Patrol and Reconnaissance Aircraft program office (PMA-290) requires the disassembly, overhaul, and refurbishment of the HPC rotor and stator modules of P-8A ESN 362142 as well as replacement of the 3rd stage Booster Vane Assembly to return the engine to read-for-issue (RFI) condition.

Additionally, CFM Service Bulletins are required to be incorporated to bring the engine into the latest approved configuration. The estimated total value of the supplies and services to meet requirements is approximately $[REDACTED].

4. Identification of the Justification Rationale (see FAR 16.505(b)(2)) and, if applicable, a Demonstration of the Proposed Contractor's Unique Qualifications to Provide the Required Supply or Service.

Pursuant to FAR 16.505 (b)(2)(i)(C), the order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

As a result of competitive Solicitation N00019-15-R-2004, on 1 February 2018 Standard Aero was one of two awardees for P-8A Poseidon engine repair IDIQ contracts. The Government also issued orders to the awardees concurrently pursuant to the minimum and maximum quantities requirements indicated in contract clauses 5252.216-9506 and H-1, including Order N0001920F0474 issued to Standard Aero. The order procured the induction of P-8A ESN 362142.

On 17 December 2019, P-8A ESN 362142 was inducted into Standard Aero’s facility. On 20 December, pursuant to the Order, Standard Aero delivered an Engine MRO Assessment Report detailing the results of the assessment, the inspection findings, and the recommended workscope to return the engine to RFI condition, which included refurbishing the HPC modules as well as the incorporation of CFM Service Bulletins. On 13 April 2020, the 3rd stage Booster Vane Assembly was determined to be corroded beyond repairable limits requiring it to be replaced. An order modification must be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to the order, as the engine is in an opportune state to repair the HPC module, incorporate Service Bulletins, and return the engine to RFI condition.

5. A Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The contractor’s cost to perform the engine overhaul and repair consists of labor and material. The effort, as a whole, falls under the cognizance of the HPC Rotor Module Refurbishment FFP CLIN, HPC Stator Module Refurbishment FFP CLIN, Minor Repair T&M CLIN, and Technical Directives T&M CLIN. The HPC Rotor Module Refurbishment and HPC Stator Module Refurbishment CLIN prices were negotiated and established at contract award. The Minor Repair and Technical Directives CLINs each have a single labor hour rate and material mark-up rate. Those rates were established during the overarching competitive IDIQ contract source selection process. As to establishing a fair and reasonable price, the Contracting Officer will obtain a cost estimate from the contractor that includes bases for the estimated hours. The contractor’s estimate will be reviewed for reasonableness by a Government technical team prior to the Contracting Officer establishing the T&M price for the effort. Ultimately, the contractor will be paid for actual hours applied and material costs incurred toward meeting the requirements in accordance with the contract.

6. Any other Facts Supporting the Justification.

The additional tasking described in Section 3 performed as a stand-alone event would create duplicative actions for the contractor to perform, costing the Government an estimated additional $79,900. The duplicative efforts entail (a) preparing and shipping the engine to another facility and (b) inducting the aircraft and performing inspections, inventory, and partial dismantling to access and assess the core. Also, to compete the additional tasking and award to a different source would result in an unacceptable delay of 3 to 6 months in fulfilling those requirements. Additional impacts to the Government include inducting the engine back into a contractor’s facility and surveilling the duplicative effort that is currently part of the engine repair tasking. Combining these additional repair requirements concurrently with the induction ensures Navy aircraft and aircrew safety and improves readiness, reduces cost, and helps meet schedule requirements.

7. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers that Led to the Exception to Fair Opportunity before any Subsequent Acquisition for the Supplies or Services is Made.

The two IDIQ contracts include a base period and six option periods. The firm fixed prices were subject to competition at award. Each option period is subject to competition between the two IDIQ contractors which includes obtaining competitive T&M rates for the Minor Repair and Service Bulletin Implementation CLINs.

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.

[REDACTED] [REDACTED] [REDACTED]

Signature Name (Printed) Phone No.

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

[REDACTED] [REDACTED] [REDACTED]

Signature Name (Printed) Phone No.

APPROVED

Upon the basis of the above justification, I hereby approve the solicitation of the proposed procurement(s) described herein using other than full and open competition, pursuant to the authority of FAR 16.505 (b)(2)(i)(C).

[REDACTED]

[Signature, Name, and Title]