JEFO 25-0063 Redacted.pdf

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

N AV A L A I R S YS T E MS C O MM A N D

N AV A L A I R S YST E MS C O MMA ND HE A D Q UA RT ER S

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JEFO Number: 25-0063

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 Federal Acquisition Regulation (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 N0001924F5017 under Indefinite Delivery Indefinite Quantity Contract (IDIQ) N0001924D0109 awarded to AAR Government Services, Inc. (AAR) Wood Dale, IL on 13 September 2024 for P-8A Airframe Depot Maintenance and Repair services.

Order modification P00001, executed on 25 October 2024, exercised options to enable the maintenance and repair of P-8A Poseidon aircraft

. This JEFO authorizes the procurement of the incorporation of Service Bulletins into the aforementioned aircraft. These Service Bulletins (classified as Technical Directives (TDs)) are required to ensure the aircraft are returned to the Government in the latest required configuration.

3. Needs (including the estimated value).

The Maritime Patrol and Reconnaissance Aircraft program office (PMA-290) requires the incorporation of Service Bulletins (which are classified as TDs) into P-8A Poseidon aircraft to ensure the aircraft are returned to the Government in the latest configuration. The estimated value to fulfill the requirements is

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 contract action 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 P-8A Airframe Depot Maintenance and Repair competitive Solicitation N0001924R0002, AAR was awarded one of two IDIQ Multiple Award Contracts (MACs) and was awarded Order N0001924F5017 which includes CLINs and Options to enable the depot maintenance and repair of up to P-8A aircraft. Order modification P00001, JEFO Number: 25-0063 executed on 25 October 2024, exercised options to enable the maintenance and repair of P-8A Poseidon aircraft . This JEFO authorizes the procurement of the incorporation of Service Bulletins into the aforementioned aircraft. The incorporation of these Service Bulletins is required to ensure the aircraft are returned to the Government in the latest required configuration.

Pursuant to Order N0001924F5017, aircraft are scheduled for induction facility. The requirements described in paragraph 3 above are a logical follow- s existing requirements as the aircraft will be in an opportune state for incorporation of the Service Bulletins.

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

Bulletin TD Compliance Time-and- Materials (T&M) CLIN. The T&M CLIN has a single labor hour rate and material mark-up rate per year, respectively. Both of those rates were established during the overarching competitive IDIQ contract source selection process. Ultimately, the contractor will be paid for actual hours applied and material costs incurred toward meeting the requirements in accordance with the contract. Based on the information provided and the prices previously established under adequate competition, the Contracting Officer anticipates the costs to the Government will be fair and reasonable.

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 other contractor and the Government to perform. After fulfilling all other depot maintenance and repair requirements for each aircraft, AAR would be required to re-assemble each aircraft to an airworthiness state. squadron personnel would be required to take delivery of the aircraft and fly it from AAR to the other contractor Waco, TX facility. The other contractor would be required to disassemble each aircraft and, subsequent to incorporating the Service Bulletins, reassemble each aircraft to an airworthiness state. The DCMA with cognizance over the other contractor would be required to inspect and accept the incorpor squadron would be required to come out a second time to accept the aircraft delivery. These duplicative efforts would create negative cost and schedule impacts to the Government.

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.

For the reasons set forth in Paragraphs 4 and 6 above, NAVAIR has no plans at this time to offer fair opportunities on subsequent acquisitions of similar supplies or services.

JEFO Number: 25-0063

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.

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

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).