JOFOC_Posting.pdf

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA)

Kennedy Space Center (KSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

For Kennedy Flight Operations Contract (KFLOC)

1. Federal Acquisition Regulation (FAR) 6.303-1(b)(1) – Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for other than full and open competition.”

This document is a justification for other than full and open competition prepared by NASA and the contracting activity is KSC.

2. FAR 6.303-2(b)(2) – The nature and/or description of the action being approved:

This justification provides the rationale for contracting by other than full and open competition to award a sole-source contract with Airbus Helicopters, Inc. for H-Care Infinite maintenance and operations services for three Airbus H135-F2 T3 aircraft. The contractor shall supply KSC with all the services (technicians and crew support/pilots) necessary to operate and maintain the three aircraft and support equipment, which include the avionics, aviation ground support equipment (AGE) special tooling. The contractor shall also provide initial and recurrent training for contractors operating (including crew support/pilots) or performing work (including technicians) on the aircraft or support equipment. To ensure the highest levels of safety and to preserve residual value to the Government, all work performed by this contract shall be with Airbus certified parts, procedures, and personnel.

3. FAR 6.303-2(b)(3) – A description of the supplies or services required, to meet the

Agency’s needs (including the estimated value):

The NASA KSC Flight Operations Office is responsible for the operation of all aviation assets utilized by NASA KSC and its contractors. These responsibilities include providing aerial helicopter-based services for multiple customers and programs at KSC. Specific missions include airborne security/law enforcement, airborne force projection and airspace patrol, astronaut flight crew security, emergency medical transport, aerial surveillance, airborne firefighting, aerial environmental assessments, time critical spaceflight hardware and science transport, research and science activities, patient transport for mass causality events, and personnel transport for operational requirements. KSC Flight Operations must maintain the appropriate balance between the ever-increasing need to maintain and implement required services, execute missions at the highest level of safety, and implement the mandates and missions of spaceport services as operations continue to grow and expand.

To meet NASA and KSC’s objectives, KSC Flight Operations manage three Airbus H135-F2 T3 aircraft and the required maintenance, operations, and repair services to ensure the aircraft are continuously mission capable in a time critical and dynamic launch and security environment. NASA KSC Flight Operations requires the proper tools, operations, and maintenance support to safely provide its customers the most effective, safe, and cost-effective aerial support services.

KSC Flight Operations has procured three new Airbus H135-F2 T3 aircraft (Contract Number GS-07F-139DA/80KSC019F0230), with an anticipated delivery of two aircraft on or around September 2020, and an anticipated delivery of the third aircraft on or around February 2021. The new aircraft, with significantly reduced maintenance, increased uptime, and vastly improved safety systems will enable KSC Flight Operations to meet and surpass current mission requirements and safety. To ensure the aircraft are readily available to support mission requirements, the aircraft must be maintained and operated at FAA and NASA standards and adhering to Airbus requirements and directives.

Airbus Helicopters Inc. offers an all-inclusive commercial maintenance and operations service for their Airbus aircraft to all customers under their Airbus Helicopters H-Care Infinite program. The H-Care Infinite program provides a total parts, maintenance, inspection, and operations solution that is fully compliant with NASA and FAA standards.

Additionally, by NASA KSC utilizing the Airbus H-Care Infinite program, the Government ensures that the aircraft meet all Airbus standards and requirements to maintain the Original Equipment Manufacturers’ (OEM) warranty and airworthiness. The program is designed to maximize efficiencies and minimize repair timelines by drawing directly on the OEM capabilities, and ensures priority parts and support availability. H-Care Infinite provides all of the required personnel, hardware, systems, and tools necessary to operate the H135 aircraft to NASA’s high standards in a dynamic and mission critical environment.

The Period of Performance is expected to be a two-year base contract with four two-year options, for a total of ten years, with a start date of 01 October 2020. The total estimated maximum value of this acquisition is $15,000,000.

4. FAR 6.303-2(b)(4) – An identification of the statutory authority permitting other than full and open competition:

The statutory authority permitting other than full and open competition is 10 U.S.C.

2304(c)(1), as implemented by FAR 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements.

5. FAR 6.303-2(b)(5) – A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

The rationale supporting the use of 10 U.S.C. 2304(c)(1) is that NASA KSC Flight Operations requires that the Airbus helicopters maintain the capabilities for continuity of service, in a timely and safe manner, in order to meet current and future missions as defined by Center and Program requirements. Airbus Helicopters, Inc. offers an all-inclusive commercial maintenance and operations service for their Airbus aircraft to all customers under their Airbus Helicopters H-Care Infinite program. The H-Care Infinite program provides a total parts, maintenance, inspection, and operations solution (including technicians and crew support/pilots) that is fully compliant with NASA and FAA standards.

Utilizing the Airbus H-Care Infinite program, the Government ensures that the aircraft meet all Airbus standards and requirements to maintain the Original Equipment Manufacturers’ (OEM) warranty and airworthiness. The program is designed to maximize efficiencies and minimize repair timelines by drawing directly on the OEM capabilities and ensures priority parts and support availability. H-Care Infinite provides all the required personnel (maintenance technicians and crew support/pilots), hardware, systems, and tools necessary to operate the H135 aircraft to NASA’s high standards in a dynamic and mission critical environment.

H-Care Infinite program utilizes technicians that are fully Airbus trained for the performance of all scheduled and unscheduled maintenance actions and owns the process of identifying and diagnosing an issue, requisitioning parts, conducting the repair and tracking the task through to completion. On a highly advanced aircraft, such as the H135-F2 T3, this process is time consuming, technically challenging, costly, and can require multiple diagnostic tests to resolve. Maintaining a single source (OEM) to manage the entire process minimizes the risk to the Government by eliminating the use of another contractor that could introduce a costly mistake or misdiagnosis whereas leaving the government ultimately liable for a warranty violation or the cost of the replacement part. The OEM also conducts required, annual training with their technicians to sustain and improve technical skills, identify trending aircraft issues, and improve the overall process.

Utilizing the H-Care Infinite program for maintenance and parts services ensures the Government is given priority availability access to any spare parts required during the life of the contract. For routine customers, Airbus seeks to fill all planned maintenance action orders within 14 days. For those participating in the H-Care Infinite program, that timeline is 7 days. All unscheduled, aircraft on ground (AOG) shipping orders receive a fulfillment goal of 24 hours from requisition. In the mission critical environment KSC Flight Operations operates in, the ability to obtain replacement parts quickly is essential to maintaining the ability of NASA aircraft to support launch critical events. For many launch providers, the availability of NASA aircraft required for launch operations is critical to the missions at KSC. If the aircraft is unavailable at any point, significant costs would be incurred due to a mission delay, such as a scrub.

Airbus H-Care Infinite Program is not available from a third-party small business. A contractor’s error, other than OEM, would not be covered through a parts-only purchase agreement, such as the H-Care Easy program, a program NASA would expect to subscribe to in the event OEM were not used. The H-Care Easy program (a lesser plan than H-Care Infinite) would allow the government to maintain an acceptable non-mission capable time for the aircraft and manage budget considerations by supplying all scheduled and unscheduled parts. By utilizing a maintenance supplier other than OEM, NASA would be required to setup and manage the parts ordering system because third party vendors cannot order parts directly for the H-Care Easy program customer, NASA. This intermediary step increases the risk of flight readiness delays, cost, and levels of work to the Government.

It is the Government’s assessment the H-Care Infinite program meets the need of maintaining NASA’s H135-F2 T3 aircraft for continuity of service, in a timely and safe manner to meet NASA’s current and future missions. Airbus Helicopters, Inc. is the only provider and offers the best technical solution to meet those needs.

6. FAR 6.303-2(b)(6) – A description of the efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies:

A notice to the Government Point of Entry Web site, (beta.sam.gov), will be published in accordance with FAR Subpart 5.2. The posting will inform potential sources of NASA’s intent to award to Airbus Helicopters, Inc. as a sole source; only one responsible source and no other supplies or services will satisfy Agency requirements.

7. FAR 6.303-2(b)(7) – A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer’s signature on this document indicates that the Contracting Officer has determined that the anticipated cost to the government will be fair and reasonable. The Contractor shall be required to submit a proposal to be evaluated by the Government. Prior to issuance of any contract award, the Contracting Officer will conduct a proposal analysis, to include a price and cost analysis, where applicable, to sufficiently determine the contract action is fair and reasonable to meet the Government’s needs. Reasonableness of proposed price will be established in accordance with FAR 15.404-1(b)(2)(ii), comparison of proposed prices to historical prices paid, whether by the Government or other than the Government, for the same or similar items. This method may be used for commercial items, including those “of a type” or requiring minor modifications.

8. FAR 6.303-2(b)(8) – Description of the market research conducted, and the results, or a statement of the reasons a market research was not conducted:

In accordance with FAR 10.002(b)(2)(i), The Contracting Officer met with NASA KSC Flight Operations personnel to discuss the requirements and known industry sources for the helicopter operations and maintenance. These representatives are intimately familiar with services and materials required to operate helicopters, and are the requirement owners of the current Kennedy Flight Operations and Maintenance Services Contract (KFOMSS). The representatives conducted market research on GSA Advantage, manufacturer’s literature, direct interactions with manufacturer’s representatives at HeliExpo 2019, and found that no other entity can fulfill the unique capabilities of Airbus Helicopters as the OEM of the H135- F2 T3 aircraft.

KSC Chief of Flight Operations conducted a comparison of the ALICE contract at Johnson Space Center, and Vertex (maintenance personnel) and i3 (pilots) contracts at Armstrong Flight Research Center to determine if either of those contracts would be a viable option for KSC’s aircraft to provide maintenance, flight operations, and repair services of the new Airbus helicopter fleet. All three contracts provide services to fixed-wing aircraft. There is a distinct difference between fixed-wing aircraft and helicopters. Helicopters have far more moving parts than fixed wing aircraft so typically vibrate more than fixed wing. The uniform flight paths of a fixed wing are more relatable to other forms of transport such as driving a motor vehicle. The fixed-wing aircraft gets its lift from a fixed airfoil surface. The helicopter gets lift from rotating airfoils called rotor blades. A helicopter uses two or more engine-driven rotors from which it gets lift and propulsion. There is a lack of experience and technical skills for the three contracts identified above to provide helicopter maintenance, flight operations, and repair services of the new Airbus H135-F2 T3 aircraft. The technical risk by not working with the OEM is deemed unacceptable. A contract with Airbus Helicopters, Inc. is the best solution to ensure optimal integrity of the aircraft.

By utilizing the OEM and the H-Care Infinite program, NASA maintains a greater residual value of the aircraft. An example of this value has been determined by using HeliValues, a common industry website used to estimate used helicopter values, and reviewing similar, hypothetical aircraft. The market research, residual value example used was a 2016 EC135T2 with 60% component life used. The first aircraft was maintained using a power by the hour (PBH) model (referred to here as H-Care Infinite program) and the second was maintained by a third party. The results of the comparison indicate that the aircraft utilizing the PBH model retained a value of ~$3.925M while the aircraft not meeting that standard was valued at ~$2.380M; approximately a $1.5 million dollars increase in residual value per aircraft. Since KSC maintains three aircraft, at the completion of the useful life of the aircraft to KSC, the Agency will retain an increased value in this hypothetical example of approximately $5 million dollars. To maintain this residual value, the aircraft must be maintained through the use of an Airbus approved service center or the use of approved technicians. NASA’s use of the H-Care Infinite program meets that standard.

The use of the OEM through the proposed 10-year contract award would provide the Government a predictive cost structure while simultaneously saving time and money. Airbus typically charges an annual escalation cost of 2.5% for five-year contracts, however, based on the 10-year model, Airbus reduces the escalation to 2% annually. Over the life of the contract, the savings to the government is approximately $75,000. Airbus also determines the cost of the PBH program for the next ten years based on today’s predictive values. This allows the Government to lock in a rate based on current prices using only OEM presumptive estimates for future rates of increase for material and labor within the supply chain. By doing so, NASA ensures a predictable annual budget for Flight Operations regardless of future market forces.

Overall, the additional costs related to the annual technician and pilot training, the potential costs incurred due to delayed missions, the greater aircraft residual value of approximately $5M, and the predictive cost escalation, outweighs any potential cost savings using full and open competition.

9. FAR 6.303-2(b)(9) – Any other facts supporting the use of other than full and open competition:

None.

10. FAR 6.303-2(b)(10) – A listing of the sources, if any, that expressed an interest in writing in the acquisition:

In accordance with FAR 5.203(a)(2), the Contracting Officer may use the combined synopsis and solicitation procedures for acquisitions of commercial items. Therefore, there are no sources of expressed interested at this time. The proper actions will be taken to record any and/or all sources that show interest in the acquisition.

11. FAR 6.303-2(b)(11) – A statement of actions, if any, the Agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required:

The Agency will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements.

LISA MORALES MORALES

Digitally signed byLISA

Date: 2020.04.21 15:08:48 -04'00'

LAURA

ROCHESTER

Digitally signed by LAURA

ROCHESTER

Date: 2020.05.15 16:08:48 -04'00'

JOFOC Signature Page for Kennedy Flight Operations Contract

Technical Officer: I certify that the supporting data presented in this justificationare accurate and complete.

04/21/2020 David Ramsey, Date NASA Flight Operations

Contracting Officer: I certify that this justification is accurate and complete to thebest of my knowledge and belief.

04/21/2020 Lisa Morales Date Contracting Officer

CONCURRENCE:

Kelvin Manning Date Center Competition Advocate

APPROVED: Based on the preceding justification, it is determined that thestated circumstance for restricting consideration applies to the resultant order. Moreover, the preceding justification serves as the written determination required by FAR 8.405-6(c)(2)(xi).

Laura B. Rochester Date Head of Contracting Activity

KELVIN MANNING Digitally signed by KELVIN MANNING Date: 2020.05.15 10:45:47 -04'00'