Justification and Approval for Other Than Full and Open Competition_Redacted 21JAN25 (002).pdf

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

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6.302-1 – 10 USC 3204(a)(1), Only One Responsible Source - No Other Supplies or Services Will Satisfy Agency Requirements

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USAF/AFMC/AFRL/PZLEQ

This is an individual Justification and Approval (J&A) for Other than Full and Open Competition (Sole Source) for a new contract (FA2396-25-C-TBD) using Firm-Fixed Price Contract Line-Item Numbers. The United States Air Force School of Aerospace Medicine Aerospace Medicine Directorate, Aerospace Medicine Education Branch (USAFSAM/FEEE) has a requirement to obtain highly specialized services to educate student flight surgeons on the physiological effects of flight on the human body.

This specialized training has been an integral part of the Air Force's training of flight surgeons for many decades. A rudimentary version of these services was originally provided to USAFSAM/FEEE by AETC until 15 years ago.

When AETC was no longer able to provide these services, these services were sought from the private sector and the program's curriculum was revised and expanded to fully cover all the physiological effects of flight on the human body. The past 15 years has proven the new curriculum as essential in ensuring our graduated flight surgeons understand their patient's physiological environment and are better able to provide for their medical needs.

Under the contemplated contract, MacAir Aviation, LLC (MacAir) will be required to supply all personnel, including FAA certified flight instructors, all aircraft, training aids, supervision, materials, maintenance, equipment, and services necessary to perform the Aeromedical Aviation Laboratory (AAL) as defined in the PWS and as outlined in the Core Aerospace Medicine Principals (CAMP) Aerospace Medicine Primary(AMP), and Resident in Aerospace Medicine (RAM) syllabus.

Estimated period of performance is 4 December 2024 to 3 December 2029. Appropriations used to fund this effort are 3400 (Operations and Maintenance (O&M)) funds. The budget estimate for this program was calculated using historic cost for similar recent programs, delivering same or similar services. Contract cost estimates are summarized below:

Base Period (1 year), Option 1 (1 Year), Option 2 (1 Year), Option 3 (1 Year), Option 4 (1 Year), Total (5 Years)

Contract line items (CLINs) for this contract include:

CLIN X001 Session Fee (FFP)

CLIN X002 Glass Cockpit Aircraft Flight Hours (FFP)

CLIN X003 Aerobatic Aircraft Flight Hours (FFP)

CLIN X004 Rotory Aircraft Flight Hours (FFP)

CLIN X005 Surge Glass Cockpit Aircraft Flight Hours (FFP)

CLIN X006 Surge Aerobatic Aircraft Flight Hours (FFP)

CLIN X007 Surge Rotory Aircraft Flight Hours (FFP)

CLIN X008 Session Fee (FFP)

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CLIN X009 Glass Cockpit Aircraft Flight Hours (FFP)

CLIN X010 Session Fee (FFP)

CLIN X011 Aircraft Flight Hours (FFP)

CLIN X012 Instrument Aircraft Flight Hours (FFP)

CLIN X013 Multi Engine Aircraft Flight Hours (FFP)

CLIN X014 Ground School (FFP)

CLIN X015 Data

10 U.S.C. 3204(c)(1), as implemented by FAR 6.302-1(a)(2)(iii), and required by FAR 6.303-2(b)(4).

A. Only One Responsible Source -- Original Source for a Follow-On Contract:

MacAir holds the current support contract for USAFSAM/FEEE, under contract number FA2396-22-C-0017, which was awarded 11 March 2022 and expires 3 December 2024. The previous four (4) contracts for this effort were also awarded to MacAir. MacAir first received a competitive award in 2011, and each successive follow-on effort has been awarded competitively except for 2021. 2021 was a one year directed award to MacAir as a result of the US Government failing to exercise the last option year on the previous contract due to an administrative error.

In 2017, the US Government identified two (2) companies to compete with MacAir. Of the two (2) companies that were identified, none submitted a proposal. After the directed award to MacAir in 2021, the US Government identified one (1) company to compete with MacAir in 2022. That company failed to submit a proposal. The market research phase for this current contract returned no potential competitors.

Subsection 1

1(a). Continued provision of highly specialized services: This acquisition will be for the continued performance of highly specialized services specifically tailored to the needs of USAFSAM/FEEE. MacAir has spent over 11 years developing and tailoring their classroom and in-flight AAL curriculum to specifically address and demonstrate the physiological effects of flight on the human body. Since their first AAL contract award in 2011, MacAir has continued to renovate and expand their facilities to be better tailored to meet the AAL requirements. MacAir is currently able to provide education and training to up to 80 CAMP students in a 3-day period. This includes providing 2 hours of classroom instruction, 1 hour of aircraft simulation training, and 1 hour of in-flight training to each of those 80 CAMP students.

MacAir is also currently able to provide education and training to up to 40 AMP students in a 9-day period. The AMP students each receive 16 hours of classroom instruction, 2.5 hours of aircraft simulation training, and 8.7 hours of in-flight instruction to each of those 40 AMP students.

No other Fixed Base Operator (FBO) within 50 driving miles of WPAFB currently has the available facilities or developed curriculum to provide services at this intense level.

MacAir has specifically designed their unique scheduling algorithm to be able to schedule and reschedule around the ever-changing weather here in the Dayton, OH area. Other non-DoD flight services do not have the requirement to train this many flight students within a specific short calendar period and subsequently do not possess the skills and algorithms to provide this kind of minute-by-minute rescheduling capability.

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Subsection 2: Award to any other source would result in unacceptable delays in fulfilling the Air Force's requirements.

2(b). Unacceptable delays in fulfilling the agency's requirements:

The Air Force has a complicated and fixed schedule for training physicians and flight surgeons. The training schedules are fixed at least a year in advance in order to ensure the required number of physicians and flight surgeons are graduated in time to replace those scheduled to retire or resign. The first AAL class of these pipeline flight surgeons starts in April of 2025. An award to a new contractor at this time would almost certainly result in a delay in providing these AAL services to that first April 2025 class as a new contractor would need to develop the curriculum and facilitates to provide these services. This would result in the students scheduled for this class not being graduated and many would have to be rescheduled for the next year. Under the current contract, there are no PWS requirements for MacAir to train and assist a follow-on contractor. The US Government has spent countless hours mentoring MacAir over the past 11 years to bring them up to the level of providing AAL services currently considered the standard for these services. It would take another 11 years of US Government mentoring to bring a new contractor up to these same standards. Any gap in the pipeline of new flight surgeons will result in flying bases going without their required flight surgeons. Without these flight surgeons out in the field treating the Air Force and National Guard flight crews, many flight mission may be cancelled or may be flown with crewmembers who should not be flying.

Aerospace Medicine Primary (AMP) 1 is the capstone training class for student flight surgeons. Without AMP 1, physicians cannot become certified flight surgeons. The first two classes of the year for the AAL contract are AMP1 classes and these two classes are scheduled back-to-back. Each of these classes are predicted to have 40 students. If these first two classes do not occur on schedule, there may be up to 80 vacant flight surgeon positions that will go unfilled in the early part of 2025.

To have everything in place for these first two classes, the contract needs to be awarded at least 3 months in advance so rental aircraft and qualified flight instructors can be scheduled from around the country to be flown in and available for these classes. The first Aeromedical Aviation Laboratory (AAL) class is scheduled for 14 April 2025.

Subsection 3: USAFSAM has determined that an award to any other source would result in unacceptable delays in fulfilling the agency's requirement.

In accordance with (IAW) FAR 10.002(b)(2) and DFARS PGI 206.303-2(b)(i), the US Government posted a Sources Sought Synopsis on sam.gov on 21 June 2024, which requested respondents include a capability statement that describes how a potential source can meet the requirements listed in the draft PWS with a targeted set aside to Service-Disabled Veteran Owned Small Business. Only the response from MacAir was received. This Sources Sought Synopsis was updated on 22 July 2024 to expand the target set aside to all Small Businesses. It was posted for 30 days.

IAW FAR 5.203(a), this acquisition is required to be publicized at least 15 days before issuance of a proposed contract action.

Based upon certified cost or pricing data provided in the offeror's proposal, the contracting office expects they will be able to determine that the anticipated costs to the Government will be fair and reasonable.

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As described in Section VI, market research, IAW FAR Part 10, was conducted by posting a sources sought on sam.gov on 21 June 2024, which requested respondents include a capability statement that describes how a potential source can meet the requirements listed in the draft PWS with a targeted set aside to Service-Disabled Veteran Owned Small Business. The only response was from MacAir Aviation, LLC. This Sources Sought Synopsis was updated on 22 July 2024 to expand the target set aside to all Small Businesses and was posted for 30 days. No new responses were received.

Internet searches were conducted in May of 2024 to find companies providing similar training services. Over 100 were identified who provided standard flight training with their final goal of awarding FAA certified pilots license to their students. Two were identified who provide flight screening to potential military pilots to determine their potential assignments to military pilot training schools. Only MacAir Aviation, LLC was identified as currently teaching their students the physiological effects of flight on the human body.

There are 18 fixed base operators (FBO) airports within 50 driving miles of Wright-Patterson AFB. Over the past two years, our market research team has conducted telephone and on-site visits to all these FBOs with the goal of soliciting interest on providing AAL services. None of these sources have expressed any interest in providing AAL services to the Air Force with the exception of the incumbent contractor MacAir Aviation, LLC out of the Greene County Regional Airport.

None

MacAir Aviation, LLC is the only source from which we received interest of any kind, written or verbal, of providing these services.

No barriers to competition for these services have been identified.

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

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

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