Justification for Other than Full and Open_Redacted.pdf

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

CONTROLLED UNCLASSIFIED INFORMATION

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I. Agency and Contracting Activity.

Air Mobility Command, 436 CONS

II. Nature and/or description of the action being approved.

436 CONS intends to award a sole source contract to Federal Integration Team (FIT), Inc. under the authority outlined under Federal Acquisition Regulation (FAR) 6.302-1 (Only One Responsible Source) and FAR 6.302-5 (Authorized or Required by Statute).

III. Description of supplies/services required to meet agency needs.

The 436th Maintenance Squadron (436 MXS) requires preventative, unscheduled, and emergency maintenance services for the Dover Air Force Base (AFB) C-5 Galaxy Isochronal (Iso) Stand System. The contractor shall provide all management, tools, supplies, equipment, and labor necessary to ensure continuous and safe operation of the Iso Stand System's wing, empennage, fuselage, landing gear, and engine stands, as well as a Hydraulic Power Unit. The Contracting Officer's Representative will furnish all relevant documents for execution of maintenance planning as needed by the contractor.

Upkeep and repair of the Iso Stand is deemed a mission essential service to ensure 24/7 operability of the Iso stand by 436 MXS for maintenance of the C-5 Galaxy fleet.

IV. Demonstration that the contractor's unique qualifications or the nature of the acquisition requires use of the authority cited above.

436 CONS initially awarded a long-term Iso Stand Maintenance contract (FA449718C0022) through the Small Business Administration (SBA) 8(a) Business Development (BD) program to United Global Group (UGG) in FY18. However, due to financial hardship, UGG ceased performance, and the contract was terminated for Government convenience via a no-cost settlement, effective 30 June 2020. To avoid mission degradation, an emergency sole source contract was awarded to UGG's subcontractor, FIT, Inc. (FA449720P0027), under FAR 6.302-2 to provide interim maintenance for the C-5 aircraft. As a follow-on, an 8(a) sole source contract (FA449721C0012) was issued to D. Gillette Industrial Services (DGI), with SBA Regional Office of Eastern Pennsylvania endorsement, and set for a five-year term ending 30 September 2025. A subsequent five-month extension through 28 February 2026 was granted to address operational needs during a 43-day Government shutdown.

FAR 6.302-5 Authorized or Required by Statute

During follow-on contract negotiations under the 8(a) BD program for contract FA449721C0012, it was discovered that Dover had been incurring a 20% premium on this 8(a) award despite DGI's subcontractor, FIT, Inc., performing over 51% of the work, raising concerns over compliance with FAR 52.219-14 ("Limitations on Subcontracting"). Upon further engagement with the SBA, it was agreed to release the Iso Stand Maintenance contract from the 8(a) BD program under FAR Overhaul 19.108-11(a)(2), contingent on setting the contract aside for a Women-Owned Small Business (WOSB), Service-Disabled Veteran-Owned Small Business (SDVOSB), or Historically Underutilized Business Zone (HUBZone). 436 CONS intends to meet this contingent through a SDVOSB sole source under the authority at FAR 6.302-5 (Authorized or Required by Statute).

FAR 6.302-1 Only One Responsible Source

On 4 December 2025, 436 CONS spoke with the 439th Contracting Flight (CONF) at Westover Air Reserve Base (ARB), Massachusetts, the home of the only other C-5M (major/minor) Iso stand, regarding their acquisition history for their T-Tail (Iso) Stand contract. During their last acquisition, 439 CONF received proposals from FIT, Inc. and Kern Steel, the manufacturer of the C-5 Iso stand, and awarded the contract to FIT based on price comparisons. No other offers or interested

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Based on the market research conducted, 436 CONS has identified FIT as the only responsible source for the Iso Stand contract. While Kern Steel is the original manufacturer of the Iso Stand, it is a large business and therefore ineligible for a WOSB, SDVOSB, or HUBZone set-aside under FAR Overhaul 19.108-11(a)(2). FIT has directly performed maintenance operations on the Isochronal Stand as a subcontractor and a prime contractor since FY18 for Dover AFB's Iso Stand and since at least FY21 for Westover ARB's Iso Stand. With the majority of C-5M isochronal inspection services concentrated at Dover AFB and Westover ARB, there are no other contractors who perform maintenance on C-5 Iso Stands. Due to the limited availability of parts and the highly specialized nature of the equipment, FIT remains the only contractor with the necessary connections to the commercial marketplace to acquire the specially-fabricated parts of the stands and the specialists who can perform the work. Since no other sources were found during market research to be both responsible and eligible, 436 CONS intends to utilize the sole source contract authority outlined under FAR 6.302-1 (Only One Responsible Source) and FAR 6.302-5 (Authorized or Required by Statute).

V. Description of 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

FAR 5.202 applies.

436 CONS posted a sources sought notice on 4 December 2025 and received responses from 3 interested vendors: Begini Howard Private Equity (BHPE) LLC (CAGE 9SWS7), Simpson Alloy Services (SAS) Inc (CAGE 7TGD8), and FIT Inc. (CAGE 839J3).

The Government requested that any interested parties submit qualifications as an SDVOSB and 5 years of past performance on Kern Steel Fabrication's C-5 Iso Maintenance Stand, due to the limited availability of parts and the highly specialized nature of the equipment. Neither BHPE LLC or SAS Inc provided the requested capability statement.

VI. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

By removing the requirement from the 8(a) BD program under FAR Overhaul 19.108-11(a)(2), the Government will be eliminating a 20% premium paid to the prime contractor. By contracting directly with FIT, Inc. the Government will cut approximately $700,000 in costs paid to DGI. By decreasing costs from the previous requirement, the Contracting Officer anticipates that all costs to the Government received from the Contractor will be fair and reasonable.

VII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

A search of the AbilityOne Procurement List was conducted on 5 August 2025 and yielded one vendor who could provide "Custodial and Maintenance Service": SourceAmerica. The current requirement is for "aircraft maintenance", which requires specialized technical expertise and training in accordance with the Performance Work Statement (PWS), beyond the basic repairs and maintenance capabilities of "janitorial maintenance". AbilityOne cannot provide the required services as the sole mandatory source for services according to FAR 8.002.

VIII. Any other facts supporting the use of Other Than Full and Open Competition.

In accordance with FAR 6.303-2(b)(9)(i), all technical data packages, specifications, engineering descriptions, statements of work, and/or purchase descriptions required for full and open competition on the Government Point of Entry are developed and available. The PWS approved by the Quality Assurance Plan Coordinator, with all the information required to compete for this acquisition, was provided with the sources sought notice described in Section V above.

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IX. List of any sources that expressed, in writing, an interest in the acquisition.

Begini Howard Private Equity (BHPE) LLC (CAGE: 9SWS7)

Simpson Alloy Services (SAS) Inc (CAGE: 7TGD8)

Federal Integration Team (FIT) Inc. (CAGE: 839J3)

X. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisitions for the supplies or services required.

When planning the acquisition for the FY31 Iso Stand contract, 436 CONS will consider removing the requirement from the socioeconomic programs in FAR part 19. Due to the requirement of FAR Overhaul 19.108-11(a)(2) to set-aside the follow-on acquisition for a WOSB, SDVOSB, or HubZone, the agency cannot currently open competition beyond these socioeconomic programs. For future acquisitions, the agency may consider opening beyond these programs to remove barriers to potential competition.

XI. Certification by the Contracting Officer.

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

XII. Certification by the technical/requirements personnel.

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