L6WA18 JA 14 Jul 26 PCO Signed_Redacted.pdf

Fall Protection Systems

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

I. Agency and Contracting Activity (RFO 6.104-1(a)(1)):

Agency: AFMC/WR-ALC Contracting Activity: Air Force Sustainment Center (AFSC)/PZIMB-R

II. Nature and/or description of the action being approved (RFO 6.104-1(a)(2)):

This document approves the award of a contract on a sole source basis to the Fall Arrest System (FAS) manufacturer for all the materials, parts, equipment, engineering, labor, shipping and travel necessary to provide fabrication, installation, and integration of a fall protection/fall arrest system for C-130 programmed depot maintenance (PDM) performed in B2390 and B91 in support of the Capital Improvement Program (CIP) L6WA18 B2390/L7WA05 B91 Fall Protection System. This justification is made on an Individual basis.

EXP Energy Services Inc.

CAGE: 57BP4

POC: Jung-Hoe Hopgood, Task Lead Jung-hoe.hopgood@exp.com 850-692-0372 2510 Miccosukee Rd, Suite 200 Tallahassee, FL 32308

III. Description of supplies/services required to meet agency needs (RFO 6.104-1(a)(3)):

The system shall provide fall protection for maintenance operations performed on the C-130 wing, center-wing box, empennage, and horizontal stabilizer. The installed FAS shall accommodate non-stretched and stretched C-130 fuselage variants. The Government prefers one FAS that provides fall protection for both variants. The contractor shall use passive systems, such as guard rails, fall restraint, and fall arrest means in this order of government preference. The system shall not contact any aircraft components. Delivery shall include operation manuals, maintenance manuals, recommended preventive maintenance, drawings, SolidWorks models and training of 402d Aircraft Maintenance Group (AMXG) at Robins Air Force Base (AFB), Georgia.

L6WA18 B2390 Total estimated cost of $3,244,300.00 CLIN Description (details below) Qty (EA) Cost/Unit Total Cost 0001 Bay #1 Fabrication and Install of FAS for 1 $811,075.00 $811,075.00

Base/Stretched Model 0002 Bay #2 Fabrication and Install of FAS for 1 $811,075.00 $811,075.00

Base/Stretched Model 0003 Bay #3 Fabrication and Install of FAS for 1 $811,075.00 $811,075.00

Base/Stretched Model 0004 Bay #4 Fabrication and Install of FAS for 1 $811,075.00 $811,075.00

Base/Stretched Model 0005 Data CDRL (A001-A009) NSP 1 $0 $0 mailto:Jung-hoe.hopgood@exp.com

L7WA05 B91 (option) Total estimated cost of $5,677,525.00 CLIN Description (details below) Qty (EA) Cost/Unit Total Cost 1001 Bay #1 Fabrication and Install of FAS for 1 $811,075.00 $811,075.00

Base/Stretched Model 1002 Bay #2 Fabrication and Install of FAS for 1 $811,075.00 $811,075.00

Base/Stretched Model 1003 Bay #3 Fabrication and Install of FAS for 1 $811,075.00 $811,075.00

Base/Stretched Model 1004 Bay #4 Fabrication and Install of FAS for 1 $811,075.00 $811,075.00

Base/Stretched Model 1005 Bay #5 Fabrication and Install of FAS for 1 $811,075.00 $811,075.00

Base/Stretched Model 1006 Bay #6 Fabrication and Install of FAS for 1 $811,075.00 $811,075.00

Base/Stretched Model 1007 Bay #7 Fabrication and Install of FAS for 1 $811,075.00 $811,075.00

Base/Stretched Model 1008 Data CDRL (A001-A009) NSP 1 $0 $0

Detail Description:

-System Type: Free standing, ground-based, enclosed track with a rigid rail style. Must not interfere with aircraft docking or maintenance.

-Coverage: Provide fall protection over all elevated surfaces of the aircraft fuselage and the rear of the leading edge of wings.

-Included Components: All tracks, trolleys, Self-Retracting Lifeline (SRL) devices, support structures, and associated hardware. (Excludes user harnesses).

-Deliverables: A preliminary design and a final, complete drawing and specification package stamped by a Professional Engineer who is also a Qualified Person for Fall Protection.

-Compliance: Must be 100% compliant with AFMAN 91-203, OSHA 29 CFR 1910/1926, and ANSI Z359.

IV. Statutory Authority Permitting Other Than Full and Open Competition (RFO 6.104-1(a)(4)):

• 41 U.S.C. 1901, Simplified Acquisition Procedures

V. Rationale for Use of Authority (RFO 6.104-1(a)(5)):

The Government’s requirement for four Fall Arrest Systems (FAS) in Building 2390 with an option for seven FAS in Building 91 is justified on a sole-source basis due to the custom design, fabrication requirements, unique technical capabilities of the currently approved system and rapidly increased workload that has now moved into early fiscal year 2027 vs the original time-frame of late FY 2027. Procuring these systems from any alternate manufacturer would result in substantial duplication of cost to the Government and unacceptable delays to production operation/mission TEMPO. The current production operations will increase the dock work in the upcoming years, very specifically FY 26 and 27. The FY26 induction is for 46 C-130 aircraft and by FY31 there will be an increase of 42.6% with a total throughput of 67 C-130 aircraft for PDM work.

GRAND TOTAL: $8,921,825.00

The current schedule of induction would allow for B2390 and B91 flexibility to complete scheduled PDM work. The Government POC will be able to provide contractors with a schedule to provide the fall protection system that will keep our personnel safe as workload ramps up to meet the mission goal and providing a safe environment for employees.

The existing FAS design—previously engineered and installed in Building 91, Bay 1—has been validated through operational use and has demonstrated full compliance with all safety and performance requirements for C-130 aircraft maintenance. The system supports simultaneous use by twelve aircraft mechanics (six per side) without disrupting workflow or compromising safety. Its unique configuration is specifically tailored to the C-130 production environment and cannot be replicated without significant redesign to both the mobile and non-mobile FAS.

Replicating or re-engineering the system through competitive procurement would require new engineering, testing, and certification efforts, resulting in an estimated additional cost of approximately $1.0M. These efforts would also introduce schedule delays that would negatively impact aircraft maintenance throughput.

Standardizing the FAS in Building 2390 using the proven design from Building 91 ensures compatibility across maintenance bays, reduces life-cycle and sustainment costs, and maintains continuity in production processes. Introducing a different manufacturer or design would create interoperability challenges, increase sustainment complexity, and degrade overall efficiency of the fall protection system.

The Economic Analysis (EA) completed on B2390 FAS includes attachment 3 that demonstrates the need for fall protection while PDM work is being accomplished. There are four noted incidents where aircraft mechanics fell while utilizing current stands and causing injury. AF Form 3, Hazard Abatement Plan, was completed and the Description of the Permanent Abatement Action is as follows: Engineering actions will be required to alleviate hazard. Installation of overhead fall protection systems will be required. For these reasons, only the current FAS manufacturer can meet the Government’s requirements without incurring substantial duplication of cost or unacceptable delays, thereby justifying the use of the authority under FAR 6.104-1(a)(5).

VI. Integrated Market Analysis and Efforts to Solicit Competition (RFO 6.104-1(a)(6), (8), and (10)):

1.Market research was conducted on 01/07/2026 to 02/12/2026 in accordance with RFO Part 10.001. The Market research was completed on 02/23/2026. It was performed by reviewing Dynamic Small Business Search (DSBS) and System for Award Management (SAM).Gov databases using North American Industry Classification System (NAICS) Code 333923- Overhead Traveling Crane, Hoist and Monorail System Manufacturing and key word "Fall Arrest", looking for businesses that could provide this requirement. A review of small businesses to include 8(a), HUBZone, Service-Disabled Veteran Owned Business, and Women Owned Small Business was conducted in search of a company that could provide these units. This query resulted in 1 small business KAM Industrial Services - VOSB.

2.Internet searches were conducted and reviewed, two vendors (MSA Safety and Flexible Lifeline Systems). MSA Safety is not registered in SAM.Gov and according to the research are not capable, due to MSA products focus on electronics, mechanical systems and advanced material to protect users with self-contained breathing apparatus, gas detection instruments. Flexible Lifeline Systems is registered in SAM.Gov as a large business and website review deemed Capable. They focus on fall arrest systems in a number of industrial areas.

3. A GSA query was ran. There were sub-assemblies and parts for a Overhead Fall Protection System listed. But an FAS at this size and magnitude was not shown available. See attached Internet query.

4. Government POC has extensive working knowledge of EXP with past performances in creating B91 Overhead Fall Protection System. Also, EXP has had design and project overseer responsibilities with previous and current projects on the FA8571-22-D-0001 A&E Environmental Services to support WRALC. The approved FAS design that EXP created will work in both B91 and B2390. The efficiency of EXP with the design, fabrication and installation of the FAS deems them capable of providing the same service. EXP will be able to efficiently meet the revised timelines and specifications where others will not be able to.

SAM.gov has been checked to ensure these sources have been registered to do business with the Federal Government.

VII. Determination of Fair and Reasonable Cost (RFO 6.104-1(a)(7)):The Contracting Officer is responsible for evaluating, determining, and documenting the anticipated contract cost/price is fair and reasonable in accordance with RFO Subpart 15.4, Contract Pricing.

VIII. Any Other Facts Supporting the Justification (RFO 6.104-1(a)(9)):

The current situation in Building 2390 is untenable. The patchwork of workarounds represents a systemic failure that directly compromises personnel safety on a daily basis and demonstrably hinders the squadron's ability to perform its core mission efficiently. The acquisition of a fully integrated, ground-based fall arrest system is therefore not an upgrade, but an urgent and necessary corrective action to eliminate known hazards, ensure OSHA compliance, and restore the intended productivity of the C-130 PDM line.

To address known deficiencies, new raised-platform wing stands were recently installed to replace legacy stands that failed to meet Occupational Safety and Health Administration (OSHA) standards. Based on the current design, design approval, fabrication, cost saving, and satisfaction with the B91 FAS utilizing the vendor EXP is the ultimate sole-source provider for the four FAS in B2390 and the option for the additional seven in B91.

IX. Actions to Overcome Barriers to Competition (RFO 6.104-1(a)(11):

The current plan to remove or overcome barriers to competition is to verify any updates to drawings and fabrication that would broaden the FAS equipment to be used during PDM work. The Government is unable to procure a different sole-source equipment without the Government suffering significant cost, approximately $1.0M, to providing a safer work environment.

Date 14 July 2026

Program Mgr Lisa Matney CIP Program Manager

Signature

Date Contracting Officer Signature

14 July 2026

BRYAN D. CANADY

Contracting Officer