Limited_Source_Justification__LPP_for_GSA.pdf

LIMITED SOURCE JUSTIFICATION APPROVAL

(FAR 8.405-6, as supplemented)

Contracting Activity: AFICA 765 SCONF

Purchase Request/Local Identification Number: PR # F2FF045152A001

Program/Project Name: Low Profile Parachute System

Estimated Cost/Price of the Action: $6.35M

Type Program: Other Contracting

AF Form 3215 Number: N/A__________________________

Contracting Officer: ____________________________________________ _____________

Maj Martin Muniz AFSOC A7/765 SCONF Date Signed

DSN: 579-4770, COM: (850) 884-4770

Program Manager: ____________________________________________ _____________

SMSgt Daniel Lewis AFSOC/A3TL Date Signed

DSN: 579-2178, COM: (850) 884-2178

Local Legal

Reviewer: ____________________________________________ _____________

David Charitat AFSOC/JA Date Signed

DSN: 579-5593, COM: (850) 884-5593

LIMITED SOURCE JUSTIFICATION

I. Contracting Activity

Air Force Installation Contracting Agency, th

Specialized Contracting Flight, Hurlburt Field, FL 32544

Contracting Officer:

Major Martin Muniz

(850) 884-4770

Limited Sources Justification

PR# F2FF044195A001

II. Nature and/or Description of the Action Being Approved

This action is for a new order placed under Federal Supply Schedule through General Service

Agency (GSA) under Schedule/SIN #084/426 99 for a Low-Profile Parachute (LPP) manufactured by Butler Parachute Systems, which is identified as LPP Part Number 11083 and

Oxygen Pull Cable Assembly Part Number FPII1285. There is only one source that can provide the level of quality, safety, and risk mitigation to fulfill this requirement as approved by

AFLCMC/WNU Human System Division with an approved Safe to Fly memo. The type of order will be a Firm Fixed Price (FFP) with contract line item for 600 LPP Systems (Part

Number 11083).

III. Description of the Supplies/Services Required To Meet Agency Needs

a. Requirement: Place an order for purchase of 600 LPP Systems for aircrew members aboard the AFSOC AC-130 U/H models. This system is intended to be a constant-wear or quick-don parachute for emergency bailout to replace the current BA -22 parachute system. The LPP is a configuration-frozen version of a Federal Aviation Administration certified commercial emergency parachute system Total System (PN: 11090): LPP (PN:

11083), Aircrew Cybernetic Parachute Release System (CYPRES) II (PN: AAD2C2P-

03), and Oxygen Pull Cable Assembly (PN: FPII1285).

b. The AFLCMC/WNU Human Systems Division located at Wright-Patterson AFB, completed a safety risk analysis on the LPP system. In general, the risk analysis assumes that an emergency egress is imminent, and does not lower risk by calculating the probability of such egress being required. Results from this test generated a “Safe to Fly” using the LPP system.

c. Butler Parachute Systems, Inc. is the sole manufacturer and distributor of the LPP (PN:

11083).

d. Estimated Cost: $6.35M

e. Description Breakdown: In an effort to provide a lighter, thinner, and safer parachute

AFSOC intends to transition to the LPP System. This solution offers a long term operational fix for deficiencies identified by the 1997 safety board associated with legacy parachute system.

f. Initial training and certification to maintain, store and repair the Butler LPP system is included in the total cost of this purchase and will be provided by a Butler LPP Systems, Inc. representative at each fielded location.

g. The 4 and 8 year maintenance calibration inspections for the CYPRESS Automatic

Activation Device (AAD) installed on all Butler LPPs for AFSOC are included in the total cost of this purchase.

IV. Authority and Supporting Rationale for Limiting Sources and Demonstration of the

Contractor’s Unique Qualifications to Provide the Required Supply/Service

FAR 8.405-6 requires an ordering activity to justify its actions when restricting consideration of schedule contractors to fewer than required in FAR 8.405-1 or 8.405-2. In addition, DFARS

208.405-70(c) (1) requires that all orders exceeding $150,000 be placed on a competitive basis

(by providing a fair notice of the intent to make the purchase) unless a written determination is justified and approved. The specific circumstance that justifies restriction for this acquisition is

FAR 8.405-6(a)(1)(i)(B)

The applicable FAR citation is FAR 8.405-6(a)(1)(i)(B) Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized. Due to mishap related to the old legacy BA-22 parachute system and from recommendations identified by the Air Force 1997 Safety Investigation Board

(SIB), AFSOC established a written requirement to replace the old legacy AC-130 aircrew BA-

22 parachute systems. The requirement was turned over to AFMC at Wright-Patterson; who then down selected to approve an LPP system and then conducted a “Safe to Fly” (STF) evaluation.

The LPP system is intended to be a constant-wear or quick-don parachute for emergency bailout to replace the current BA -22 parachute system. LPP will replace current emergency parachutes which are too bulky or heavy to be worn by aircrew during all operations. The LPP will be a complete emergency bailout parachute system to include the features, accessories, and will be a constant wear parachute for the gunners and other back end A/C-130 aircrew during flight in war and peace time.

The AFLCMC/WNU Human Systems Division located at Wright-Patterson AFB, completed a thorough review, STF evaluation and a safety risk analysis on LPP systems. AFLCMC/WNU determined that LPP systems presented by Butler Parachute Systems, Inc. was selected and determined to meet the STF for use by AFSOC AC-130 U/H Models aircrew members. The LPP is a configuration-frozen version of a Federal Aviation Administration certified commercial emergency parachute system Total System (PN: 11090): LPP (PN: 11083), Aircrew Cybernetic

Parachute Release System (CYPRES) II (PN: AAD2C2P-03), and Oxygen Pull Cable Assembly

Part Number (FPII1285). Initial training and certification to maintain, store and repair the Butler

LPP system is included in the total cost of this purchase and will be provided by a Butler LPP

Systems, Inc. representative. The life cycle of every 4 and 8 year required maintenance calibration inspections for the CYPRESS Automatic Activation Device (AAD) installed on the

Butler LPPs are included in the purchase of each LPP system. In addition, the Butler LPP also reduces repack time by approximately 2.5 hours per assembly. With each Butler LPP being repacked every 365 days, it will save the Air Force over 16K labor hours every year for the next

25 years. Therefore, currently Butler Parachute Systems, Inc. is the only LPP system authorized and approved to be utilized in fulfilling this requirement.

a. Butler Parachute Systems, Inc. is the sole manufacturer and distributor of the LPP (PN:

11083).

b. Estimated Cost: $6.35M

c. Description Breakdown: In an effort to provide a lighter, thinner, and safer parachute

AFSOC intends to transition to the LPP System. This solution offers a long term operational fix for deficiencies identified by the 1997 SIB associated with legacy parachute system.

V. Determination by the Ordering Activity Contracting Officer that the Order Represents the Best Value Consistent with FAR 8.404(d)

Supplies offered on the GSA schedule are listed at firm fixed prices with quantity discounts.

GSA has already determined the prices of supplies to be fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing but confirmed with the vendor that no additional discounts were offered. By placing an order against a schedule contract using the procedures in FAR 8.405, the ordering activity has concluded that the order represents the best value (as defined in FAR 2.101) and results in the lowest overall cost alternative (considering price, special features, administrative costs, etc.) to meet the

Government's needs.

VI. Description of the Market Research Conducted Among Schedule Holders and the

Results

AFLCMC/WNU Human System Division released a Request for Information (RFI) to industry in May 2009 to determine if a small business could meet the requirement to manufacture a LPP system. A Sources Sought synopsis with final P-Spec was posted to FedBizOps in November

2010 in order to determine what types of companies would be able to fulfill the requirements sought by this procurement. The responses received from this notice determined whether this procurement would be set-aside for small businesses or if full and open competition would be appropriate. Five contractors responded. A review of the responses was accomplished and it was determined that the responses were the same as the May 2009 RFI responses; therefore, another assessment was not conducted. Three of the respondents were small businesses. Of the three small businesses that submitted responses only one vendor, Butler Parachute, was determined technically acceptable in meeting the performance specification requirements. At this time, the

AFLCMC/WNU Human Systems Division located at Wright-Patterson AFB, completed a 36 month thorough “Safe to Fly” evaluation and a safety risk analysis on LPP systems costing the

Air Force $1.2M to accomplish this process that determined the Butler Parachute Systems, Inc.

LPP system to be the only currently approved and authorized system for use on AC-130 U/H models that met the requirements. The Butler Parachute Systems, LPP Systems (Part Number

11083) is available on the GSA schedule GS-07F-9649S.

VII. Other Facts Supporting the Justification

Since orders placed against Federal Supply Schedules are not considered DoD orders, Section

854 of the National Defense Authorization Act for FY2005 (P.L. 108-375) applies. Therefore, the justification should address how compliance with DFARS 217.78, Contracts or Delivery

Orders issued by a Non DoD Agency, will be accomplished. (Note: DFARS 217.78 requires review and approval in accordance with agency procedures that the order is in the best interests of DoD). Also recommend stating whether the order will be a direct acquisition or an assisted acquisition.

VIII. Actions the Agency May Take to Remove or Overcome Any Barriers that Led to the Restricted Consideration Before Any Subsequent Acquisition For the Supplies or

Services is Made

The Aircrew Performance Branch (AFLCMC/WNUV) successfully completed the Safe-To-Fly

(STF) testing on the LPP and Human Systems Division issued the LPP STF recommendation on

23 September 2013. This purchase would traditionally be performed by WNUV who is the

Procurement Contracting Office for a platform purchase. Due to the lack of 3080 procurement funding AFSOC and subsequent MAJCOMs must make the procurement. WNUV performed an extensive acquisition that started in May 2009 and concluded with an award on Sep 2011. A small business named Butler Parachute Systems, Inc. won the award and was the only proposal found technically acceptable. Based on the technical evaluation, the Butler proposal was determined technically acceptable for the Air Force LPP requirement. Butler Parachute System went on to complete the “Safe to Fly” testing /certification. Butler was awarded the STF memo on 27 Sep 2013. Out of the five vendors that responded to the RFP FA8606-11-R-6361 Butler was the only vendor to be determined technically acceptable in meeting the performance specification requirements and was issued a STF memo after completion of applicable Air Force testing & evaluations. Therefore, this J&A provides for the Butler LPP is the only current STF

LPP system to be utilized by AC-130 aircrew. Due to recent findings and current industry market at this time no other LPP systems meet the performance specification requirements nor are any other LPP systems approved or authorized for use.

IX. Contracting Officer’s Certification

I certify that data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

X. Technical/Requirements Personnel’s Certification

As evidenced by their signatures on the signature page, the technical and/or requirements personnel have certified that any supporting data contained herein which is their responsibility are both accurate and complete.