Limited Sources Justification - 47QRAA18D006A_Redacted.pdf

Limited Sources Justification and Approval (J&A)

FOR OFFICIAL USE ONLY

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I. Contracting Activity.

Name: Mr. Michael W. Piller Organization: 338th SCONS/RAPIDx Address: 701 Brazos St., Austin, TX 78736 Email: Michael.Piller.1@us.af.mil

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

Nature of the Action: Sole Source Modification to an existing order.

Name of Schedule: Educational Professional and Support Services (EPASS) Blanket Purchase Agreement (BPA);

Managed by the General Services Administration (GSA)

GSA Schedule Number: 47QRAA18D006A

Order Number: FA3002-19-F-A170

Contractor: C² Technologies, Inc.; 1921 Gallows Road, Suite 200; Vienna, VA 22182; CAGE: 09UJ3

Period of Performance (PoP):

Base Period: 16 Sep 19 - 15 Mar 20 (6 Months)

Option Period 1: 16 Mar 20 - 15 Sep 20 (6 Months)

Option Period 2: 16 Sep 20 - 15 Mar 21 (6 Months)

Option Period 3: 16 Mar 21 - 15 Sep 21 (6 Months)

Type of line items on the order: Firm Fixed Price (FFP)

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

The services being procured under order number FA3002-19-F-A170 include all onsite program integration and developmental services that encompass skillsets that adapt to the active projects being accomplished by the Maintenance Next program. The Maintenance Next program is an exploratory experiment managed by the Air Education and Training Command (AETC) Detachment 23 that was established to accomplish the development of a system that delivers virtual training environments by exploring existing innovative commercially available information technology software and hardware. Given the amount of technology and emerging technology, the Maintenance Next program required contractor supplied integration services since the AETC was not able to staff the technical experts needed to develop a training system from scratch.

The awardee from the original competition, C2 Technologies, supplied a technically acceptable proposal. The order was awarded on 16 September 2019 and provided the immediate system integration services related to eLearning development skills, IT Systems architect, virtual environment modelers, as well as assorted software developers in addition to the onsite system integrator services. The original award did not include milestones due to the simple fact that the requirement was still in it's infancy. However, milestones were added after contract award. The proposal from the contractor was for three full time equivalents (FTEs).

The types of services being procured under the contract range by core competency but are directly related to the development of the Maintenance Next Virtual Training Environment and system. The services encompass labor categories that are proposed on a performance based basis to achieve the accomplishment of the development of a proof of concept, creation, implementation of adaptive learning capabilities, test and deliver a full crew course in a

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As a result of the requiring activity's definition of the milestones needed to accomplish the development of the virtual training environment, a request for an updated proposal was issued which resulted in the base period being modified adding to the original cost of the contract, bringing the total of the effort to .

The additional full time equivalents postured the project to successfully execute a demonstration of the capabilities in February 2020. The requiring activity requested that the remaining periods of performance be modified to include the additional full time equivalents.

The modification increases the number of full time equivalents from three to eight due to the increased amount of effort needed to accomplish the set program milestones for the remaining periods of performance on the contract.

The proposal was evaluated by the technical representative who determined the requiring activity needed five additional full time equivalents in the remaining periods of performance. That increased the contract value by over the course of two and a half years of performance.

IV. Identification of the justification/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.

FAR 8.405-6(a)(1)(i)(C), “The new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures.”

The original order was not issued under sole source or limited source procedures.

The very nature of the Maintenance Next program system requirement has been centered on accomplishing goals that were novel and innovative. The reason this sole source modification was accomplished was because of the fact that C2 Technologies has assembled the team that helped develop the plan to fully build a virtual training platform.

Therefore, C2 Technologies is the only contractor that possesses the staff that has intimate knowledge on this program. No other schedule holder (company) who was sent the original request for proposal could recruit, hire, train and place all needed positions to successfully meet the programmatic milestones. The core element of these services is the role of system integrator which has been foundationally important for the program's development.

The Maintenance Next program is manned by six Active Duty and Air National Guard Aircraft Maintenance Crew Chief Subject Matter Experts. None of these individuals are technically trained to develop a highly technical training system. Thus, the corporate knowledge of the current workforce will be fundamental for the Maintenance Next program to remain on schedule to meeting milestones that were levied upon them from AETC. Thus, no other company would be able to `pick up' where the current company is with respect to producing program content. Any contractor would have to possess the same history and corporate knowledge as C2 Technologies in order for the program to be successful in meeting the program's milestones. Besides initial development and strategy creation, the contractor possesses the working knowledge of the maintenance crew mission and even the understanding of the environments in which the virtual learning course must replicate.

C2 Technologies were pivotal in the development of a storyboard to transform course realistic scenarios into usable theatrically based interactions that are not Virtual Reality (VR) Developer or Programmer methodologies. The storyboards are not Game Design Documents (GDD) that convey all the VR environment design, mechanics, dynamic and static interactions required to build a VR environment that achieves the primary objectives set by the Maintenance Next program. Therefore, the current team must continue to create the virtual environment at a level design for each component of the storyboard, each scene must be detailed to a game developer's understanding to create the Maintenance Next Program's expected level of fidelity to achieve the learning objectives. The C2 Technology team is building the course content from scratch using standard and innovative game design strategies to produce the best outcome for the course mission.

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On top of the aforementioned skillsets and experiential knowledge that is unique to the current contractor, there would be an extensive amount of time needed for any other contractor to learn about all of the wide array of information technology hardware and software that constitutes the basis of the program. A part of the Maintenance Next program that was the AF needed to look at commercially available technology and the current items were brought together to demonstrate that the creation of a less expensive, adaptive system could be developed. C2 has been a part of the initial development of the integration of not only hardware solutions (like virtual reality headsets and computers) but also the incorporation of software that was developed in parallel to the efforts happening at a rapid rate.

V. Determination by the ordering activity Contracting Officer that the order represents the best value consistent with

FAR 8.404(d).

All prices proposed are in line with or below the published price list related to the contractor's BPA schedule 47QRAA18D006A. A review of the contractor's proposed price list was reviewed at the original award of the contract. A review of the proposed prices (labor rates) was accomplished by the contracting officer and documented in the contract file.

In accordance with FAR 8.404(d), the original award of the order was competed amongst all schedule holders. The awardee, C2 Technologies, had a price list that showed the hourly rates which represented the types of labor categories proposed. The CO has been informed of the circumstances surrounding this modification and has determined that the price for this modification is constituted of the needed labor categories that have been executing under the contract and therefore represent the best value to the Air Force (AF).

VI. Description of the market research conducted and the results, or explain why market research was not conducted.

Market research was not conducted because of the nature of this action being a modification that adds additional scope to the original award. The market research that was originally conducted had identified that the EPASS BPA was the preferred acquisition method for the developmental system integration services.

VII. Other facts supporting the justification.

FAR 8.405-6(a)(1)(i)(C) is cited for a follow-on acquisition as the basis for this justification, and to further substantiate the claims made in this justification, the following details on why the delay related to the re-competition of this effort would be unacceptable.

The current effort is being executed at an expedited rate since the middle of January 2020. The timeline needed to maintain positive trends in the development of the virtual training environment is shown as follows:

Need By Date/Description of Work Needed

Mid-March: Completion of prototype environments (Incorporating all suggestions and improvements as a result of the February demonstration)

Mid-April: Completion of the integration of the virtual reality computer system and hardware architecture (Requires the system integrator's continued observation and testing)

Mid-May: Finalization of the full course asset modeling (This is a cumulative effort pulling from all elements of the development team)

Mid-June: Finalization of realistic virtual learning environment to meet the Maintenance Next objectives.

Mid -July: Live demonstration of the systems capabilities to AETC leadership.

In comparison, if there was to be a recompete of the effort, the assumption is that the current PoP would be stopped completely which means that all other current contractors working on Maintenance Next would need to

March 2018 FOR OFFICIAL USE ONLY Page 6 of 6 stop working. The understanding that the market for the types of workers is very competitive right now and given that there are other job opportunities in the surrounding metropolitan areas (such as Austin), it is assumed that there would be a loss of the current workforce (and subsequently all the corporate knowledge) since they would go to other employment opportunities. Then, once Maintenance Next began again, the Air Force would likely pay a premium on existing positions and then paying for more bodies to make up time. The traditional effort for the execution of the effort would be for the effort required to continue the development of the system which could not be accomplished by AF assets since the current military members are not technological experts.

The acquisition timeline for this effort would be as follows:

End of March: Release of Request for Proposal (14 Day timeline to ensure we get as many proposals as possible)

Mid-April: Receipt of the proposals.

End of April: Have evaluation of proposals accomplished and contract file and award created to begin reviews (Estimated cost would be at least $1M to $3M for another base period of 6 months, and three six-month option periods)

Beginning of May: Announcement of award and contractor would begin their efforts to recruit all positions on the contract.

Mid-May: Contractor has recruited all positions and placed them in Maintenance Next program office.

End of May: Contractors have completed all needed training to be brought up to speed.

Beginning of April: New milestones would have to be created based off of the contractor's proposed solution to approaching the effort.

The fact that there would be no actual work accomplished in the timeframe of this highly ambitious timeline is one of the most important points to understand when weighing out how a recompetition for this effort would seriously derail the program's timeline.

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.

As the Maintenance Next program continues through development the goal is for the project to turn into a program of record of which the follow on would be opened up to all companies. The goal of this project has been to use commercially available technologies of which any commercial company should be able to assist in sustainment.

Overall, the training for all maintainers is trending towards becoming organic and this virtual training environment should also be treated as a system in which the AF could sustain without outside support.

IX. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

X. Certification by the technical/requirements personnel.

As evidenced by our signatures above, we certify that any supporting data contained herein, which is our responsibility, is both accurate and complete.