LMTF JA 20250911 Final_Redacted.pdf

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Little Mountain Test Facility (LMTF) Justification and Approval to go Sole Source
Solicitation number
FA820726LMTFJA
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This is a Justification and Approval (J&A) document for a sole-source contract award by the United States Air Force for operations and maintenance of the Little Mountain Test Facility (LMTF) located in Ogden, Utah. The contracting activity is AFNWC/P2BC at Hill Air Force Base. The contract is structured as an Indefinite Delivery/Indefinite Quantity (ID/IQ) follow-on to a previous contract (FA8207-17-D-0001) with The Boeing Company, valued at over $100 million, with a base period of five years and two option periods (each 2.5 years) for a total possible ordering period of 10 years. The scope includes engineering services and technical support for operating and maintaining LMTF's three specialized nuclear effects testing labs (Radiation, Electromagnetic Effects, and Shock & Vibration), which conduct comprehensive testing for the Minuteman III (MMIII) and Sentinel Intercontinental Ballistic Missile systems, as well as other Department of Defense and Department of Energy programs. Specific services encompass operating and maintaining test facilities, designing and developing test plans, conducting tests, analyzing test data, equipment modernization, equipment replacement and upgrades, fabrication tasks, configuration management, and technology transfer through Cooperative Research and Development Agreements (CRADAs). Funding will be allocated across multiple CLINs: Operation & Maintenance (O&M), ICBM Testing, Non-ICBM Testing, Equipment Purchase, CDRL Data, Other Direct Costs/Travel, and a Transition Option Period.

The Air Force justified the sole-source award under 10 U.S.C. 3204(a)(1) based on only one responsible source and no other supplies or services satisfying agency requirements. Boeing has been the integral LMTF operator since 1974 and possesses unique qualifications including proprietary Subject Matter Expertise in nuclear effects testing design, approved Nuclear Regulatory Commission training certifications for Radiation and Shock & Vibration lab operations, two patents for Linear Accelerator and Small Flash X-ray equipment, and established CRADAs with DoD partners. The J&A emphasizes that transition to any other contractor would result in unacceptable delays due to facility shutdown, loss of contractor-specific certifications, capability gaps, and estimated minimum costs of several million dollars in duplication for overlapping contractor support during a three-year transition period. The Air Force conducted market research from November 2023 to February 2025, including five Requests for Information, an industry day, and market analysis, which confirmed Boeing as the only source capable of meeting requirements without substantial cost duplication and unacceptable delays. Pricing will be Cost Plus Fixed Fee, Cost Reimbursable, or other contract types as appropriate for individual task orders, with contractor submission of Certified Cost or Pricing Data, technical program office evaluation, potential Defense Contract Audit Agency audit, and price negotiation procedures. To promote future competition, the Air Force will require Boeing to transfer all design authority, product engineering data, software, and training materials via Contract Data Requirements Lists, establish an alternate source plan, engage in early industry involvement four years before contract expiration, implement a small business subcontracting plan with teaming arrangements, and include an optional Transition Option Period CLIN for overlapping operations with a successor contractor.

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In accordance with Federal Acquisition Regulation (FAR) 6.305 and the Freedom of Information Act, this document has been redacted to remove proprietary data, confidential commercial information, and/or source selection information that is exempt from public disclosure.

1158523066C Highlight

CUI

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

CUI August 2023 Page 5 of 8

Boeing also holds the approved Nuclear Regulatory Commission (NRC) training certifications required for operations of the Radiation lab equipment (i.e., use of Radioactive Material (RAM)) and the Shock & Vibration (S&V) lab. These certifications are contractor-specific, so transitioning to any other contractor would require that contractor to acquire new certifications, causing potential shutdown delays at LMTF.

Additionally, any transition to a new contractor, at this time, would result in significant technical/operational capability gaps. Shutting down LMTF for any amount of time is an unacceptable solution. A shutdown would stop all testing activities. A stop in testing or a lack of continual certification would impact the USAF's ability to support the nuclear deterrence mission including MMIII sustainment efforts (i.e., MMIII Missile Guidance Set Nuclear Hardness Surveillance (MGS HSP)), Sentinel system development (i.e., Radiation Lot Acceptance Test), and the Navy Trident missions. A sole source award will maintain the integrity of the specialized test equipment and labs and prevent compromising mission readiness.

To prevent an initial LMTF shutdown at the time of contract award to a new contractor, the USAF would be required to pay both Boeing and the follow-on contractor for up to a 3-year transition period. The USAF estimates a minimum of $ in duplication of costs to pay two contractors. A new LMTF contractor would need time to set up and establish its operations (obtaining cybersecurity accreditations, RAM handling/NRC authorizations, establishing safety protocol, logistic footprints, entering a new CRADA with the Air Force Nuclear Weapons Center (AFNWC) ICBM Directorate, and building its CRADA customer base). The time for a new LMTF contractor’s set up is as follows:

The RSO specific training certifications and all other training certifications above can be achieved in a parallel effort within a three-year transition period. While personnel carry general equipment certifications, any transition to a new contractor would require re-completing the special test equipment training to meet the new contractor company requirements developed and approved for LMTFs' unique test capabilities.

The Government proposes a 10-year contract that would allow for the completion of the modernization of LMTF. A shorter ordering period would impact on performance and schedule, due to shutdown of test activities and transition periods as discussed above. In addition, the completion of modernization activities and the development of new test stands (R&D efforts) would be interrupted, delaying further the completion of modernization for transition to Sentinel and the return to testing.

The options to extend this effort up to a 10-year ordering period will support the strategic AFNWC growth goals through the modernization process. The ID/IQ contract structure offers flexibility should weapon system transition begin earlier or later than planned, or if there is significant market change. MMIII is a mature weapon system that is in the sustainment phase of its life cycle. As a critical leg in the strategic nuclear triad, MMIII weapon system requires continued sustainment to ensure operational capabilities are maintained. Sentinel, as it progresses through its life-cycle phases from Engineering, Manufacturing and Development (EMD) to Production and Deployment, and into Sustainment and then retirement in 2075, will rely on LMTF's modernized state of the art test capabilities to ensure its operational capabilities are maintained.

CUI August 2023 Page 7 of 8

Contract Pricing, as follows:

1. The contractor will be required to submit Certified Cost or Pricing Data.

2. The MMIII LMTF Program Office will perform a technical evaluation to include an evaluation of the contractor's proposal, to include comparison to historical efforts.

3. The Contracting Officer will obtain a Defense Contract Audit Agency (DCAA) audit of the contractor's cost proposal, if deemed necessary.

4. The Pricing Office, or delegated authority, will evaluate the contractor's cost/price proposal and consider inputs from DCAA and the program office technical evaluation in establishing the Government's price position.

5. The Preliminary Price Negotiation Memorandum (PPNM) will be submitted and reviewed during Business Clearance and a Final PNM (FPNM) will be completed during negotiations.

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

As described in Section V above, IAW FAR Part 10 was conducted by posting five RFIs, hosting an industry day tour, advising industry of the pending acquisition, and soliciting inquiries from interested parties. The research demonstrated that only Boeing has the technical ability to provide the continuity of analysis necessary to meet the government's requirements without causing substantial duplication of costs and unacceptable delays.

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

Establishing CRADAs is another significant performance risk for a new contractor at LMTF. CRADA is a technical transfer agreement. The CRADA customer base allows LMTF to support additional test customers within the larger DoD nuclear enterprise (including MMIII and Sentinel). These CRADAs provide critical funding to the LMTF facility and ensure that the technical expertise needed to execute testing and facility maintenance for the nuclear mission is in place and fully employed at LMTF. The Government believes it will take a minimum of one to two years for a new contractor to establish new CRADAs in place of the current CRADAs Boeing has with established partners. This estimate includes 4-6 months for the CRADA development and approval, including coordination with the contractor, AFNWC ICBM Directorate, and AFRL; and 6-18 months for the contractor to develop its customer base under the CRADA and implement its administrative processes to reach the minimal operational level.

These funds also significantly supplement the cost of facility upgrades and equipment maintenance. CRADA funded positions prevent delays in critical ICBM testing support during surges. ICBM testing is given priority in the labs and does not have to rely solely on contract funded positions to support mission requirements. Additionally, supporting the needs of the CRADA customer base is essential for maintaining the larger nuclear enterprise that the Government relies on to support the ICBM mission.

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

See Section V above.

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.

In addition to previously procured O&M manuals, the new contract task orders will require Boeing to transfer all design authority, product engineering data, software developed and training materials to the USAF via Contract Data Requirements Lists.

CUI August 2023 Page 8 of 8

The USAF team will also promote early industry involvement prior to the next acquisition. To accomplish this, approximately four years before the contract expires, the USAF will provide industry with detailed technical requirements to include: the PWS, current modernization requirements, Government-owned O&M manuals, RAM management permitting process, equipment certification requirements, CRADA information etc. for the next LMTF contract. The USAF team will follow this up with a question/answer period, with interested vendors, to include potential subcontractors and/or small businesses interested in teaming arrangements, can ask questions, and request additional information as needed to promote a competitive environment on the next acquisition.

In addition, the USAF team will take efforts to broaden the industrial base through the small business subcontracting plan, requiring Boeing to team with small businesses to directly support the O&M mission. These teaming arrangements will also provide flexible support during surges of required testing.

To protect the on-going critical testing mission at LMTF, the USAF team will work with Boeing to establish an alternate source plan prior to contract award. This plan, supported by the small business subcontracting plan, will outline a strategy to transfer knowledge, IP, and technical data necessary for another contractor to assume operations with the least amount of impact and risk as possible. The alternate source plan will take effect if Boeing decides they no longer want to operate and maintain LMTF, or if another vendor is awarded a competitive contract.

The USAF will also include an optional CLIN (X007) for an extended transition towards the end of the period of performance. This CLIN would be implemented so that Boeing would continue operations while a new contractor transitions to take over LMTF. If during early industry involvement activities, it's determined that the industrial base has broadened and there are opportunities to compete, the USAF team will pursue a competitively awarded contract at least one year prior to contract expiration. An extended transition period will ideally provide a new contractor time to align personnel, establish a CRADA customer base, obtain the necessary permits and certifications, and establish Standard Operating Procedures (SOPs).

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

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