JA_JFO_Bridge_Redacted_Copy_26_May_2016.pdf

UNITED STATES MARINE CORPS

MARINE CORPS SYSTEMS COMMAND

2200 LESTER STREET

QUANTICO, VIRGINIA 22134-6050

Code: CT-2.79 J&A Number: 16,238.1

JUSTIFICATION AND APPROVAL (J&A)

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

JUSTIFICATION

1. Contracting Activity.

Marine Corps Systems Command Other Supported Systems (OSS) 2200 Lester Street Quantico, VA 22134-6050

2. Description of the Action Being Approved.

The use of other than full and open competition to award a sole source, Firm-Fixed Price (FFP) bridge contract to II Corps Consultants Inc., 35047 Constitution Ave, Locust Grove, VA 22508 to maintain mission critical Joint Fires Observer (JFO) Program support.

3. Description of Supplies/Services.

The proposed contracting action is to procure non-personal support services for Training & Education Command (TECOM) for the JFO Program.

On-site contractor support is required at three JFO regions, which include Expeditionary Warfare Training Group Pacific (EWTG PAC), Coronado, California; Expeditionary Warfare Training Group Atlantic (EWTG LANT), Little Creek, VA; and Marine Detachment, Fort Sill, Oklahoma. Additional contractor support, provided via Mobile Training Teams, is required at sites which include Camp Pendleton, California;

and Camp Lejeune, North Carolina. The JFO program provides Joint Services personnel with training in engaging targets with AC-130 aircraft, naval surface fires, indirect surface fires, and procedures for providing timely and accurate targeting information to a qualified Joint Terminal Attack Controller (JTAC) for Type 2 and 3 Close Air Support (CAS) and conducting Terminal Guidance Operations (TGO). The United States Marine Corps (USMC) requires CAS training for Forward Observers (FOs), Reconnaissance Marines and Special Operators to prepare them to assist in the control of CAS aircraft when a qualified JTAC is not co-located with the FO. The JFO training program provides a limited capability to control CAS in situations where a qualified JTAC is not physically located with the FO and the situation requires immediate assistance from available CAS assets. The JFO training curriculum is closely tied to that of the Tactical Air Control Party (TACP) training course in order to provide a common understanding of the principles of effective use of CAS. Though the USMC has robust training for the request and delivery of surface to surface and air to surface fires, they do not have training that is certified by the joint community. In order to request and control joint fire support assets, the USMC must provide joint validated and certified instruction using approved Programs of Instruction (POI). The JFO program provides this joint validated training. Contractor personnel will provide instructional services, POI management services and scenario development in support of the JFO Program. Training and equipping personnel to fulfill JFO and TACP duties is a United States Code Title 10 responsibility of each component within the Department of Defense (DoD).

The current task order for these services, N00178-08-D-5451, MUT3, was awarded by the Regional Contracting Office - National Capital Region (RCO-NCR), and expires on 28 July 2016. Approval of this Justification and Approval (J&A) will allow time for a competitive source selection and contract award processes. The FFP bridge contract will have a 5 month base period of performance, from 29 July 2016 through 28 December 2016, and two option periods providing a total of 5 months of additional support for a total of 10 months if all options are exercised. Shorter option periods are not possible due to overlapping class schedules that create limited opportunities to transition between contractors without interrupting or cancelling scheduled courses. The Base and Option Periods are as indicated in the following table:

*Because of training schedule requirements, the period of performance of the option periods varies slightly for each location.

The estimated dollar value for this procurement is (REDACTED) over 10 months, if all option periods are fully executed. The estimated costs are:

Appropriation FY16 FY17 Total

O&M (REDACTED) (REDACTED) (REDACTED)

4. Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting use of other than full and open competition is 10 U.S.C. 2304(d)(1)(B) as implemented by the Federal Acquisition Regulation (FAR) 6.302-1(a)(2)(iii)(B), award to any other source would result in unacceptable delays in fulfilling the agency’s requirements.

Location Base Period Option 1 Option 2 EWTG PAC 29 Jul 2016 - 28 Dec 2016 29 Dec 2016 - 24 Feb 2017 25 Feb 2017 - 28 May 2017 EWTG LANT 29 Jul 2016 - 28 Dec 2016 29 Dec 2016 - 10 Feb 2017* 11 Feb 2017 - 28 May 2017 Fort Sill 29 Jul 2016 - 28 Dec 2016 29 Dec 2016 - 24 Feb 2017 25 Feb 2017 - 28 May 2017

5. Rationale Justifying Use of Cited Statutory Authority.

The current task order expires on 28 July 2016. A gap in services as currently projected would result in the loss of up to 200 trained JFOs through December 2016 alone, which is 52% of the annual training requirement, and represents 22% of the Service-Level JFO force requirement for operational sustainment mandated by PP&O and Title 10.

The loss of this many trained JFOs would be difficult, or impossible to overcome due to the limited availability of appropriate combined arms training ranges; would severely impact force and operational readiness for the USMC by not meeting the minimum availability of trained, deployable JFOs; and would fail to meet the minimum requirement for annual training as established by PP&O to meet the Title 10 requirements. A competitive follow-on contract is being conducted; however, the time required to complete that effort is currently estimated at 4 to 6 months. Any gap in service would create an immediate negative impact on Marine Corps operational readiness in that an entire series of scheduled courses would have to be cancelled, reducing the number of trained, deployable JFOs. This would decrease the effectiveness of deployed units as they would not be staffed with personnel trained to control CAS in situations where immediate CAS assistance was required, and a qualified JTAC was not available.

Awarding an interim contract to anyone other than the incumbent will also result in unacceptable delays, as a new contractor would require time to staff instructor positions and train those instructors in the existing POI. Awarding a bridge contract to II Corps Consultants will prevent a gap in services, eliminates staff turnover during training cycles, avoiding the learning curve delay, and will provide the follow-on contractor adequate time to hire and train personnel.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

Market research was conducted for the solicitation of the follow-on contract, M67854-16-R-7902 by searching for vendors capable of providing the required services using the North American Industry Classification System (NAICS) code 611430, Professional and Management Development Training, size limitation of $11,000,000. The Government reviewed information obtained via previously provided vendor capability statements, the commercial marketplace via a Google search, a review of GSA eLibrary, a review of data from previous contracts for Instructional Services, and the web sites of vendors who are known to have previously performed like services. Further information was obtained through phone and email correspondence, with identified vendors responding to questions regarding current business size, and current (within 3 years) experience working with like requirements.

The results of this market research indicated that there are more than two small businesses capable of fulfilling the Government’s requirement. As such, the follow on contract will be awarded through a full and open competition, after exclusion of sources (small business set aside). Because the market research for the follow-on contract is relevant and appropriate to the circumstances of this bridge effort, no further market research was conducted for the reasons indicated in Section 5, above.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer has determined the anticipated cost to the Government of the supplies/services covered by this J&A will be fair and reasonable.

8. Actions to Remove Barriers to Future Competition.

A follow-on contracting action using competitive procedures is being conducted in parallel to the bridge contract. The Procuring Contracting Officer is currently waiting for completed Procurement Request package documents. The follow-on contract, anticipated to be awarded on 30 November 2016, is a full and open competition, after exclusion of sources (small business set aside), that will provide uninterrupted training support for a five year period.

J&A 16,238.1 APPROVED 16 MAY 2016