CNATRA_T-54A_Final_8.29.24_Signed_Redacted.pdf

EFO Number: 24-0279

JUSTIFICATION FOR AN

EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity.

Naval Air Warfare Center Training Systems Division (NAWC-TSD) Orlando, FL

2. Nature and/or Description of Action being Approved.

This Exception to Fair Opportunity (EFO) authorizes and approves, on a sole source basis, the issuance of a Firm-Fixed Price Task Order (TO) modification to Fidelity Technologies Corporation (Fidelity). Additional Contract Instructional Services (CIS) will be added to the TO in order to support Multi-Engine Training System (METS) curricula in newly acquired T-54A Flight Simulation Training Devices (FSTDs) being delivered to the Chief of Naval Air Training (CNATRA) under a Program Management Activity (PMA) 273 Program of Record (POR). This action will be awarded under Fielded Training Systems Support V (FTSS V) Basic Contract N6134022D1005 TO N6134023F0289 (“CNATRA CIS”).

The FTSS V Indefinite Delivery/Indefinite Quantity (ID/IQ) Multiple-Award Contract (MAC) provides a wide scope of training and training system support services that includes training device maintenance, operations, instruction, and curriculum support as required by the Government. Chief of Naval Operations Instruction (OPNAVINST) 1551.11B - Policies and Procedures for Fielded Training Systems Support, provides Chief of Naval Operations (OPNAV) guidance under which NAWCTSD, as the Contracting Agency for FTSS, operates.

Fidelity, under its competitively awarded CNATRA CIS TO provides Contractor Instructors (CIs) and In-Flight Contractor Instructors (ICIs) in support of CNATRA pilot and flight officer training requirements for Training Air Wings ONE, TWO, FOUR, FIVE, and SIX (TWs 1, 2, 4, 5, and 6, at NAS Meridian, MS, NAS Kingsville and NAS Corpus Christi, TX, and NAS Whiting Field and NAS Pensacola, FL, respectively). In general, such training consists of normal and emergency procedures, take-off, landings, flight profiles, visual and instrument flight rules, navigation, communication, and introductory tactics, techniques, and procedures.

3. Description of the Supplies or Services Required to Meet the Agency’s Needs (including the estimated value).

Actions taken under this EFO would add additional CIS requirements to the existing CNATRA CIS TO requirements for Undergraduate Military Flight Training in order to support METS curricula in the newly acquired T-54A FSTDs being delivered to CNATRA

DEPARTMENT OF THE NAVY

NAVAL AIR WARFARE CENTER TRAINING SYSTEMS DIVISION

12211 SCIENCE DRIVE

ORLANDO, FLORIDA 32826-3224

under a PMA-273 POR . The addition will support CNATRA Naval Flight Student (NFS) training requirements in newly developed METS CIS curricula at Training Wing FOUR (TW-4) onboard Naval Air Station (NAS) Corpus Christi, TX.

The anticipated modification will be structured with a 44-month period of performance, consisting of 12 months (Nov-Oct) in FY25, 12 months (Nov-Oct) in FY26, 12 months (Nov-Oct) in FY27, and 8 months (Nov-Jun) in FY28 to align with the CNATRA CIS TO period of performance and CNATRA need. The additional 6 months for FAR clause 52.217- 8 will also be evaluated, which could extend the contract through December 2028. Award of this action would add the following:

Estimated Dollar Value

Total

O&MN $

Total $

4. Identification of the Justification Rationale (see FAR 16.505(b)(2)) and, if applicable, a Demonstration of the Proposed Contractor's Unique Qualifications to Provide the Required Supply or Service.

FAR 16.505 (b)(2)(i)(B), Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

Supporting Rationale:

Pilot training in the United States Navy (USN) is directed at performing a largely dangerous activity (flying) under the safest possible conditions - through the concepts of risk mitigation via repetition and proficiency. As such, CNATRA’s responsibility is to provide continuity and standardization of training such that when a Naval Aviator receives their wings, they have been provided the same high quality of instruction and preparation throughout their training pipeline as their predecessors and peers.

In order to meet CNATRA requirements to minimize risk through training quality and standardization, the most effective acquisition methodology for the T-54A CIS is to add it to the existing CNATRA CIS FTSS V TO that supports CNATRA’s pilot and flight officer training requirements. This approach not only mirrors the intent and guidance provided to NAWCTSD in OPNAVINST 1551.11B, but it also provides cost efficiencies in the acquisition of CIS to support the ground-based component of its T-54A METS curriculum.

Under its overarching CNATRA CIS TO, CNATRA is best able to accomplish that mission through one contractor. Under the CNATRA CIS TO, each training squadron’s military Instructor Pilots (IPs) and each training wing’s CIs are under the standardization purview of the CNATRA Assistant Chief of Staff (ACOS) for Training (N7) and subject to annual standardization inspections. Each of the IP/CI Flight Instructors’ Standardization and Training (FIST) Jackets are updated, reviewed, and analyzed at each of these inspections. Corrective actions for deficiencies found at TW-5 (NAS Whiting Field, FL), for example, can be easily applied to each of the other wing IP/CI cadres, if desired.

With regard to existing FTSS efforts, Fidelity is the only contractor that is currently providing CIS at each of CNATRA’s five Training Air Wings. Performance Work Statement (PWS) Appendices identify CIS services for numerous CNATRA curricula, supporting winging of Naval Aviators and Naval Flight Officers into various USN and United States Marine Corps (USMC) aircraft (F/A-18, E/A-18, F-35, A/V-8, E-2, C-2, E-6, H-60, H-53, P- 8, etc.), as well as providing CIS to some Foreign Military Sales (FMS) customers (International Traffic In Arms Regulations (ITAR) compliant) and others. Action under this EFO would simply add another Appendix to the TO with additional CIS ground-based training requirements for the new METS, based upon the delivery of the T-54A training platform.

Fidelity is the only contractor that has communication, Information Technology (IT), and management infrastructure in place – a Program Manager (PM) at CNATRA Headquarters (HQ), and Site Managers and Alternate Site Managers at each of the five TWs – that fully supports CNATRA’s requirements related to training quality and standardization. It has established management processes, communication methodologies, and interpersonal relationships that are in place and highly functioning, and applied across all of the TWs.

This collaboration between Government and Contractor, simplified through the relationship that exists between the required PM at CNATRA HQ, the CNATRA Technical Point of Contact (TPOC) (ACOS for Requirements (N9)), and CNATRA N7, is extremely beneficial to the functioning of the entire CNATRA IP/CI cadre. Again, because of the relationships and collaboration developed with the Government and contractor under the current CNATRA CIS TO, Fidelity is the only source capable of quickly providing the T-54A CIS training required at the high level of quality and standardization required. This enhances risk mitigation, thereby improving safety.

As stated above, T-54A aircraft and FSTDs are being delivered under a POR to meet CNATRA’s multi-engine training requirements to support pilot winging and fills to specific fleet aircraft (e.g. E-2, C-2, P-8, and CV-22). T-54A METS is an obsolescence replacement for T-44C METS. CNATRA will be divesting of T-44C aircraft and training services as T- 54A aircraft and FSTDs are delivered to TW-4/NASCC. CNATRA will sustain its METS pilot production requirements as more individual NFSs are input to T-54A and less are input to T-44C as T-54A training capability increases (as aircraft and FSTDs are delivered).

Any disturbance to pilot production is unacceptable, since CNATRA must bend the curve and increase throughput to the Fleet Replacement Squadron (FRS). Since Fidelity is currently providing the required CIS curricula at all sites, Fidelity is the only contractor that can perform the T-54A CIS requirement with, effectively, zero additional performance risk to CNATRA pilot and flight officer production.

Finally, in the interest of economy and efficiency, adding this service to the existing CNATRA CIS TO allows NAWCTSD to meet the customer need in the most-timely manner while also utilizing the most economical means of procuring the services. The approach of accomplishing this requirement through a modification to Fidelity’s TO will help ensure

CNATRA’s evolving pilot production needs are met. This action is scheduled to award by 31 October 2024 in order to support CNATRA’s required need date.

5. A Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The Contracting Officer has determined the anticipated cost to the Government of the services covered by this EFO will be fair and reasonable.

6. Any other Facts Supporting the Justification.

Notice of Tentative Acquisition Strategy:

The Government emailed a Sole Source Notice of Tentative Acquisition Strategy on 30 July 2024 to all seven (7) FTSS V MAC Lot I (Unrestricted) Awardees in order to solicit exceptions to the Government’s approach. The Notice identified that NAWCTSD was contemplating the acquisition strategy described herein. The Notice also specifically stated, “Alternatives to the FTSS V vehicle are not contemplated and will not be pursued.”

Responses were requested by 05 August 2024.

All seven (7) FTSS V MAC Lot I Awardees responded acknowledging receipt of the Notice.

No exceptions to the proposed approach were received from any FTSS V MAC Lot I Awardee. In addition to the five (5) acknowledgements, two (2) of the Awardees communicated agreement with the Government’s approach. The first of these stated;

is in receipt of this email and provides concurrence with this tentative acquisition strategy.” The second provided a letter that stated does understand that this would create additional administrative burden and therefore why it is beneficial to add it to the existing contract, among the reasons listed by the Government”. It further expressed;

“We wanted to formally provide this feedback that while we understand the reasoning for the sole source award, should the Government ultimately decide to compete this wor would submit a proposal.”

The lack of exceptions to the Notice of Tentative Acquisition Strategy affirms that industry agrees with the government’s assertion that adding this work to the existing CNATRA CIS TO is the most sensible course of action to meet CNATRA’s immediate need. Of note, all of the work under this TO will be subject to the next TO recompete beginning in FY27.

Alternative Sources:

The Government reviewed other potential sources to determine viability, including the already awarded T-44C Command Aircraft Crew Training (CACT) contract.

Approximately 10 years ago, the T-44C METS was identified for divestiture. At the same time, CNATRA felt that its current, PMA-273 fielded, T-44C FSTDs had become inadequate to provide required training capabilities. Not through FTSS, but through its Command

Aircraft Crew Training (CACT) IPT, NAWCTSD was able to provide CNATRA with turnkey training as a service helping bridge the gap to METS.

Solely in order to accomplish this acquisition scheme, such that the Government could purchase services at contract award, CNATRA accepted risk, and the subset of T-44C CIS requirements were moved out of the contemporaneous CNATRA CIS TO and onto a separate T-44C CACT contract. CIS was purchased at Contract Support Date of its base period, and contractor-owned FSTDs were incrementally installed at the site during later contract option periods.

Somewhat later than original planning estimates, divestiture of the T-44C METS is now under way. PMA-273, through its business case analysis, determined that contracting for contractor-owned FTSD services was not an appropriate acquisition model for the T-54A program. As a result, its POR is to acquire Government-owned T-54A FSTDs to meet CNATRAs training requirements. As such, the prime contractor for the CACT effort has already been notified that T-44C CACT services (providing CIS and fielding cont owned FTSDs) will no longer be required at the end of its current contract and will not be renewed.

Because the central piece of the T-44C CACT effort, fielding contractor-owned FTSDs, is missing from the T-54A CIS effort, there is not a “logical follow on” argument to be made, nor does this qualify as consolidation as this is a new requirement being contracted for. For all these reasons, the T-44C CACT Contract is not an Alternative Contract Vehicle to the FTSS V MAC CNATRA CIS TO for T-54A CIS.

7. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers that Led to the Exception to Fair Opportunity before any Subsequent Acquisition for the Supplies or Services is Made.

There are no barriers to fair opportunity for the CNATRA CIS recurring requirement. The T- 54A CIS requirement will be added to the CNATRA CIS follow-on TO. FTSS contractors will be provided a fair opportunity to compete, under FAR 16.505, at the normal re-competition time frame for the CNATRA CIS TO (i.e., after the last priced option available to the Government is exercised). The end of performance date for this last TO option is 30 June 2028; however, the TO may be extended up to six months in accordance with FAR 52.217-8. Historical experience supports the expectation that the re-compete beginning in 2027 will result in meaningful competition for the follow-on effort, including T-54A CIS.

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.

Technical Cognizance:

Signature Name (Printed) Phone No. Date

Requirements Cognizance:

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

CONTRACTING OFFICER CERTIFICATION

I certify that this Justification is accurate and complete to the best of my knowledge and belief.

APPROVED

Upon the basis of the above justification, I hereby approve the solicitation of the proposed procurement(s) described herein using other than full and open competition, pursuant to the authority of FAR 16.505 (b)(2)(i)(B), Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.