J A_TF34_MFC__Revision_4_FBO.docx

J&A Control No: 13-003

JUSTIFICATON AND APPROVAL FOR

CONTRACTING WITHOUT FULL AND OPEN COMPETITION

1. IDENTIFICATION OF AGENCY & CONTRACTING ACTIVITY:

Requiring Agency Fleet Readiness Center Southeast (FRCSE) Code 6.6.1.9, TF34 Fleet Support Team (FST) Logistics Jacksonville, FL 32212

Contracting Activity NAVSUP Fleet Logistics Center Jacksonville (FLCJ) 110 Yorktown Ave, Box 97 Jacksonville, FL 32212

2. DESCRIPTION OF ACTION BEING APPROVED: This Justification and Approval (J&A) authorizes the award of a sole source firm fixed price requirements contract to Woodward Governor Co., Rockford, IL, for overhaul, repair and remanufacturing of TF34 fuel control components.

This action covers a one (1) year base period with four (4), one (1) year option periods.

3. DESCRIPTION OF SUPPLIES: The contractor shall perform various tasks including inspecting, cleaning, repairing, testing, certifying and/or recertifying the following TF34 fuel control components:

8062-353

4. STATUORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN COMPETITION: The statutory authority permitting other than full and open competition is 10 U.S.C. 2304(c)(1), Only one responsible source and no other supplies or services will satisfy agency requirements, as implemented by FAR 6.302-1.

5. RATIONALE JUSTIFYING USE OF CITED STATUTORY AUTHORITY:

Safety of Flight: On 27 March 2008 an A-10 aircraft crashed due to a TF34 engine failure. This resulted in a long running technical evaluation of all TF34 engine components. This evaluation produced several new re-work requirements for the engine. These have been implemented over time, however the A-10/TF34 continue to experience compressor stalls (i.e. loss of power) resulting in “In Flight Shut-downs.” While these stalls have yet to result in loss of additional aircraft, they have caused squadrons to repeatedly abort combat support missions and impose a safety of flight issue. After investigation by both Air Force and FRCSE engineers, it was determined that the Main Fuel Controls (MFCs), part of the fuel control system, were failing at a higher rate and the proper course of action was to have the Original Equipment Manufacturer (Woodward) overhaul Main Fuel Controls (MFCs) in a more robust manner during overhaul. Currently the MFC piece-parts are replaced on an “as needed” basis by the OEM during overhaul. To alleviate this safety of flight issue the Air Force issued a directive in April 2012 that requires 100 percent replacement of all Main Fuel Control piece-parts listed in (Attachment 1) during overhaul. FRCSE does not have the capability to repair DPBAs and VGFHAs, or certify/recertify FCAs and JRLAs.

Only one responsible source: The TF34 fuel control components are only available from the original equipment manufacturer (OEM) - Woodward Governor who is the sole manufacturer of these components. All repair manuals and part prints are proprietary and solely owned by Woodward Governor. The parts required for the components of the fuel control system, of which the MFCs are a part of are also protected by Woodward Governor’s proprietary rights. The Government cannot authorize manufacture of these parts by any other source or request reverse engineering of those parts. There are no other authorized providers to perform factory authorized overhaul and repairs.

Woodward Governor has granted FRCSE limited use of their technical information necessary to overhaul the TF34 MFCs but did not give the Government access and/or rights to their repair manuals or prints. Woodward only supplied technical information (that cannot be shared) to FRCSE so they can develop technical orders (T.O.) 2J-TF34-4 and T.O. 6J3-4-106-4, both of which have been approved by Woodward. The Government cannot share this information with others in effort to obtain other sources of repair for these components. In accordance with technical order (T.O.) 2J-TF34-4 with Change 18, dated 23 Aug 2012, Figure 034, the MFC manufactured by Woodward Governor is the only MFC authorized for installation on the TF34-GE-100. In accordance with T.O. 6J3-4-106-4, with Change 2, dated 15 Feb 2012, the VGFHA (cited in Figure 13); the DPBA (cited in Figure 17), and the JRLA (cited in Figure 19) manufactured by Woodward Governor are the only components authorized for use in the fuel control system.

When contractor support is required for this aspect of work due either to critical parts shortages or inadequate capacity to handle unscheduled production volume surges, the work must be sent back to Woodward. The contractor will provide augmented technical expertise and manpower to support TF34 fuel control overhaul and repairs for the TF34 Logistics Division. Additionally, the contractor will certify/recertify one (1) each of a Government furnished JRLA and FCA unit during the base year period only.

6. DESCRIPTION OF EFFORTS MADE TO SOLICIT OFFERS FROM AS MANY OFFERORS AS PRACTICABLE: The contract specialist conducted online research which included review of small business capabilities under the Small Business Administration’s Dynamic Small Business search function and a review of the Government Point of Entry (GPE) websites (NECO/FedBizOpps) for the same or similar requirements. As a result of this research, the negotiator reached the same conclusion as the requiring activity regarding the available sources for meeting this requirement. To ensure that this conclusion is correct and in accordance with FAR 5.201, a notice of intent to award a sole source contract to Woodward Governor for this work will be posted to the GPE website prior to awarding. If any responses are received from other than the sole source, those responses will be evaluated. The pertinent information contained in this justification and approval will also be made available through the GPE within 14 days after the contract award and will remain posted for a minimum of 30 days.

7. DETERMINATION OF FAIR AND REASONABLE COST: In accordance with DFAR 215.402 and PGI 215.402(1), the Contracting Officer must purchase supplies and services from responsible sources at fair and reasonable prices. Analysis of the proposal will be performed by technical analysts and contract specialist with the assistance of DCAA auditors as required. The FLCJ Contracting Officer will use Government expertise, including DCAA and others to determine that the cost to the Government for the action covered by this J&A is fair and reasonable.

8. ACTIONS TAKEN TO REMOVE BARRIERS TO COMPETITION: For the reasons set forth in Paragraph 5, FLCJ has no plans at this time to compete future contract actions for the requirement covered by this document. However, every future contract action for this type of requirement will be assessed on a case-by-case basis regarding the feasibility of competition.

9. CONTRACTING ACTIVITY POINTS OF CONTACT:

Felicia Williams, Contract Specialist; Ph: 904-790-4581; Email: felicia.n.williams@navy.mil Prudence Howard, Contracting Officer; Ph: 904-542-0927; Email: prudence.howard@navy.mil