PneuDraulics_JA_20260415_Redacted V2.pdf

Department of the Air Force: Justification for Other Than Full and Open Competition

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I. Agency and Contracting Activity (RFO 6.104-1(a)(1)):

Agency: USAF F-15EX (AFLCMC/WAQK)

II. Nature and/or description of the action being approved (RFO 6.104-1(a)(2)):

This initiative aims to develop a self-sufficient, organic maintenance and repair capability for the F-15EX aircraft at the Air Logistics Complex (ALC). A primary goal is to maximize the reuse of existing F-15 legacy capability and capacity to ensure cost-effectiveness and efficiency.

To achieve this, a sole-source Indefinite Delivery/Indefinite Quantity (IDIQ) contract will be awarded to the PneuDraulics Inc.

This action is justified under FAR 6.302-1 as they are the only responsible source for the Priority Valve, a key component integrated into the F-15EX's baseline design. The contract will facilitate Depot Activation (DA), a process to establish the capability for comprehensive overhaul, upgrading, or rebuilding of parts and subassemblies, along with necessary equipment testing and reclamation, as defined in 10 USC Section 2460. This process involves identifying the necessary facilities, equipment, materials, and certified personnel to perform depot-level maintenance. Depot activation is a strategic, long-term investment aimed at ensuring a ready and controlled source of technical competence and resources to respond to national defense contingencies and other emergency requirements.

This contract covers the procurement of essential parts and associated Depot Activation actions for the Priority Valve, supporting both current and future F-15EX sustainment needs.

Due to cost and schedule constraints, the IDIQ contract will have a three-year base ordering period with an additional one-year option. The total ceiling for this Justification and Approval (J&A) is set at $ which is based on a Rough Order of Magnitude (ROM) estimate for the depot-level repair capability required for Priority Valve repairs.

III. Description of supplies/services required to meet agency needs (RFO 6.104-1(a)(3)):

Establishing an organic, depot-level repair capability requires the strategic delivery of a complete product support package to the designated ALC(s). This consists of acquiring the required hardware, software, test, technical publication, training, supply support, packaging, support equipment and data for the designated ALC to repair the depot level repairable(s). To establish the organic repair capability, delivery of the core infrastructure for depot-level hardware testing and repair is required. This includes the identification of requirements for, and the subsequent design, build, or purchase of, the following components: Specialized Test Equipment (STE), Test Program Sets (TPS), and Interface Test Adapters (ITAs).

The United States Air Force (USAF) will provide all common support equipment for this activation effort. Due to proprietary restrictions stemming from private investment in the development of F-15/F-15EX Line Replaceable Units (LRU), the government's current ability to establish organic repair of the LRU is not possible. Technical data is restricted by the manufacturer's intellectual property rights constraints. Therefore, to establish organic repair of the Priority Valve, the USAF needs to negotiate licenses for only the sensitive data needed to repair the LRU. The repair and maintenance of Priority Valves require not only the Priority Valve itself but all associated parts/spares and the rights in technical data necessary to maintain and ensure the software used in the displays functions correctly to support verification of repairs at designated ALC.

The Priority Valve is a hydro-mechanical flow control device that manages hydraulic fluid distribution to ensure the operational integrity of primary flight control systems. The valve senses the main hydraulic system's flow rate and pressure.

Under normal system operation, the Priority Valve directs the specified flow rate to the primary flight control circuit. Any flow exceeding the primary circuit demand is passed downstream to operate secondary, non-flight-critical systems. In the event of a hydraulic pump failure, line rupture, or a excessive system demand, the valve automatically modulates or completely shuts off hydraulic flow to the secondary circuits to ensure that that the available hydraulic fluid is dedicated exclusively to the primary flight control circuit, guaranteeing the pilot retains essential control of the aircraft during low-pressure or emergency situations.

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Primary Contract Purpose

Primarily, this IDIQ will be a contract focused on ensuring the USAF can repair the current and future Priority Valve specs authorized to be installed on F-15EX aircraft. Incidental to the provision of Priority Valves are field and depot-level support, engineering necessary to implement future variants within the EX-airframe, provisioning and support equipment. Section IV of this document explains these requirements in greater detail.

Contract Framework and Competition This IDIQ will allow efficient award of depot activation capabilities associated with the Priority Valve. The CLIN structure may include separately priced CLINs for intellectual property (IP) rights as negotiated with the Contractor. The Contract will be asked to include a data rights assertion list which will be provide as part of the RFP Package sent to the OEM.

Cost Ceiling Justification The requested $ individual J&A ceiling is based on the PO's estimate for the entire Priority Valve DA IDIQ ordering period, assuming each option is exercised. This ceiling was derived from current programmatic activities based on in-house cost estimates for future projected DA requirements as explained above.

Cost Exclusions In keeping with the programmatic need to leverage legacy EX hardware, the cost ceiling for this IDIQ excludes costs associated with qualifying an entirely new Priority Valve solution, implementing that new solution onto existing EX airframes, altering the production line to install that new solution on future EX airframes, and the stand up of new DA capabilities for any Priority Valve solution other than the one being awarded under this contract. These duplicative costs have been excluded for reasons explained in Section IV below.

IV. Statutory Authority Permitting Other Than Full and Open Competition (RFO 6.104-1(a)(4)):

10 U.S.C. 3204(a)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.

V. Rationale for Use of Authority (RFO 6.104-1(a)(5)):

Background

Currently, PneuDraulics Inc. produces the Priority Valves installed on every F-15EX through sole-source procurement and integration by The Boeing Company (Boeing). PneuDraulics Inc. is the only responsible Original Equipment Manufacturer (OEM) capable of providing the Priority Valve and associated technical data rights necessary for Depot Activation of the Priority Valves. Historically, repairs have been contracted to Boeing, who subcontracted with PneuDraulics Inc. for Priority Valve repairs and maintenance.

PneuDraulics Inc. Priority Valve is fully developed, integrated, and has been certified/qualified for use on all F-15EX aircraft.

The Priority Valve further meets all safety, suitability, and effectiveness requirements necessary for fielding EX aircraft. As the OEM of the only compliant Priority Valve available to the USAF, PneuDraulics Inc. is the only source in possession of the technical expertise, technical data, source code, proprietary engineering documentation, and knowledge necessary to fulfill the delivery and DA requirements the USAF requires to continue fielding EX aircraft without substantial impacts to cost and schedule.

The risk factors associated with procuring a new organic maintenance repair solution for an Priority Valve that is not the current Priority Valve provided by PneuDraulics Inc. are as follows:

Integration Complexity A new OEM must design and qualify a part, requiring the USAF to act as integrator while Boeing incorporates that part into the aircraft. This process involves drawing updates, technical order updates, and training updates. The complexity increases if, as is the case with Priority Valves, the part contains software that interfaces with the mission computer, requiring additional integration activities and a direct contract with Boeing for Operational Flight Program (OFP) updates to achieve flight clearance.

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Interim Support Degradation The existing OEM has no incentive to continue maintaining OEM Specialized Test Equipment (STE) needed to repair existing parts under Interim Contractor Support (ICS) or Contractor Logistics Support (CLS) while the USAF waits for new parts to complete the design, qualification, and integration cycle. This results in degraded performance for maintaining existing hardware during the transition period.

Depot Activation Continuity New OEM selection must include the assumption that the new part will undergo depot activation. Otherwise, the USAF will face the same OEM limitations with the new supplier as currently experienced with existing OEMs.

The challenges above present considerable cost, schedule, and budgetary risks that the USAF cannot expect to overcome via the issuance of a competitive source selection for a new Priority Valve OEM.

Cost Prohibitions

Procuring and qualifying a new Priority Valve solution would result in substantial cost duplication that the Government cannot expect to recover by conducting a competitive source selection.

Schedule Constraints

The schedule impacts associated with new Priority Valve qualifications and implementation are unacceptable. The timeline to award and qualify a new Priority Valve solution includes: 1-2 years for a source selection, 3-5 years for qualification, and an additional 2-4 years to qualify a new Priority Valve source's facilities, personnel, processes, and procedures.

This entire 6-11 year process would be required if a new Priority Valve OEM is selected. With existing contractual support for inorganic Depot Activation expiring at the end of FY 2026, any solution other than sole-source award to PneuDraulics Inc.

will result in EX aircraft being grounded during this extended timeline.

PneuDraulic's Unique Position

PneuDraulics Inc. Priority Valve is fully developed, integrated, and has been certified/qualified for use on all F-15EX aircraft.

The Priority Valve further meets all safety, suitability, and effectiveness requirements necessary for fielding EX aircraft. As the OEM of the only compliant Priority Valve available to the USAF, PneuDraulics Inc. is the only source in possession of the technical expertise, technical data, source code, proprietary engineering documentation, and knowledge necessary to fulfill the delivery and DA requirements the USAF requires to continue fielding EX aircraft without substantial impacts to cost and schedule.

Accordingly, PneuDraulics Inc. is the only viable OEM capable of providing the supplies and services identified in Section III above without the cost, schedule and budgetary risks explained in this section.

VI. Integrated Market Analysis and Efforts to Solicit Competition (RFO 6.104-1(a)(6), (8), and (10)):

In accordance with FAR Subpart 5.2, a synopsis of the proposed contract action was published on SAM.gov.

Furthermore,market research was conducted to identify all potential sources for this requirement, consistent with the procedures outlined below.

Regulatory Requirement

DFARS PGI 206.302-1(d) states that "When utilizing the authority at FAR 6.302-1, the Contracting Officer shall post a request for information or a sources sought notice, and shall include the results of this inquiry in the justification required by FAR

6.303. This requirement to post may be waived by the Head of the Contracting Activity, or designee. The waiver authority may not be delegated lower than a general or flag officer or a member of the Senior Executive Service."

Market Research Conducted

In fulfillment of this requirement, the Government conducted two separate market research inquiries via SAM.gov to identify sources capable of meeting the full scope of the Government's needs.

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Broad-Scope RFI: A Request for Information (RFI) was posted for 60 days (1 May - 28 June 2025) to identify sources capable of providing depot-level maintenance and repair services for a variety of F-15EX components, including the Priority Valve.

Targeted RFI: A second, more targeted RFI was posted for 14 days (3 Dec - 16 Dec 2025) specifically seeking sources for the integrated Priority Valve requirement, encompassing both immediate depot repair services and the elements required for a full Depot Activation.

Results of Market Research

The comprehensive market research effort confirmed that no viable alternative sources exist.

No respondent to either RFI was able to demonstrate the existing capability to perform depot-level repair of the F-15EX Priority Valve. Further, no respondent could demonstrate possession of, or a viable path to obtaining, the necessary proprietary technical data, OEM-certified engineering expertise, and source code required to establish an organic DA capability.

The results of this inquiry affirm that PneuDraulics Inc., as the OEM, is the only source with the unique qualifications, proprietary data, and technical expertise required to perform both the immediate depot repair services and to provide the essential support needed to establish a permanent, organic government depot solution.

VII. Determination of Fair and Reasonable Cost (RFO 6.104-1(a)(7)):

The Contracting Officer is responsible for evaluating, determining, and documenting the anticipated contract cost/price is fair and reasonable in accordance with RFO Subpart 15.4, Contract Pricing.

VIII. Any Other Facts Supporting the Justification (RFO 6.104-1(a)(9)):

Contracting Officer Assessment

The F-15EX Contracting Officer has determined that the Government can obtain and negotiate a fair and reasonable price for the Priority Valve requirement defined in Section III above if acquired from PneuDraulics Inc. on a sole-source basis.

Analysis and Evaluation Support

Thorough technical, price, and cost analyses will be performed as necessary by the F-15 System Program Office (SPO) with assistance from the Air Force Life Cycle Management Center (AFLCMC) Pricing Division, the Defense Contract Audit Agency (DCAA), and the Defense Contract Management Agency (DCMA). The F-15EX program may utilize the DCMA Integrated Cost Analysis Team (ICAT) for technical evaluation, pricing evaluation, and negotiation support, if warranted.

The undersigned Contracting Officer has determined that the anticipated cost to the Government for this acquisition of full DA capability will be determined fair and reasonable.

This determination will be based on a comprehensive analysis of the contractor's proposal, as outlined below:

Comprehensive Government Cost Analysis

The SPO, with expert support from the Air Force Life Cycle Management Center (AFLCMC) Pricing Division, the Defense Contract Audit Agency (DCAA), and the Defense Contract Management Agency (DCMA), will perform a thorough technical and cost analysis of the contractor's proposal. This analysis will evaluate the reasonableness of all proposed costs for both the recurring depot repair services and the non-recurring engineering and data deliverables associated with the Depot Activation effort.

Final Negotiation and Verification

The Contracting Officer will use the results of the comprehensive government cost analysis as the primary basis for negotiating a final, binding price.

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Market Research Conducted

In accordance with DFARS PGI 206.302-1(d), the Program Office conducted comprehensive market research to identify all potential sources for the required Priority Valve depot repair and sustainment services. This research included two separate Requests for Information (RFI) posted on SAM.gov:

Broad RFI: A 60-day RFI (1 May - 28 June 2025) was published to survey the industrial base for sources capable of providing depot-level maintenance for a wide range of F-15EX avionics, including the Priority Valve.

Targeted RFI: A subsequent 14-day RFI (3 Dec - 16 Dec 2025) was published, focusing specifically on sources for the integrated Priority Valve requirement.

Market Research Results and Barriers to Competition

No alternative sources for the Priority Valve supplies and services were identified through either RFI posting. The market research confirmed that PneuDraulics Inc. remains the only responsible source capable of providing:

-Priority Valve hardware -Associated technical data rights necessary for Depot Activation -Required engineering expertise and proprietary documentation

The market research effort demonstrated that no source other than the OEM can satisfy the Government's requirement. The research confirmed the existence of the following barriers to competition:

Proprietary Technical Data & Source Code: The market research confirmed that the OEM exclusively owns and controls the Technical Data Package (TDP), schematics, and software source code. This data is essential for both (a) diagnosing and repairing current unserviceable units and (b) transferring the knowledge required to establish a government-owned repair line . No other source has access to this data.

Proprietary Specialized Test Equipment: The research verified that the specialized equipment and Test Program Sets (TPS) required to test, diagnose, and certify the Priority Valve are proprietary to the OEM. A new OEM would need to reverse-engineer and develop new STE, an effort that would introduce prohibitive cost and an untenable schedule delay.

Integrated Engineering Expertise: Respondents lacked the specific, embedded engineering expertise of the Priority Valve's design, manufacturing, and software integration. This unique OEM knowledge is critical for troubleshooting complex failures during repair and is the foundation of the training and engineering support required for Depot Activation.

Conclusion on Overcoming Barriers

This comprehensive market research confirms that no viable competition exists in the marketplace. The proprietary nature of the data, equipment, and expertise required for this effort constitutes a barrier to competition that the Government cannot overcome without incurring substantial, unbudgeted costs and unacceptable, mission-crippling delays. Therefore, PneuDraulics Inc. is the only responsible source capable of providing the complete and integrated Priority Valve depot solution.

IX. Actions to Overcome Barriers to Competition (RFO 6.104-1(a)(11):

Continuous Market Assessment The SPO continually searches for opportunities to compete or break out components from prime contractors to enhance competition and reduce costs.

Future Review Process: An F-15EX business review board will review all future efforts being considered for modifications to the Depot Activation requirement. Individual program managers will be required to present their market research results during the business review board prior to requesting a proposal.

Contracting Officer Review: Before awarding any delivery orders, the Contracting Officer will review the J&A and determine if sole-source award to PneuDraulics Inc. is within the scope of this J&A, ensuring continued compliance with acquisition regulations and competitive opportunities. This sole-source action is designed to give the Government the technical data and expertise necessary to create competition for this and similar requirements in the future.

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Acquisition of TDP & Licenses: The government has not received the necessary data rights from previous contracts. In accordance with standard procedure, the CLIN structure will not include separately priced CLINs for intellectual property (IP) rights. Instead, the contractor will include a data rights assertion list as part of their proposal, which will be an attachment to the contract. The cost for securing these Government-Purpose Rights (GPR) will be covered under the existing Data CLIN or the Technical Publications CLIN.This approach ensures the government obtains the essential information required to perform and sustain repairs (such as proprietary technical manuals, schematics, and specifications) and enables future competition for spare parts and other support services.

Establishment of a Government-Owned Organic Depot Capability: The stand-up of a government-owned and operated repair line, staffed by trained and certified government personnel, directly creates a viable alternative to the OEM. For all subsequent Priority Valve sustainment needs, the Government will have an organic capability, allowing it to act as its own "prime"and compete portions of the work if deemed appropriate.

Ongoing Market Surveillance: The SPO will continue to conduct market surveillance for any new or emerging sources capable of providing depot-level support for F-15EX components. Following the completion of this DA, any future market research will be conducted with the understanding that the Government now possesses the requisite technical data to potentially qualify an alternative source or partner. Upon successful completion of this DA effort, the Government's long-term sustainment strategy for the Priority Valve will change. Any subsequent acquisition for supplies or services related to this component will be subject to a new acquisition strategy and market research determination, based on how the Government's organic capabilities impact potential competition.