Redacted DRAGON ICS FA8730-20-C-0053 JA.pdf

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

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I. Agency and Contracting Activity.

This Justification and Approval (J&A) is a justification for Other Than Full and Open Competition. The contracting activity is Air Force Materiel Command (AFMC), Air Force Life Cycle Management Center (AFLCMC), Intelligence, Surveillance and Reconnaissance (ISR) and Special Operations Forces (SOF) Directorate - Airborne Warning and Control System (AWACS) Division, AFLCMC/WIWK, 3 Eglin Street, Hanscom AFB, MA 01731. The Contracting Officer is

II. Nature and/or description of the action being approved.

This is an individual Other Than Full and Open Competition J&A, which supports an extension of the AWACS Diminishing Manufacturing Sources (DMS) Replacement of Avionics for Global Operations and Navigation (DRAGON) Interim Contractor Support (ICS) contract (FA8730-20-C-0053) in accordance with (IAW) FAR 52.217-8, Option to Extend Services. FAR 52.217-8 clause was incorporated by reference in the base contract award; however, the potential option to extend services for up to six (6) months was never requested through the request for proposal (RFP) process, thus neither the contractor (Rockwell Collins, Inc. (Collins Aerospace)) nor the Government formally or informally proposed and evaluated the projected cost to extend these services. Therefore, this individual J&A also serves to clarify and execute FAR 52.217-8 within the contract itself.

This will provide the Government a six (6) month extension to the existing contract (FA8730-20-C-0053) to sustain warehouse support and repairs/overhaul of repairable spares. The DRAGON Program was scheduled to transition to sustainment at the end of the current period (option year (OY) four (4)), at which point the 407th Supply Chain Management Squadron (SCMS) and 422nd SCMS were to assume responsibility of supply (warehousing) and repair capabilities of DRAGON assets. Continued performance of this contract is required while follow on repair efforts are established by the 407th and 422nd SCMS in preparation of that transfer to organic support at Tinker Air Force Base, Oklahoma. Contract FA8730-20-C-0053 is set to expire on 22 July 2025. This extension is to be awarded to CA, the sole source contractor, 400 Collins Rd NE Cedar Rapids IA, 52498-0505.

The DRAGON Program modernizes the AWACS from an analog to digital configuration. Developed by The Boeing Company (Boeing), who chose CA as the Flight Management System Suite (FMSS) developer, all technical aspects of the FMSS are attributed to CA who is regarded as the true original source of the requirement. The FMSS consists of Line Replaceable Units (LRUs) from multiple contractors, yet CA owns the majority of the LRUs and the proprietary data within. A cooperative effort with the North Atlantic Treaty Organization (NATO), the DRAGON ICS supports the repair of DRAGON LRUs, warehousing of spares with support staff, packaging, shipping, and transportation of DRAGON assets for the USAF and NATOs Communication/Navigation System/Air Traffic Management (CNS/ATM) fleet. Additionally, ICS addresses DMS and Material Shortages (DMSMS) which are increasing in frequency as the E-3 AWACS fleet ages. DRAGON has experienced multiple DMSMS problems because parts are no longer procurable.

. As DRAGON modified aircraft gain more flight hours, part failure rates are projected to increase. Furthermore, as commercial equipment utilized in the DRAGON system ages, unpredictable DMSMS issues are anticipated to become more common. The viability of the E-3 AWACS is heavily dependent on the availability of spares. Maintenance costs continue to rise as available vendors decrease and LRUs exceed their intended service life. This drives the use of overhauled parts to preserve the readiness of the fleet. Thus, the services provided by CA are essential to maintaining an adequate supply of spares critical to the operational status of the E-3.

In July 2023 the 407th SCMS notified the Program Management Office (PMO) of their growing concern surrounding the ICS contract and it's projected July 2025 Period of Performance (PoP) end date. In August of 2023 the DRAGON team kicked off Logistic Reassignment meetings with designated organizational points of contact (POCs). Initial discussions were primarily focused on specific parts and associated documentation being transferred, with the 407th SCMS and the 422nd SCMS raising questions and seeking clarification on assignment decisions. For several months there was extensive back and forth regarding parts information and inquiries. These exchanges were cited as the reason why the 407th SCMS and 422nd SCMS could not begin some of their contracting processes, which included questions and clarifications on parts usage data, repair information, spares availability, technical orders, and database codes. Internally, the 407th SCMS and 422nd SCMS require at least 2+ years to award a contract thus elevating the risk for a gap in service if a sustainment requirement was not initiated in the summer of 2023. The DRAGON PMO requested details on the 407th SCMS and 422nd SCMS contracting processes in an effort to expedite milestones to ensure contracts were in place to support a transition of services at the end of the current PoP. After much discussion, the 407th SCMS and 422nd SCMS indicated that meeting the ICS July 2025 deadline was not feasible.

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On 19 August 2024 the Government issued it's Notice of Intent to Extend Contract FA8730-20-C-0053 IAW FAR 52.217-8, Option to Extend Services, for a period of six (6) months to avoid a break in service to CA

On 2 April 2025, the 448th SCMW/FMR issued a Assurance of Funds memorandum to the PMO stating that the 422 SCMS is committed to executing FY25 funding ISO budget code 8 assets on the DRAGON ICS contract. Funding utilized will be Working Capital Funds

On 11 June 2025, the 422nd SCMS communicated to the PMO that they had made the determination that exercising the clause FAR 52.217-8, Option to Extend Services on the ICS contract (FA8730-20-C-0053) was not necessary based on the amount of spares, assets in work, and repair history of repairable spares. The PMO and 407th SCMS do not concur with this analysis; furthermore, NATO has a requirement for continued services to support their E-3 airframes. In lieu of funding from the 422nd SCMS, the PMO made the decision on 18 June 2025 to continue to pursue the extension of services IAW FAR 52.217-8, Option to Extend Services with 3010 (Aircraft Procurement) appropriation monies.

The USAF will fund of the effort whereas NATO will fund commensurate with the amount of support required for NATO assets. A certified Form 9 in support of (ISO) NATO was received on 24 April 2025 in the amount of

, in which will be obligated on contract. A certified Form 9 ISO of the USAF was received on 26 June 2025 in the amount of .

The Government will utilize a combination of Firm Fixed Price (FFP) for warehouse support and repairs of Collins Aerospace (CA) repairable spares (per FFP B-table costs) CLINs, and Cost Plus Fixed Fee (CPFF) CLINs for repairs of repairable spares with which third party vendors provide repair quotes (per CPFF B-table costs).

A gap in warehousing and repair capabilities ultimately puts the E-3 fleet at risk of being non-operational. Due to the aforementioned circumstances that were beyond the Contracting Officer's control, continued performance of this contract is required to ensure the readiness of the E-3 fleet.

III. Description of supplies/services required to meet agency needs.

Under the proposed DRAGON ICS Contract (FA8730-20-C-0053) J&A, five (5) new contract line-item numbers (CLINs) shall be incorporated to support the extension of services from 23 July 2025 to 22 January 2026. These service CLINs will increase the contract value by to in which CA will continue to provide the following:

Warehouse Support Services (FFP)

Warehouse Support is defined as the contractor providing a contractor owned, staffed warehouse facility to house Government Furnished Property (GFP)/Spare Support List (SSL) spares and other contract-required equipment to store spare parts for aircraft. Furthermore, it includes providing detailed reconciliations and transaction records to include dispositions, requisitions, and transfers IAW the Performance Work Statement (PWS) section 2.8.

Spares Repair (FFP & CPFF)

Spares Repair is defined as all ICS related repairs and overhaul of repairable spares and unique support equipment in accordance with the PWS section 2.10. Repairs are executed on a FFP basis if they are a CA part and have known associated cost information. Repairs of non-CA parts are executed on a CPFF basis as they are sent to a 3rd party vendor for a repair cost.

The proposed additional CLINs breakout is as follows:

5003: Warehousing (FFP) 5007: NATO Repairs (CPFF) 5008: NATO Repairs (FFP) 5009: USAF Repairs (CPFF) 5010: USAF Repairs (FFP)

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FAR 5.202 applies.

IAW FAR 5.203, a Notice of Contract Action (NOCA) was posted to SAM.gov on 2 July 2025 to provide notification to industry partners that the agency intends to award a contract extension pursuant to FAR 52.217-8, Option to Extend Services, to CA to provide warehousing support and repairs of repairable spares ISO the E-3 System AWACS DRAGON Program. This NOCA was posted for fifteen (15) calendar days. There were no responses.

In the effort to award the original DRAGON ICS contract (FA8730-20-C-0053) a Request for Information (RFI) was issued to GSA OASIS Unrestricted Pool 1 in September 2018 when, at the time, the total estimated value of the effort was . That RFI resulted in responses from interested parties. After careful consideration, a re-examination of requirement, GSA Pools, initial spares, and the addition of the NATO AWACS fleet to the ICS effort, it was determined that a second RFI with Sources Sought language should be published under GSA OASIS Unrestricted Pool 3. At this point in the market research process, the Independent Government Cost Estimate (IGCE) increased from to . , the incumbent contractor for DRAGON Reach-back was the only interested company that provided a response.

In order to garner more interest and establish a reasonable expectation that two or more respondents would submit priced offers, the DRAGON contracting team made follow up phone calls to GSA OASIS Pool 3 contractors to inquire as to whether the RFI was seen and whether the contractor would be interested in proposing. The DRAGON contracting team contacted 8 contractors off the Pool 3 list, 4 of which provided feedback.

reviewed the requirement and determined that they were incapable of performing in accordance with the PWS.

responded that the requirement is outside their capability/portfolio focus.

did not fully understand the requirement and gave unrealistic schedule and delivery capabilities, rending the decision that they were not a viable option.

assumed the RFI was posted as market research in order to justify a sole source to and/or leading to a non-response. A follow-up phone call with clarified that the Reach-back requirement will be competed requested an in-person one on one meeting to further discuss the requirements. visited Hanscom AFB on 11 June 2019 to discuss the Reach-back requirement for market research purposes. revealed that similar requirements have been performed by in the past for UK AWACS and JSTARS and that has employees near Tinker AFB. posed many questions strictly regarding Reach-back requirements that included topics such as condemnation of parts, DMS resolution time lines, shipments, to/from NATO, Government Furnished Equipment (GFE) inventory, labor categories for engineering Reach-back, Reach-back processes, and more. disclosed that they plan to bid to the solicitation upon it's release.

A final, very brief RFI was distributed to GSA OASIS in June 2019 to finalize a list of interested parties. , and a third unexpected party, all responded. Their respective CAGE codes were researched on CPARS as well as the historical performances on PSC code J015.

An industry day was held the week of 5 August 2019. One-on-one sessions were held with and during which each party restated their interest in proposing to the requirement.

The final RFP was released to GSA OASIS Pool 3 on 16 September 2019 with a proposal submission date of 1 November 2019.

expressed their withdrawal of interest shortly thereafter citing an inability to provide a competitive price in relation to expected competition. did not notify the Government of their withdrawal until five (5) days before the deadline which drastically delayed the contract award schedule despite the program office being assured of their intent to submit a proposal at all times leading up to the proposal deadline including during FOPR draft stages and industry day. stated they withdrew their interest citing an inability to provide spares according to the solicited delivery schedule, contradicting their assertions to the contrary in prior discussions with Government. was then contacted to gauge its continued interest at which time they declined citing the company had chosen to focus on other bids.

The Government then contacted CA to gauge their interest in entering into a sole-source contract for the DRAGON ICS effort.

CA originally communicated to the Government they were not interested in bidding on this effort and were not a vendor in

August 2023 Page 6 of 7 the GSA OASIS pool where the RFI was posted. After Rockwell merged with United Technologies Corporation and went through organizational changes, they reconsidered and notified the Government that they would be willing to enter into a sole-source contract agreement for this effort.

A Notice of Contract Action (NOCA) was posted to SAM.gov on 25 February 2020 notifying industry of the sole source contract to CA. There were no responses.

VI. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

This effort will cost . The final contract cost will be negotiated in accordance with (IAW) procedures in FAR Part 15, which will ensure that the cost to the Government is fair and reasonable. To ensure that prices are fair and reasonable, the Contracting Officer will compare historical prices from the original contract award and all subsequent contract actions where new work was added, and historical pricing information where available. In this specific effort, the price is determined by using current option period rates (OY four (4)) IAW FAR 52.217-8, Option to Extend Services for an extension of up to six

(6) months, which shall be confirmed by both Government Costs Analysts and CA.

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

Market research for the original DRAGON ICS effort was extensive comprising of several RFIs, a draft Fair Opportunity Proposal Request (FOPR), and an industry day, all of which date back to September 2018. New RFIs were produced in April 2019 and June 2019 after the program adjusted its initial requirements to include NATO spares and parts replacement as well as fine-tune the PWS, ultimately leaving the Government with a reasonable anticipation of competition. An industry day was held on 6 August 2019 at which three one-on-one sessions were held with interested parties to address questions resulting from the draft FOPR which had been released in the weeks prior to industry day. All parties assured their intent on submitting proposals in response to the final FOPR. However all parties withdrew their intent to propose after the release of the final FOPR to the surprise of the Government. As a result, the Government's decision was to sole-source this action to CA.

No additional market research was conducted to support the six (6) month extension as:

CA holds a large majority of proprietary data within the DRAGON Program. CA is regarded as the true original source for this requirement as they created the design and functionality of the FMSS. Spares that would need to be repaired, stored, and replaced under ICS all result from this FMSS and it's LRUs.

CA has the most knowledge of any potential contractor to immediately address both warehousing and spare repair support to interface with the AWACS aircraft. If the DRAGON ICS contract was competed again, it would result in unacceptable delays in fulfilling the agency's requirements. If the contract is not sourced to CA, there could be other delays due to unfamiliarity with DRAGON, FLITES, and/or the need for additional time to develop an effective teaming arrangement with CA and/or other manufacturers of the LRUs.

No potential offeror other than the incumbent (CA) would be able to learn the requirements, propose a responsible proposal, and begin performance on a new contract without a gap in critical mission support resulting in unacceptable loss of mission ready E-3 aircraft for the USAF and NATO.

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

The Government's original market research as of 25 February 2020 was verified to be accurate as of 17 July 2025, sustaining