Redacted JA for 312th Fire Burner Trainers Renovation_revised 1 Jul 2026.pdf

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

CUI

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

Agency: AETC

17 CONS/PKB

Goodfellow AFB, TX 76908

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

This document approves the award of a contract on a sole source basis to KFT for renovation/replacement of previously delivered large frame aircraft, dumpster, cylinder, and car fire training systems. This justification is made on an individual basis.

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

The proposed action is to procure specialized renovation, component replacement, and system upgrade services for the existing Dumpster and Large frame aircraft fire training systems located at the Louis F. Garland Fire Academy at Goodfellow AFB, TX. This single-source action is necessary to ensure the safe and functional restoration of the trainer's control and combustion systems without compromising the integrated proprietary design of the existing mockup.

The agency requires comprehensive renovation and mechanical replacement services to restore the operational capabilities and safety standards of the Dumpster Fire Trainer. The specific supplies and services required to meet this need encompass a complete overhaul of the control, electrical, water, and propane management systems, specifically including:

Control Station Renovation: Execution of a complete control station renovation in strict accordance with the technical specifications outlined in Statement of Work (SOW) section 3.4.2.

Water System Overhaul: The removal and replacement of all water lines connecting the control stand with the trainer. This requirement covers all integrated piping and lines routed to both the interior and exterior sprinkler systems, as well as the burner control boxes.

Electrical Infrastructure Upgrades: The safe removal of legacy electrical components and the installation of new, fully integrated wiring and conduit throughout the trainer's operational footprint.

Combustion and Burner Management Replacement: The extraction of old propane components and the installation of new, technologically current propane control valves, burner management systems, and interlock pilot light systems necessary to safely control and sustain the “interior fire” training scenarios.

Additionally, the contractor shall replace the Car Fire Trainer and Propane Tank Fire Trainer as described below.

Control Station Renovation: Complete renovation of the control station in accordance with the specifications outlined in SOW section 3.4.2.

Vehicle Prop Replacement: The complete removal, proper disposal, and replacement of the existing vehicle mockup prop with a new, fully integrated vehicle training prop.

Electrical Infrastructure Upgrades: The safe removal of legacy electrical components and the installation of new wiring and conduit.

Water System Overhaul: The removal and replacement of all water lines connecting the control stand with the trainer, including all piping/lines running to the interior/exterior sprinkler systems and burner control boxes.

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Interior Fire Combustion System: Removal of old and installation of new propane control valves, burner management systems, and interlock pilot light systems for the “interior fire” burner.

Ground Fuel Fire Combustion System: Removal of old and installation of new propane control valves, burner management systems, and interlock pilot light systems specifically for the "ground fuel fire" burner.

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)):

This requirement is for the procurement of comprehensive maintenance support, specialized repairs, and proprietary software updates for the A-500 Large Frame Aircraft Fire Trainer and O-250 computer-controlled propane-fueled firefighter trainers at the Louis F. Garland Fire Academy at Goodfellow AFB, TX. As the original designer, manufacturer, and installer of the A-500 and O-250 mockups, KFT is the sole provider equipped with the necessary resources, materials, and specialized equipment to fully support these trainers. The services acquired will ensure minimal operational downtime through the application of integrated and interchangeable system controls. Furthermore, the procurement includes all scheduled software updates developed for similar trainers, which KFT provides at no additional cost.

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

Necessary Intellectual Property (IP) Required to Meet Mission Needs:

The A-500 and O-250 trainers rely on proprietary software developed and exclusively owned by KFT.

KFT maintains strict control over its source code and does not release it to any external entities for any purpose. Consequently, third-party integration, modification, or software-level troubleshooting is impossible without violating IP protections or rendering the systems inoperable. Additionally, KFT possesses a vast intellectual property portfolio, including numerous patents covering their propane-fueled firefighter trainer technology, solidifying their unique technical capability. Due to these IP constraints, no outside organizations are authorized or capable of conducting maintenance or repairs on these trainers, with the sole exception of Goodfellow maintenance personnel who have been explicitly trained by the KFT Customer Service Team for routine, authorized tasks.

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

April 2026 CUI Page 4 of 5 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)):

Market research was conducted to identify sources capable of providing the required maintenance, repair, and upgrades for the KFT A-500 and O-250 fire trainers. The research included a review of industry capabilities and direct inquiries with the Original Equipment Manufacturer (OEM), KFT. The Market research points to KFT to reduce duplicate costs and unacceptable delays for the training mission.

The market research confirmed that KFT is the exclusive owner of the proprietary software, source code, and patented technology integral to the operation of the A-500 and O-250 systems. KFT confirmed they do not license their proprietary technology or authorize any third-party service providers for complex maintenance or software modifications. Therefore, while other fire trainer manufacturers exist, market research concludes that no other source has the legal rights or technical capability required to maintain, repair, or upgrade the existing KFT-manufactured systems at Goodfellow AFB.

1. Exclusive Ownership of Proprietary Data & In-House Training Integration: The A-500 and O-250 trainers rely on proprietary software developed and exclusively owned by KFT. KFT maintains strict control over its source code and does not release it to any external entities, making third-party integration, modification, or software-level troubleshooting technically and legally impossible. Furthermore, the Goodfellow Trainer Maintenance team has been exclusively trained by KFT. This specialized KFT-specific training allows our in-house personnel to troubleshoot and replace parts swiftly, getting trainers back online in a short duration to ensure the training mission is never compromised. Introducing a third party or a non-KFT system would instantly void this internal capability and mandate entirely new training protocols, creating an unacceptable operational gap.

2. Unacceptable Life-Safety and Liability Risks: The A-500 and O-250 are live-fire, propane-fueled training systems where safety is paramount. Allowing an unauthorized third-party vendor, who would lack the proprietary schematics and software access, to attempt repairs on the computer-controlled gas and combustion systems would introduce severe and unacceptable life-safety risks to military personnel and trainees. Such action would invalidate system safety certifications and expose the Government to extreme liability.

3. Zero Tolerance for Duplication of Cost and Mission Impact: Because third-party integration is precluded by KFT's proprietary data rights, the only alternative to a sole-source award to KFT would be the complete removal of the existing trainers and the installation of an entirely new, non-proprietary system. The Government will not accept any additional costs associated with replacing these systems. Funding is tightly constrained, and any duplicated costs would directly impact the project scope, potentially preventing the project from happening at all. Most critically, the Louis F. Garland Fire Academy operates on a rigorous schedule and cannot tolerate any training deficiencies. The extended time required to design, procure, and install new trainers from scratch would leave the Academy's propane training capabilities non-operational for an extended period. This extended downtime is completely unacceptable and would critically degrade firefighter training and readiness across the DoW.

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

To overcome the barriers to competition caused by KFT’s proprietary software, patented technology, and the lack of a Government-owned Technical Data Package (TDP), the Government will take several targeted actions. First, the 312 Fire Fighter Training Squadron along with Contracting Officer will continue to monitor the marketplace to determine if KFT alters its licensing posture or

April 2026 CUI Page 5 of 5 authorizes third-party maintainers in the future. Second, the 312 TRS will continuously evaluate upcoming maintenance requirements to determine if non-proprietary mechanical components can be safely carved out and competed.