Redacted_JA_Redacted.pdf

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

FOR OFFICIAL USE ONLY

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- Task:

- Time to Perform Task (months):

- Cost to Perform Task ($):

- Total Months:

- Total $:

The Air Data Computer has a current monthly demand rate (MDR) of .2 with a repair cost $6,457. Average annual repair cost is MDR (.2) X Months (12) X Repair Cost ($6,457) = $15,496.80

Assuming a reverse engineering effort would result in a 10% reduction in repair cost, the new annual repair cost would be, Current Repair Cost ($6,457) X 90% = $5,811.30 per repair X MDR (.2) X Months (12) = $13,947.12.

The annual savings for repair of the Air Data Computer would be $15,496.80 - $13,947.12 = $1,549.68. The initial $1,825,000 investment in reverse engineering divided by annual savings $1,549.68, it would take more than 1,100 years to get a return on investment (ROI).

Airspeed Indicator (6610-01-444-0169LG)

- Task:

- Cost to Perform Task ($):

The Airspeed Indicator has a current monthly demand rate (MDR) of 1.00 with a repair cost of $5,833. Average annual repair cost is MDR (1.00) X Months (12) X Repair Cost ($5,833) = $69,996.

Assuming a reverse engineering effort would result in a 10% reduction in repair cost, the new annual repair cost would be, Current repair Cost ($5,833) X 90% = $5,249 per repair X MDR (1.00) X Months (12) = $62,996.

The annual savings for repair of the Airspeed Indicator would be $69,996 - $62,996 = $7,000. The initial $1,150,000 investment in reverse engineering divided by annual savings $7,000, it would take more than 164 years to get a ROI.

Altitude Alerter (6340-01-445-0138LG)

- Task:

The Altitude Alerter has a current monthly demand rate (MDR) of 0.2 with a repair cost of $3,517. Average annual repair cost is MDR (0.2) X Months (12) X Repair Cost ($3,517) = $8,440.

Assuming a reverse engineering effort would result in a 10% reduction in repair cost, the new annual repair cost would be, Current repair Cost ($3,517) X 90% = $3,165 per repair X MDR (0.2) X Months (12) = $7,596.

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The annual savings for repair of the Altitude Alerter would be $8,440 - $7,596 = $844. The initial $1,450,500 investment in reverse engineering divided by annual savings $844, it would take more than 1,718 years to get a ROI.

The current estimated life of the C-130H aircraft is 2030, approximately 10 more years.

Since the Government does not own data rights and reverse engineering of these 1980 vintage items is cost prohibitive and impedes competition from other sources; therefore, directs the solicitation be made to the approved source only. Accordingly, Innovative Solutions and Support Inc., is the only source capable of providing the supplies and services described in Section III above without the USAF, ANG and AFR experiencing substantial delays, approximately 36 months for data, prototype development and testing and 4 months for first article evaluation to qualify a new repair source, followed by another 6 months for repairs to start fulfilling requirements.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

This requirement was posted on the Federal Business Opportunities (FedBizOps) web page on 11 October 2019 citing conditions which precluded Full and Open Competition. No sources expressed an interest as a result of the posting by close of business 28 October 2019. Although the Government does not own data to support acquisition of these C-130H Aircraft Avionic Components from any other source, any source who responded to the Government would have been identified to the prime contractor as a potential source for subcontracting possibilities. This is a pre-award contract action as required by FAR 5.201 in advance of issuance of the solicitation.

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

The overall cost of this acquisition will be fair and reasonable to the Government based upon FAR 15 negotiation procedures. The Contractor will be required to submit data other than certified cost or pricing data in accordance with FAR 15.403-3. Thorough price analysis will be conducted using available information and approved pricing techniques that will support the contracting office in making a determination that the price paid to the contractor is fair and reasonable to the Government.

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

Market research was conducted by the System Engineer in accordance with FAR 10 and was completed 31 December 2019 using Internet searches, such as Central Contractor Registration, Thomas Registry, IHS Haystack, ILSmart, and Google for part numbers, NSNs and item descriptions. Also qualified individuals within the appropriate Government sections were contacted for assistance gathering product background information. A search for HUB zone and service disabled veteran owned businesses was also conducted using the Dynamic Small Business Search Engine. The subject NSNs on this repair contract are used exclusively on C-130H aircraft. These items are used by the USAF, USANG and USAFR are not commercial items due to special military specifications. The data rights to the drawings are proprietary and are owned by Innovative Solutions and Support Inc and they are not willing to release the data rights or sell the data. ISS was contacted by the 409 SCMS/GUEA Engineering Office via e-mail on 5 March 2017 about purchasing the data and responded Research identified no sources, other than Innovative Solutions and Support Inc, that are currently qualified to satisfy this requirement. Therefore, these items should be repaired by ISS, because they retain proprietary rights to the data packages. No other contractual vehicles are in place to repair these items, and it is not a feasible option to reverse engineer and qualify another source at this time.

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

None.

X. List of any sources that expressed, in writing, an interest in the acquisition.

See section VI above.

XI. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before making subsequent acquisitions for the supplies or services required.

Innovative Solutions and Support Inc., is the only known source that can provide supplies and services described herein within the timeframe required. As of 5 March 2017, Innovative Solutions and Support Inc., is not willing to sell, lease or loan the data.

Reverse engineering is a desirable and viable avenue whenever applicable and practical. However, because of the low repair quantities, low MDRs and the length of time to recover investment from reverse engineering, it is not a feasible option at this time.

While the current Market Research indicates a sole source environment for these NSNs, there are steps the Government will take to overcome barriers to competition for future acquisitions.

1. Revisit the designated Repair Method Code/Repair Method Suffix Code screening every 1-5 years.

2. Continue to engage Innovative Solutions and Support Inc. on selling the technical data package to the Government. current J&A does not require higher level approval in accordance with DFARS PGI 206.304(a) (S-70) (ii).

3. Work with 429 Supply Chain Management Squadron/Strategic Alternate Sourcing Program Office to request funding to acquire data/drawings/repair technical manuals, through reverse engineering, during the appropriate fiscal cycle for data sufficient for competition.

Once the data/drawings/repair technical manuals are available the Government will compete future requirements or establish organic repair.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.