Redacted JEFO 20-0180 v2.pdf

D E P A R T M E N T O F T H E N A V Y

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N A V AL A I R S YS TE MS C O MMA N D H E A D Q U A R TE R S

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JEFO Number: 20-0180

JUSTIFICATION FOR AN

EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity.

Naval Air Systems Command (NAVAIR) Headquarters

2. Nature and/or Description of Action being Approved.

Pursuant to FAR 16.505(b)(2)(i)(C), this Justification for an Exception to Fair Opportunity (JEFO) authorizes and approves the award of an order modification as a logical follow-on to existing Order

N0001919F2630 under Indefinite Delivery Indefinite Quantity Contract (IDIQ) N0001918D0110 awarded to

Standard Aero on 24 January 2019 for the induction of fourteen (14) P-8A Poseidon aircraft engines for the incorporation of Power Plant Change 13 (PPC-13), the SermeTel coating of engine High Pressure

Compressor Front Stator Cases. The instant modification will procure minor repairs, to address discrepancies unrelated to PPC-13, that must be accomplished in order to return the engines back to Ready-

For-Issue (RFI) condition.

3. Description of the Supplies or Services Required to Meet the Agency’s Needs (including the estimated value).

The Maritime Patrol and Reconnaissance Aircraft program office (PMA-290) requires the minor repair of engine discrepancies to return fourteen (14) engines to RFI condition. The engine discrepancies are not connected with the cases or the SermeTel coating, but were identified as a result of the level of disassembly required to remove the cases to perform the SermeTel coating. The estimated value of the supplies and services to meet requirements is approximately $[REDACTED].

4. Identification of the Justification Rationale (see FAR 16.505(b)(2)) and, if applicable, a

Demonstration of the Proposed Contractor's Unique Qualifications to Provide the Required Supply or

Service.

Pursuant to FAR 16.505 (b)(2)(i)(C), the order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

As a result of competitive Solicitation N00019-15-R-2004, on 1 February 2018 Standard Aero and Boeing were the two awardees for P-8A Poseidon engine repair IDIQ contracts. An order-level competitive Request for Proposal (RFP) was issued to both Standard Aero and Boeing on 09 October 2018 soliciting proposals to fulfill Option Period 1 SeremeTel requirements. Standard Aero was awarded the Order, which procured the incorporation of PPC-13 on fourteen (14) engines.

Between 28 January 2019 and 23 December 2019, fourteen (14) Engines were inducted into Standard Aero’s facility pursuant to Order N0019192630 for the incorporation of PPC-13. Each engine has been disassembled to the extent required to remove the case to apply the SermeTel coating. During the disassembly process discrepancies, unrelated to incorporating PPC-13, requiring repairs have been identified by Standard Aero. Until each engine was disassembled to accomplish the PPC-13 effort, there was no reason to assume that such repairs would be required. As a result, an order modification must be issued on a sole source basis in the interest of economy and efficiency because it is a logical follow-on to the order, as the engines are in an opportune state to effect the repairs to return the engines to a ready-for-issue (RFI) condition.

5. A Determination by the Contracting Officer that the Anticipated Cost to the Government will be

Fair and Reasonable.

The contractor’s cost to perform the minor repairs consists of labor and material. The effort, as a whole, falls under the cognizance of the Minor Repair time-and-materials (T&M) CLIN. That CLIN has a single labor hour rate and material mark-up rate. Both of those rates were established during the overarching competitive

IDIQ contract source selection process. As to establishing a fair and reasonable price, the Contracting

Officer will obtain a cost estimate from the contractor that includes bases for the estimated hours. The contractor’s estimate will be reviewed for reasonableness by a Government technical team prior to the

Contracting Officer establishing the T&M price for the effort. Ultimately, the contractor will be paid for actual hours applied and material costs incurred toward meeting the requirements in accordance with the contract.

6. Any other Facts Supporting the Justification.

The additional tasking described in Section 3 performed as a stand-alone event would create duplicative actions for the contractor to perform, costing the Government an estimated additional $1,118,600 ($79,900 per engine). The duplicative efforts entail (a) preparing and shipping fourteen (14) engines to another facility and (b) inducting each engine and performing inspections, inventory, and partial dismantling to access and assess the core. The estimated hours for duplicative actions are approximately 150 hours per engine. Also, to compete the additional tasking and award to a different source would result in an unacceptable delay of 3 to 6 months in fulfilling those requirements. Additional impacts to the Government include inducting the engine back into a contractor’s facility and surveilling the duplicative effort that is currently part of the

Sermetel tasking. Combining these additional repair requirements concurrently with the Sermetel effort ensures Navy aircraft and aircrew safety and improves readiness, reduces cost, and helps meet schedule requirements.

7. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers that Led to the Exception to Fair Opportunity before any Subsequent Acquisition for the Supplies or

Services is Made.

NAVAIR plans to include estimated minor repair requirements in future order-level competitive RFPs for the fulfillment of SeremeTel requirements.

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.

[REDACTED] [REDACTED] [REDACTED]

Signature Name (Printed) Phone No.

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

CONTRACTING OFFICER CERTIFICATION

I certify that this justification is accurate and complete to the best of my knowledge and belief.

APPROVED

Upon the basis of the above justification, I hereby approve the solicitation of the proposed procurement(s) described herein using other than full and open competition, pursuant to the authority of FAR 16.505

(b)(2)(i)(C).

[REDACTED]

[Signature, Name, and Title]