Redacted LSJ initial.pdf

J&A – Limited Sources – ITSS ID: ID02200014 – U.S. Army Apache AH-64E Maintenance Trainers.

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION FAR 8.405-6

Procurement Office: General Services Administration (GSA) – Assisted Acquisition Services (AAS), Region 2, Federal Acquisition Services (FAS) Agency: U.S. Army, Apache Project Office Task Number:

Description of Requirement: Apache Maintenance Trainers AH-64E L7, with MSPU (Mobile Supply Power Unit) Estimated Dollar Value: $39,345,784.04 Period of Performance: 60 Months Vendor Name: Logistics Services International, Inc. (LSI) Procurement Vehicle: Federal Supply Schedule (FSS) Contract

Description of action being approved:

FAR 8.405-6 Limited sources justification and approval.

IAW FAR 8.405-6(a)(1)(B) – Only one source is capable of responding due to the unique or specialized nature of the work.

Description of Supplies or Services Required:

The Apache Attack Helicopter (AAH) Project Management Office (PMO) requires personnel, materials, facilities, engineering and production services and support to complete production and delivery of four (4) phase 2 build AH-64E Version 4 (V4) L7 Apache Maintenance Training Devices with Mobile Power Supply Units (MPSU). The phase 1 production activity was awarded in August of 2019. Intuitive Research Technology is the incumbent contractor.

However, Logistics Services International (LSI) serves as the subcontractor to Intuitive and is responsible for 100% of the effort.

The phase 1 effort will run concurrent to the phase 2 effort. The Apache devices herein are numbered L7 #9, L7 #10, L7 #11 and L7 #12. Device L7 #9 will be completed by contract award and ready for phase 2. The remainder L7 #10, L7 #11 and L7 #L12 will still be in phase 1 production.

The contract value is $39,345,784.04 as set forth in the IGCE. The below is the period of performance detailed estimates as documented in the ICGE:

Base period: Four (4) phase 2 Apache L7 D to E Conversion $ 15,727,884.59.

Option New Build AH-64E: $7 ,872,633.15 Option New Build AH-64E: $7 ,872,633.15 Option New Build AH-64E: $7 ,872,633.15 Total: L7 D to E conversion plus 3 Option New Builds $ 39,345,784.04

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Identification of Authority and Supporting Rationale:

The rationale for this Limited Source justification is FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of responding due to the unique or specialized nature of the work for orders placed against the Multiple Award Schedule Program.

LSI is the only company that possesses the required full technical data package, associated with the Apache Maintenance Trainers (AH-64E L7). LSI has the specific technical and engineering disciplines to perform total integration and assembly of all of the required hardware and software subsystems into the L7 device and deliver in the time frame required by the U.S. Army.

The U.S. Army does not possess the full data rights to the GFE/systems, Test Equipment and Control Documents to provide as Government Furnished Information. The technical data required for manufacturing and editing the software code was never required by the U.S. Army as a deliverable due to the complexity of the L7 device and the limited total number of L7s to be produced for the U.S. Army and Foreign Military Sale customers.

Demonstration that the Acquisition Requires the Use of the Authority Cited:

LSI is currently working on phase one production activities, and has successfully developed and delivered six Apache Maintenance Trainers. LSI has the significant background, experience and knowledge of the devices complex software, hardware and electrical interfaces to the numerous Government Furnished Equipment components and systems utilized on the training device. The highly complex, unique components are not detailed in any of the Contract Data Requirements List currently in possession of the U.S. Army, as they were never procured by the U.S. Army with that level of detail. The lack of detailed technical information will put the U.S. Army at a significant risk/disadvantage from a cost, schedule and interoperability standpoint.

Overall Description of the Technical Data The technical components and subsystems have performance specifications and interface control documents that are described by the US Army as proprietary information. The technical requirements include the manipulation/editing of complex coding and electrical inputs and outputs to and from aircraft components that require control and feedback. Failure to faithfully replicate aircraft functions and responses poses a safety risk to the Soldier.

The US Army identified the following technical data as not owned by the US Army: Electrical interface control, position monitoring, stimulation and calibration of all Flight Control Servo Actuators; all Pylon Actuators excitation control and position monitoring; Ammunition Handling Subsystem components and timing, control and stimulation; M230 Turret Subsystem and associated components required for position monitoring, control and calibration; Stabilator Control subsystem; Automatic Rollover Detent De-coupler and Linear Variable Differential Transformer electrical stimulation and interface as part of the back-up flight control system (BUCS) control, positioning and flight model/BUCS laws hierarchy; Helicopter Air Data Sub System; Sensors and Sighting sub-system motor control, resolver excitation and monitoring, DocuSign Envelope ID: FFC7B3EA-DA0E-4F87-AF98-AF591E386AD2DocuSign Envelope ID: 4428E328-8026-482A-95B3-F088E13BFDAF

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TiffanySJohnson Highlight switching and calibration and over 477 monitored connectors and 240 monitored switches that provide feedback to the Instructor Operator Station when actioned by the student.

Establishing another source would require a full technical data package, specifications and technology to be developed delaying production by 2-3 years. Non Recurring Development and production cost of the first L7 device cost the U.S. Army in excess of $17,450,000.00 in 2012 dollars and over 3.5 years in schedule for development of a baseline AH-64E version 2 configured devices.

Another factor that will significantly drive cost for the U.S. Army is the Second Destination Transportation (SDT) of all current L7 and L7 production assets to support a phase 2 production cycle at another vendor’s production facility. The cost per device to move is $30,000.00 due to the specialized tractor trailers required for transportation and the surveillance of highly sensitive assets. Additionally, the additional GFE and production assets would have to be moved at a currently unfunded expense. Total estimated cost of SDT would exceed $235,000.00. The U.S.

Army has no facilities for short term or long term storage of this magnitude. This additional storage cost, as yet unfunded, would conceivably exceed $175,000.00 per FY during L7 production.

Additionally, a comparative analysis of similar training devices identified a significant learning curve for vendors who do not possess full build Apache experience further negatively impacting the schedule for development and production. The Apache Maintenance Trainer is five times more complex on average and fully supports 3-4 times the number of training tasks on over twice the amount of systems as compared to Blackhawk and Chinook training devices. At this time, no other vendor possesses the required full spectrum of in house skill sets at the required densities to complete a full development and production of Apache Maintenance Trainer.

Description of market research conducted and Description of Efforts to Solicit as Many

Potential Offers as Practicable

GSA Assisted Acquisition Service issued five (5) sources sought synopsis notices and obtained a total of 7 capability statements from industry partners. It was determined that no vendor other than LSI has all the core competencies to meet the minimum requirements to build the Apache Maintenance Training Devices.

GSA AAS considered four feasible acquisition alternatives to meet the US Army requirements for the Apache Maintenance Trainers. The alternatives considered were Open Market, the Multiple Award Schedule Professional Services Schedule, OASIS Pool 3 Unrestricted and Alliant2.

Open Market

A total of four responses were received from the open market sources sought synopsis under NAICS 333318 Other Commercial and Service Industry Machinery Manufacturing.

The initial RFI restricted to small business concerns was published on June 2, 2020, and received two responses. The requisite past experience of building full platform Apache Maintenance

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Trainers was not demonstrated by the responses. The capabilities focused on upgrades to already existing helicopters or building utility helicopters. Additionally respondents did not meet the minimum level of quality due to a lack of experience with Apache Maintenance Trainers, lack of adequate materials, and/or an adequate manufacturing facility.

A subsequent RFI notice was shared via open market and unrestricted responses based on business size. The second open market RFI published on Jun 23, 2020 had a response date of Jun 30, 2020 and received two responses. The required experience with full build Apache Maintenance Trainers was not met from the second posting to open market. It was determined that none of the respondents from the open market could meet all of the requirements to successfully build the Apache Maintenance Trainer.

OASIS Pool 3

A source sought synopsis was shared with OASIS Pool 3 vendors on May 27, 2020 and closed on June 12 under NAICS 541330 Exception A-Engineering for Military and Aerospace Equipment and Military Weapons. Capability statements were requested from forty two vendors and two responses were received. The notice failed to produce sources with technical, engineering, manufacturing disciplines in the Apache Maintenance Training devices. As a result, capability was not obtained through the OASIS 3 contract vehicle.

Alliant2

Sources were sought from 51 vendors on Alliant2 contract vehicle; however no capability statements were received. RFI Alliant2 was published on May 27 and closed on June 12, 2020.

MAS Professional Services Schedule The sources sought synopsis was posted to the Professional Services Schedule on May 27 and closed on June 12, 2020. This requirement falls under the purview of Special Items Number 874-9 Off- the-Shelf Training Devices under NAICS Code 33318 Other Commercial and Service Industry in which there are 89 small and large business vendors. One response was received from Logistic Services International (LSI), the current developer of phase 1 Apache AH-64E Maintenance Trainers. LSI is the only vendor who provided a capability statement with experience designing and manufacturing Apache Maintenance Training Devices.

In addition to inviting industry partners to submit white papers on the professional services schedule, Boeing and Intuitive Research and Technology Corporation were contacted via email after the RFI closed. Neither company responded through their MAS schedule nor did they respond to the emails.

The essential areas of performance addressed in the Sources Sought Synopsis are listed below.

LABOR CATEGORIES/SUPPLIES

PERFORMANCE ON FFP BASIS

RESOURCES/MANPOWER

3 PAST EXPERIENCE

EXPERIENCE WITH FULL PLATFORM

APACHE TRAINERS

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WHERE ARE THEY FIELDED

MANAGEMENT WITHOUT SOURCE DATA

ESTIMATED DELIVERY

APPROACH WITH NO DATA AND NON

RECURRING ENGINEERING REQUIRED

TIME ONSITE AT CUSTOMER LOCATION:

THE 128TH

CORE BUSINESS ALIGNMENT WITH

REQUIREMENT

SUB TIER VENDORS REQUIRED

UPGRADE CAPABILITIES

Based on the responses from the sources sought synopsis, it was determined that no respondent, other than LSI, had the requisite experience necessary on the Apache Maintenance Trainers, and the experience provided through the sources is not transferable to fully build an Apache Maintenance Trainer based on the unique nature and high complexity of the device.

Additionally, database searches of the Apache AH-64E devices were performed on beta SAM, GSA Advantage, and Multiple Award Schedule Professional Service Schedule price lists to identify other potential sources. These searches produced limited results as there are very few procured quantities of the Apache Maintenance Trainers.

The incumbent contractor Intuitive Research and Technology Corporation, subcontracts 100% of the requirement to LSI. Intuitive did not provide a capability statement to the request for information. Additionally the incumbent contractor was contacted via email on June 23, 2020 and July 15, 2020 and no response was received. It appears that Intuitive Research and Technology Corporation has no direct ability and/or interest in performing on this requirement based on their lack of response to the sources sought synopsis, no reply to emails and no direct performance on the phase 1 predecessor contract.

Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable and Represents the Best Value

Prior to placing the order, the Contracting Officer will seek price reductions from LSI’s quote and the quote will be reviewed to ensure that pricing and terms are IAW their Multiple Award Schedule contract, GS-02F- 0133W. A price reasonableness determination will be documented.

The Contracting Officer will utilize prices paid in previous acquisitions for the same items to further substantiate the price reasonableness of the products quoted to the Government. Other than certified cost or pricing data will be requested to verify price reasonableness as needed.

Other facts supporting the justification

Deliveries are required to begin the fourth quarter of FY21, to comply with the long range fielding schedules.

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Schedule impacts of an award to a vendor other than LSI would be measured in years, not just months, at a time where the US Army is experiencing a critically high attrition rate for the 15R and 15Y Military Occupational Specialties (MOSs). Selection of other than LSI for this effort will incur additional integration, cost and delivery risk and result in the Army’s inability to train and field competent 15Y Soldiers in time to backfill deploying units. This in turn will have a significant impact on combat readiness and safety of deployed formations as current planned device densities have been agreed to since 2012.

Additionally, the U.S. Army repurposes a baseline software product across all devices and also supports Foreign Military Sale customers. A large percentage of this software code is reused for other Apache Operator, Maintainer, and Foreign Military Sales training device projects. Delay in award of this contract will adversely affect the United Kingdom which is in the beginning stages of an acquisition plan with a Letter of Offer and Acceptance directing limited source to LSI for an AH-64E V6 L7 device in support of in-country training. If another source is selected this will set the United Kingdom program back 3 years at a minimum and severely impact the planned U.S. Army V6 technology efforts.

List of sources that expressed an interest in the acquisition

AVT Simulation Flight Safety J.F. Taylor, Inc.

Leidos Logistic Services International Mission Driven Innovative Solutions, Inc.

Shen Te Enterprises Kratos

Statement of Actions to overcome barriers of competition

N/A.

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Technical and Requirements Certification

I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

Derryn Jones, U.S. Army Maintenance Training Devices Lead, Apache Project Office, Production and Fielding Department of the Army

Contracting Officer Certification:

I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief, that the order represents the best value to the government and the anticipated cost to the government will be fair and reasonable.

Lynn Womack Contracting Officer, GSA AAS Region 2

JONES.DERRYN.G

ATES.1013114966

Digitally signed by

JONES.DERRYN.GATES.1013114966

Date: 2020.08.14 06:07:19 -05'00'

LYNN WOMACK

Digitally signed by LYNN

WOMACK

Date: 2020.08.14 08:48:08 -04'00'

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Prepared By:

Tiffany Johnson Contract Specialist, GSA AAS Region 2

Lynn Womack Contracting Officer, GSA AAS Region 2

Lawrence Unger Branch Chief, GSA AAS Region 2

Theresa Ramos Division Director, GSA Assisted Acquisition Service, Region 2 Competition Advocate, GSA Federal Acquisition Service Region 2

Kristen M. Nowadly Senior Assistant Regional Counsel, GSA, Region 2

Jeff Lau Head of Contracting Activity, GSA FAS, Region 2

Tiffany Johnson Digitally signed by Tiffany Johnson

Date: 2020.08.14 08:16:50 -04'00'

LYNN

WOMACK

Digitally signed by LYNN

WOMACK

Date: 2020.08.14 08:51:19

-04'00'

LAWRENCE

UNGER

Digitally signed by LAWRENCE

UNGER

Date: 2020.08.14 10:46:26 -04'00'

Theresa Ramos Digitally signed by Theresa Ramos Date: 2020.08.14 14:02:25 -04'00'

DocuSign Envelope ID: FFC7B3EA-DA0E-4F87-AF98-AF591E386AD2DocuSign Envelope ID: 4428E328-8026-482A-95B3-F088E13BFDAF

8/18/2020

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