Sole Source Justification and Approval (NADTC Custom Configuration Spares) - Simplified-Acquisition Procedures (SAP).pdf

SIMPLIFIED ACQUISITION PROCEDURES (SAP)

Determination Memorandum for Sole Source Acquisitions Over $15,000 but not Exceeding $350,000

SOLICITATIONS MAY BE LIMITED TO ONE SOURCE ONLY IF THE CONTRACTING OFFICER DETERMINES THAT ONLY ONE SOURCE IS REASONABLY AVAILABLE. WHEN THE CUSTOMER DESCRIBES AN ITEM OR SERVICE, WHICH LIMITS THE AVAILABILITY TO ONE SOURCE, THE DETERMINATION MUST EXPLAIN WHY THE ITEM OR SERVICE PROVIDER IS THE ONLY ONE THAT WILL MEET THE GOVERNMENT'S REQUIREMENT. STATEMENTS SUCH AS "ONLY KNOWN SOURCE" OR "ONLY SOURCE WHICH CAN MEET THE REQUIRED DELIVERY DATE" ARE INADEQUATE TO SUPPORT A SOLE SOURCE PURCHASE. THIS FORM MAY BE USED IN LIEU OF THE DETERMINATION DESCRIBED IN FAR 13.106. THE CUSTOMER SHALL

PROVIDE THE FOLLOWING INFORMATION:

1. PURCHASE REQUEST OR REQUISITION NUMBER: 2. PROJECT/TASK NUMBER: 3. ESTIMATED AMOUNT:

4. BRIEF DESCRIPTION OF SUPPLIES OR SERVICES REQUIRED AND THE INTENDED USE:

5. UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE, WITH THE REASON NO OTHER SUPPLIES OR

SERVICES CAN BE USED:

6. EXPLAIN WHY AN ADEQUATE PURCHASE DESCRIPTION OR OTHER INFORMATION SUITABLE TO SOLICIT MORE THEN ONE

SOURCE HAS NOT BEEN DEVELOPED:

7. PROVIDE A STATEMENT OF ACTIONS, IF ANY, THE GOVERNMENT MAY TAKE TO REMOVE OR OVERCOME ANY BARRIERS TO

COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED:

8. CUSTOMER

8a. Name: 8b. Code: 8c. Phone#:

8d. Signature/Date:

9. CONTRACTING OFFICER

9a. Name: 9b. Code: 9c. Phone#:

9d. Signature/Date:

NAWCTSD 4200/6 (REV 10/01/2025)

This acquisition will be conducted on a sole source basis for the specific commercial components detailed below, solicited via a Provisioned Item Order (PIO). The prime contractor, Aero Simulation, Inc., (ASI) shall be responsible for the procurement, inspection, and delivery of a complete spares package that is certified as fully compatible with the NADTC-LANT system.

ASI shall deliver the complete spares package to Naval Air Station (NAS) Oceana, VA. The required delivery date is No Later Than (NLT) February 15, 2027. To facilitate logistics and acceptance, shipments shall be consolidated to the greatest extent possible. Early delivery is authorized and encouraged.

5 UNIQUE CHARACTERISTICS THAT LIMIT AVAILABILITY TO ONLY ONE SOURCE WITH THE REASON NO OTHER SUPPLIES OR SERVICES CAN BE USED: The NADTC-LANT system utilizes a complex, approved system-of-systems architecture. It is a highly customized, mission-critical platform rather than a standard Commercial-Off-The-Shelf (COTS) product. ASI possesses unique and proprietary knowledge of this architecture. Therefore, ASI is the only responsible source capable of providing the required brand name and custom-modified hardware spares to meet the Government's needs. Awarding this requirement to any other vendor, or utilizing alternative component brands, would result in a substantial duplication of cost to the Government that is not expected to be recovered through competition, as well as unacceptable delays in fulfilling the agency's critical training mission. This justification is supported by the following factors:

1. Requirement for Custom Modification based on Proprietary Data: A portion of the required initial spare parts require custom modification to integrate seamlessly into the proprietary NADTC-LANT architecture. ASI is the sole entity possessing the requisite proprietary data, system knowledge, and engineering expertise to execute these modifications. Procuring unmodified COTS hardware from a third party would result in the delivery of incompatible components, rendering the spares unusable and risking system failure. Rectifying this would necessitate a subsequent, costly integration contract with ASI to modify the items as Government-Furnished Equipment (GFE), driving substantial duplicated costs and critical schedule delays.

2. Mandatory Brand Name Requirement for System Interoperability: In addition to ASI's proprietary integration, the NADTC-LANT architecture strictly mandates the use of specific brand name components. These specific brand name items are essential to maintain critical system interoperability, ensure seamless software-to-hardware communication within the existing enclave, and prevent the voiding of overarching system warranties. Introducing alternative, non-brand name components would require extensive, re-engineering, software reprogramming, and complete system recertification, resulting in unacceptable mission delays and unrecoverable costs.

3. Obsolescence and Form, Fit, and Function (FFF) Replacement: The Government has identified some required spare parts are approaching end-of-life and will soon lack Original Equipment Manufacturer (OEM) support. ASI is already actively executing engineering efforts to identify, test, and certify suitable FFF replacements for these specific brand name components within the proprietary architecture.

4. Supply Chain Scarcity and Engineering Synergy: During the Government market research, at least one critical spare part could not be located on the Open Market or via GSA Advantage. It is in the Government's best interest to consolidate the procurement of this hard-to-find item with ASI, as they are already managing the complex FFF engineering and certification process. ASI is uniquely positioned to either source the brand name item through their established supply chain or immediately initiate an authorized FFF replacement effort. This strategy mitigates significant technical and schedule risks.

Consolidating the engineering and procurement efforts with ASI is the most efficient and logical path to ensure system sustainment. Due to the proprietary nature of the required custom modifications, the strict brand name requirements necessary for interoperability, and the ongoing FFF engineering efforts for obsolete and scarce components, ASI is the only source capable of delivering a complete, functional, and certified initial spares package without causing unacceptable delays and unrecoverable duplicated costs.

6 EXPLAIN WHY AN ADEQUATE PURCHASE DESCRIPTION OR OTHER INFORMATION SUITABLE TO SOLICIT MORE THEN ONE SOURCE HAS NOT BEEN DEVELOPED: Market research was conducted to ascertain the state of the market for this requirement. This research confirmed that while the base COTS components (e.g., Dell servers, Rave Computers, Dell 24 Port Ethernet Switch) are available through numerous resellers and distributors, the Government's actual requirement is not for simple COTS hardware. The critical requirement is for a set of fully integrated and in some cases custom-modified, initial spare parts that are guaranteed to be compatible with the proprietary NADTC-LANT system.

As detailed in Section 5, no source other than the ASI possesses the proprietary technical data, engineering drawings, or detailed system knowledge necessary to perform the required custom modifications on the seven identified computer and peripheral parts. Furthermore, ASI is the only entity with the in-depth system expertise currently performing the FFF engineering analysis required to certify replacements for the three identified obsolete components. Therefore, while other vendors can sell the base hardware, none can meet the full, actual requirement of delivering a functional customized and certified initial spare parts.

Past Performance under Provisioning Logistics Management (PLM): Historically, the NADTC Deputy Assistant Program Manager for Logistics (DAPML) utilized multiple PLM contracts as the primary method for spares acquisition. As documented in PLM Delivery Orders (DO) 52, 108 and 174, the program experienced unacceptable performance and delivery issues. These failures included the delivery of unauthorized "like item" substitutions that compromised system integrity, as well as unfulfilled orders. This documented history reinforces the risk of utilizing non-proprietary sources for this highly specialized requirement.

Sources Sought Notification / General Service Administration (GSA) Request for Information (RFI): A formal sources sought notice and GSA RFI was deemed impractical and unlikely to yield any qualified sources. The unique and proprietary nature of the required modifications and the ongoing FFF engineering efforts are intrinsically tied to ASI position as the system integrator. Issuing an RFI would be asking the market if they can replicate proprietary engineering without access to the underlying data, which is not a viable path to competition. Such an action would only serve to delay the procurement of critical initial spares necessary for maintaining the operational readiness of the NADTC-LANT training system.

Based on these efforts, the Government concludes that ASI is the only source capable of meeting this unique and highly specialized requirement.

7 PROVIDE A STATEMENT OF ACTIONS IF ANY THE GOVERNMENT MAY TAKE TO REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE FUTURE ACQUISITIONS ARE REQUIRED: This procurement action is considered a one-time requirement to support the current set of system upgrades and encompasses all requirements as detailed herein. As such, the Government does not intend to compete this specific requirement again in the future.

However, the Government will continue to conduct market research to identify and evaluate alternative sources and new technologies that may meet NADTC-LANT training system's stringent requirements for reliability, supportability, and performance for future needs.

Notwithstanding future possibilities, for the current system configuration, any deviation from the established technical standard has been determined to be detrimental to the program. It would result in an unacceptable duplication of costs, schedule delays, and a mis-allocation of Government resources required to re-engineer, re-test, and re-certify the system. Therefore, no actions can be taken to overcome the barriers to competition for this specific procurement.