J&A6.302-1cSPE7M220C0008.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION SPE7M219R0020

DLA Land & Maritime Justification for Other Than Full & Open Competition

(FEB 2017)

[ X ] ORIGINAL

1. The Defense Logistics Agency, DLA Land and Maritime, is the contracting activity.

2. The action being approved is the acquisition of supplies on other than a full and open competition basis.

3. The supplies required to meet the using activity’s needs are described as follows:

BRIEF DESCRIPTION NSN/P/N QUANTITY EST. VALUE AMSC

Cable and Reel Assy/Purchase Cable 1710-01-454-7454 20 AY C

Identify end item, weapon system, or class of item: NSN 1710-01-454-7454. This Cable and Reel Assembly is currently being used by the Navy Carrier fleet and is a Critical Safety Item (CSI) for the (OEN) MK7 Arresting Gear System. The item is used on the WSDC 82N, (Aircraft Launch and Recovery Equipment) weapon system.

The MK7 MOD 3 Arresting Gear Engine absorbs the energy generated during an aircraft arrestment. During aircraft recovery, the cable and reel assembly is subjected to extremely high loads imposed in arresting aircraft.

J&A attached for recent contract SPE7M218C0031.

The Product Specialist of record reviewed the updated requirements and AMC/AMSC codes on April 5, 2019. The AMC/AMSC code is correct.

ESTIMATED BASE VALUE: 20 AY/46,000 Feet -

4. The statutory authority permitting other than full and open competition is:

[X] 10 U.S.C. 2304(c)(3) as implemented by 6.302-3 Industrial mobilization; engineering, developmental, or research capability; or expert services. This J&A is for the use of other than full and open competition as required by the Competition in Contracting Act. The J&A is citing the authority of 10 U.S.C Sec 2304 (c)(3) as implemented by 6.302-3 Industrial Mobilization, which allows the head of a military agency to use other than full and open competitive procedures in awarding a contract to a particular source or sources when such action is necessary to maintain a facility, producer, manufacturer, or other supplier available for furnishing property or services in case of a national emergency or to achieve industrial mobilization.

The Purchase Request will be solicited as unrestricted and sole sourced to Cage 77141, Wirerope Works Inc., a domestic small business located in Williamsport, PA pursuant to FAR 6.302-3 (a) (2).

FAR 6.302-3 (a) (2), provides that full and open competition need not be provided for when it is necessary to award the contract to a particular source or sources in order to maintain a facility, producer, manufacturer, or other supplier available for furnishing supplies or services in case of a national emergency or to achieve industrial mobilization. Additionally, use of the authority in paragraph (a)(2)(vi) of FAR 6.302-3 (b) (1) is appropriate when there is a need to divide current production requirements among two or more contractors to provide for an adequate industrial mobilization base.

Currently, (77141) Wirerope Works Inc., (WWI) and (35043) Industries De Cables D’Acier LTEE also known as Wire Rope Industries (WRI) are the only two mobilization producers of the item. (35043) WRI have 2 ongoing production contracts. WWI has assumed inactive status as they completed the recent contract for 10 AY. Since the loss of WWI’s facilities and critical skills would cause a delay in furnishing the item at a rate required for mobilization, DLA Land and Maritime has determined it in the best interest of the military customer to restrict the competition to WWI for this procurement. (80967) WireCo World Group Incorporated is a third source identified as a potential source, however, when DLA reached out to WireCo World Group in 2016, they indicated no interest in participating. In addition, an internet search indicated that WireCo World Group was selling its steel wire rope manufacturing plant in St. Joseph, Missouri.

Current contracts for WRI are SPE7M217C0031 for 160, with a contract delivery date of October 31, 2019 and SPE7M218C0031 for 110 has a contract delivery date of June 29, 2020. Delivery is a partial shipment of approximately 10 to 12 a month. Market research indicates that WWI can complete 20 in approximately 420 days, also providing partial shipments as items are completed.

Current stock situation:

NMCS IPG I IPG 2

LN 15 1 2 13

QTY 30 4 7 23

5. If restricted to the only source(s) of supply, include source(s) and CAGE code: (77141) Wirerope Works Inc., (WWI). This manufacturer has the proven capabilities and manufacturing processes required to produce this Critical Safety Item.

The use of the authority cited below:

[ X ] AMC 1. Suitable for competitive acquisition for the second or subsequent time.

The use of the authority cited is based on:

[ x ] AMSC C. This part requires engineering source approval by the design control activity in order to maintain the quality of the part. Existing unique design capability, engineering skills, and manufacturing knowledge by the qualified source(s) require acquisition of the part from the approved source(s). The approved source(s) retain data rights, manufacturing knowledge, or technical data that are not economically available to the Government, and the data or knowledge is essential to maintaining the quality of the part. An alternate source must qualify in accordance with the design control activity's procedures, as approved by the cognizant Government engineering activity. The qualification procedures must be approved by the Government engineering activity having jurisdiction over the part in the intended application. If one source is approved, AMCs 3, 4, or 5 are valid. If at least two sources are approved or if data is adequate for an alternate source to qualify in accordance with the design control activity's procedures, AMCs 1 or 2 are valid.

The components being acquired under this solicitation have been classified as “critical,” requiring engineering source approval by the design control activity, Naval Air Systems Command (NAVAIR). This is a flight critical safety item and in accordance with DFARS 209.270, DLA must procure this item only from those sources approved by NAVAIR. (35043) Wire Rope Industries, Canada, (77141) Wirerope Works Incorporated and (80967) WireCo World Group Incorporated have been identified as having the required and essential manufacturing capabilities. Only those companies who have submitted requests for source approval and have been approved will be eligible for award. Any manufacturers that are not approved by NAVAIR will be required to submit a Source Approval Request (SAR) Package for a review by NAVAIR.

The replacement of cable assemblies occur approximately every 1,075 to 1,300 aircraft arrestments or every 15 months regardless of condition (mandatory replacement). A shortage of these items in the system would create significant concerns for the Navy Carrier Fleet. The lack of required quantities will have an immediate negative impact on carrier aviation readiness and could result in the inability of the carrier fleet to make the required number of aircraft arrestments thus degrading the overall carrier fleet mission. In addition, the level of complexity to manufacture the cable and reel lies in the need to produce high quality wire rope within tight design parameters that will pass testing at NAVAIR in Lakehurst. The attaching of terminal requires special skills as the tolerances for dimensions and straightness are demanding.

Failure to have a second experienced and capable source for this item could result in the inability of the carrier fleet to make the required number of aircraft arrestments thus degrading the overall carrier fleet mission. DLA has previously procured this item from one source, Wire Rope Works, Canada, who may not be able to deliver the required quantities to fill demands and keep the item healthy.

6. I hereby determine that the anticipated cost to the Government will be fair and reasonable based on obtaining cost data from WWI. The Acquisition Specialist will be going through the DLA Land and Maritime Pricing office for assistance.

7. Efforts to ensure that offers are solicited from as many sources as practicable are: Not applicable when using

FAR 6.302-3.

Market Survey [10 U.S.C. 2304(f)(3)(D)]:

[ X] A market survey was conducted on/during April 9, 2019 to April 17, 2019.

Total number of vendors contacted: 1

Names of vendors contacted and responding: (77141) Wirerope Works Incorporated.

Techniques used to conduct survey: A Sources Sought Notice was not posted pursuant to FAR 5.202 (a) (10), the proposed contract action is made under conditions described in 6.302-3. A questionnaire was sent via email to Wire Rope Industries on April 9, 2019.

Types of information requested: Business size, willingness to participate, estimated price and delivery, commerciality, and willingness to provide certified cost and pricing data if necessary.

Summary of information received:

• 77141 - Wirerope Works Incorporated is interested in providing a proposal. Although asked to provide an estimated price and delivery, no information was received. The buyer also reviewed the market survey from past procurements.

Sources Sought Notice: No Sources Sought Notice posted pursuant to FAR 5.202 (a) (10), the proposed contract action is made under conditions described in 6.302-3. However, it is noted that no responses to a sources sought has been received for past procurements.

Information received regarding the commerciality of the item(s): There is no evidence that this NSN is available on the commercial market nor is it of a type customarily used by the general public or by non-governmental entities for purposes other than government or military purposes as defined in FAR 2.101. An Internet search did not find any commercial uses. This item is made to military standards and serves no other purpose than for the use for military applications aboard the U.S. Aircraft Carriers.

8. A listing of sources, if any, indicating an interest in the acquisition are: (77141) Wirerope Works Inc.

9. The following actions are being taken to identify additional sources:

[ ] Solicitation contains DLA Procurement Note, M06 Evaluation of Offers for Part Numbered Items [ ] VE Bailment Program [ ] Source Development Review [ ] Reverse Engineering [ X] Other (Explain) the solicitation and technical documents will posted for 15 days to FedBizOpps and to the DLA DIBBS website for 30 days. The synopsis will state that the procurement is a mobilization base acquisition restricted to one source. Any alternate sources who submit offers will be required to complete a SAR package for future procurements.

I hereby certify that the information contained in this justification is accurate and complete to the best of my knowledge and belief. If not exceeding $700,000, this signature serves as the approval.

James E. Duffala/Contracting Officer Date

APPROVAL REQUIREMENTS

[ x ] Up to $700,000 Contracting Officer

[ X] $700,000 to $13,500,000 Competition Advocate

[ ] $13,500,000 to $93,000,000 Head of Contracting Activity (HCA)

[ ] over $93,000,000 Senior Procurement Executive (AQ)

DUFFALA.JAME

S.E.1230229100

Digitally signed by

DUFFALA.JAMES.E.1230229100

Date: 2019.05.06 14:43:00 -04'00'