SPRDL1-22-R-0110 Redacted.pdf
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- Redacted Justification & Approval (J&A) Federal contract opportunity
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- SPRDL1-22-R-0110
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This is a justification and approval document for a sole source procurement of hub assemblies for High Mobility Multipurpose Wheeled Vehicles (HMMWVs). The Defense Logistics Agency Land and Maritime is procuring the hub assemblies as spare parts for HMMWVs. The hub assembly was designed by original equipment manufacturer AM General for the HMMWV, and AM General retains the data rights. Attempts to purchase the technical data package from AM General or develop an alternative supplier through research and development or reverse engineering are estimated to cost over $4 million and take 3-4 years. Utilizing the sole source is expected to maximize small business opportunities as subcontracting will be required unless awarded to a small business. No other suppliers for this component were identified from market research.
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SPRDL122R0110 (JA-00528)
Previous J&A SPRDL1-18-R-0281 is available
5. Reason for Authority Cited: The Hub Assembly, Vehicular is part of the braking system for the HMMWV and is considered a critical component to the safety of the operators. This item was designed and developed by AM General for the HMMWV. To speed up the development and procurement process, the Government agreed to allow AM General to retain the data rights to the Hub Assembly, Vehicular. AM General LLC integrated this item into the HMMWV during development of the vehicle. AM General is the Original Equipment Manufacturer (OEM) of the HMMWV.
The Government does not have rights to the TDP or specifications. This item was developed by AM General, and the Government does not own the TDP.
There are no known funding efforts in progress at this time to acquire the commercially controlled data needed to make NSN 2530-01-413-3653 fully competitive.
Consequently, there are no current plans to acquire a fully competitive TDP because funds are not available to acquire the data necessary. Technically, there are three choices for the Government to pursue and obtain the data to this item. The three choices are: Research and Development of a new design; Reverse Engineering if the Government is unable to procure the item; and the final option is to ask AM General LLC for a price to purchase the technical data. This light tactical vehicle (LTV) office has tried to obtain a price to buy the TDP during a contract rebid in 2010. The Government asked for costing on the Armor, HVAC system and all Rev B components of the HMMWV. AMG’s response was “Not for Sale.” Again in 2014, on the M997A3 HMMWV Ambulance program, this office tried to obtain the full HMMWV TDP from AM General during contract negotiations which would have included HMMWV chassis and the Geared Hub but AM General was not willing to sell it to the Government. AM General has not changed its position on selling the TDP. This leaves the Government with two remaining options to acquire the data. They are as follows:
1. Research and Development (R&D): To develop a competitive data package through a R&D effort, procuring proprietary data, and qualifying additional sources will entail a significant amount of time, facility resources, man-hours, and funding. Based on experience with similar efforts, the estimated cost of R&D exceeds $5.0M with a setback of 42 months. Required funding would include $3.5M for personnel to support R&D of an item that would perform the same task as this NSN. That $3.5M would also include funding for staff to develop the Computer Aided Design (CAD) models and drawings that would be required for any potential vendor to manufacture from. An additional $1.5M-$2.0M would be required to develop prototypes to test and validate the Government design that functions identically to the original. If funding for a new-start R&D effort became available, the 42-month process would consist of the following:
Requirements development 12 Months Design and prototype development 6 Months Component, safety, and system level testing 12 Months Write TDP, technical bulletins and provision parts 12 Months
Estimated Time to research and develop 42 Months
2. Reverse Engineering (RE): To reverse engineer, validate the design, procure prototypes for testing, and release a competitive data package would entail a significant amount of time, facility resources, man-hours, and funding. Based on past development experience, the estimated cost to develop a reverse engineered competitive product is $4.0M, with an estimated delay of no less than 36 months. Required funding would include $3.0M for personnel to support reverse engineering, validation of the design, and staff to develop the CAD models and drawings. An additional $1.0M would be required to develop prototypes, test, and finalize the product to verify that the newly created item provides equivalent performance when compared against the original. If funding for reverse engineering became available, LTV Engineering estimates the following timeline for RE:
Obtain existing parts 3 Months Tear down and understand the design 3 Months Prototype development 6 Months Component, safety, and system level testing 12 Months Write TDP, technical bulletins and provision parts 12 Months
Estimated Time to Reverse Engineer 36 months
To complete the reverse engineering process successfully, the Government would have to obtain a sufficient sample size of existing parts to provide a 95% probability and 90% confidence level in the actual size of the existing item to be studied. Once a large enough sample has been collected, the Government would then tear down and understand the design, conduct prototype development, and produce the final TDP and associated provisioning documents at an estimated cost of $4.0M.
In addition to the cost and delay for an R&D action or RE effort, LTV Engineering estimates that it would take approximately one additional year to establish another source and procure these kits on a competitive basis. Specific events would include additional market research, solicitation, evaluation and awarding a contract. Finally, any new source of supply would require component, safety and system level testing that is estimated to take six months. These estimates are based on similar Government projects. These events combined are estimated to take an additional 18 months after development of the item.
The Government would not be able to recover, through subsequent competition, the additional costs involved in reverse engineering the item to create a new and competitive TDP within a reasonable amount of time. At the current average usage rate of 612 units each year, an estimated unit cost of , and assuming 15% cost savings achieved through competition, the in annual savings would take over years to offset the estimated $4.0M cost of reverse engineering the item and qualifying another source.
6. Efforts to Obtain Competition:
a. Effective competition: Due to the reasons cited in section 5 above, the Government is not pursuing competition for this item.
b. Subcontracting competition: Unless the contract is awarded to a small business, the solicitation and resulting contract will include FAR clauses 52.219-8, "Utilization of Small Business Concerns"; 52.244-5, "Competition in Subcontracting"; 52.219-16, "Liquidated Damages--Subcontracting Plan";" and Defense Federal Acquisition Regulation Supplement (DFARS) 252.219-7003, "Small Business Subcontracting Plan (DoD Contracts)," to maximize small business opportunities and utilization.
SOLE SOURCE: Notices required by FAR 5.201 will be posted.
7. Actions to Increase Competition: There are no plans to increase competition for future procurements due to the reasons cited above.
8. Market Research: A Sources Sought Notice was posted to SAM.gov on 17 June 2022 and was open for 15 days. No responses were received.
Additionally, the Contract Specialist performed web-based market research on 7 July 2022 and determined the Hub Assembly, Vehicular is a commercial item pursuant to FAR 2.101-Definitions. The hub assembly being procured by this action may have a limited application; however, hub assemblies in general have a wide variety of applications in the commercial marketplace. No sources were identified as being able to manufacture the NSN being procured.
Throughout the past year engineering has reviewed online catalogs and published product literature by manufacturers and distributors claiming to provide a suitable product for the HMMWV Hub Assembly, Vehicular. As suspected, the HMMWV suspension configuration is a relic of the past and no companies offer new product that would satisfy mission requirements for new production spare parts in this exact configuration. Furthermore, no vendors have approached this office to become a qualified source within the past year. There are no other known sources of supply for this component at this time.
Engineering has performed strategic market research and arrived at the conclusion that no other vendor can meet the Government’s requirement for this item without an entire replacement or modernization of the HMMWV powertrain, or without substantial requalification and testing to ensure the safety of the operators. Currently, the Army has no plans in place for the revitalization of the HMMWV and its capabilities since the program is in sustainment and is expected to remain in sustainment until the year 2048 when the HMMWV will be washed out of the fleet.
To date, no other sources have written to express an interest, nor has the Government identified any other source possessing an interest in being an alternate source for this NSN.
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