JA_SPRDL1-17-R-0002_redacted.pdf

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SPRDL1-17-R-0002

2. Reasons the item is not suitable for full and open competition:

a. Status of the Technical Data Package (TDP):

(1) The purpose of the Fuel Thermal Oxidation Tester (FTOT) is to determine the thermal stability of jet fuels. The Falex 400 by Compass Instruments meets all requirements of ASTM D3241; Standard Test Method for Termal Oxidation Stability of Aviation Turbine Fuels. No technical data that would define the production specifications is available because the Falex 400 was developed and tested at private expense and such data is therefore considered proprietary to the supplier. Compass Instruments developed, tested, and obtained ASTM approval of this item at its own cost.

The Government did not fund Compass Instruments’ efforts in developing or testing this item. Additionally, the Government did not fund it to prepare a fully detailed TDP after approval. Compass Instruments is the sole source owner of the drawing package and technical data rights. The lack of such data requires the Falex 400 to be procured on a non-competitive basis from the current manufacturer for all replenishment acquisitions

(2) The Acquisition Method Code (AMC) for this item is 3. The Acquisition Method Suffix Code (AMSC) for this item is H

AMC 3. Acquire, for the second or subsequent time, directly from the actual manufacturer.

AMSC H. The Government physically does not have in its possession sufficient, accurate, or legible data to purchase this part from other than the current source(s). This code is applicable only to parts under immediate buy requirements and only for as long thereafter as the deficiency is under review for resolution and appropriate recoding. This code is only assigned at the conclusion of limited screening, and it remains assigned until the full screening process resolves physical data questions and results in assignment of a different AMSC. If one source is available, AMCs 3, 4, or 5 are valid. If at least two sources exist, AMCs 1 or 2 are valid.

b. Efforts to Increase Competition or Qualify a New Source in Relation to this

Procurement:

(1) This procurement is for a quantity of 5 each of Falex 400 Fuel Thermal Oxidation Tester, in support of the Petroleum Quality Analysis System – Enhanced (PQAS-E). The PQAS-E is a mobile lab that is intended to test fuels in theatre to a modified level B standard. The instruments in the lab perform tests according to ASTM International and ISO standards to determine fuel quality. The Falex 400 will be procured pursuant to this J&A. The Petroleum Quality Analysis System Enhanced (PQAS-E) increases testing capabilities to ensure the quality of fuel that is received, stored, and issued from any of the following: commercial, military, and captured enemy stocks throughout the theater of operation.

Procurement by other than full and open competition is necessary because Compass Instrument’s Falex 400 was chosen through research for the PQAS-E and are needed to ensure standardization of equipment, test procedures, training, spare parts, and manuals with the PQAS-E. These Compass Instruments items are the only approved items for these systems. Due to the specific dimensions of the interior of the PQAS-E, the only suitable fuel thermal oxidation tester available is the Falex 400 model. Also, the mounting brackets and trays have been specifically designed for the Falex 400, and will not work with any other models. Furthermore, counter space is also conserved due to the small size of the instrument which allows for two identical instruments to be mounted on the counter top. If a new instrument were used, these benefits would be lost. Lastly, the Technical Manual has been written specifically for this instrument. If a new instrument were to be used, it would be very costly and time consuming to update the TM to reflect the new operating procedures.

(2) Limitations to developing a Competitive Package (R&D Effort) or Procuring Proprietary Data or Qualifying Additional Sources: Cost / Delay

Cost: The PQAS-E is a low density system. Currently there are only 68 fielded PQAS- E systems. If alternatives to Falex 400 Fuel Thermal Oxidation Tester were used in the PQAS-E, the Government would lose the benefit of the commonality of equipment with the mobile labs. This would lead to additional costs not only for the testing and qualifying of different equipment, but also the cost to train soldiers in the use of different equipment. A new instrument would require time for testing and qualification, and additional training for soldiers as well. Additionally, it would be costly for the Technical Manuals to be rewritten and validated/verified for a new model.

Delay: Testing and training would be unacceptable because it would further delay soldiers from having accessibility to the PQAS-E in the field These instruments meet the necessary form, fit, and function, and without standardization our soldiers are placed under an unnecessary risk that could cause inaccurate results and safety hazards. This procurement will not be subject to those costs or delays in the program schedule.

(3) Limitations to reverse engineering: Cost / Delay

At this time, there is no level III TDP for the fuel thermal oxidation tester. There are no plans or funds to complete this work.

c. Demonstration of Approved Contractor's Unique Qualifications:

(1) Compass Instruments Falex 400’s were recently procured in 2014. There is a fully provisioned PQAS-E Army Technical Manual in place for sustainment.

(2) There are no known issues with the Compass Instruments Falex 400’s that are within the previously assembled PQAS-E mobile labs.

d. Efforts to Qualify Additional Suppliers for future procurements:

At this time, there is no level III TDP for the Falex 400. There are no plans or funds to complete this work.

Name: Leah Bourdeau Title: Contracting Officer Date: 9/21/16 Signature: //s// LCB

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

Name: Leah Bourdeau Title: Contracting Officer Date: 9/21/16 Signature: //s// LCB

PART V - Legal Concurrence

Concur:

Date: 9/23/2016

PART VI - Approval Authority for Acquisitions Equal to or Greater Than $700,000.

APPROVAL OF JUSTIFICATION

FOR OTHER THAN FULL AND OPEN COMPETITION

Based on the foregoing Justification, I hereby approve the procurement of NSN 6630- 01-564-5517 from Compass Instruments, Inc, with a total estimated value of

. This action will be awarded on an other than full and open competition basis, pursuant to the authority of 10 U.S.C. 2304(c) (1), and FAR 6.302-1(a)(2)(ii)(A) and (B), subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Name:

Title: Competition Advocate Date: 3 Oct 2016

Signature: