JA_PRON_EH8E0107EH_SPRDL1-18-R-0415_Redacted.pdf

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

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variable speed governor which, depending on system load, optimizes the engine operating speed.

The APU gross weight is under 330 pounds, and provides 8.5 kW at 28-vDC power output (with voltage ripple independte of the engine speed or load at less than 100mV RMS). The USG does not own the Technical Data Package (TDP) for 306-9000-M. MLS is the sole owner of their technical data. The Government does not own proprietary rights to the TDP that would be required to produce a competitive TDP. The above identified supplier has developed, tested and obtained Government approval for this item for application in the MLRS system at their own cost. The Government did not fund their efforts in developing and testing this item. Only MLS has the capability to manufacture the Auxiliary Power Unit, perform failure analysis, develop inspection and acceptance criteria for components, and repair/rebuild and test the Auxiliary Power Unit. Installing hardware that has not undergone similar verifications could lead to a failure of the Unit under battlefield conditions and could damage the vehicle, compromise the mission function.

Due to the limited performance and technical data available on the Auxiliary Power Unit, Reverse Engineering is the only recourse the Government could entertain to increase competition through development of a competitive TDP. A significant amount of time and money would be necessary to reverse engineer, procure and test prototypes, and release the design. Further, there is no funding to develop and qualify additional Auxiliary Power Unit manufacturers for this effort. Even if a reverse-engineering effort is successful, the Government would incur excessive costs and lead-time delay. The cost to reverse-engineer the critical components is estimated at $6.85M and 5.5 years to complete. Reverse Engineering the TDP includes, but is not limited to the following:

Estimated cost to reverse engineer the APU: $4,000,000 Estimated time to reverse engineer the APU: 2.5 years

Estimated cost to perform RAM vehicle testing (5000 miles) - 3 vehicles at $750,000 per vehicle: $ 2,250,000 Estimated time to perform RAM vehicle testing: 2 years

Estimated cost to develop a Technical Data Package: $ 600,000 Estimated time to develop a Technical Data Package: 1 year

The Government does not have the funds available nor would the Government be able to recover, through subsequent competition, the additional costs involved in either procuring the proprietary data or reverse engineering the item to create a competitive package. At the current usage rate of 1 units per year, at the current unit cost of assuming the saving achieved through competition, the savings would take over 516 years to offset the estimated $6.85M cost of reverse engineering the item and qualifying another source.

The consequential time delay of 5.5 years to reverse engineer, develop and test the new design and then qualify a new vendor would prohibit delivery of the APU in a time frame that would satisfy the Government's needs. Currently there are 15 backorders for a total quantity of 33, and an upcoming Improved Armor Cab program that will create an additional, time-sensitive

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demand. Further delay to procurement will negatively impact fleet readiness, and future program efforts.

6. Efforts to Obtain Competition:

(a) Competition: Based on the detailed rational provided in paragraph 5 above, the Government has no plans to obtain competition for this proposed contractual action.

(b) Subcontracting Competition: FAR clause 52.244-5, Competition in Subcontracting, will be included in the contract to assure that the prime contractor obtains as much competition as possible in its subcontracting.

7. Actions to Increase Competition:

As stated in section 5 above, there is no TDP available to support a competitive procurement.

Due to the costs associated with developing a competitive TDP that cannot be recovered also stated in section 5, the Government is not actively pursuing the development of a competitive TDP for future procurements.

Contractors interested in becoming a source of supply need to meet the requirements of the Source Approval Program including vehicle level qualification testing, at their own expense.

The TACOM Life Cycle Management Command, Competition Management Office (CMO), is the lead proponent for the Source Approval Program. While interested contractors can contact the CMO for assistance with the Source Approval Program, Engineering requires successful vehicle level qualification testing to support the approval of a new source of supply and the Government has no plans or funding to complete qualification testing at this time. To date, there has not been any expressed interest by any known vendor(s) to become qualified source(s) to produce this item.

8. Market Research: Market research was completed by TARDEC Engineering in the preparation of this document. There are other sources, such as Honeywell, Dewey, and HDT Global, likely capable of developing an Auxiliary Power Unit. Although these companies have no identifiable replacement for this MLS hardware, they do make similar items for the commercial market. Extensive analysis, prototyping, and vehicle testing as described in section 5 above would still need to be done to ensure that the MLRS will properly meet performance specifications with a new supplier’s hardware. The cost of such analysis, prototyping, and testing would far exceed any cost savings realized by adding another source.

9. Interested Sources: To date, no other sources have written to express an interest in qualifying as a source of supply. A Sources Sought Synopsis (Notice 2017-355) was posted to Fed Biz Opps on 03 August 2017 for the MLRS Auxiliary Power Unit, NSN : 6130-01-549-0407, Part Number 306-9000 and is valid of one year. Any responses received will be evaluated by the appropriate office.

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Date: 12 Apr 18 Signature: //s// ______

13. Fair and Reasonable Cost Determination:

I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable. This determination will be based on the results of a detailed cost and or price analysis. The contractor will be required to submit certified cost and pricing data as the expected value of this procurement falls within the threshold. This item is non-commercial..

Name: Eric E. Tucker Title: Contracting Officer Date: 4/26/2018 Signature: //EET//

14. Contracting Officer Certification:

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

Name: Eric E. Tucker Title: Contracting Officer Date: 4/26/2018 Signature: //EET//

14. Legal Concurrence:

Concur: // // Date: 05/21/2018

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

APPROVAL OF JUSTIFICATION

Based on the foregoing Justification, I hereby approve the procurement of the following:

a. NOUN: Power Supply Assembly

b. NSN: 6130-01-549-0407

c. QUANTITY: 47

d. ESTIMATED VALUE:

e. OPTION PERCENT: 100

f. QUANTITY WITH OPTION: 94

g. ESTIMATED VALUE WITH OPTION:

This action will be awarded under other than full and open competition pursuant to the authority of 10 USC 2304(c)(1) and subject to the availability of funds. This approval is subject to the proviso that the property herein described has otherwise been authorized for acquisition.

Signature:

Date: 24 May 2018

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