JA_SPRDL1-19-R-0009_Redacted.pdf

J&A SPRDL1-19-R-0009

No previous J&A SPRDL1-17-P-0212 (simplified).

Previous J&A W56HZV-08-C-0398 is available.

Defense Logistics Agency Justification and Approval for Other Than Full and

Open Competition

1. Contracting Activity: The Contracting Activity for this action is the Defense Logistics Agency- Warren (DLA-WRN)

2. Description of Action: The proposed action is to award a contract, on a limited source basis, to Data Device Corporation (Cage Code 19645) for the manufacturing of new “CIRCUIT CARD ASSY, POWER CONTROL MODULE, 15 AMP” (per TACOM source control drawing 12473754), commonly referred to as the CCA Power Control Module. The type of funds to be used are Army Working Capital Fund (AWCF).

3. Description of Supplies/Services: Data Device Corporation (Cage Code 19645) shall provide the Circuit Card Assembly for the M1 Abrams tank application per part number listed in Table 1. The unit value is $ each. The Minimum Guaranteed Quantity and Dollar Value is 93 EA, $ and the Maximum 5-year quantity and Dollar Value for the contract period is 943 EA, $ .

This component interfaces with the Analog Input Module, Hull Power Distribution Unit, Hull Remote Switching Module, and Turret Remote Switching Module of the M1 Abrams tank to provide controlled load switching, load protection, load status power functions, vehicle switch/cable disconnect monitoring, and harness/physical address encoding data functions.

Table 1 – part numbers

NSN NOMENCLATURE P/N

5998-01-549-1284 CIRCUIT CARD ASSY,

POWER CONTROL

MODULE, 15 AMP

Military: 12473754 (19207)

MPN: RP-3T015M0-600 (19645)

SRPC15D28-501 (13409)

Acquisition Method Code (AMC): 3 Acquire, for the second or subsequent time, directly from the actual manufacturer.

Acquisition Method Suffix Code (AMSC): B This part must be acquired from a manufacturing source(s) specified on a source control or selected item drawing as defined by the current version of DoD- STD-100. Suitable technical data, Government data rights, or manufacturing knowledge are not available to permit acquisition from other sources, nor qualification testing of another part, nor use of a second source part in the intended application. Although, by DoD-STD-100 definition, altered and selected items shall have an adequate technical data package, data review discloses that required data or data rights are not in Government possession and cannot be economically obtained.

4. Authority Cited: The statutory authority permitting other than full and open competition is Title 10 United States Code (U.S.C.) Section 2304(c)(1), as implemented by FAR 6.302-1(a)(2)(ii)(A), “Only one responsible source and no other supplies or services will satisfy agency requirements.”

5. Reason for Authority Cited: This CCA Power Control Module is a critical item of the electrical power system in the M1 Abrams tanks. This item shall meet the requirements of Specification

SC-SA15155 and be fabricated in accordance with Source Control Drawing 12473754. Only the CCA Power Control Module described on this drawing, when produced by the Manufacturer identified on this drawing, is approved for use in the M1 Abrams by the United States Army TACOM Life Cycle Management Command (TACOM LCMC). A substitute item shall not be used without prior approval by TACOM. It is imperative for the procuring activity to ensure, at the time of award of contract, this product demonstrates compliance to design requirements, qualification requirements, qualification tests (including testing for compliance with the Electromagnetic Interference (EMI) requirements using the methods described in MIL-STD-462), and conditions required in verifying that this item meets its required performances, as specified on Source Control Drawing 12473754 and Specification SC- SA15155. This is a survivability item that is critical for the soldiers’ safety.

Data Device Corporation has developed, tested, and obtained Government approval for this item for application in the M1 Abrams tank at their own cost. Only Data Device Corporation has the capability to manufacture this CCA Power Control Module, perform failure analysis, develop inspection and acceptance criteria for components, and repair/rebuild and test the item. Installing hardware that has not undergone similar verifications could lead to a failure of the tank’s electrical power system. Under battlefield conditions, such a failure can render the tank unable to proceed with its mission function and will endanger the life of the crew.

Currently, the CCA Power Control Module is sole sourced to Data Device Corporation. This manufacturer is the only approved source to make this CCA Power Control Module for the USG. It is the sole owner of the technical data package (TDP). The USG does not own the technical data of the CCA Power Control Module, nor does the USG have proprietary rights to the technical data, which is necessary to develop a competitive TDP. Due to the limited availability of performance and technical data on this item, reverse engineering is the only option for the USG to develop a competitive TDP, needed to increase competition. Reverse engineering is a multi-layered process. It requires the procurement and testing of prototypes and the release of the design. These efforts involve a significant amount of time and money; the USG does not have the funding required to develop and qualify additional sources for this product. Even if a reverse-engineering effort was affordable, this process would incur excessive lead-time delay. Prototypes, provided by a new manufacturer, need to be tested in conjunction with the overall electrical system of the M1 Abrams tank. The cost to reverse-engineer this unique component is estimated at $701K and 53 months to complete. Reverse engineering the TDP includes, but is not limited to the following:

Reverse Engineering Activity Delay Costs Obtain existing part samples 4 months $1.7K Hardware design, integration and fabrication/install 20 months $250K Component and vehicle system testing 20 months $250K Documentation (drawings/ECP/Tech Manuals) 9 months $200K Total Estimated Time to Reverse Engineer 53 months $701K

The Government would not 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 84 units per year, at the current unit cost of $ ea, and assuming the 25% saving achieved through competition, the annual savings would take 39 years to offset the estimated $701K cost of reverse engineering the item and qualifying another source.

6. Efforts to Obtain Competition: Effective Competition: Per section 7, potential vendors can submit requests to become a source through the Source of Approval Process at any time. Per section 9, a Sources Sought Notice was posted. Based on the detailed rational provided in paragraph 5 above, the Government has no plans to obtain additional competition for this proposed contractual action.

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 complete TDP available to support a competitive procurement. The Government does not own the TDP necessary to procure this item as full and open competition. This item is source controlled to Data Device Corporation. This manufacturer owns the respective technical data and is the only approved source of supply for this item. 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. The Government would not be able to recover the cost to reverse engineer the CCA Power Control Module within a justifiable time frame.

The CCA Power Control Module appears on the Competition Advocate Shopping List (CASL) dated 16 January 2018. The CASL contains TACOM-Warren’s projected buy list of sole source items for the next three years. This list is updated twice a year and advertised in the FedBizOpps; it is available to interested contractors on the TACOM-Warren Business Opportunities website under the Future and Potential Buys link. Contractors interested in becoming a source for this item need to meet the requirements of the Source Approval Program. This is done at the contractor’s expense, to include vehicle level qualification testing. The TACOM Life Cycle Management Command, Competition Management Office (CMO), is the lead proponent for the Source Approval Program. Specific information and point of contact for the Source Approval Program is available at https://www.tacom.army.mil/cmo/sap.html. 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, no other sources have approached this office with questions or comments on how to become a qualified source to produce this item.

8. Market Research: Market research was performed by TARDEC Engineering July 2018, by reviewing vendor catalogs and available product literature published online, to determine if commercial items or non-developmental items are available to meet Government's needs, or could be modified to meet the Government's needs. While many types of CCA Power Control Modules are produced by several manufacturers, those are not tailored (form, fit, and function) to be specifically used in the M1 Abrams tanks. In addition, the subassembly of this CCA Power Control Module is of modular design such that another component of the same modular design with the same functional, physical, and performance characteristics can be interchangeable without alteration of the component itself (or of the adjoining components) and without subsequent alignment or calibration. To date, no other CCA Power Control Module manufacturer was found to have completed the necessary testing to become a qualified source as described in section 5. TARDEC Engineering contacted Data Device Corporation representative, , and verified that this Vendor plans to continue to manufacture the Power Control Module CCA for future U.S. ARMY use. Data Device Corporation is a world leader in the design and manufacture of high-reliability solid-state power controller products for aerospace and defense vehicles.

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 the following:

a. Noun: CIRCUIT CARD ASSY, POWER CONTROL MODULE, 15 AMP

b. NSN: 5998-01-549-1284

c. Minimum Quantity: 93 ea

d. Minimum Estimated Value: $

e. Maximum Quantity: 943 ea

f. Maximum Estimated Value: $

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 provision that the property herein described has otherwise been authorized for acquisition.

Signature:

Date: 10/29/2018

SHEARER.MAR

Y.E.1250702449

Digitally signed by

SHEARER.MARY.E.1250702449

Date: 2018.10.29 11:22:46 -04'00'