SPRDL119R0047_Redacted.pdf

J&A SPRDL1-19-R-0047

Justification and Approval (J&A) for Other Than Full and Open Competition

1. Contracting Activity: The contracting activity responsible for this action is DLA Land Warren.

2. Description of Action: The proposed action is to award a new contract for the procurement of circuit card assemblies. Although the Government owns the drawings, the top drawing is source controlled with only one approved source. The approved source is Kearfott Corporation, CAGE Code 88818. The type of funds to be used is C-AWCF. The contract type will be a firm fixed price contract.

3. Description of Supplies/Services:

Noun: Power Amplifier Circuit Card Assembly (CCA)

NSN: 5998-01-456-0999

Part Number: 12437140:19200 (Manufacturer’s Part Number: A538C662-01, CAGE Code 88818, Kearfott Corporation)

Quantity: 18 EA

Option Quantity: 18 EA

Unit Price: (estimated)

Estimated Total Value: Base ETV: $147,852.36. Base with Option ETV:

Vehicle System: M1A2 Abrams Tank System EnhancementPackage Versions 1 & 2

Acquisition Method Code (AMC): 3

Acquisition Method Suffix Code: (AMSC): B

PRON Number: EH8E1042EH

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) and (B), “Only one responsible source and no other supplies or services will satisfy agency requirements”.

5. Reason for Authority Cited:

The customized military-grade Power Amplifier CCA (Part Number: 12437140) is a vital part of the Improved Fire Control Electrical Unit (IFCEU) (Part Number: 12549922-3) which is used on the M1A2 Abrams Tank System Enhancement Package Version 1 & 2.

The government has limited rights in accordance with DFARS 252.227-7013 and 7017; the Technical Data Package (TDP) acquisition production specification data is not fully defined because the drawings do not give enough information to actually design the item. Thus, the drawings are inadequate for production without access to Kearfott Navigation & Guidance Corporation’s (CAGE Code: 88818) design and procedures.

The customized military grade Power Amplifier CCA was developed and tested at Kearfott Navigation & Guidance Corporation expense. Thus, Kearfott Navigation & Guidance Corporation owns the rights to the design.

No contractor other than Kearfott Navigation & Guidance Corporation has been approved to manufacture and sell the Power Amplifier CCA to the government.

Based on the above information, sole source procurement to Kearfott Navigation & Guidance Corporation is the only method of procurement currently available to ensure supportability of fielded vehicles.

6. Efforts to Obtain Competition:

No vendors are in the process of being qualified at this time, nor will be prior to the contract award.

At this time, there are no current or planned efforts to qualify additional sources due to the fact that there is no technical data available to produce a competitive TDP.

Any new vendor who decides to pursue the qualification process will be directed to the Competition Advocate’s Source Approval Program.

The Competition Mangement Office will encourage interested parties to submit a Source Approval 1Request for this time for future buys.

No contractors have expressed interest in becoming a qualified source to produce this Power Amplifier CCA.

7. Actions to Increase Competition:

There are no current plans to acquire a competitive TDP because funds are not available to acquire the data necessary to support a competitive acquisition. In addition to not having the information necessary to develop a competitive TDP, ARDEC-RI engineer estimates that the cost and to develop a competitive package for this item through reverse engineering, qualification procedures and engineering analysis is $1,200,000.00 and 36 months as listed below:

Estimated costs associated with reverse engineering: $450,000

Estimated time associated with reverse engineering: 12 months

Estimated costs associated with the development of qualification procedures: $300,000

Estimated time associated with the development of qualification procedures: 12 months

Estimated costs associated with the conducting engineering analysis: $450,000

Estimated time associated with the conducting engineering analysis: 12 months

The aggregate cost of reverse engineering, writing the qualification procedures and conducting an engineering analysis would be at least one million two hundred thousand dollars ($1,200,000), which would not be recovered through subsequent competition.

The aggregate delay in the acquisition process for reverse engineering Power Amplifier CCA (Part Number 12437140), the preparation of qualification procedures and the engineering analysis to determine if a new source met the qualification procedures is at least thirty-six (36) months. A delay of this scale is unacceptable in fulfilling the Army’s requirements and would have significant detrimental impact on the Army’s ability to support the soldier in the field and on Army readiness. The delay would deadline the M1A2 Abrams Tank System Enhancement Package Version 1 & 2; deadlining this system degrades the tank crew’s ability to fight and jeopardizes crew safety.

Note: This will not be a government funded reverse engineering effort because Kearfott Navigation & Guidance Corporation has more than enough customized military grade Power Amplifier CCAs (Part Number 12437140) available. Thus, if any contractor decides to take on an effort to reverse engineer and/or procure proprietary data, the new contractor will be solely responsible for taking on all of the cost listed in the above paragraphs with little to no assistance from the government.

8. Market Research:

On August 2, 2018, Lance Brock (ARDEC-Rock Island CMO/Engineer) conducted a search on the World Wide Web for the customized military grade Power Amplifier CCA. The results of this search did not yield new production sources for this item. There are no commercial equivalents or non-developmental items available to meet the Government's requirements or that will satisfy the Government need without qualification testing.

9. Interested Sources:

This procurement action was synopsized on the Federal Business Opportunities website on August 1, 2018, as required by FAR 5.201(c), to improve access to acquisition information and to enhance competition by identifying subcontracting opportunities. To date, no responses have been received.

10. Other Facts: Discuss any other facts supporting the use of other than full and open competition, such as the following:

a. Procurement History: Past procurements have been awarded to General Dynamics Land Systems. The most recent contract was DAAE20-02-G-0009 for 21 each at $8,049.43 awarded on 29 Nov 16.

b. Acquisition Data Availability: This item has a source controlled top drawing with only one approved source. The approved source is Kearfott Corporation, CAGE code 88818. Due to the age of the most recent acquisition of this part, the contract specialist/contracting offier was unable to find any previous J&As in the Paperless Ccontract File or Procurement Integrated Enterprise Environment systems.

c. Subcontracting Competition: The Government will insert the appropriate clauses/provisions relating to subcontracting competition into the solicitation.

11. Technical Certification:

I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Typed Name:

Title: APO, Abrams Matrix Support ARDEC-RI Signature:

Date: 28 August 2018

12. Requirements Certification:

I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Typed Name:

Date: 10/1/2018 Title: Inventory Management Specialist Signature: //

Typed Name:

Date: 01-Oct-2018 Title: M1A2 Team Leader Signature:

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. Cost and price analysis techniques will be used to determine if the offered price is fair and reasonable. Other techniques will be used if needed. Due to the anticipated value of this procurement ( ), the Government does not anticipate that certified cost or pricing data will be required. Other that certified cost or pricing data will be requested if needed for use in determining if the offered price is fair and reasonable.

Typed Name: Laura L. Monteith Date: 22 Jan 19 Title: Contracting Officer Signature: //Laura L. Monteith//

14. Contracting Officer Certification:

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

Typed Name: Laura L. Monteith Date: 22 Jan 19 Title: Contracting Officer Signature: //Laura L. Monteith//

15. Legal Concurrence:

Typed Name:

Date: JAN 28, 2019 Title: Legal Advisor Signature: