JA00989_SPRDL125R0066_Redacted.pdf

SPRDL1-25-R-0066 (JA-00989)

Previous J&A: Not Applicable

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

SPRDL1-25-R-0066

1. Contracting Agency: Defense Logistics Agency – Land, Warren (DLA-WRN).

2. Description of Action: DLA-WRN proposes to award a New Firm-Fixed-Price contract to an offeror providing the product of Parker-Hannifin Corporation (Parker Hannifin), Commercial and Government Entity (CAGE) 9F512, the approved source for National Stock Number (NSN) 2540-01-692-2291, Purchase Request Order Number EH5C0086EH, Door Damper Assembly, using Army Working Capital Funds.

3. Description of Supplies/Services: The NSN 2540-01-692-2291, part number 648683 / 12628189, Door Damper Assembly, is used on the Multiple Launch Rocket System (MLRS) M993A2 in the door operating system to assist in opening or closing the doors. The deliverable for this basic and option contract is for a base quantity of 44 each, with an option quantity of 44 each, making a total quantity of 88 each. The total maximum value of this contract is $ .

Acquisition Method Code (AMC):

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

Acquisition Method Suffix Code (AMSC):

B - Acquisition of this part is restricted to source(s) specified on "Source Control", "Altered Item" or "Selected Item" drawings/documents.

4. Authority Cited: The statutory authority permitting other than full and open competition for this effort is 10 United States Code (U.S.C.) 3204(a)(1) as implemented by the Federal Acquisition Regulation (FAR) 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

5. Reason for Authority Cited: The M993A2 has an Improved Armored Cab (IAC) which has extremely heavy, armored personnel doors. The damper assembly is and allows the soldier to pump the handle to move a piston that assists in opening the door, especially if the door is opened when the vehicle is not stopped on level ground.

Parker Hannifin has demonstrated that their system meets the Army requirements to include integration and interoperability with the vehicle through component and system level testing. As detailed in the following paragraphs, Parker Hannifin is the only contractor that can provide the Door Damper Assembly. Procurement from any other source will result in substantial duplication of cost that is not expected to be recovered through competition within a reasonable amount of time.

The Government does not own the necessary intellectual property data rights to the pertinent technical data to enable competitive re-procurement.

Parker Hannifin developed, tested, and obtained the Government's approval of this item for application in the MLRS Family of Vehicles. Parker Hannifin has demonstrated the unique and proven manufacturing capabilities to establish and maintain the processing control required to repetitively produce this item. The use of incorrect material and/or fabrication of this item could result in further downtime of vehicle and impede vehicle safety for the soldiers. The Government did not fund Parker Hannifin’s efforts in developing and testing this item. The Government did not appropriate funds for a complete Technical Data Package (TDP) preparation. The Government does not have drawings and specifications for various down parts, such as the test requirement document of the Door Damper Assembly. The Government is missing the document necessary to test and verify the design functionality of the Door Damper Assembly. As a result, Parker Hannifin is the only approved source of supply listed on the drawing.

Due to the lack of performance and technical data available on the Door Damper Assembly, 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. The nature of this vehicle cabin component requires significant qualification testing and system level testing. Engineering conducted parts procurement history and utilized a Subject Matter Expert (SME) to determine the reverse engineering costs by reviewing the costs for the design effort for the current Door Damper Assembly. The SME estimate is based on previous experience evaluating the initial development costs of this item and other comparable vehicle cabin component systems. Developing the hardware design and requirements is estimated to be $1,000,000. The cost of labor for integrating and fabricating the hardware on two vehicles for bench testing is $250,000. Developing and validating the TDP will cost $400,000.

Reverse Engineering Activity Costs Requirements Development & Hardware Design $1,000,000 Integration & Fabrication/Installation $ 250,000 Develop & Validate TDP $ 400,000 Total Time & Cost for Reverse Engineering $1,650,000

The Government would not be able to recover, within a reasonable amount of time through subsequent competition, the duplication of costs involved in either procuring the proprietary data or reverse engineering the item to create a competitive package. At the current average usage rate of , a current unit cost of $ , and assuming 25% savings achieved through competition, the $ in annual savings would take over years to offset the estimated $1,650,000 total cost of reverse engineering the item and validating a competitive TDP or qualifying another source.

Calculation: Cost to Reverse Engineer: $1,650,000/ (Average U/P $ x Door Damper Assembly yearly demand = $ ) x 25% assumed savings = $ ) = years.

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. Notices required by FAR

5.201 will be posted.

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.

7. Actions to Increase Competition:

There are no contractors currently in the process of being qualified as an alternate source of supply for this item. 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 18 December 2024, was open for 16 days and closed 3 January 2025. One response was received from an interested vendor.

BHPE LLC (CAGE 9SWS7), a small disadvantaged and service-disabled veteran-owned small business concern, expressed interest. BHPE LLC was informed of the requirements to become an approved source.

The Small Business Administration dynamic search was utilized searching for the North American Industry Classification System code 336992 and keyword “damper”. A total of two small businesses were identified under this particular search that could potentially provide this item. These businesses would have to undergo the source approval process.

In accordance with FAR 10.002(b)(2)(vii), market research was conducted by the U.S.