JA_for_PR_No__FD2020-15-00636_Signed.pdf

FD2020-15-00636

20 MAY 2015

COORDINATION AND APPROVAL DOCUMENT

(Also known as Justification Review Document)

Contracting Activity: DLA Aviation Ogden Purchase Request Number: FD2020-15-00636 Project/Program Name: C-130 BALL SCREW ASSEMBLY Estimated Contract Cost: $322,553.70 Type Program: Other Contracting Authority: 10 U.S.C. 2304(c)(1), as implemented by FAR 6.302-1 Type J&A: Individual

COORDINATION:

5/28/2015

X Kathleen Anderson Kathy Anderson, 430 SCMS/GUID, 801-777-5066 Program Manager / Requiring Official Signed by: ANDERSON.KATHLEEN.1266458831

X Michael J. O'Farrell, DLA Counsel-Aviation Associate Counsel, 801-586-5297

APPROVED:

X Rocky Tello, DOD DLA/AUB, 801-777-6501 Contracting Officer

JUSTIFICATION FOR OTHER THAN

FULL AND OPEN COMPETITION

I. CONTRACTING ACTIVITY:

Defense Logistics Agency DLA Aviation Ogden 6051 Gum Lane Bldg 1225 Hill AFB UT 84056-5826 Contracting Officer: Rocky Tello Phone Number: 801-777-6501 PR Number: FD2020-15-00636

II. NATURE AND/OR DESCRIPTION OF THE ACTION BEING PROCESSED:

A. Upon approval to use other than full and open competitive procedures, DLA will issue a new contract under “Other Contracting Procedures” to procure C-130 Ball Screw Assemblies, used by the FMS Countries Colombia, Saudi Arabia, India and Pakistan; to CEF Industries 320 S Church St., Addison, Il 60101, cage code: 00268 or Aero Precision, 201 Lindbergh Ave., Livermore, CA 94551 cage code: 0ZTJ5 or Beaver Aerospace & Defense Inc., 11850 Mayfield St., Livonia, MI 48150 cage code: 088K1.

B. Contract Type & Structure: A supply contract to procure a total quantity of 21 units with an anticipated Firm-Fixed-Pricing arrangement will be issued. The estimated award date is 15 Nov 2015 with performance and delivery expected through 28 Feb 2016.

C. Type J&A: Individual

III. DESCRIPTION OF THE SUPPLIES/SERVICES REQUIRED MEETING THE

AGENCY’S NEEDS:

A. This is a C-130 Ball Screw Assembly used on the Landing Gear on the C-130 Aircraft.

Extends and retracts the main landing gear.

NSN Name Qty Price/Unit Ext. Price 1620-01-263-6733 Ball Screw

Assembly 21 $15,359.70 $322,553.70

Total $322,553.70

B. Total estimated cost is: $322,553.70. This estimate is based on D200, D43A and procurement history. This action will use 47SH 4F FMS funds.

IV. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION:

10 USC 2304 (c) (1) as implemented by FAR 6.302-1 Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

V. DEMONSTRATION THAT THE CONTRACTOR’S UNIQUE QUALIFICATIONS

OR NATURE OF THE ACQUISITION REQUIRES THE USE OF AUTHORITY CITED

ABOVE (APPLICABILITY OF AUTHORITY):

A. The above authority was selected because the requirement is for manufacture of a highly specialized component whose design is currently limited to CEF’s Industries, or Beaver Aerospace and Defense Inc. Aero Prescision is CEF’s distributor. Per the 417 SCMS/GUEA Engineer, the C-130 Ball Screw Assemblies are considered highly specialized because the geometry, materials and processing requirements have been optimized as part of the landing gear system. If the wrong materials, processes, and geometry are used for the Ball Screw Assembly it could be either ineffective, unreliable, or both. That is why it needs to be qualified with the rest of the system. These parameters are limited to the Original Equipment Manufacturer (OEM), CEF, with the designs, data, and drawings created at CEF’s own expense, or the equivilant designs, data and drawings developed by Beaver at their own expense. Since the data required to manufacture the C-130 Ball Srew is limited to CEF and Beaver, interested vendors would have to be willing to invest the time, funding, and manpower required to reverse engineer the entire C-130 Ball Screw package at their own expense.The 417 SCMS/GUMC Program Manager believes that award to any other source will result in substantial duplication of cost to the Government that is not expected to be recovered through competition. Therefore, this acquisition is for continued production of highly specialized compnents. The country acquiring this asset is not interested in and will not fund reengineering efforts by a new vendor

B. The last attempt to obtain data, rights, drawing, etc. was 19 Nov 2014 by 417 SCMS/GUES

Egnineer. CEF replied on the same day and declined to provde or sell the government the above necessary data. Likewise, Beaver has declined to sell their proprietary data outright.

C. The 417 SCMS/GUES Engineer has determined that reverse engineering costs are estimated to exceed $4,239,209.44 for NSN 1620-01-263-6733, part number BA22750. Based on this cost it would take over 12.58 years to break even.

D. Accordingly, CEF, via its distributor Aero Precision, or Beaver Aerospace and Defense Inc.

are the only firms capable of providing the supplies described in Section III above, without the government experiencing substantial duplication of cost that could not be expected to be recovered through competition.

VI. DESCRIPTION OR EFFORTS MADE TO ENSURE THAT OFFERS ARE

SOLICITED FROM AS MANY POTENTIAL SOURCES AS DEEMED PRACTICABLE:

A. A combined Request For Information/Source Sought Synopsis (RFI/SSS) was posted to

FBO.gov on 1 December 2014 to provide industry an opportunity to inform the government of any interest in, or the capability to manufacture subject item. The RFI/SSS closed on 12 January 2015; however, no response from industry was received by the contracting office.

B. Other actions: None

C. Qualifying Country Sources: None

VII. DETERMINATION BY THE CONTRACTING OFFICER THAT THE

ANTICIPATED COST TO THE GOVERNMENT WILL BE FAIR AND REASONABLE:

The following steps will be taken to ensure that the anticipated cost of this acquisition will be fair and reasonable. The Contracting Officer will comply with the procedures and criteria contained in Federal Acquisition Regulation (FAR) under Part 30 - Cost Accounting Standards, Part 31 - Contract Cost Principles and Procedures, Subparts 15.4 - Contract Pricing; to include technical evaluations and audits, as appropriate. Additional steps to ensure price reasonableness will be under the guidance of the Contract Pricing Reference Guides, jointly developed by the Federal Acquisition Institute and the Air Force Institute of Technology. The Contracting Office will obtain certified cost and pricing data IAW FAR Subpart 15.403, when required. The final step is to include the Price Negotiation Memorandum (PNM). This detailed documentation and justification of price reasonableness will be disclosed in the official PNM, to be prepared upon completion of negotiations.

VIII. DESCRIPTION OF MARKET RESEARCH CONDUCTED AND THE RESULTS,

OR A STATEMENT OF THE REASONS MARKET RESEARCH WAS NOT

CONDUCTED:

A. As described in Section VI above, Market Research, in accordance with FAR Part 10, was conducted by synopsis of the proposed acquisition, advising industry of the pending acquisition and soliciting inquiries from interested parties. There were no other interested sources.

B. Additionally the 417 SCMS/GUMC Integrated Product Team conducted market reseach that yielded the following:

1. On 10 Dec 2014 a search conducted on the Thomas Net.com from the Thomas Registry with NSN 1620-01-263-6733 part number BA22750 and part number 8430M4 resulted in zero results in the product, company name, brand name, Computer Aided Design (CAD) drawings and industrial web directories.

C. On 10 Dec 2014, a review of commercial catalogs and other product literature was completed. The review indicated no other alternate commercial item or nondevelopmental item (NDI) will meet the requirement, nor can the requirement be modified to permit use of existing commercial items or NDIs.

IX. ANY OTHER FACTS SUPPORTING THE USE OF OTHER THAN FULL AND

OPEN COMPETITION:

None

X. LIST OF SOURCES, IF ANY, THAT EXPRESSED INTEREST IN THE

ACQUISITION:

See Section VI above

XI. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO

REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE MAKING

SUBSEQUENT ACQUISITIONS FOR THE SUPPLIES OR SERVICES REQUIRED:

None

XII. CONTRACTING OFFICER’S CERTIFICATION:

The Contracting Officer’s signature on the Coordination and Approval Document evidences that he/she has determined this document to be both accurate and complete to the best of his/her knowledge and belief (FAR 6.303-2(a)(12)).

XIII. TECHNICAL/REQUIREMENTS PERSONNEL’S CERTIFICATION:

As evidenced by their signatures on the Coordination and Approval Document, the technical and/or requirements personnel have certified that any supporting data contained herein, which is their responsibility, is both accurate and complete (FAR 6.303-2(b)).