SPRWA1-24-00419_Redacted.pdf

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

CONTROLLED UNCLASSIFIED INFORMATION

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I. Agency and Contracting Activity.

This Justification and Approval is to request authority for Other Than Full and Open Competition supporting requirements generated for the Receiver Transmitter (RT) that is installed in the Combined Altitude Radar Altimeter (CARA), AN/APN-232. This requirement is a Foreign Military Sales (FMS) procurement for 11 each supporting requisition numbers DCIF5433105600, DTWM2550137500, and DPLZ5443465504. The contracting activity for this requirement is SPRWA1 DLA/AWB. The purchase request number supporting this contracting action is FD2060-24-00419.

II. Nature and/or description of the action being approved.

Due to the circumstances described herein, the activity requests authority to acquire the supplies listed in the document using Other Than Full and Open Competition as prescribed by FAR 6.302-1. Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. This action will result in the award of a Firm-Fixed Price contract. The period of performance for manufacture production on this contract will be one year.

This sole source requirement will be purchased from the following company:

Symetrics Industries, LLC dba Extant Aerospace 1615 W NASA Blvd Melbourne, FL 32901 CAGE Code: 22830

III. Description of supplies/services required to meet agency needs.

This acquisition is for the procurement of the AN/APN-232 CARA (Combined Altitude Radar Altimeter) assemblies. These AN/APN-232 CARA assemblies are utilized in conjunction with the AN/APN-232 Electronic Altimeter Radar Set. This requirement provides the material for the National Stock Number (NSN) listed below:

Buy requirements for NSN: 5841-01-349-9175 P/N 8010000788-1 are as follows:

CLIN Noun NSN P/N Est Unit Cost Total

0001 RT 5841-01-349-9175 8010000788-1 $ 11 EA

Total: $

This Line Replaceable Unit (LRU), CARA Receiver Transmitter (RT), is installed in the F-16 platform.

The CARA RT consists of nine (9) circuit card assemblies, two (2) regulated power suppliers, switch filter assembly, mother board, and RFA. Typical system installation consists of a CARA RT and two antennas (transmitting and receiving), one or more Height Indicators.

The estimated acquisition cost of $ is based on quote from Symetrics Industries, LLC dba

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Extant Aerospace (Extant). Payment for this procurement if funded using the country's funds. The NSNs have been screened and assigned the following Acquisition Method Code (AMC)/Acquisition Method Suffix Code (AMSC) (AFMC Form 761).

AMC/AMSC Codes of 5/P applies to the RT NSN: 5841-01-349-9175

AMC: 5, Acquired directly from a sole source contractor which is not the actual manufacturer

AMSC: P, The rights to use the data needed to purchase this item from additional sources are not owned by the Government and cannot be purchased.

NAVCom (CAGE: 57057) sold CARA technical data rights to Symetrics Industries, LLC dba Extant Aerospace (Extant) in Oct 2018. The 407th Engineer approved Extant (CAGE: 22830) as a procurement source in February 2021. Past contracts with NavCom (CAGE: 57057) are identified on the AFMC Form 761 for the RT.

IV. Demonstration that the contractor's unique qualifications or the nature of the acquisition requires use of the authority cited above.

The agency's minimum needs can only be satisfied by the unique supplies or services available from Extant. The CARA system technical data rights were purchased by Extant from NavCom Defense Electronics, Inc., the Original Equipment Manufacturer (OEM), in Oct 2018.

The last buy contract was sole source to NavCom under contract SPRWA112D0004. Period of performance was from 01 Nov 2012 to 30 Oct 2013. NavCom completed the entirety of this contract.

The Government does not possess the complete technical data package or Government purpose data rights to pursue a full and open competition manufacture strategy for this LRU. The Government owns Technical Order (TO) 12P5-2APN232-13, which is used to test and maintain a number of CARA RT SRUs. The complete Technical Data Package (TDP) for manufacture of the RT is now owned by Extant. A complete engineering data package is not available for competitive solicitation due to proprietary rights claims by the manufacturer. This data is proprietary and the contractor refuses to release the rights or sell the data. No further breakout effort will be made at this time.

Since NavCom sold the CARA system to Extant, the Government reached out to Extant on 5 February 2025 to request a quote to purchase the technical data rights for the RT. On 11 February 2025 the contractor declined to provide a quote and stated they were not willing to sell the data.

The RT requires highly specialized technical skills, use of Extant proprietary data, and specialized equipment and facilities to manufacture these items. Due to limited availability of packaged Mil-Spec solid state microwave components in the restricted 4.2 to 4.4 GHz radar altimeter band, a unique and highly specialized RF module was developed by NavCom during the 1980's. The manufacture efforts require the use of proprietary processes, procedures, and critical RF tuning to match impedance.

The CARA system is military unique and must meet form, fit, function, and interface (F3I) requirements, military standards, and pass applicable inspection and acceptance processes according to Extant's engineering drawing design. Extant possesses the unique skill, equipment, facilities, and production data

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Reverse engineering to obtain data to support a competitive award was considered. However, this buy requirement is for a FMS country that is unwilling to wait the minimum 2 years that reverse engineering would require in order to potentially obtain manufacture data to support a competitive acquisition.

Therefore, reverse engineering is not practical or feasible for this requirement.

Accordingly, Extant is the only firm capable of providing the requirements described in Section III above without the United States Air Force (USAF) experiencing an unacceptable delay in fulfilling its requirements.

V. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under

FAR 5.202 applies.

A Sources Sought Synopsis (SSS) was posted to Sam.gov on 19 March 2024 with a response date of 2 April 2024 under Notice ID SPRWA1-00419. The SSS requested responses from interested vendors that possess the expertise, capabilities, and experience to meet qualification requirements for this effort.

Integrated Procurement Technologies, on behalf of Extant, was the only source that expressed an interest and submitted a response.

Extant is the only source identified through the market research that possesses the technical data, facilities, test equipment, and expertise required to manufacture and repair the CARA RT. The Government does not possess a technical data package to support a competitive award, nor does the Government have the capability to independently validate the operational capability range of end repair or production items. The incumbent, Extant was determined to be the only capable vendor.

A pre-solicitation notice of the requirement will be synopsized on the Sam.gov in accordance with FAR 5.201(b), citing conditions which preclude Full & Open Competition. Sources expressing an interest as a result of the synopsis will be investigated for their capabilities to perform on this and/or future requirements. Any source(s) that expressed interest as a result of this synopsis will be identified to the prime contractor as a potential for subcontracting possibilities.

VI. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

Based upon (1) certified cost or pricing data provided in the offeror's proposal in accordance with FAR 15.403-4; (2) the program office or expert technical personnel analysis of the offeror's Basis of Estimates;

(3) inputs from the Defense Contract Management Agency, the contracting officer expects to determine the anticipated cost to the Government to be fair and reasonable.

VII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

Market research was conducted 3 April 2024 through 27 March 2025 in accordance with FAR Part 10.001 and 10.002. The market research report was completed on 20 May 2025. The market research techniques used included SSS, searches on Purchase Request Process System (PRPS), Air Force stock number search in D043A, Haystack search using Robins PDM Gateway, review of NavCom website, and query using Small Business Administration Dynamic Small Business Search (DSBS) engine.

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SSS: As described in Section VI above, SSS Notice ID SPRWA1-00419 was synopsized on Sam.gov on 19 March 2024 with a response date of 2 April 2024. Integrated Procurement Technologies, on behalf of Extant, was the only source that expressed an interest and submitted a response.

Searches on PRPS, D043A, Haystack, NavCom website, and DSBS query utilizing NSNs, part numbers, North America Industry Classification System code 334511, and keyword CARA resulted in the following:

NavCom was the only company with valid procurement history for the CARA system. All drawings in our systems show as proprietary to the OEM NavCom. These data drawings have since been purchased by Extant.

Commercial Opportunities: The RT is not a commercial item. The item is peculiar for military application and the manufacturing processes and components used in the manufacture are unique to the avionics industry; therefore, these items do not meet the commercial definition in FAR Part 2.101. There are no commercial items or non-development items available to meet this requirement.

The market research concluded Extant is the only manufacturer/repair source of supply for the AN/ APN-232 CARA RT systems in the current market. Extant is the only source that possesses the unique skills, equipment, facilities, TDP, and processes necessary to perform these manufactures.

VIII. Any other facts supporting the use of Other Than Full and Open Competition.

None.

IX. List of any sources that expressed, in writing, an interest in the acquisition.

See Section VI above

X. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisitions for the supplies or services required.

While the current market research indicates a sole source environment for the CARA system, the Government will engage Extant on an annual basis to determine the feasibility of procuring the TDP.

The plan to break barriers to competition in the prior J&A was to continue engaging NavCom on selling the RT TDP. NavCom subsequently sold the RT TDP to Extant in Oct 2018. The Government reached out to Extant on their interest in selling the RT TDP or partnering with the Depot. Extant expressed they are not willing to discuss any type of partnership with the Depot or sell of technical data until the Government has an initial contract with them. Actions were taken to complete the prior plan to remove barriers to competition, therefore the current J&A does not require higher level approval in accordance with DFARS PGI 206.304(a)(S-70)(ii).

Data is insufficient to verify exactly why the Government did not acquire sufficient IP deliverables and IP rights. We can speculate that at the time of acquisition that funding was not available to make the purchase.

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Due to the fact that the contractor is not willing to sell the TDP it is possible that even at the time of acquisition the TDP was not available for purchase.

XI. Certification by the Contracting Officer.

As evidenced by my signature above, I certify that this justification is accurate and complete to the best of my knowledge and belief.

XII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.