SSJ 20Q2143 Redacted_Redacted.pdf

J&A No. N104-Q-2143

JUSTIFICATION AND APPROVAL FOR USE OF OTHER THAN FULL AND OPEN

COMPETITION

1. Contracting Activity: Department of the Navy, Military Sealift Command (MSC) - Norfolk.

2. Description of the Action Being Approved: Award of a sole source firm fixed price contract to supply updated design and equipment for Hull Monitoring System on a second EPF class vessel as part of a pilot program to obtain American Bureau of Shipping (ABS) Condition Based Class (CBC) Notation.

3. Description of Supplies/Services: MSC Norfolk requires Light Structures AS; the Original Equipment Manufacturer (OEM) for the EPF Hull Monitoring System (HMS) to provide an updated design and materials for installation on a second EPF class vessel.

The second system will use the same type of Fiber Optic Strain Gauge equipment in a modified arrangement in an attempt to reduce the number of sensors and get better stress monitoring results. The modified sensor arrangement is based on recommendations made by ABS. Once the new EPF HMS is designed and procured, that system will be installed on a second EPF during a regularly scheduled ship repair availability. Installation is not part of this requirement. Data results from the original installation on EPF-1 will be compared to data received from the system procured under this action in order to determine the optimum arrangement for use on the remaining EPF vessels.

4. Statutory Authority Permitting Other Than Full and Open Competition: The statutory authority for this commercial procurement is 41 U.S.C. 1901(e)(2) as implemented by FAR Part 13.501(a), Simplified Procedures for Certain Commercial Items, Sole Source.

5. Rationale Justifying Use of Cited Authority:

MSC is working with ABS to develop and obtain CBC Notation on the EPF class vessels.

Light Structures was selected to supply the system for EFP-1 based upon their unique experience with the design of shipboard fiber-optic sensor systems for the USCG. As a result they have developed a detailed model of the vessel and proprietary software for evaluation and display of the data. They have also been the sole contractor working with ABS on the CBC project for government vessels. In order to evaluate the data and relate that information to overall hull stresses they had to create a computer model for the hull and dashboards to display the data in a format usable by the ship’s operators. The system on EPF is now providing real time information for the ships operators so that they are aware if the ship is being operated outside MSC’s desired Safe Operating Envelop (SOE).

Light Structures AS unique technology and marine experience is critical to this important project to provide the second EPF system. MSC is not aware of another company that has the knowledge, technology, skills and experience to develop the computer model, software, system design and interfaces for a fiber-optic sensor system to monitor stress/strain, fatigue life, temperatures, sea and environmental conditions and provide real-time data analysis and indication for operation within defined operational thresholds.

It also maintains continuity with MSC’s regulatory partner, ABS, and ensures a consistent interface for crew members transitioning between the vessels.

Light Structures AS has developed file structures and communication protocols which interface with Shipboard Automated Maintenance Management (SAMM) file transfer function to allow transmission of sensor data ashore for additional monitoring by MSC and ABS personnel.

The manual and designs provided for EPF 1 are proprietary as stated in the supplied light structures manual; LS18004MA002 Rev. 0100 | Light Structures AS Functional Description for Hull Monitoring System, Paragraph 1. Which states: “Light Structures AS proprietary rights are included in the information disclosed herein. Recipient by accepting this document agrees that neither this document nor the information disclosed herein nor any part thereof shall be reproduced or transferred to other documents or used or disclosed for any purpose except as specifically authorized in writing by Light Structures AS.”

The cost and time associated with evaluating an entirely new system which is approved by ABS is significant and not in the Government’s best interest.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable:

A Sources Sought Notice was posted on www.beta.sam.gov on 19th February 2020 and was closed on 6th March 2020. Light Structures AS was the only company to provide a response to the notice. At this time Light Structures AS is the only known vendor who can provide the design and material needed by MSC and ABS for support of CBC Notation on EPF Class Vessel.

7. Determination of Fair and Reasonable Cost: The Contracting Officer will determine that the cost to the Government of the supplies/services covered by this J&A is found fair and reasonable in accordance with FAR Part 13.106-3.

8. Actions to Removed Barriers to Future Competition. For reasons set forth in Paragraph 5 and 6, MSC has no plans at this time to solicit these requirements competitively, other than synopsizing the requirements. If another potential source emerges, MSC Norfolk will assess whether competition for future requirements is feasible.