SSJ_Redacted.pdf

CUI

SOLE SOURCE JUSTIFICATION

Simplified Procedures for Certain Items

I. Contracting Activity.

This Sole Source Justification to request authority for Other Than Full and Open Competition (OTF&OC) supports requirements generated for the Air Force Sustainment Center (AFSC), 638 Supply Chain Management Group (SCMG), 409 Supply Chain Management Squadron (SCMS)/GUMB. The contracting activity for this requirement is AFSC/PZAAB, Robins Air Force Base, Georgia 31098. The Purchase Request number supporting this contracting action is

FD2060-24-00002.

II. Nature and/or Description of the Action Being Processed.

Due to the circumstances described herein, the activity requests authority to repair the items listed in this 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 requirement is for the award of a follow-on, Firm-Fixed-Price (FFP) Requirements Indefinite Delivery contract consisting of a 12 month basic and four (4) annual option periods. This repair contract will support United States Air Force (USAF), United States Air Force Reserve (USAFR) and United States Air National Guard (USANG) at the contractor depot repair facilities for the C-130 Ground Collision Avoidance System (GCAS).

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

International Enterprise, Inc. (IEI) 108 Allen Street Talladega, Alabama 35160-1302

CAGE CODE: 50218

Large Business

This ID contract will be awarded as a Single Award Task Order/Delivery Order Contract based on FAR 16.504(c)(1)(ii)(B)(1) – only one contractor is capable of providing performance at the level of quality required because the supplies or services are unique or highly specialized -- in which this SSJ provides supporting rationale.

III. Description of the Supplies/Services Required to Meet Agency Needs.

This requirement is for the depot-level repair source for the C-130 AN/ASN-167(v) Ground Collison Avoidance Computer (GCAC). Services shall include maintenance services and repair of recoverable items, packaging, handling, storage, transportation and data collection. The purpose of this process is to enhance supportability of the GCAC and ultimately that of the C- 130 aircraft.

This acquisition is in support the United States Air Force (USAF) by providing a continued flow of serviceable assets to the warfighter. The projected requirements are shown below:

OPTION 4 Quantity Repair Cost Total

5841-01-463-3343LG 8

5841-01-449-9255LG 30

NFF 1

BER 1

Option 4 Total

The total estimated value of this acquisition is . The repair cost estimates are derived from negotiated repair pricing on current USAF contract FA8538-19-D-0001, including a 5% inflation factor. The type of appropriation for the repair of NSNs is Consolidated Sustainment Activity Group (CSAG) 4930. The period of performance is for a total of 60 months, which consist of a 12 month Basic and four (4) annual option periods. Award of this acquisition is anticipated to be 21 February 2024 with period of performance (PoP) through 20 February 2029.

Delivery of the assets is 45 days after receipt of order.

Both NSNs included in this effort have an Air Force Material Command, AFMC Form 762 Contract Repair Screening Analysis Worksheet, Repair Method Code (RMC) and Repair Method Suffix Code (RMSC) that indicate a sole source requirement.

The RMC/RMSC Codes are R5/R.

RMC: R5 repair directly from a sole source contractor which is not the actual manufacturer.

RMSC: R The government does not own the data or rights to the data needed to contract repair of these parts from additional sources. It has been determined to be uneconomical to buy the data or rights to the data. It is uneconomical to reverse engineer these parts.

In accordance with FAR 16.504(c) (1) (ii) (B) (1), Only one contractor is capable of providing performance at the level of quality required because the supplies or services are unique or highly specialized, and therefore a sole source ID contract was determined to be the most effective and efficient vehicle to procure the supplies and services necessary given the Government cannot predetermine the precise quantities of supplies and services within a definite period.

IV. Statutory Authority Permitting Other Than Full and Open Competition.

10 U.S.C. 3204(a) (1), as implemented by FAR 6.302-1, and required by FAR 6.303-2(b) (4).

V. Demonstration that the Contractor’s Unique Qualifications or Nature of the Acquisition Requires the Use of the Authority Cited Above (Applicability of Authority).

The Ground Collision Avoidance Computer (GCAC) is a critical application item that is essential to weapon system performance and operation. The services required for this acquisition serve the purpose of enhancing supportability of the GCAC and ultimately that of the C-130 aircraft. The GCAC is currently installed on 453 C-130 aircraft and is exclusive to the C-130 fleet. Continued sustainment and repair is necessary in order to support mission over the next six

(6) years. The C-130 life cycle is through 2040; however, the GCAC will be replaced on the C- 130 with the Avionics Modernization Program (AMP) Increment 2 by 2028.

The critical significance of the GCAC is its ability to provide visual and aural warnings to the pilot and copilot that help identify the cause of a warning and take appropriate action to prevent a crash. Currently the specific design process used for manufacturing the GCAC has become obsolete; parts obsolescence problems are being experienced by the Government. Test equipment that is in marginal condition or technicians that lack seasoned proficiency in the repair of GCAC can destroy next higher assembly and thus affect cost and schedule for end item repair.

There are currently no new technologies applicable to testing that could provide an affordable best value alternative to the current design. The Ground Collision Avoidance System (GCAS) is listed on the minimum essential list (MEL) of equipment required for the C-130 aircraft and congressionally mandated; no troops or passengers may be carried on the C-130 without an operational GCAC engaged. As such this acquisition is necessary for continued performance in order to support mission requirements.

Given the criticality of this item, the agency’s minimum needs can only be satisfied by the unique services available from International Enterprise, Inc. as demonstrated in the following paragraphs. IEI possesses the skilled employees, equipment, facilities, repair data and processes necessary to perform this requirement via a license agreement finalized with Honeywell International, Inc. in August 2017. Honeywell International, Inc. is the Original Equipment Manufacturer (OEM) of the GCAC. IEI is currently providing repair services for the GCAC managed by Robins Air Force Base via contract FA8538-19-D-0001 which is set to expire 20 February 2024.

Honeywell International, Inc. had been the only source to possess the expertise, facilities, equipment, repair data, proprietary data rights on software and depot level manuals to provide repair support of the national stock numbers covered for this requirement. In response to a GCAS redesign effort initiated in December 2016, Honeywell International, Inc. provided a white paper in March 2017 which advised the Government of their intention to remove themselves from the repair services specific to the GCAC. They maintained that they would only provide sustainment services of the Air Data Computer (ADC) and the Ground Proximity Warning System (GPWS).

The Government does not own the data or the rights to the data needed to contract repair the GCAC from additional sources. The data needed to compete contract repair is not physically available, it cannot be obtained economically, nor is it possible to draft adequate specifications or any other adequate, economical description of repair for a competitive solicitation. The Government also possesses no viable repair data on these items in its Joint Engineering Data Management Information and Control System (JEDMICS) repository or Technical Order Library. The Government contacted Honeywell International, Inc. Honeywell International Inc.

responded on 12 Sep 2022 stating they are unwilling to sell the rights of the data to the

Government. Honeywell International, Inc. has repeatedly responded that they are unwilling to sell the repair data, proprietary software nor depot level manuals.

In accordance with System Engineering, reverse engineering is typically cost effective only if the item to be reverse engineered will result in a high return in investment or the OEM is no longer willing or able to provide support. A reverse engineering estimate and return on investment analysis was done with utilizing government certified facilities. Based on past official estimate, funding this type of effort will take approximately 24 months to receive one (1) A condition GCAC, Technical Data Package (TDP) for depot stand-up of GCAC and depot level maintenance instructions with IPB. This was estimated to cost . A break-even analysis was performed by AFSC/FZC-R on the subject NSNs using the Sole Source and Reverse Engineering alternatives. Based on the analysis, the savings gained through competition does not offset the costs of reverse engineering within the six (6) year analysis.

Current contract: FA8538-19-D-0001 Value:

Quantities: 380 Awarded Contractor: International Enterprise Incorporation (IEI) Cage: 50218 Limited Source (FFP) PoP: 21 Feb 2019 – 20 Feb 2024

NAICS: 811219

PSC/FSC: 5841

RMC/RMSC: R5/R

Previous contract: FA8538-16-D-0018 Value:

Quantities: 370 Awarded Contractor name: Honeywell International Incorporation Cage: 1W4TB Sole Source (FFP) PoP: 30 Sep 2016 – 29 Sep 2018 Previously used NAICS: 334511

PSC/FSC: 5841

Previous RMS/RMSC: R2/R Notified of Honeywell International Incorporation’s licensing agreement with International Enterprise Incorporation (IEI) (Aug 2017)

Previous contract: FA8538-10-D-0015 Value:

Quantities: 900 Awarded Contractor name: Honeywell International Inc.

Cage: 1W4TB Sole Source (TT&E) PoP: 30 Sep 2010 – 29 Sep 2015 Previously used NAICS: 334511

PSC/FSC: 5841

Previous RMS/RMSC: R2/R

Accordingly, International Enterprise, Inc. is the only capable source of providing the supplies and services for this instant acquisition without the USAF experiencing unacceptable delays and duplication of cost in fulfilling its requirements.

VI. Description of Efforts Made to Ensure that Offers are Solicited From as Many Potential Sources as Practicable.

This requirement will be synopsized on the SAM.gov website as required by FAR 5.201.

Although the Government does not own the data to support acquisition of these components from any other source, any source who responds to the Government because of this synopsis will be identified to the prime contractor as a potential source for subcontracting possibilities.

Request for Sources Sought Synopsis (SSS)/Request for Information (RFI) for Non-competitive Repair of C-130 AN/ASN-167 (V) Ground Collision Avoidance Computer (GCAC) was posted to SAM.gov on 31 March 2022 resulting with no response by close of business 29 April 2022.

VII. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The overall cost of this acquisition will be fair and reasonable to the Government. In accordance with FAR 15.403-3, it is anticipated that negotiations will be conducted using certified cost and pricing data from the Contractor. Thorough price analysis and/or cost analysis will be conducted using available information and approved pricing techniques that will support the contracting office in making a determination that the price paid is fair and reasonable to the Government and the Contractor.

VIII. Description of the Market Research Conducted and the Results, or a Statement of the Reasons Market Research was not Conducted.

Market Research was conducted and completed 21 July 2022 in accordance with FAR Part

10.001 and 10.002. The following market research techniques were used:

Thorough documentation searches were conducted within the government data bases, combined with various internet searches (HIS Haystack, GSA Advantage, NSN Search, Google) for part/national stock numbers and noun. An assessment to determine the capabilities of individual vendors through Internet Search was performed. The assessment results have been annotated as Capable, Not Capable or N/A. Qualified individuals, within the appropriate government sections, were contacted and assisted with the gathering of product background information.

Correspondence was held with the OEM to determine the present status of the items.

Small Business (SB) search was performed to specifically find SB vendors that may be capable of repairing these items. A search of HUB Zone and Service Disabled and all subcategories of small businesses was conducted using the Dynamic Small Business Search Engine (http://dsbs.sba.gov/dsbs/search/dsp_dsbs.cfm) using criteria consisting of keywords (Ground Collision Avoidance System) pertaining to the item descriptions and the NAICS code 811219.

An unmodified GCAC is commercially available but the C-130 requires military modifications proprietary to Honeywell for both usage and repair. Therefore, these items do not meet the criteria of a commercial item as defined by FAR 2.101. Engineering has determined that this AN/ASN-167(V) is C-130 unique with no other use because they were modified, qualified and manufactured exclusively for the military and no commercial versions of the GCAC currently exist to meet the USAF’s requirements. The IPT has determined that this repair service will be noncommercial based on FAR 2.101 “Commercial Item” (3)(ii) Minor modifications of a type not customarily available in the commercial marketplace made to meet Federal Government requirements. Minor modifications means modifications that do not significantly alter the nongovernmental function or essential physical characteristics of an item or component or change the purpose of a process. Installation services, maintenance services, repair services, training services and other services. “Commercial Service” (1)(ii) The source of such services provides similar services contemporaneously to the general public under terms and conditions similar to those offered to the Federal Government. All repair data and test equipment software for this particular version is proprietary to Honeywell International Inc. Therefore, the only sources currently capable of repairing the GCAC is Honeywell and International Enterprise Inc.

A request for Information (RFI) for Limited Competitive Repair of C-130 AN/ASN-167(V) Ground Collision Avoidance Computer (GCAC) was posted to SAM.gov on 31 Mar 2022 resulting with no response(s) by close of business 29 Apr 2022.

The Market Research Report concluded Honeywell owns the data rights to all repair data pertaining to the units (including manuals, procedures and test equipment). Honeywell have stated they are unwilling to repair these items; henceforth, they have licensed their tech data and tooling to IEI for repair capabilities.

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.

The Ground Collision Avoidance Computer (GCAC) is planned for service until 2028. In accordance with Systems Engineering, reverse engineering is typically cost effective only if the item to be reverse engineered will result in a high return in investment or the OEM is no longer willing or able to provide support. Based on the breakeven analysis conducted, the saving gained through competition does not offset the costs of reverse engineering with the six (6) year analysis. Market surveillance will continue through the monitoring of technical literature, discussion with other engineers and attendance at expos for potential repair sources/suppliers of the subject NSNs.

While the current market research indicates a sole source environment for the repair of the GCAC, the Government will continue to engage with the OEM, Honeywell International Inc. on an annual basis, prior to the exercise of each option period with IEI to determine the feasibility of procuring the data rights in order to promote full and open competition. As of 12 Sep 2022, Honeywell International Inc. is unwilling to sell the technical data package or rights to it.

XII. Certification by the Contracting Officer.

As evidenced by my signature on the Coordination and Approval Document (CAD), I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. Certification by the Technical/Requirements Personnel.

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