T-45 CLS Training EFO_Final_REDACTED_1.pdf

JEFO # 25-0127

DEPARTMENT OF THE NAVY

NAVAL AIR WARFARE CENTER AIRCRAFT DIVISION

21983 BUNDY ROAD BLDG 441

PATUXENT RIVER, MARYLAND 20670-1127

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity.

Naval Air Warfare Center Aircraft Division (NAWCAD) Patuxent River, MD

2. Nature and/or Description of Action being Approved.

The Department of the Navy (DoN) Program Executive Office Tactical Aircraft PEO(T) Program Management Air 273 (PMA-273) Naval Undergraduate Flight Training Systems and Chief of Naval Air Training (CNATRA) requires contractor services to conduct aircraft maintenance, engineering, and logistics support of the United States Navy (USN) T-45 Training System (T-45TS) aircraft program at NAS Kingsville, TX; NAS Meridian, MS; NAS Pensacola, FL; NAS Patuxent River, MD; and several off-site detachment locations in the continental United States. This Contractor Logistics Support (CLS) includes Organizational (O), Intermediate (I), and Depot (D) Level maintenance. CLS also currently includes acquiring equipment, tools, direct materials, and indirect materials required to maintain all Navy T-45 aircraft, aircraft systems, and related support equipment (SE) in support of flight test and evaluation operations. These services are currently being provided by Vertex Aerospace (Vertex) under the Contracted Maintenance, Modification, Aircrew, and Related Services (CMMARS) Multiple Award Contract (MAC), specifically under Task Order (TO) N68520-22-F-7005. The CMMARS TO was awarded competitively on 15 October 2021. It is presently in its third option period of performance.

An Exception to Fair Opportunity (EFO) is being pursued under the current CMMARS TO to provide T-45 certified technical representatives to perform Organizational level maintenance activities on the T-45 aircraft at the Fleet Logistics Center Southeast (FRCSE) located at Naval Air Station (NAS) Jacksonville. The contractor shall also allow FRCSE Government personnel to observe and receive “Over the shoulder” on the job training (OJT) allowing FRCSE to become self-sufficient to support new T-45 Service Life Extension Program (SLEP) efforts at FRCSE in June 2025 and beyond. This support includes T-45 O and I Level maintenance required to complete preparation, repair, and returning the aircraft to full mission capable status prior to the functional check flights (FCF) associated with aircraft wing swaps, SLEP and related modifications and in-service repairs (ISR) associated with these aircraft modifications.

The CMMARS MAC provides a wide scope of aircraft maintenance and logistics support services as required by the Government. An EFO under the current TO provides an opportunity to satisfy O and I maintenance and training requirements for FRCSE to perform T-45 maintenance and modifications at NAS Jacksonville, FL

3. Description of the Supplies or Services Required to Meet the Agency’s Needs (including the estimated value).

Vertex will provide O and I level maintenance services and maintenance training support for the T-45 aircraft being moved to FRCSE at NAS Jacksonville, FL to support FRCSE’s ability to properly perform assigned T-45 maintenance tasks. This will include the development of FRCSE personnel’s skills, knowledge, and experience so they can properly perform these assigned O and I level task. The O and I level support will include all inspections, servicing and handling as well as corrective and preventive maintenance. The Contractor will provide technical support needed to return the aircraft to full mission capable status.

The cost estimate for the anticipated contract action covered by this EFO is $ , inclusive of options. The modification of the TO, under the authority of this EFO, will be issued no later than 30 April 2025.

4. Identification of the Justification Rationale (see FAR 16.505(b)(2)) and, if applicable, a Demonstration of the Proposed Contractor's Unique Qualifications to Provide the Required Supply or Service.

FAR 16.505 (b)(2)(i)(C), The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

Supporting Information:

Adding this support on a sole-source basis via a modification to the CMMARS TO is both economical and efficient since competing these FRCSE support requirements would be cost and time prohibitive. Issuing a new stand-alone competitive TO for this task would result in a substantial delay to the service start date thereby adversely impacting support for CNATRA pilot production due to time consuming administrative burdens of the source selection process. Issuing a stand-alone competitive TO for FRCSE support would also result in substantial duplication of contractor CLS costs and government labor costs. On a stand-alone TO effort, a contractor would have to spend a significant amount of time acquiring the appropriate T-45 specific maintenance training and certifications before they would be able to support FRCSE requirements. The mobilization costs would not be recovered through competition. The contractor would also be required to price in all the associated management costs and corporate costs to complete the required training and certifications. Adding this maintenance support to an existing TO, which includes this T-45-specific CLS maintenance support and contract management infrastructure already in place results in cost savings to the government. In the interest of efficiency, adding these maintenance services to the CMMARS TO allows NAWCAD to meet the timeline needed by FRCSE to facilitate aircraft wing swap and SLEP modifications in 3rd quarter FY25.

While there are other contractors performing training aircraft maintenance, none possess any current appreciable T-45 maintenance expertise except the current T-45 CLS contractor, Vertex.

Vertex maintains a cadre of T-45 certified technicians who meet or exceed Performance Work Statement qualification requirements and can rapidly deploy to support FRCSE at NAS Jacksonville, FL. This allows Vertex to manage its existing, certified workforce to accommodate these complementary services while avoiding additional Government personnel and associated costs for contract oversight and administration. While there are three option years remaining (of a seven-year TO period of performance), these short term, additional CLS services at NAS Jacksonville supporting FRCSE should be completed during the current period of performance (1 January 2025 – 31 December 2025).

The additional $ for this support is far less than % of the total value of the current T-45 CLS TO. If this specific minimal level of FRCSE maintenance support had been included in the original solicitation, it is not anticipated that there would have been a different competitive set of offers’ ( of twenty MAC holders submitted offers), and based on the source selection results, it is reasonable to assume that it would not have changed the evaluation results.

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

In accordance with FAR 15.402, the Contracting Officer will ensure fair and reasonable pricing.

The contractor will be required to provide a detailed cost proposal identifying each individual cost element. The cognizant Contract Specialist will utilize the information submitted to perform a thorough cost evaluation. In addition, further information to the extent deemed necessary to perform a cost analysis will be requested. The Contract Specialist will consider the advisory input of the Technical Advisors in determining a fair and reasonable price.

6. Any other Facts Supporting the Justification.

None.

7. A Statement of the Actions, if any, the Agency May Take to Remove or Overcome any Barriers that Led to the Exception to Fair Opportunity before any Subsequent Acquisition for the Supplies or Services is Made.

It is anticipated that other contractors will be provided a fair opportunity under FAR 16.505 at the normal re-competition time frame for the next T-45 CLS TO (i.e., after the last priced option available to the Government is exercised). The end of performance date for this last TO option is 31 December 2028.

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.

Technical/Requirement Cognizance:

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

CONTRACTING OFFICER CERTIFICATION

I certify that this Justification is accurate and complete to the best of my knowledge and belief.