T700 JA Final 29Nov2018 redacted_Redacted.pdf

DEPARTMENT OF THE NAVY

NAVAL AIR SYSTEMS COMMAND AIRCRAFT DIVISION

21983 BUNDY ROAD

BUILDING 441, UNIT 7

PATUXENT RIVER, MARYLAND 20670

IN REPLY REFER TO:

J&A_18_0055

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity.

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

2. Description of the Action Being Approved.

This Justification and Approval (J&A) authorizes and approves the award of a Fixed Price (FP)

Indefinite-Delivery/Indefinite-Quantity (IDIQ) contract on a sole source basis for Commercial Depot

Level Services for the T700 variant engines for PMA-299, PMA-276, and Foreign Military Sales (FMS) customers to General Electric Engine Services, Inc. (GEES), 1000 Western Ave, Lynn, MA 01905-2655.

The resultant task orders will be Firm Fixed Price (FFP) and awarded on a sole source basis to GEES for the procurement of services in support of the T700 engines.

3. Description of Supplies/Services.

The orders issued under the IDIQ contract will provide Commercial Depot Level Services for T700-GE-

401C and T700-GE-401 engines along with the Cold Section Modules (CSMs) and Power Turbine

Modules (PTMs) for PMA299, PMA 276, and FMS for a total ordering period of five years. The work shall be performed at the Contractor’s facility. Because of the flight criticality of these aircraft engines and modules, it is mandatory that the Contractor be an approved source of repair in accordance with the

Joint Aeronautical Commanders’ Group (JACG) Aviation Source Approval and Management Handbook, dated 16 Mar 2011, Secretary of the Navy Instruction 4140.2, and be a certified Federal Aviation

Administration (FAA) repair station or equivalent. Additionally, all Critical Safety Item (CSI) parts shall be obtained from USN Naval Air Systems Command (NAVAIR) approved sources only. The total estimated value of this J&A is $ million. Estimated dollar value is delineated below and comprised of the following funding type:

Estimated Dollar Value in Millions

FY19 FY20 FY21 FY22 FY23 Total

O&MN

O&M,NR

APN-1

FMS

Total

J&A_18_0055

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

10 U.S.C. 2304(c)(1): Only one responsible source and no other supplies or services will satisfy agency requirements.

5. Rationale Justifying Use of Cited Statutory Authority.

GEES is the Original Equipment Manufacturer (OEM) of the T700 engine, including the subassemblies

CSM and PTM, used in all H-60 and H-1 aircraft. GEES is the current aircraft engine maintenance support contractor and is the only company with the knowledge and in-depth experience required to provide the complete T700 depot repair and overhaul services anticipated under this J&A without unacceptable delays in fulfilling the Government’s requirements.

The contracting effort covered by this J&A is a follow-on contract to the single-award IDIQ contract

N61340-14-D-0004 with GEES, which was procured under a full and open competitive process. GEES was the only offeror to submit a proposal. Similarly, GEES was the only offeror to submit a proposal under the predecessor contracts, N00421-09-D-0008 and N00019-03-D-0013, which were competed on a full and open basis.

GEES is the only source with the experience, capabilities, facilities and resources to provide complete

T700 depot repair and overhaul services of the engine and modules (CSM and PTM) in a timely manner.

GEES possesses a highly specialized and trained team of engineers and overhaul technicians with intimate knowledge and expertise to perform complete repair and overhaul of the engine and modules.

GEES’ facility and personnel are an approved source of repair and have FAA certification as a CT7/T700

Repair Station. In addition, as a division of General Electric Aircraft Engines, the developer of the T700 engine, GEES maintains a volume repair/overhaul capability, that includes the commercial variant of the engine, to be able to meet the Government’s required repair turnaround time (RTAT) thresholds of 90 calendar days for T700-GE-400 or T700-GE-401C engines and CSMs and a RTAT threshold of 60 calendar days for PTMs. Meeting the Government’s required RTAT thresholds is crucial to maintaining the engine, which is essential to supporting the mission as the processes and procedures employed in servicing the engine have an impact on the life of the engine and the Time On Wing (TOW), which affects fleet availability and maintenance costs.

In order to maintain the supply of ready for issue T700-401 and T700-401C engines and modules used on

HH-60H, MH-60R, MH-60S, AH1W, AH-1Z, UH-1Y aircraft, repair inductions must begin May 2019.

Assuming approximately 18-24 months to complete a competitive acquisition and an additional six months for another company to set up depot facilities, including transfer of Government Furnished

Property (GFP), obtaining skilled resources, and procurement of parts and services to meet the required through-put requirements of the schedule, pursuit of award to any other source would delay the repair inductions until at least July 2020. This would result in an immediate unacceptable delay (of more than one year) in fulfilling the T700 requirements, which would impact H-1 and H-60 aircraft availability to conduct Navy and Marine Corp missions. Therefore, GEES is the only responsible source capable of providing the services to satisfy the Government’s requirements within the scheduled timeframe.

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

Market research was conducted through a sources sought that was posted on FedBizOps on 28 February

2017; a response was received from one source, . is the only other known source that has the required source of repair approval. Following a technical assessment of Vector’s response to the sources sought, representatives of the Program Office and the Contracting Officer held discussions with

Vector to determine its capability to provide the services required.

A request for information (RFI) was issued whereby the Government inquired if could support a turn-around time of 90 calendar days for up to 30 engines at a time. responded that it currently has the facility and technical experts on hand to process up to ten (10) engines at a time, allowing for a turn-a-round time of 90 calendar days. stated that, in order to adjust to the production level of 30 engines at a time, however, it would require a six-month transition period. In addition, the Government noted consistent historical responses to sources sought publications for the same services and inquired why has never elected to submit a proposal to date. In response to this question, stated that it elected not to participate as the anticipated contracts would be issued on a FFP basis. Facing the FFP reality, realized that under this condition its pricing would not be competitive and it represented a significant financial risk to . The anticipated contract type for the current requirement is FFP.

also stated that it elected not to submit a proposal during the last full and open competition because deemed that another contender may have a substantial parts cost advantage in which estimated that it would have a low chance of being awarded the program. stated this is most common when an OEM, the manufacturer of such parts, is also a Maintenance, Repair and Overhaul

(MRO) service provider. GEES is the OEM for the T700 engines and thus the OEM and the MRO service provider for this requirement.

No additional Market Research was conducted and based on the sources sought results and the rationale contained within Section 5 above, it is not anticipated that any other source would be able to provide the required services than GEES. Any responses received prior to contract award will be evaluated. A synopsis outlining the USN’s intent to issue a contract on a sole-source basis to GEES was published on the FedBizOps website from 04 October 2018 through 19 October 2018 and received no written responses.

7. Determination of Fair and Reasonable Cost.

In accordance with FAR 15.403-1(c)(3) any item that the Contracting Officer determines meets the commercial item definition in 2.101, is exempt from the requirement for certified cost or pricing data. In accordance with FAR 15.402(a), the Contracting Officer shall ensure that all supplies ordered under this contract are procured at a fair and reasonable price. Cost and/or price analysis of the Contractor's proposal will be performed by experienced Government technical analysts, auditors, and contract specialists in order for the Contracting Officer to determine that prices are fair and reasonable. Based on historical data from similar efforts, the Contracting Officer, NAVAIR Technical Experts, and the cognizant Defense

Contract Management Agency have adequate information and background to assist in making these determinations.

8. Actions to Remove Barriers to Future Competition.

For the reasons set forth in Paragraph 5, NAWCAD has no plans at this time to compete future contracts for the types of services covered by this document. If another potential source emerges, the USN will assess whether competition for future requirements is feasible for competition.

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 Cognizance:

Signature Name (Printed) Phone Date

Requirements 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.

SENIOR PROCUREMENT EXECUTIVE APPROVAL

Upon the basis of the above justification, I hereby approve the solicitation of the proposed procurement(s) described herein using other than full and open competition, pursuant to the authority of 10 U.S.C.

2304(c)(1).

Date

Assistant Secretary of the Navy (Research), Development, and Acquisition) (ASN(RDA))