USAFCENT_UPS_JA_--_9_Month_Bridge_redacted_Redacted.pdf

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

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NOTE: If a Justification and Approval was approved for the preceding acquisition, a copy of the approved J&A for the predecessor action must be included in the staff package for approval of the instant J&A. This applies to J&A staff packages that are submitted for review and approval at a level above the contracting officer. The predecessor J&A will be used as a reference document by the approving official.

Choose the funding level for this J&A Document:

< $700K > $700K and < $13.5M > $13.5M and < $93M > $93M

Contracting Activity: 28th Contracting Squadron

Purchase Request / Local ID Number: FA4690-16-C-0003

Program / Project (and PE, if applicable): USAFCENT Uninterrupted Power Supply (UPS) Engineering and Maintenance -- Nine

(9) Month Bridge Contract

Program Type (PEO or Other Contracting): Other Contracting

Authority (include full title): 10 U.S.C. 2304(c)(1) and 10 U.S.C. 2304(d)(1)(B) as implemented by FAR 6.302-1(a)(2)(iii)

Estimated Contract Cost (including options): $0.00 J&A Type: Class Individual

COORDINATION (AFFARS 5306.304(a) )

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Date Signature

APPROVAL (AFFARS 5306.304(a) )

Date Signature

Date Signature

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I. Contracting Activity.

a. Organizational Activity: USAFCENT A6 523 Nelson Ave Bldg. 1102 Office 213 Shaw AFB, SC 29152

b. Contracting Agency: 28 CONS/LGCA 1000 Ellsworth St Suite 1200 Ellsworth AFB SD 57706

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

This Justification and Approval (J&A) supports awarding a nine (9) month bridge contract in support of the USAFCENT UPS Engineering and Maintenance requirement currently being fulfilled by . The current contract expires on 3 August 2016. Continuation of services is vital in guaranteeing critical backup power services to support Command, Control, Communications, Computers, and Intelligence (C4I) systems in the USAFCENT AOR. A nine (9) month bridge contract is necessary to meet USAFCENT UPS Engineering and Maintenance services until a follow-on contract can be awarded.

Due to a severely abridged acquisition time line resultant from a late contract transfer from the Space & Naval Warfare Systems Command (SPAWAR) to 28 CONS (transfer date 8 January 2015), requirement changes to the Performance Work Statement (PWS), and contract conversion from a Cost Plus Fixed Fee (CPFF) to a Firm Fixed Price (FFP) contract, a nine (9) month bridge contract is required to ensure continuity of services for this vital service. An additional nine (9) months will allow enough time for solicitation evaluation, contract award, and contractor mobilization.

The estimated cost for the nine (9) month bridge contract is The Independent Government Estimate for the nine (9) month bridge contract is based off of the six (6) month 52.217-8 extension exercised against task order N65236-11-D-3835-CT10 on 20 January 2016 and an estimated battery replacement cost due to the ending life cycle of 16 system batteries up to Actual costs on the current CPFF USAFCENT UPS Engineering and Maintenance contract are in-line with projected costs for the nine (9) month bridge contract.

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

This requirement for backup power for communication systems support in Southwest Asia (SWA) has been developed in response to requests by United States Central Command Air Forces (USCENTAF) and United States Army Central Command (USARCENT) to ensure C4I communication systems are available to forward deployed forces supporting continuing mission requirements of the Department of Defense (DoD). This effort will provide mission critical backup power systems engineering and sustainment to military personnel and coalition forces, primarily in the United States Central Command (USCENTCOM) Area of Responsibility (AOR). Tasks under this requirement include: a) procuring, engineering, installing, maintaining, and managing critical power systems; b) logistics support for backup power systems, and c) unscheduled maintenance.

IV. Statutory authority permitting Other than Full and Open Competition.

10 U.S.C. 2304(d)(1)(B) as implemented by FAR 6.302-1(a)(2)(iii)(A) and (B), provides that for the Department of Defense, services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in:

(a) Substantial duplication of cost to the Government that is not expected to be recovered through competition, or

(b) Unacceptable delays in fulfilling the agency's requirements.

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V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

USAFCENT/A6X and 28 CONS contends that award to any other source other than the incumbent would result in substantial duplication of cost to the Government that is not expected to be recovered through competition. Additionally, award to any other source other than the incumbent would result in unacceptable delays in fulfilling the Air Force's requirements.

(a) Duplication of costs: Awarding an interim bridge contract to any other source would result in the duplication of mobilization and contract transition costs. The USAFCENT UPS Engineering and Maintenance contract currently supports multiple locations in the USAFCENT AOR which requires contractor personnel to remain in-theater during contract performance. In addition to personnel stationed in-theater, the contractor must also provide all diagnostic and test equipment used for engineering and maintenance of UPS systems. Awarding an interim bridge contract to any other source but the incumbent would result in the Government incurring excessive travel costs and demobilization and mobilization costs. The duplication of mobilization costs that are not expected to be recovered through competition for establishing a bridge contract is approximately . In addition to the duplication of mobilization costs, significant costs are incurred during the administrative transition of contracts (i.e., the incumbent would have to transition to a bridge contractor that subsequently would have to again transition to the long-term, follow-on contractor). The acquisition costs associated with the administrative burden of transitioning contracts is approximately . The approval of a nine (9) month bridge contract will avoid the potential for duplication of cost by ensuring only one contract transition occurs after the existing contract expires.

(b) Unacceptable Delays. Full transition of a competitive follow-on contract cannot be completed by the end of the existing contract expiration date, 3 August 2016. The inability to establish a sole source bridge contract under FAR 6.302-1(a) (2)(iii) would result in the following mission impacts: the loss of critical back-up power coverage for multiple C4I systems across the USAFCENT AOR and the loss of emergency maintenance on UPS systems. Although UPS engineering and maintenance is an inherently redundant power requirement, a gap in service may result in the catastrophic failure of multiple C4I systems across the USAFCENT AOR in the event of a power outage. Award of a competitive interim bridge contract to run in parallel with the reacquisition of a long-term follow-on contract is not feasible. The execution of simultaneous acquisitions for the same requirement with the same contracting and technical personnel would increase the risk of delays in the long-term acquisition. The incumbent contractor is the only firm capable of providing the supplies and services described in Section III above without the Air Force experiencing substantial duplication of cost that could not be expected to be recovered through competition and unacceptable delays in fulfilling the Air Force's requirements.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

Currently, 28 CONS in concert with USAFCENT/A6X is working the long-term (Base Year Plus Four (4) Option Years) UPS Engineering and Maintenance contract. A Sources Sought RFI posted on 21 July 2015 suggested that multiple contractors are interested in the long-term, follow-on requirement. Issuing a competitive solicitation for the interim period would create a duplication of effort and would not provide a sufficient transitional period between the incumbent and follow-on contractor. On 4 March 2016, the NAICS for the long-term acquisition was changed to 517919 -- All Other Telecommunications. A query using the Small Business Administration's Dynamic Search tool revealed nine (9) WOSB contractors capable of performing UPS engineering and maintenance. Two WOSBs demonstrated interest in the requirement. Refer to the USAFCENT UPS Engineering and Maintenance Market Research Report (long-term contract) for more details.

The Air Force intends to limit competition to the incumbent contractor as supported by this J&A. Based on the current timeline, it is unrealistic to solicit other potential sources for award of a nine (9) month bridge contract with performance beginning on 4 August 2016. Significant mobilization costs resulting from the logistical burden of moving personnel and equipment to the USCENTCOM AOR for an abridged duration makes soliciting an interim contract impractical. It is impracticable to incur costs associated with conducting a new, competitive acquisition for a nine (9) month contract.

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

Historical cost data from the current USAFCENT UPS Engineering and Maintenance contract (N65236-11-D-3835-CT10) indicates that operation and maintenance costs for supporting current in-theater UPS systems during the nine (9) month bridge contract should mirror (with small deviations) current costs. The nine (9) month bridge contract will only include tasks involving scheduled and unscheduled maintenance of known UPS locations. No UPS Special Projects will be contemplated during the nine (9) month bridge contract. Costs for the 52.217-8 extension of services on N65236-11-D-3835- CT10 were found to be fair and reasonable. The estimated cost is based on the cost of the 52.217-8 six month extension of services plus an additional three (3) months of service ) plus an estimated battery replacement cost due to the ending life cycle of 16 system batteries up to . The Independent Government Estimate for the nine (9) month bridge contract is $ .

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

Market conditions and the abridged acquisition time line make it unfeasible to perform contract transition by the end of the current contract period of performance, 3 August 2016. Due to the logistical burden of mobilizing personnel and equipment to the USAFCENT AOR, it would be unrealistic to expect that a firm other than the incumbent contractor could continue this service without interruption or mission impacts. It would also result in duplication of costs as stated in paragraph V above. Awarding a bridge contract in any other way other than a sole source award would result in a gap in service and severe degradation to the mission. All market research activities performed below are in direct support of the long-term, USAFCENT UPS Engineering and Maintenance requirement:

On 10 July 2015, 28 CONS sent NETCENTS-2 a draft RFI, PWS, and QASP to perform a scope map. The purpose of the scope map was to determine if NETCENTS-2 small business contractors could satisfy the requirement. On 16 July 2015, NETCENTS-2 confirmed that the requirement fell within the scope of the NETCENTS-2 contract. Although the requirement could be performed by NETCENTS-2 NetOps & Infrastructure small business contractors, discussions with NETCENTS-2 contracting officers regarding executing the requirement within the parameters of a NETCENTS-2 task order resulted in the determination that NETCENTS-2 was not a viable contracting vehicle to adequately support this requirement.

On 21 July 2015, a Request for Information (RFI) was posted to FedBizOps with a response date of 7 August 2015. The RFI was used to determine whether there was sufficient small business capability to warrant a socioeconomic small business set-aside or to open the requirement to all small businesses. Additionally, the RFI also sought industries' input on the revised Performance Work Statement (PWS) and Quality Assurance Surveillance Plan (QASP). Two Women Owned Small Businesses (WOSB) responded to the RFI.

All small business contractors awarded a NETCENTS-2 NetOps & Infrastructure contract were contacted regarding the FBO sources sought. Aside from the incumbent, no other NETCENTS-2 NetOps & Infrastructure small business contractors submitted a response to the RFI.

On 4 March 2016, the NAICS for the acquisition was changed to 517919 -- All Other Telecommunications. A query using the Small Business Administration's Dynamic Search tool revealed nine (9) WOSB contractors under the NAICS 517919 capable of performing UPS engineering and maintenance. Two WOSBs demonstrated interest in the requirement. Refer to the USAFCENT UPS Engineering and Maintenance Market Research Report (long-term contract) for more details.

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

The Air Force currently lacks the organic capability to perform engineering and maintenance of UPS systems in the USAFCENT AOR. A gap in contractual support cannot be supplemented with institutional forces. In the event of a power outage and/or UPS failure, all capabilities relating to correcting the problem would have to be contracted resulting in excessive mobilization costs and unacceptable mission delays.

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X. List of sources, if any, that expressed interest in the acquisition.

A RFI posted on 21 July 2015 revealed multiple interested contractors however, these sources were only interested in a long-term contract (12 months followed by four, 12-month option periods). Due the abridged acquisition time line and duplication of cost, it is impractical to solicit an interim contract. See Section V and VI above.

The incumbent contractor is:

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 Air Force is preparing a solicitation to provide future sustainment for USAFCENT UPS Engineering and Maintenance services in support of the USCENTCOM AOR with a base period of 12 months followed by four, 12-month option periods. The anticipated award date for this acquisition is December 2016.

XII. Certification by the Contracting Officer.

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