JA_M119A3_Buffer_Recoil_Seals_Redacted.pdf

Program/Item: M119A3 Recoil Seals Estimated Dollar Value:

Control No.:

For Official Use Only

JUSTIFICATION REVIEW DOCUMENT

FOR OTHER THAN FULL AND OPEN COMPETITION

Program/Equipment: M119A3 Howitzer Buffer Recoil Seals

Authority: 10 U.S.C. 2304(c)(1); FAR 6.302-1(a)(2)(ii)(A) & (B); Only one responsible source and no other supplies or services will satisfy agency requirements

Amount:

Prepared by: Typed Name: DSN:

Title: Contract Specialist Date: 9/29/2015 Email:

Contracting Officer: Typed Name: DSN:

Title: Contracting Officer Date: 10/06/2015 Email:

Technical Representative: Typed Name: DSN:

Title: Acquisition Manager Date: 9/29/2015

Email:

Requirements Representative: Typed Name: DSN:

Title: Program Manager Date: 10/01/2015 Email:

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Contracting Officer ACC-NJ-JA Date: 10/06/2015

Group Manager ACC-NJ-JA Date 10/7/2015

Center Director ACC-NJ-JA Date 10/8/2015

Legal Counsel AMCLC-APG-ARD Date 10/8/2015

Associate Director ACC-NJ Date 10/28/2015

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

1. CONTRACTING ACTIVITY:

U.S. Army Contracting Command - New Jersey

2. DESCRIPTION OF ACTION:

a. The proposed contracting action is a new Firm Fixed Price (FFP) contract for the procurement of 550 Buffer System Recoil Seal Kits. This procurement will utilize FY15 Weapons and Tracked Combat Vehicle (WTCV) funding.

b. The period of performance will be 16 months from date of award. The estimated contract value is

c. The proposed Other than Full and Open Competition contracting strategy is a sole source contract to Lancer Systems, 7566 Morris Court, Suite 300, Allentown, PA 18106.

d. Pursuant to Defense Federal Acquisition Regulation Supplement (DFARS) 207.103(d)(i)(B), an Acquisition Plan is not required as this effort is under the $50 million threshold for new production programs and less than $25 million for any fiscal year.

3. DESCRIPTION OF SUPPLIES/SERVICES:

The function of the recoil system is to absorb the energy of recoil effectively and then return the gun to the “in battery” position. Damping of the system is controlled by the Buffer which uses ‘fluid throttling’ to control the energy of recoil. The Recuperator stores energy from the recoil in the form of compressed Nitrogen and helps return the system into battery. The current system operation has revealed several shortfalls. There are reliability issues associated with the Recuperator and buffer seals which routinely leak oil and lubricant during use. The current variable recoil linkage is prone to breaking and binding during firing and thus requires constant adjustment in the field as well as a large amount of maintenance time. The redesigned system eliminates the variable recoil and simplifies the Recuperator, eliminating the Nitrogen bottle, making for a more reliable system. It also addresses the leakage of oil at the seals. The external Replenisher provides greater temperature compensation and eliminates the frequent need to add or remove oil. The System Recoil Seal Kits are required to ensure the effective operation of the recoil system by providing containment of recoil fluids to the recoil mechanism.

These seals will be integrated with the new metal parts as well as legacy parts in order to form the new recoil system. The recoil system will operate more efficiently and reduce the maintenance required on the system.

4. AUTHORITY CITED:

10 U.S.C. 2304(c)(1); FAR 6.302-1(a)(2)(ii)(A)&(B), Only one responsible source and no other supplies or services will satisfy agency requirements, (A) Substantial duplication of cost to the Government that is not expected to be recovered through competition and

(B) Unacceptable delays in fulfilling the agency’s requirements.

5. REASON FOR AUTHORITY CITED:

The following subparagraphs provide rationale under the authority of FAR 6.302- 1(a)(2)(ii)(A)&(B), only one responsible source and no other supplies or services will satisfy agency requirements for the procurement of Buffer System Recoil Seals Kit and Unacceptable delays in fulfilling the Agency’s requirements. Paragraph 6.302- 1(a)(2)(ii) applies when the agency’s need for supplies may be deemed to be available only from the original source in the case of a follow-on contract for the continued development or production of a major system or highly specialized equipment, including major components thereof, 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 and (B) Unacceptable delays in fulfilling the agency’s requirements.

a. Duplication Costs: Only one responsible source is applicable for this acquisition, where 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.

Competition for this requirement is not feasible and would result in substantial duplication costs of approximately Lancer Systems is the only provider of the sealing solutions for the M119A2 Howitzer that can meet the requirement for seals of the redesigned M119A3 recoil system. Lancer Systems is a recent subsidiary of the well-known Green Tweed, an international provider of sealing solutions for both commercial and military applications. Lancer Systems was formed to specifically focus on Military sealing applications for Green Tweed. These Recoil System Seals are necessary for a FY15 fielding of the redesigned recoil system. Lancer Systems is the only approved source for the current M119A3 recoil seals. The existing M119A2 recoil systems

Significant duplication of costs would be incurred by the Government to qualify another vendor’s seals which would further delay delivery of the seals for use in validating the M119A3 recoil design. The duplication costs, broken out by labor category are due to the need for the qualification of another vendor’s product, substantial engineering and design efforts, additional testing, and revision of technical documentation.

The need for engineering, design efforts and revision to technical documentation arises from the difficulties that any new company will have in manufacturing Recoil System Seals.

The duplication cost is estimated as follows:

b. Unacceptable Delays in fulfilling the agency’s requirements are anticipated if award were made to other than the proposed source. Lancer is the current provider of recoil seals for the M119A3. They are also the provider of the prototype seals currently undergoing evaluation. Lancer has done a

Lancer is the only entity with the necessary knowledge and experience to produce the required units in a timely manner to support the fielding of the new recoil system It is estimated that there would be a delay before a new contractor was in a position to begin manufacture of a qualified recoil seal. This delay is due to the following actions a new vendor would be required to conduct: development of a manufacturing process prototype production testing cycle to validate design and manufacture of a reliable unit of the Recoil Seals. The Government would be harmed because the fielding would be delayed by twelve months. Fulfilling this requirement with a sole source award to Lancer would result in on-time delivery to support production.

c. Analysis of Alternatives to other than Full and Open Competition

(i) Two (2) potential procurement strategies to satisfy the requirement were analyzed. One (1) strategy is a sole source award to Lancer Systems and the other is a full and open competition (F&OC) for the Buffer System Recoil Seals Kits. Lancer Systems is the only approved source for the current M119A3 recoil seals. The existing M119A2 recoil systems are source controlled and only available from Lancer Systems.

Award of a sole source contract to Lancer Systems is the only alternative that assures cost effective and timely requirement for the Buffer System Recoil Seals Kits.

(ii) Requirements: Any source other than Lancer Systems would have to undergo a process development as the current process is proprietary. As the only approved source of the Buffer System Recoil Seals Kits Lancer Systems possesses the unique knowledge and expertise to provide support of the production of these Buffer System Recoil Seals Kits.

Furthermore, Lancer Systems is the only source approved for the current M119A3 recoil seals. The existing M119A2 recoil systems are source controlled and only available from Lancer Systems. Therefore, fulfilling this requirement with a sole source contract to Lancer Systems is the only alternative that will meet technical and performance requirements.

(iii) Schedule Risk: As stated above in paragraph 5b, it is estimated that, at this time, it would require for another contractor to deliver a qualified Recoil Seal for use in M119A3 Recoil Design. The estimate clearly demonstrates the risk to the M119A3 Recoil Project if another vendor was selected. is unacceptable and would cause serious delays in fielding of the M119A3. Fulfilling this requirement with a sole source award to Lancer would result in on-time delivery.

(iv) Cost Risk: As stated above, the cost risk of competing this requirement is if the incumbent was not awarded the contract. The costs are based upon prior Government experience and the costs required to qualify a new seals manufacturer. There will be a substantial duplication of cost involved with this procurement that the Government cannot expect to recover through competition for this particular effort.

(v) Performance Risk: Without the ability to provide the current vendor’s proprietary information into the manufacture of these components, any new vendor would, through trial and error, experience a significant learning curve, need to perfect the production of a qualified seal. This information is proprietary to Lancer Systems; other vendors would have to undergo development to produce their own proprietary process. The delay for this effort as discussed above.

(vi) While a Government owned Level III TDP with associated drawings and technical data of the M119A3 design is available and adequate for competition, full and open competition is not practical at this time for the procurement. However future designs for new recoil systems will seek to incorporate seal designs and materials which could lead to increased competition.

(vii) Conclusion: F&OC would present unacceptable schedule delays, cost, and performance risk. As a result, a sole source contract award to Lancer Systems is the only alternative that will satisfy the requirement for the Buffer System Recoil Seals Kit. Award to any other source other than Lancer Systems would cause substantial duplication costs and unacceptable delays.

6. EFFORTS TO OBTAIN COMPETITION:

a. Effective competition is not anticipated since Lancer Systems is the only firm that possesses the necessary level of expertise, experience, and familiarity with the current and prototype sealing solutions for the M119A3 Howitzer that meet all of the Government objectives and performance requirements.

b. Subcontracting competition: Subcontracting competition by the prime contractor will be maximized by the Contracting Officer through publication of the solicitation, required by FAR 5.201. FAR 52.244-5, Competition in Subcontracting, will be included in this contract.

7. ACTIONS TO INCREASE COMPETITION:

Full and open competition is not practical for the proposed contract, as Lancer Systems is the only firm that possesses the necessary level of expertise, experience, and familiarity with the current and prototype sealing solutions for the M119A3 Howitzer. While a Government owned Level III TDP with associated drawings and technical data of the M119A3 design is available and adequate for competition, full and open competition is not practical at this time for the procurement due to the reasons described in Section 5; duplication of Costs and Unacceptable Delays in fulfilling the requirements. However future designs for new recoil systems will seek to incorporate seal designs and materials which could lead to increased competition.

8. MARKET RESEARCH:

Market research was recently performed though a search of the Internet, trade publications, and industrial inquiries by the Procurement Initiator in accordance with FAR 10.002 (b)(2)(i),(ii),(v),and(vii) in April 2015. During the last twelve (12) months, the Government canvassed the industrial community through trade shows and Internet research in order to obtain the latest information concerning production capability for M119A3 recoil seals. companies were identified as potential vendors for recoil seals through industry inquiries. additional companies responded to the Sources Sought Notice W15QKN-15-X-1060 that was posted on FedBizOps on 5 August 2015 and closed on 8 September 2015 for a total of vendors. The M119A3 requires a unique sealing solution and products from other vendors would have to be tested and qualified for use on the M119A3. Additionally, unique sealing solutions may have to be designed based on the proprietary nature of the sealing techniques of each vendor. It is recommended then, that this action be completed as a sole source effort due to substantial duplication costs associated and unacceptable delays with qualifying new vendors.

MR Report Status

Company Name Business Size/Type

Capable Lancer Systems SBC

Incapable LBC

Incapable LBC

Incapable WOSBC

Incapable SDBC

1) Lancer Systems 2800 Milford Square Pike Quakertown, PA 18951

Capable – Lancer Systems is the incumbent vendor who has been providing Recoil Seals for M119A3 fielding to PM-TAS. Lancer has already undergone a lengthy and painstaking process to correctly produce a qualified, functional PFM. Lancer has previous experience providing the required components to the M119A3 Program.

2)

Incapable a well-known provider of seals for weapons systems. However, current offerings are not adequate for use on the M119A3, and a unique solution would have to be created for use on the M119A3. does possess a current product that could be a drop in replacement for existing items. Any replacement would have to be specifically designed and then qualified for use on the M119A3. This would require a significant investment of capital to test and validate the new sealing systems.

3) is a commercial manufacturer of sealing systems, however not typically for the military market. has not manufactured sealing solutions for recoil systems. Based on the information submitted, they are not capable of providing the items required. The vendor would require a substantial duplication of cost and time to design, manufacture, and test unique seals for the M119A3 howitzer.

4) is a commercial machine shop which is a supplier to the Department of Defense. has not manufactured sealing solutions for recoil systems. Based on the information submitted, they are not capable of providing the items required. The vendor would require a substantial duplication of cost and time to design, manufacture, and test unique seals for the M119A3 howitzer.

5) is an established and experienced DoD support contractor that currently provides custom machined metal items to the military.

has not manufactured sealing solutions for recoil systems. Based on the information submitted, they are not capable of providing the items required. The vendor would require a substantial duplication of cost and time to design, manufacture, and test unique seals for the M119A3 howitzer.

9. INTERESTED SOURCES:

a. To date, other sources have written to express an interest;

Please see Paragraph 8 for a discussion of the Market Research conducted.

b. As required by FAR 5.201, a pre-solicitation notice will be posted on the Federal Business Opportunity website (FedBizOpps) and will contain the appropriate rationale for other than full and open competition upon approval of this J&A document. Any proposals received by other than the intended source shall be considered.

10. OTHER FACTS:

a. Procurement History:

Contract Number: W15QKN-15-C-0048 Award Date: 30 April 2015 Dollar Value:

Period of Performance: One time delivery on 02 July 2015 Item(s) Procured: M119A3 Prototype Buffer Recoil Seals Competitive Status: Sole Source contract to Lancer Systems Authority: FAR 13.106-1

Summary of Section 7:Full and open competition is not practical for the proposed contract, as Lancer Systems is the only firm that possesses the necessary level of expertise, experience, and familiarity with the current sealing solutions for the M119A3 Howitzer. While a Government owned Level III TDP with associated drawings and technical data of the M119A3 design is available and adequate for competition, full and open competition is not practical at this time for the procurement. However future designs for new recoil systems will seek to incorporate seal designs and materials which could lead to increased competition.

11. TECHNICAL CERTIFICATION: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Name: Date: 9/29/2015 Title: Acquisition Manager Office Symbol: SFAE-AMO-TAS Signature:

12. REQUIREMENTS CERTIFICATION: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Name: Date: 10/01/2015 Title: Business Manager Office Symbol: SFAE-AMO-TAS Signature:

13. FAIR AND REASONABLE COST DETERMINATION: I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable.

The resulting proposal will be subjected to a formal technical evaluation, cost/price analysis, and comparison to Independent Government Cost Estimate (IGCE) that will be used to determine the anticipated cost are fair and reasonable. In addition, Certified Cost and Pricing data will be required in accordance with FAR 15.403-4.

Name: Date: 10/06/2015 Title: Contracting Officer Office Symbol: ACC-NJ-JA Signature:

14. PROCURING CONTRACTING OFFICER CERTIFICATION: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Name: Date: 10/06/2015 Title: Contracting Officer Office Symbol: ACC-NJ-JA Signature:

APPROVAL

Based on the foregoing justification, I hereby approve the procurement of 550 Buffer Recoil Seal Kits on an other than full and open competition basis pursuant to the authority of 10 U.S.C. 2304(c)(1), FAR 6.302-1(a)(2)(ii)(A)&(B) subject to the availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Date: 10/22/2015

Contracting Officer

ACC-NJ