CAO-18-0079_M777A2_and_M119A3_Retrofit_Support_(Redacted_12-19-17).pdf

Control Number:

FOR OFFICIAL USE ONLY

JUSTIFICATION REVIEW DOCUMENT

FOR OTHER THAN

FULL AND OPEN COMPETITION

Program/Equipment: M777A2 and the M119A3 Towed Howitzers Retrofit Support

Authority: 10 U.S.C. 2304(d)(1) as implemented by FAR Part 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

Amount:

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

Technical Representative:

Date: 13 Nov. 2017

Group Manager:

Date: 20 Nov. 2017

Center Director:

Date: 21 Nov 2017

Prepared by:

Date: 11/09/2017

Contracting Officer:

Date: 11/10/2017

Technical Representative:

Date: 11/13/2017

Requirements Representative:

Date: 11/13/2017

Control Number: CAO-18-0079

Legal Counsel:

Date: 22 Nov 2017

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

1. CONTRACTING ACTIVITY: US Army Contracting Command - New Jersey

2. DECSCRIPTION OF ACTION: Project Manager - Towed Artillery Systems (PM-TAS) requests award of a Firm Fixed Price (FFP) follow-on contract to Contract No. W15QKN-12-C-0122. The Government anticipates award of the new contract by December 2017. This procurement will utilize FY18 Weapons and Tracked Combat Vehicles, Army (WTCV) appropriations.

3. DESCRIPTION OF SUPPLIES/SERVICES: The Program Management Towed Artillery Systems (PM-TAS) has a requirement for fielding and retrofit support of the M777A2 and the M119A3 Howitzers. The estimated contract value including Options is . The period of performance will be 3 years, one base year as well as 2 additional option years. The services to be performed include serving as the program office field representative for fielded howitzers on the West Coast and performing retrofits and incorporating new design items at the major M777A2 and M119A3 manufacturing facilities. This support requires extensive knowledge and experience in large caliber artillery systems including:

hydraulic recoil, system operations, fire control installation, verification, testing, inspection procedures for critical system components and processes, which includes titanium weld inspection. Due to the current retrofit and fielding schedules, as well as the schedule of units in the field, these services are required for up to three years. This will ensure proper execution in a timely manner so that the artillery units have what they need to complete their missions.

To ensure successful execution, the Program Management Towed Artillery Systems (PM-TAS) requires additional resources to support many of these critical activities. This proposed acquisition will provide M777A2 and M119A3 Yuma Proving Ground (YPG) Field Support. The Contractor will be based at YPG, AZ, and will provide support to the fielding process, Digital fire control systems (DFCS) retrofit process, troubleshooting weapon operation failures, and crew and maintenance issues.

4. AUTHORITY CITED:

10 U.S.C. 2304(c)(1) as implemented by FAR Part 6.302-1 -- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

5. REASON FOR AUTHORITY CITED:

(a) As described at FAR 6.302-1(a)(2), when the supplies or services required by the agency are available only from one responsible source, or for DoD, NASA and the Coast Guard, from only one or a limited number of responsible sources, and no other types of supplies or services will satisfy agency requirements, full and open competition need not be provided for.

The following subparagraphs provide the rationale for use of the authority under FAR 6.302-1, only one responsible source and no other supplies or services will satisfy agency requirements. Paragraph 6.302-1(a)(2)(iii)(B) applies when the agency’s need for the services may be deemed to be available only from the original source in the case of a follow-on contract for the continued provision of highly specialized services when it is likely that award to any other source would result in (B) unacceptable delays in fulfilling the agency requirement.

In accordance with the authority cited above, the M777A2 and the M119A3 Towed Howitzers Retrofit Support contract will be solicited on a sole source basis and award made to TD Solutions, Inc., 4851 E. County 8-1/2 ST, Yuma, Arizona 85365 based on the following:

FAR 6.302-1(a)(2)(iii)(B) Unacceptable Delays: The Program Manager for Towed Artillery Systems (PM-TAS) is currently in a phase of its program in which many critical activities are occurring, M777A2 and M119A3s are being fielded to Army units; and there are ongoing retrofits related to product improvements and engineering change actions. Repairs and sustainment are also a crucial requirement in the life cycle of these systems. Substantial time would be required to gain expertise on the M777A2 and M119A3 howitzer, and the testing and inspection procedures described above.

The incumbent Contractor has the unique skills and experience to provide the necessary support. The incumbent Contractor has extensive knowledge and experience in large caliber artillery systems, hydraulic recoil, system operations, fire control installation, verification, testing, inspection procedures for critical system components and processes (including titanium weld inspection). In addition, the contractor has extensive design and manufacturing skills to fabricate unique tools for both field and shop use.

This delay will negatively impact the ability to conduct timely retrofits of fielded howitzers to the Army and Marine Corps. This is unacceptable and would cause serious delays in the implementation of critical obsolescence and performance enhancements thus causing harm to the U.S. Government and the Warfighter. The following provides additional insight into the delays that would be caused should a new contractor be hired to perform the duties of this contract:

Retrofit experience - The incumbent Contractor is currently the retrofit team leader for all West Coast and Pacific OCONUS M777A2 & M119A3 howitzers. The contractor is responsible for installation and inspection of retrofits and Modification Work Order (MWO) kits, coordinating various field site visits, assigning workloads to the retrofit teams, design, fabricate and manufacture any special tools and equipment to support the various tasks for the retrofit effort to include the installation and upgrades to the current DFCS fire control system. In addition, at the completion of each site visit he conducts an out brief to the Unit commanders which summarizes all the modifications done to the equipment. The Contractor’s efforts have enabled the successful application of retrofits and have helped ensure that the M777A2 and M119A3 howitzers are meeting the latest configuration. Which allows for the systems to be readily deployable for in-theatre operations.

Titanium Weld inspection - Titanium weld inspection is a very specialized and unique ability. The main structural components of the M777A2 and M119A3 howitzer are fabricated with titanium. The incumbent Contractor’s expertise in titanium weld inspection has enabled them to quickly assess questionable welds on the M777A2 and M119A3 howitzer, and to make a determination as to whether welds needed further scrutiny. The contractor’s expertise and contributions in this area has contributed to the M777A2 and M119A3 program’s ability to acceptance test 10 howitzers per month at YPG.

Expertise on design and maintenance of the M777A2 and M119A3 howitzer.

The incumbent Contractor has worked on the M777A2 and M119A3 howitzer and its predecessor for over ten years. The Contractor is an expert on many parts of the howitzer, including the critical hydraulic operating system and the recoil operating system. The Contractor’s expertise on the design and maintenance of the howitzer has enabled them to quickly diagnose and repair problems as they arose during M777A2 acceptance testing. The success of the M777A2 acceptance testing program and the ability of the Program Management Towed Artillery Systems (PM-TAS) to accept and field M777A2 howitzers on schedule is due in large part to the contributions of the contractor.

Familiarity with YPG maintenance and testing facilities, and YPG processes.

The incumbent Contractor has worked at YPG for over 40 years and the contractor’s familiarity with the YPG maintenance and testing facilities has proved invaluable in overcoming numerous technical issues and delays associated with acceptance testing of the M777A2 howitzer. Incumbant contractor possess all the proper clearances, training certificates, and security access to immediately begin performing retrofits and access YPG machine shop facilities. Again, this has contributed tremendously to the success of the M777A2 acceptance testing and the ability of PM-TAS to field M777A2 howitzers on schedule.

The incumbent Contractor has become a key member of the de-processing team in which they are involved with performing the Limited Technical Inspection of the new equipment with the receiving Unit as well as the installation and inspection of the Prime Mover Truck modification required. In addition the contractor is involved with all Basic Issue Items and Special tool and Test Equipment pre ship inventory and pack at YPG as well as the transfer and sign off to the receiving unit, these items in total are in excess of 3,500 items.

The incumbent Contractor’s expertise in fabricating, machining, testing and finishing of prototype projects enables both the M777A2 and M119A3 howitzer design teams to conduct efficient operations during developmental, test and acceptance activities. The contractor’s special skills will be critical in the success of several key Joint Program Management Office events to include evaluating product improvement to the M777A2 and the M119A3.

The incumbent Contractor possess all the proper clearances, training certificates, and security clearances to access YPG maintenance and fabrication facilities which provides an extensive array of fabricating tools and the technology that allows the contractor to quickly and competitively meet our fabrication needs; this includes complete welding services and the ability to rebuild or recondition older equipment and one-of-a-kind special tools. Reconditioned items are re-introduced to the work force at much less the cost of newer systems and much quicker. The contractor’s knowledge of our system’s performance envelopes provides for quality rebuilds and fabrications that are on time and at competitive costs. A new contractor would be required to obtain all necessary documentation to access the facility and utilize each machine within the facility immediately delaying current retrofit schedule.

(b) Alternatives:

(i) Two (2) potential procurement strategies to satisfy the requirement have been analyzed. One (1) strategy is a sole source award to TD Solutions and the other is full and open competition for the retrofit and fielding support. Any source other than TD Solutions would have new personnel subject to a prolonged learning curve in order to obtain the skill level and technical expertise required to perform the retrofit and fielding support of the M77A2 and M119A3. TD Solution personnel already possess the necessary level of access, expertise, experience, and familiarity with the current systems. Award of a sole source contract to TD Solutions is the only alternative that assures timely completion of requirements for the PM TAS mission to provide fielding and retrofit support of the M777A2 Lightweight and M119A3 Light Towed Howitzer.

(ii) Schedule Risk: It is estimated that competition of this contract would cause a schedule delay of . It would take to train another contractor on the retrofit and fielding support required for this program. A new contractor that has no experience with the systems would have to learn and understand the systems, the testing and inspection procedures described above. The break in service will prevent the Warfighter from being fielded the systems with the most current performance enhancements. Fulfilling this requirement with a sole source award to TD Solutions would result in the Government’s requirements for Retrofit Support being met.

(iii) Cost Risk: Any source other than TD Solutions would require costs associated with training new personnel. A Sources Sought notice, W15QKN-17- X-1812 was conducted for market research which showed the increase cost the government would incur if a different source was awarded this contract. These costs include the additional costs of acquiring multiple sources to provide support on the range of functions for the YGP Fielding, Retrofit and West Coast FSR support. The increase costs are as shown in the market research section below. Therefore, fulfilling this requirement with a sole source contract to TD Solutions is the only alternative that will meet cost requirements.

(iv) Performance Risk: A new contractor that has no experience with the M777A2 and M119A3 systems would have to learn precise skills that would require hands on training for at least . Due to the current fielding and retrofit schedule and the inability to gain the knowledge any other way, performance of these efforts would be greatly compromised. The units may see unexpected delays and the howitzers themselves will not be as precisely maintained.

Conclusion: Full and open competition would present an unacceptable level of technical/performance, cost, and schedule risks. As a result, a sole source award to TD Solutions is the only way to satisfy this requirement. Award to any other contractor would cause unacceptable delays.

6. EFFORTS TO OBTAIN COMPETITION:

a) Effective Competition: This requirement is intended to be conducted on a sole source basis.

b) Subcontracting Competition: Subcontracting competition by the prime contractor will be maximized by the Contracting Officer through the publication of the solicitation notice required by FAR 5.201 and the contract will include FAR Clause 52.244-5 entitled “Competition in Subcontracting.”

7. ACTIONS TO INCREASE COMPETITION:

Full and open competition is not practical at this time for procuring of the fielding and retrofit support of the M777A2 and M119A3 Howitzers at Yuma Proving Grounds (YPG). A new vendor would experience an delay for to be able to provide retrofit support of the M777A2 and M119A3 Howitzers at Yuma

Proving Grounds (YPG) as well as incurring substantial duplication costs. As part of sustainment activities for the M777 Howitzer, the Government will review the howitzer for continued supportability and obsolescence, which will include a review of Fielding and Retrofit support.

8. MARKET RESEARCH:

From February to October 2017, the Government canvassed the industrial community, both domestic and foreign, in order to obtain the latest information concerning the availability of a source to meet retrofit and fielding support requirements. Members of PM-TAS, including the Technical Representatives and the Business Office, have canvassed the industrial community in order to obtain the latest information concerning the availability of the retrofit and fielding support for the M777A2 and M119A3 Howitzer. In accordance with Defense Federal Acquisition Regulation Supplement (DFARS) 205.205-71, DFARS 206.302-1(d), and DFARS Procedures, Guidance and Information (PGI) 206.302- 1(d), a market survey, The U.S. Army Contracting Command (ACC) – New Jersey on behalf of PM-TAS conducted market research via Source Sought Notice, W15QKN-17-X-1812 to understand industry capability for retrofit and fielding support. Two responses were received as a result of the Sources Sought Notice that was posted for 30 days on FedBizzOpps.com. The responses provided cannot fulfill the Government’s requirements in a timely or cost effective manner. It is recommended that this action be completed as a sole source effort because of substantial duplication cost and schedule delay.

The following companies were assessed during Market Research:

Technical Capabilities

Company Name Business Size/Type

1)

Not Capable has provided services to PM-TAS in the past, however, does not have the expertise to provide the range of support required for

YPG fielding and retrofit support. would not meet the current requirement. The areas of expertise required to meet the mission include the lengthy and proficient task of retrofitting the howitzers. Titanium weld inspection is also required and is a very specific skill which is acquired by many years of hands on effort. This same effort would not be able to be repeated without years of hands on experience, which is not available from . The requirement also necessitates access to the maintenance and fabrication facilities at Yuma, access to special tools, as well as an overall familiarity of YPG which is also not available from . If awarded to it is clear that there would be significant as well as a schedule impact due to a lengthy transition period allowing for development of expertise and training which would be necessary to meet the requirements.

4)

Not Capable was previously capable of meeting this requirement, which led to a sole source award. However, no longer retains the capabilities, training and extensive experience to meet the requirement. The areas of expertise required to meet the mission include the lengthy and proficient task of retrofitting the howitzers.

Titanium weld inspection is also required and is a very specific skill which is acquired by many years of hands on effort. This same effort would not be able to be repeated without years of hands on experience, which is not available from

. The requirement also necessitates access to the maintenance and fabrication facilities at Yuma, access to special tools, as well as an overall familiarity of YPG which no longer has and would be required to put individuals through the processes to have access. If awarded to . it is clear that there would be significant as well as a schedule impact due to a lengthy transition period allowing for development of expertise and training which would be necessary to meet the requirements.

9. INTERESTED SOURCES:

To date, no other sources have written to express an interest. The notices required by FAR 5.201 shall be published and any bids or proposals received shall be considered.

10. OTHER FACTS:

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.

Date: 13 Nov 2017

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. Certified cost and pricing data is required. The resulting proposal will be subjected to a formal technical evaluation, cost/price analysis and comparison to the Independent Government Cost Estimate (IGCE) that will be used to determine the anticipated costs are fair and reasonable.

Date: 11/22/17

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

Date: 11/22/17

APPROVAL

Based on the foregoing justification, I hereby approve the procurement of fielding and retrofit support for the Lightweight M777A2 Howitzer and M119A3 Howitzer 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)(iii)(B) subject to the availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Date: 11/22/17 Signature: ___