W31P4Q19FB003 LSJ REDACTED_Redacted.pdf

W31P4Q-19-F-B003 LSJ Control No: MZ-B-LSJ24-1704

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FAR 8.405-6 Limited Sources Justification Under the General Services Administration

Federal Supply Schedule Program

1. Contracting Activity: Army Contracting Command – Redstone Arsenal (ACC-RSA), Redstone Arsenal, AL 35898-5280.

2. Description of Action: The Apache Division of the Systems Readiness Directorate (SRD), Combat Capabilities Development Command (DEVCOM), Aviation & Missile Center (AvMC), Redstone Arsenal, Alabama, 35898, requests to non- competitively award a logical follow-on modification to PPT Solutions, Inc., 360B Quality Circle NW, Suite 210, Huntsville, AL 35806, Commercial and Government Entity (CAGE) Code 44WT1.

The SRD requests a ceiling increase of $5,123,409.92 with a period of performance (POP) extension for a total of 12 months on Task Order (TO) W31P4Q-19-F-B003 under the Expedited Professional and Engineering Service (EXPRESS) Blanket Purchase Agreement (BPA). This requirement is a Firm Fixed Price/Time and Material task order (TO) as follows:

Added Option Period Ceiling Increase POP Extension

OPT X, 6-Months $2,560,804.96 5SEP2024-4MAR2025

OPT X, 3-Months $1,281,302.48 5MAR-4JUN2025

OPT X, 3-Months $1,281,302.48 5JUN-4SEP2025

Total $5,123,409.92 12-Months

On 6 March 2019 this TO was awarded using competitive procedures under BPA GS00f422GA for technical and engineering services for a potential contract value of $18,996,186.35 with a POP of five years and six months inclusive of all options as well as the FAR 52.217-8 Option to Extend Services, if exercised.

On 21 September 2022, modification P00059, a Limited Source Justification (LSJ) was approved to increase the total potential contract value by $7,210,197.00 from $18,996,186.35 to $26,206,383.35 for continued support of the Apache Division requirement.

On 5 March 2024 modification P00087, the six-month to extend services in accordance with FAR 52.217-8 was executed to allow this task to continue form 5 March 2024 to 4 September 2024.

With the approval of this LSJ for $5,123,409.92 the revised potential ceiling amount will increase from $26,206,383.35 to $31,329,793.27 and will allow continued support of this TO if all options are exercised through 4 September 2025.

This ceiling increase and POP extension is needed and will minimize the risk of being unable to support SRD Apache critical missions. This increase will be supported using Research, Development, Test and Evaluation (RDT&E), Operations and Maintenance Army (OMA), Aviation Procurement, Army (APA) and Foreign Military Sales (FMS).

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3. Description of Supplies/Services: This effort provides Apache Division, SRD DEVCOM AvMC airworthiness, qualification, and engineering support to the Apache Attack Helicopter Project Manager’s Office (AAH PMO), and to other elements of the Life Cycle Management Center (LCMC), for U.S. Army Apache aircraft. This ceiling increase and POP extension will enable uninterrupted support for these critical technical support services until a follow- on TO can be awarded using competitive procedures. On 21 September 2022, an LSJ was approved to increase the ceiling from $18,996,186.35 to $26,206,383.35. Based on the current burn rate of for the past six-months, it is anticipated that the remaining ceiling will not be adequate to cover the anticipated requirements from 5 September 2024 to 4 September 2025.

The re-compete action for this TO is in process and the Contract Requirements Package (CRP) was submitted and received by ACC-RSA on 26 July 2023. The Government is in the process of evaluating the potential of competitively re-competing TO W31P4Q-19-F- 0495 and TO W31P4Q-19-F-B003 as a consolidated TO which would remain set-aside for small businesses. This new TO, which would be competed as 2024T-03 Apache/SOAD Engineering Support, is pending the outcome of the SSCM Technical Domain (Non-R&D) small business-on ramp protests. ACC-RSA received notification 10 June 2024 that three protests for the BPA On-ramp in the Technical Non-R&D Domain have been filed: 1 at the GAO level filed 28 May 2024 and two at the Federal Claims Court filed 30 May 2024. Currently, there are not enough small business contractors in the domain to set-aside requirements for small businesses. Therefore, until these protests are resolved, this requirement cannot be set-aside for small businesses.

This Limited Source Justification (LSJ) for additional time and ceiling of the current TO, W31P4Q-19-F-B003, will be sufficient to support requirements through the new POP of 4 September 2025, if all option periods are executed. The total estimated value of a six-month POP extension with two three-month options will be $5,123,409.92 dollars. The six-month POP extension beginning 5 September 2024 thru 4 March 2025 and two three-month optional period of performance extensions from 5 March 2025 to 4 June 2025 and 5 June 2025 to 4 September 2025 are to continue to fund the current TO until the anticipated award date of the new TO and prevent a break in service. The two three-months POP extensions are only intended to prevent mission failure, ensure economy and efficiency, and allow mission-essential efforts to continue until the protests are resolved and the Government’s recompete effort is complete. The requests are as follows:

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Initial Award Previous LSJ 21 Sep 2022

OPT X, 6-

Months

POP

Extension

5SEP2024

- 4MAR2025

OPT X, 3-

Month

POP

Extension

5MAR2025

- 4JUN2025

OPT X, 3-

Month

POP

Extension

5JUN2025

- 4SEP2025

Total

Labor Hrs

153,500 55,638 10,833 5,416 5,416 230,803

Labor $ 16,270,557.45 7,210,197.00 2,497,404.96 1,248,702.48 1,248,702.48 $28,475,564.37

Travel $ 850,000.00 0.00 53,400.00 27,600.00 27,600.00 $958,600.00

Material

$ GSA

135,000.00 0.00 10,000.00 5,000.00 5,000.00 $155,000.00

Non-

GSA $

15,000.00 0.00 0.00 0.00 0.00 $15,000.00

6-Month Option

1,725,628.90 0.00 0.00 0.00 0.00 $1,725,628.90

Ceiling 18,996,186.35 $26,206,383.35 28,767,188.31 30,048,490.79 31,329,793.27 $31,329,793.27

4. Authority Cited: Title III of the Federal Property and Administrative Services Act of 1949 (41 U.S.C. 251 et seq.) and Title 40 U.S.C 501, Services for Executive Agencies, as implemented by FAR 8.405-6(a)(1)(i)(C), in the interest of economy and efficiency, the new work is follow-on to an original Federal Supply Schedule order placed in accordance with applicable Federal Supply Schedule ordering procedures. The original order was not previously issued under a sole-source procedures.

5. Reason for Authority Cited: The proposed acquisition requires the use of the above cited authority FAR 8.405-6(a)(1)(i)(C) based on the following:

The reason for the authority cited in this Limited Sources Justification (LSJ) regarding PPT Solutions, Inc., 360B Quality Circle NW, Suite 210, Huntsville, AL 35806, Commercial and Government Entity (CAGE) Code 44WT1, is that the work to be performed during this POP extension and ceiling increase is a logical follow-on TO BPA GS00F422GA. The relationship between the initial order and the follow-on is logical in terms of scope, POP, and value. This LSJ supports the authority cited above as a logical follow-on to the existing W31P4Q-19-F- B003 TO, which was initially awarded 6 March 2019 in accordance with the applicable BPA. This acquisition is in the interest of economy and efficiency because the ceiling increase prevents costly and unacceptable disruption of services. The request is required to ensure that all requirements associated with this TO continue to be economically and efficiently performed until a new TO can be competitively awarded.

The relationship between the initial order and the follow-on is logical in terms of scope for the following reasons. The scope of the contract is unchanged. The ceiling increase and the POP extension doesn't change the original effort and the technical skill set is unchanged.

The contractor PPT Solutions, Inc., provides essential airworthiness technical and analytical support. The contractor has employees which have significant U.S. Army

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operator (aviator) and/or maintenance experience with the AH-64 aircraft. All on-site employees, except for the administrative support, have multiple years of hands-on aircraft experience and understand how the aircraft are used, how the aircraft are employed, plus how the aircraft are maintained and operated. The training background alone required to obtain this type of experience is six months to one year just to be qualified to obtain the experience. Many of the employees have over twenty years of this specific experience.

Without this experience, the contractor would have no relatable understanding of what is important with respect to airworthiness. It would have no relatable understanding of safe operational practices of the AH-64 aircraft, no understanding of how airworthiness direction is interpreted by current aircraft operators and maintainers, and no relatable understanding of US Army doctrine on how the Army uses these aircraft. This understanding is critical to perform the Performance Work Statement (PWS) tasks. Given this background is scarce and highly applicable to airworthiness, the team is uniquely qualified to perform the airworthiness assessments in accordance with the PWS. This contractor can meet the government's requirement timely, without having to find employees with these qualifications, and without interruption of support to the SRD airworthiness mission.

The relationship between the initial order and the follow-on is logical in terms of efficiency for the following reasons. This acquisition is in the interest of economy and efficiency because the increase in ceiling will prevent an unacceptable disruption of services. Without the current PPT Solutions contractor personnel, Apache Division would face difficulties in providing the annual average of over 1000 technical airworthiness positions/directions.

There are 24 federal employees and 17 on-site contractor employees in this division providing airworthiness support. Losing the contractor staff would directly impact the determination of airworthiness positions for the AH-64 fleet by as much as 30%. The airworthiness positions are required by regulation to safely operate and maintain this aircraft fleet and will impact soldiers’ lives if not provided timely. Increased accidents and fatalities will occur in the fleet without the engineering evaluation and release critical/appropriate airworthiness positions/directions. There can be absolutely no delay in filling the U.S. Army field airworthiness needs as the team provides real-time analysis in support of airworthiness positions/directions for the AH-64 aircraft.

6. Efforts to Obtain Competition:

a. Effective competition. No competition is anticipated for this action. The SRD has prepared a re-compete package and was submitted to ACC-RSA 26 July 2023 for a new TO under the EXPRESS Technical Domain which contains all applicable clauses required by FAR, DFARS and AFARS relative to competition and subcontracting. The re-compete effort is currently on-going. Currently being protested as detailed in paragraph three.

b. Subcontracting competition. To ensure the contractor obtained competition in subcontracting, all applicable clauses required by FAR, DFARS, and AFARS relative to competition in subcontracting were included in the current task order and will continue to apply for the extended options and ceiling increase.

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7. Actions to Increase Competition: No actions have been taken to seek competition for this modification, since the requested noncompetitive award is due to an increase in effort for continuation of work while ethe recompete is in process. The ceiling increase and POP extension is only intended to prevent mission failure: ensure economy and efficiency; and allow mission-essential efforts to continue until the Government’s re-compete effort is complete.

8. Market Research: IAW FAR Part 10, market research was conducted on 26 February 2024 by the COR who utilized personal knowledge of the ACC-RSA EXPRESS Program, contacted knowledgeable persons in the Government regarding the commercial nature of the requirement, and reviewed the ACC- RSA EXPRESS BPA Technical Domain sources list. Both program experience and personal knowledge were used to determine that no other source is capable of mobilizing in time to meet the requirement within the needed timeframe. FAR Part 12 will not be used in this effort, but the guidelines and clauses are contained in the ACC-RSA EXPRESS BPA.

9. Other Facts:

a. Procurement history:

(1) Task Order W31P4Q-14-A-0009-0001 was competitively awarded on 17 April 2014 for a period of five years ending 16 April 2019 with a ceiling of $14,044,335.00 to MCR Federal LLC.

(2) Task Order W31P4Q-19-F-B003 was competitively awarded on 6 March 2019 for a period of five years ending on 5 March 2024 with a total ceiling of $18,996,186.30 to PPT Solutions, Inc.

(3) On 21 September 2022 a LSJ was approved for TO W31P4Q-19-F-B003 to increase the NTE ceiling from $18,996,186.30 to $26,206,383.35.

(4) The authority previously cited was not less than full and open competition.

(5) No prior justification was prepared, as it was awarded using full and open competition.

(6) There are no changed circumstances causing this action to now limit the sources.

(7) There are no unusual patterns revealed by the history to provide explanation for.

(8) No justification was used to support the procurement made before this one as it was awarded under full and open competition.

b. Other facts: None.