A02_JA_ARC_220_8-27_Redacted.pdf

FOR OFFICIAL USE ONLY

JUSTIFICATION REVIEW DOCUMENT

FAR PART 6 JUSTIFICATION AND APPROVAL FOR OTHER THAN

FULL AND OPEN COMPETITION

Program/Equipment: Engineering services for the Army-Navy/Aviation Radio Communications-220 (AN/ARC-220) High-Frequency (HF) radio and components.

Authority: 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.

Amount:

Prepared by: Alex Nieves DSN:

Systems Engineer Email:

Date: 1 Jul 2019

Contracting Officer: Megan Grigas Contracting Officer Email:

DSN:

Date:

Technical: Alex Nieves Systems Engineer Email:

DSN:

Date:

Requirements: Allison Dutton Item Manager Email:

DSN:

Date:

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

Program Manager:

Typed Name: Robert J Lang Jr

DSN:

Legal Counsel:

Typed Name:

DSN:

Command Advocate for Competition:

Typed Name: Cynthia Jackson

DSN:

Schedule is critical to achieving system redesign success. To achieve this upon completion of the redesign the system must undergo multiple tests and qualifications in order to obtain Airworthiness and JITC certification. Ensuring this contract is awarded in FY-19 enables the LCMC to maintain systems availability in a timely manner.

In order to provide the services required to support the system’s obsolescence redesign, obtain AWR and JITC certification, access to the TDP and software source code is required. The TDP and software source code is needed to provide updates to the BOMs and address any system issues encountered during the redesign testing. This level of knowledge required and access to the TDP is needed to provide a root cause analysis of any issue observed to determine a true failure and mitigation strategy from a hardware and/or software perspective. Without access to this TDP, no other source than Collins Aerospace can provide the necessary engineering services to support redesign, updates to BOM, assessments of system interoperability issues, AWR qualification testing and JITC certification. Also, the extensive knowledge as the OEM and experience with the system to develop a redesign as well as the qualification and certification processes to address the current obsolescence issues within the schedule and independent government costs estimates requires this to be completed by the OEM as the proposed source. The current effort’s funding is limited by the funds approved by Army Materiel Command’s (AMC) AWCF to address obsolescence for this effort. The AWCF funds must be exhausted within fiscal year 2019 per Army Material Command (AMC) metrics and goals.. The AWCF funds for fiscal year 2019 have a limited window for obligation and must be used in fiscal year 2019, and without this funding source the mission cannot be met. Collins Aerospace is the only source that will be able to provide the services needed, and time required.

Any other source would require an estimated 3 to 5 years to reverse engineer the system, not including software, and another 2 to 3 years to qualify the designs of the components before they can start to address obsolescence issues. Completion of the redesign of the A6 CAA is needed by 2021 to correlate with critical software updates and reduce further impacts due to obsolesce of the A6 CAA. No other source could be identified currently that would have the knowledge and capability to be able to do the work within the schedule required and the funding available.

b. Currently, the Acquisition Method Code (AMC) is “3” meaning the requiring activity has instructed that the Government to acquire the items from the actual manufacturer or vendor, including a prime contractor who is the actual manufacturer. This AMC designation is to maintain standardization across supply systems and safety requirements, as a result of which the OEM is the only available, qualified source. The TDP is presently unavailable and the only way this code will change if the TDP comes available for full and open competition.

c. The Acquisition Method Suffix Code (AMSC) is “D” meaning that the data needed to acquire this part competitively is not physically available; it cannot be obtained economically, nor is it possible to draft adequate specifications for a competitive acquisition.

d. This particular action is for the current upgrades and redesigns to the RT-1749. In order to compete this requirement and complete this action, it would require the government to obtain the complete TDP for the ARC-220 and provide this as GFI, as well as GFE, to the competing contractor. In turn, the competing contractor would need time to develop, establish and qualify manufacturing and production lines to initially prove they are able to develop the systems with the appropriate requirements, and they also would have to obtain AWR and JITC certification on the platforms. The costs to obtain the TDP is dependent of the level of technical data to be procured with historical estimates cost prohibitive. This may not include potential yearly licensing fees involved with the firmware/software to run the system and sustainment efforts for the upgrades to the firmware/software. A new contractor would need minimum 3 years on contract, separate from the time and costs for the Government to obtain the TDP, to establish, qualify and maintain a manufacturing and production line, as well as continue support for the ARC-220 in sustainment. With the system in sustainment and most redesign efforts completed in order to support the current system, the time and costs incurred as a result of awarding to another contractor is not justifiable given the current funding situation.

Sections e and f discuss current Department of the Army (DA) initiatives to continue supporting requirements for HF radio capabilities to include advanced HF technologies.

The materiel developers are tasked to research and provide a materiel solution that will meet ground and air requirements. These actions potentially can provide for competition for HF aviation to replace the ARC-220, but do not address the current requirement to support obsolescence for the current ARC-220 system that is managed and sustained by

CECOM.

e. Alternate solutions to the ARC 220 are being sought by the Army. The Director of the Network Cross Functional Team (N-CFT) issued a memorandum for the Program Executive Officer Command, Control, and Communications-Tactical (PEO C3T) on 14 March 2019 for Rapid Fielding and Prototyping for High Frequency (HF) Communications. This memorandum is requesting PEO C3T develop a Middle Tier of Acquisition (MTA) program for HF communications. Under the MTA, programs subject to the guidance shall not be subject to the Joint Capabilities Integration Development System (JCIDS) manual and DoD Directive 5000.01, “The Defense Acquisition System,” except to the extent specifically provided in the implementing guidance. This memorandum identified a need to rapidly field a solution for demonstration in an operational environment to meet HF requirements to include Army aviation. The current commercial off the shelf (COTS) radios are readily available and are believed to meet the current military HF radio needed for ground platforms (this radio is presently not interoperable to meet the requirements of the Aviation HF radio, the ARC 220). The memorandum identified the procurement of the AN/PRC-160 radios. This is not currently a viable solution for Army aviation since it is only a ground radio and not developed for aircraft. This radio is not qualified and certified on aviation platforms which is currently at minimum a 1 to 2 year process and the MTA is only addressing a demonstration of the radio which will take at least a year to complete. This also does not address the sustainment of the current ARC-220 that is currently fielded and in sustainment as the only AWR qualified and JITC certified HF communication system for Army aviation.

There are currently 3500 systems fielded with another 700 systems currently in-line to be fielded on newer platforms. For now, any current efforts to replace the ARC-220 are being addressed by PEO C3T’s PM Tactical Radios (PM TR) via a demonstration proposed under the MTA being developed. This action will take over a year to demonstrate and the demonstration currently does not address any additional requirements to support integration onto Army aviation platforms and the cost and schedule to provide AWR qualification and JITC certification. This is not an acceptable alternative to the work needed to support the current sustainment of the ARC-220.

f. The DoD Rapid Innovation Fund (RIF) FY19 Broad Agency Announcement (BAA) addresses Advanced HF Communications requirements under BAA # ARMY-FY19-22- NCFT02. RIF funds mature technologies to transition into defense acquisition programs.

Typically 90% of RIF awards go to small businesses; however, Collins Aerospace along with others such as Harris, Raytheon, General Dynamics have submitted white papers addressing the requirements sought after by the RIF for Advanced HF Communications.

These white papers are still in review. New requirements for a wideband version of HF waveforms to increase capacity, modernized IP interfaces, modernized cryptographic system, and cooperative diversity to enhance interoperability between air and ground HF communications. This is a viable option to replace the current ARC-220 with the Advanced HF Communications system, but this is managed and run by the DoD RIF program and N-CFT.

However, the Advanced HF system this is not a viable option to replace obsolete parts within the ARC-220. Form, fit and function testing will take over a year to demonstrate and does not address any additional requirements to support integration onto Army aviation platforms or the cost and schedule to provide AWR qualification and JITC certification. This is not an acceptable alternative to the work needed to support the current sustainment of the ARC-220. The redesign is to support the current fielded system until a viable upgraded replacement is identified and then programmed to be fielded and eventually replaces, via attrition, the current system.

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. Further delays in obsolete part replacement will result in loss of long range aircraft communication and grounded aircraft resulting in mission failure.

Immediate award to another vendor will cause the Government to suffer considerable cost increases and significant schedule delays due to providing any new vendor transfer of government furnished information/equipment (GFI/GFE) and other deliverables from the current contractor to reverse engineer the system and associated software. This inexperience factor and lack of proprietary technical data on the ARC-220 impacts costs and schedule for the services requested in the period of performance needed.

Schedule is critical to achieving system redesign success. To achieve this upon completion of the redesign the system must undergo multiple tests and qualifications in order to obtain Airworthiness and JITC certification. Ensuring this contract is awarded in FY-19 enables the LCMC to maintain systems availability in a timely manner.

6. Efforts to Obtain Competition: The Contracting Officer shall publish the notices required by FAR 5.201 and any bids or proposals received shall be considered. CECOM ILSC will continue to conduct market research, attend trade shows, technical interchange meetings, consult with the Network Cross-Functional Team (N-CFT), C5ISR Center, and PM Tactical Radios to obtain additional information that would provide more opportunities to encourage and obtain competition.

a. Effective Competition: As this is a sole source action, effective competition is not applicable due to TDP ownership as well as testing of proprietary software.

b. Subcontracting Competition: FAR 52.244-5, Competition in Subcontracting, will be included in the proposed contract.

7. Actions to Increase Competition: The Government will continue to conduct market research to ascertain if changes occur in the marketplace that would enable future actions to be competed. CECOM ILSC will actively monitor competitor developments and redesigns of possible solutions via technical conferences, white papers and cost-benefit analysis of emerging technologies. The cost of the TDP will continue to be monitored by the Government to see if it will ever be in the best interest of the Government in order to continue to sustain the current system and allow for alternate sources to procure, repair, and mitigate obsolescence issues for the ARC-220 system in the future. The unlimited rights to the entire technical data package will allow Collins Aerospace to conduct the services needed on behalf of the government to fully qualify, certify and produce an upgraded ARC-220 system to address obsolescence issues and support availability and fielding of HF communications for Army aviation.

a. Acquisition Data Availability: The Government has the Collins Aerospace part numbers for these items.

8. Market Research: 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 sources sought was posted to Federal Business Opportunities website on 17 July 2019 with a response due date of 24 July 2019. This market survey was issued to obtain any interest from industry and see who has the capability to perform the engineering services required to obtain AWR for the upgraded components within the ARC-220 system. The Contracting Officer Representative notified industry that the Government did not possess any releasable technical data for the ARC-220 and that responses must include documentation, such as drawings, test results, and technical information, which demonstrates that the item will satisfactorily perform for the purpose intended by the Army. Sources sought requested to do redesign of the circuit cards within the ARC-220 due to obsolescence as described in Section 3.

The government received one (1) response from vendors to the market survey. Collins Aerospace responded on 24 July 2019.

a. Collins Aerospace responded stating that as the current manufacturer of the ARC- 220 system and its associated upgrades, they are able to perform the required engineering support services and possess the proper documentation required to make the necessary changes to the system in order to obtain the AWR, JITC certification and subsequent Production Readiness Review (PRR). The unlimited rights to the entire technical data package will allow Collins Aerospace to conduct the services needed on behalf of the government to fully qualify, certify and produce an upgraded ARC-220 system to address obsolescence issues and support availability and fielding of HF communications for Army aviation.

9. Interested Sources: In accordance with FAR 5.201, a synopsis will be posted to the FedBizOps page. Any proposals that are received will be evaluated. Additionally, In accordance with FAR 6.305, this justification shall be publicly available at the government point of entry www.fedbizopps,gov, available for a minimum of 14 days.

10. Other Facts:

a. Procurement History:

W56JSR-17-C-0014

This contract was awarded as a sole-source under FAR 6.302-1, J&A control number JA-E-17-454, on 18 September 2017, to Collins Aerospace to complete the Airworthiness Release (AWR) qualification and Joint Interoperability Testing Center (JTIC) certification of the upgraded redesigned A7 and A3 CCAs, that addressed obsolescence in the previous ECP, in the RT-1749 for production and continue to address report on new obsolescence issues that may require an ECP. In order to conduct this effort, the TDP for the software and hardware was needed and Collins Aerospace is the sole owner of the TDP. The CPFF contract was awarded on 18

September 2017 in the amount of with a twenty four (24) month period of performance.

The J&A for contract W56JSR-17-C-0014’s paragraph addressing the actions taken to increase competition stated, “The Government will continue to conduct market research to ascertain if changes occur in the marketplace that would enable future actions to be competed. CECOM ILSC will actively monitor competitor developments and redesigns of possible solutions.”

Those actions were accomplished by conducting market research as described under section 8 of this J&A. Additionally, a broad agency announcement was released to determine if alternate, competitive solutions exist that could meet the Army’s High Frequency (HF) requirement. See section 5 paragraphs e & f for further details.

W15P7T-14-C-E605

This contract was awarded as a sole-source contract under FAR 6.302-1, to Collins Aerospace to fully qualify the upgraded and redesigned A7 and A3 CCAs for production in the RT-1749. The vehicle also developed and fully qualified the A3 CCA for the radio controller as well as provided for Full Qualification Testing of the software. In order to conduct this effort, the TDP for the software and hardware was needed and Collins Aerospace is the sole owner of the TDP. The CPFF contract was awarded on 30 September 2014 in the amount of , with a twenty four (24) month period of performance.

W15P7T-10-D-D413/0010

Task order W15P7T-10-D-D413-0010, was competitively awarded on 26 September 2012 to CACI Technologies Inc. on the Rapid Response Third Generation (R2-3G). The CPFF order was awarded in the amount of to address an ECP required to update the Hardware/Software to support a redesign of the A7 and A3 circuit card assembly (CCA) for the RT-1749 ARC-220 Radio to address obsolescence. The period of performance was twenty four months.

Collins Aerospace is not one of the prime contractors on the R2-G3 contract. CACI, who is on the R2-G3, was selected as the prime contractor with Collins Aerospace designated by CACI as the only provider of the services to perform the work needed as a subcontractor. CACI subcontracted the entire effort to Collins Aerospace, resulting in excessive pass-through charges to the government.

DAAH23-03-D-0015-0088

This task order DAAH23-03-D-0015-0088 was a sole-source award under FAR 6.302-1, to Collins Aerospace on 2 August 2012, to address an ECP required to update the software to improve operability of the ARC-220 to include state of the art technologies and align with the exportable ARC-220 Radio software. In order to conduct this effort, the TDP for the software was needed and Collins Aerospace is the sole owner of the TDP.

The cost-plus-fixed-fee (CPFF) order was awarded in the amount of with a period of performance of 12 months.

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.

Typed Name: Alex Nieves Date:

Title: Systems Engineer 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.

Typed Name: Allison Dutton Date:

Title: Item Manager Signature:

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable.

This determination will be made using the following: ☐ cost analysis ☐ price analysis ☐ should cost ☒ IGCE ☐ audit: ☐ other:

As a part of this basis, certified cost or pricing data:

☐ will be required.

☒ will not be required and the following exception applies (FAR 15.403):

☐ Prices that will be agreed upon are based on adequate price competition.

☐ Prices that will be agreed upon are based on prices set by law or regulation.

☐ A commercial item is being acquired.

☐ A waiver has been granted by the head of the contracting activity (HCA) in accordance with DFARS PGI 215.403-1.

☐ The contract action is a modification to a contract or subcontract for commercial item(s).

☒ The estimated cost of the contract action is less than the threshold for certified cost or pricing data.

Typed Name: Megan Grigas Date:

Title: Contracting Officer Signature:

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Typed Name: Megan Grigas Date:

Title: Contracting Officer Signature:

Approval

Based on the foregoing justification, I hereby approve the procurement of Engineering Services for the Army-Navy/Aviation Radio Communications-220 (AN/ARC-220) High- Frequency (HF) radio and components for the estimated amount of on an other than full and open competition basis pursuant to the authority of 10 U.S.C.2304(c)(1) and FAR 6.302-1(a)(2)(ii)(A) Only One Responsible Source – Follow-on, subject to availability of funds, and provided that the services or property herein described have otherwise been authorized for acquisition.

Special Advocate for Competition Date:

Cynthia A. Jackson Signature: