YPG JA 2025 YPG 2025-5_Rev 1 Final_Redacted.pdf

Control Number: YPG 2025-5

Justification Review Document for Other than Full and Open Competition - FAR Part 6

Program/Equipment: U.S. Army Test Evaluation Command (ATEC) - Flight Services Division, U.S. Army Yuma Proving Ground (USAYPG) requests Aviation Support Services.

Authority: 10 United States Code §3204(a)(1) as implemented by Federal Acquisition Regulation 6.302-1 - Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

Amount: $599,277.45

Prepared by: DSN: 899-6163

Date: 26 Mar 2025

Contracting Officer: DSN: 899-2357

Technical: DSN: 899-2653

Requirements: DSN: 899-6790

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

Program Manager: DSN: 889-6790

Date: See digital signature

Small Business Professional: DSN: 760-380-3893

Local Legal Counsel: DSN: 899-2960

Director, MICC-YPG DSN: 899-6903

Justification and Approval for Other than Full and Open Competition – FAR Part 6

1. Contracting Activity: U.S. Army Mission and Installation Contracting Command - Yuma Proving Ground (MICC–YPG), U.S. Army Yuma Proving Ground (USAYPG), Yuma, Arizona.

2. Description of Action: U.S. Army Test Evaluation Command (ATEC) - Flight Services Division, U.S. Army Yuma Proving Ground (USAYPG) requests approval to extend the Firm-Fixed-Priced (FFP) contract W91151-19-C-0007 for Aviation Support Services (AVSS) with LOGMET, LLC. The Flight Services Division is requesting a 1.5-month extension with a Period of Performance (PoP) of 01 April 2025 through 15 May 2025 and will be funded using Fiscal Year (FY) 2025 Research, Development, Test and Evaluation (RDT&E) funds. This 1.5-month (45-day) extension is required to allow sufficient time to conclude proposal evaluations and execute procurement for the AVSS follow-on action. The Contracting Office is experiencing a longer time than originally anticipated to conduct proposal evaluations but is currently projecting a contract award date of 24 April 2025. Thus, this contract modification to extend the PoP will allow for the continuation of mission essential AVSS located at USAYPG.

3. Description of Supplies/Services: The USAYPG is a Major Range and Test Facility Base (MRTFB) that conducts RDT&E missions for Department of Defense (DoD), commercial customers and other agencies that have formal agreements with USAYPG.

The contractor provides AVSS at USAYPG, to provide administration, management, and operational support in the areas of ground and flight operations, aviation maintenance, and airfield services.

Table 1

Period Period of Performance Estimated Value 1.5-month extension 01 April 2025 through 15 May 2025 $599,277.45 Total Value $599,277.45

4. Authority Cited: 10 U.S.C. 3204(a)(1), as implemented by FAR 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. For DoD, NASA, and the Coast Guard, 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 an award to any other source would also result in unacceptable delays and negatively affect USAYPG's support of mission tests as they will need to recruit and hire qualified and cleared personnel. There would be no Phase-out period and no guarantee of institutional knowledge which gives us risk of mission failure. Not having qualified personnel, i.e. Air Traffic Controllers or Aircraft Mechanics, would shut down the airfield causing all aircraft and the SOCOM Jump School to be grounded and scheduled mission tests to be delayed or cancelled. This would be a detriment to the government as the cost would be significant due to the impact on the mission tests, other contracts, and personnel affected and lack of maintenance on the aircraft. The delays could range from 30-45 days or more, depending on the strategy of the new contractor, the scheduled tests and maintenance. The average duration of the Flight Division’s participation is approximately one week where contractor support is required, but any initial delays caused by unfamiliarity with procedures in the Flight Division’s execution of their aspects of the test has a corollary to furthers delays to the other facets of the test.

Property inventory delays of at least two weeks and Ground/Flight Operations Standard Operating Procedures (SOP) final approvals prior to flight line operations are estimated at approximately two weeks.

The Flight Services Division initially requested a modification to extend the contract for 1 month with 2 one-month options. However, it is determined that it is in the Government’s best interest to request a modification for a 1.5-month extension (45-days) due to the change in the anticipated award date to 24 April 2025. This request for modification allows time to address the delays in procurement milestones which derived from extensive proposal evaluations. Moreover, the extension is critical as it ensures that there is no disruption in AVSS, allows the incumbent Contractor to continue operations and maintenance services, while allowing the Contracting Office sufficient time to procure required services.

This extension of the current contract will allow for continued support of aviation support services while the follow-on contract is awarded, and transition is made to another contract while retaining the ability to provide a consistent level of effort without a break in service. Without continuing contract coverage, disruption of on-going requirements will result in critical mission failure and unacceptable delays in other areas, critical tests, and evaluation support, which will negatively impact testing.

Any break in service is unacceptable and will also disrupt critical functions in support of the mission at USAYPG. This action will prevent a break in service while the follow-on contract is awarded, and transition is made to another contract.

b. Alternatives.

1.) Suspension of services: Suspension of operations is not a viable option. The requirement for AVSS is directly tied to the vital needs of support of the Flight Services Division. The impact of the failure to extend the contract would immediately result in the cessation of support of all US Army Test and Evaluation Command (ATEC) assigned test support missions at Laguna Army Airfield (LAAF), USAYPG. Failure to provide these services would have a major impact on USAYPG supporting tenant activities and mission test and evaluation events.

2) Use in-house resources: This is not a viable option. Government personnel cuts and shifting to reliance on contractors to perform critical functions over the years have resulted in the transference of technical expertise from the Government to private industry. The amount of time required to recruit and hire qualified Government personnel through the civilian personnel system, and then train the personnel required to support current and upcoming requirements, render this alternative unrealistic and unachievable in the time available to do so. Additionally, there are no current in-house Government employees who have the expertise or experience to fulfil the requirements of the AVSS contract.

3) Competitively awarding a bridge contract: The current contract expiration date is one week away; this is not a viable alternative. A follow-on award of a competitive contract is currently underway. There is insufficient time for MICC-YPG to complete an interim contract before the current AVSS contract expires on 31 March 2025. A new contractor would need a transition period greater than the time remaining on the current contract to become familiar with the AVSS contract requirements. A new contractor would need to recruit, relocate, transfer property, staff, develop operations, and acquire other resources.

c. Impact if justification is not approved. Any break in service is unacceptable and will disrupt operations at USAYPG. Without the continuity of the AVSS contract would immediately result in the cessation of support of all ATEC assigned test support missions at LAAF. These tests have a direct impact on the US Army’s world-wide mission.

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.

a. Effective Competition: The current AVSS contract was awarded following a competitive source selection. This modification is an extension to the existing contract.

A Sources Sought Notice (SSN) was posted on SAM.gov from 16 January 2025 through 21 January 2025 which resulted in no companies being capable of providing the required AVSS. Only one response received from . and the Requiring Activity deemed the vendor as not capable of providing the required services. See Table

2. Therefore, this is a sole source action as effective competition is not possible.

b. Subcontracting Competition: The current AVSS contract is a Service-Disabled Veteran-Owned Small Business (SDVOSB) set aside, and the incumbent 100 percent self-performs.

7. Actions to Increase Competition: As indicated in the preceding section (6.a) above, the current AVSS contract was awarded following a competitive source selection. The approval of this Justification and Approval (J&A) will provide the 1.5-month (45-day) extension which will allow the Contracting Office sufficient time to conclude evaluations, procure the required services, and prevent a break in service while the procurement of the follow-on contract is completed with a projected award date of 24 April 2025. An SSN was posted to SAM.gov.

8. Market Research: In accordance with DFARS 205.205-71, DFAS 206.302-1(d), and DFARS Procedures, Guidance and Information (PGI) 206.302-1(d), a SSN was posted to SAM.gov on 16 January 2025 for five days and the results are identified in Table 2 below.

Table 2

Company Name Business Size Capable / Not Capable

A capability assessment was conducted based on the information the vendors provided in response to the SSN. Only one response was received from

9. Interested Sources: The capability statement submitted by the vendor in response to the SSN have been reviewed by the requiring activity who has determined that the vendor did not demonstrate the capabilities to understand U.S. Army Aviation maintenance program.

To date, no other sources have written to express interest in the acquisition.

10. Other Facts:

a. Procurement History: The AVSS requirement has historically been awarded under small business set-aside competitive procedures.

1.) Contract numbers and dates of the last several contracts for these same requirements.

Table 3

Contract Number Contractor Set-

Aside Contract Amount

Period of Performance

W9124R-11-C-0003 Boreal Aviation

SBSA $6,722,455 01 Feb 11 – 30 Apr 13

W9124R-13-C-0004 LOGMET LLC SBSA $18,469,414 01 Apr 13 – 28 Feb 19 W91151-19-C-0007 LOGMET LLC SDVOSV $17,811,066 5 Feb 19 – 31 Aug 24

2.) The competitive status of these actions. The previous contracts were set aside for small businesses.

(a) Contract W9124R-11-C-0003 was awarded to Boreal Aviation. The acquisition was solicited as a 100 percent small business set-aside and received 2 proposals.

(b) Contract W9124R-13-C-0004 was awarded to LOGMET, LLC. The acquisition was solicited as a 100 percent small business set-aside and received 5 proposals.

(c) Contract W91151-19-C-0007 was awarded to LOGMET, LLC. The acquisition was solicited as a Service-Disabled Veteran-Owned Small Business and received 7 proposals.

3.) Contract W9124R-13-C-0004 was extended twice to provide additional time for a competitive follow-on award using authority 10 U.S.C. 2304(c)(1) as implemented by Federal Acquisition Regulation (FAR) Part 6.302-1 - Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

4.) Contract W91151-19-C-0007 was extended once due to a change in the acquisition strategy and to provide additional time for a competitive follow-on award using authority 10 U.S.C. 2304(c)(1) as implemented by Federal Acquisition Regulation (FAR) Part 6.302-1 - Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

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.

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.

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.

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

TERESA V. DINWIDDIE

Contracting Officer