1. This document is a JOFOC prepared by the USDA/USFS. 2. Nature and/or description of the action being approved: This justification provides rationale for contracting by other than full and open competition for aircraft maintenance services with Neptune Aviation Services, Inc. (hereafter referred to as - Neptune), 4301 Corporate Way, Missoula, MT 59808, on a sole source basis. 3. A description of the supplies or services required to meet the agency's needs (including the estimated value): The USFS had fifteen C-23B+ Sherpa aircraft transferred from the United States Army as part of the National Defense Authorization Act of 2014. Ten of these aircraft have been FAA certificated as Short Brothers SD3-60 Sherpas. The primary use of these aircraft is to deliver smokejumpers and cargo to wildland fires and provide other multi-mission capabilities including transporting crews, teams, and cargo. In order to respond to wildfires, the Short Brothers SD3-60 Sherpas must be available for all pilot training, smokejumper recurrent and rookie training, and then the operational fire season beginning in February to be ready for operations in June. The Government intends to obtain commercial aircraft maintenance services for Government- owned/operated aircraft. Maintenance support out of Missoula, Montana, with work completed at other primary and secondary locations for up to ten Short Brothers SD3-60 Sherpas. The Contractor will be required to support maintenance on other USFS Fleet aircraft as directed by the Government. The types of services required include, but are not limited to, inspection, maintenance, preventive maintenance, rebuilding, and alteration (e.g., inspection, repair, painting, overhaul, rebuilding, testing, and servicing of airframes, engines, rotors, appliances, or component parts, etc.). The Contractor shall hold an FAA Certified Repair Station with either an appropriate class or limited rating and a capabilities list. Currently the Neptune maintenance services contract, AG-024B-C-17-0013 does not have sufficient ceiling available to achieve these goals. The current contract with Neptune was awarded on August 30, 2017 and will expire July 31, 2022. The current value of the contract is $3,600,000, which will increase by $700,000 to $4,300,000. This increase will allow for the successful completion of the remaining maintenance on operational aircraft, inspections and repairs, ensuring full mission readiness at the start of the 2022 fire season. 4. An identification of the statutory authority permitting other than full and open competition: Pursuant to 41 U.S. Code - 3304(a)(1), other than full and open competition may only be used by the agency when the services needed by the agency are available from only one responsible source and no other type of property or services will satisfy the needs of the agency. In addition, in accordance with FAR Subpart 13.5, this acquisition will be conducted utilizing simplified acquisition procedures as it is below the $7.5 million threshold. This requirement meets the definition of a commercial item in accordance with FAR Section 2.101. 5. A demonstration that the proposed contractor's unique qualifications or the nature of the acquisition requires use of the authority cited: Neptune is uniquely qualified because they are the only known contractor in Missoula, Montana with the capabilities to perform the services described above. The Short Brothers SD3-60 Sherpa is a unique, aging aircraft, with few mechanics qualified to perform these services. Neptune has a proven track record of performing maintenance on the Short Brothers SD3-60 Sherpa, as well as other USFS Fleet aircraft in Missoula, MT. Neptune has performed the FAA certification of all ten USFS-owned Shorts Brothers SD3-60 Sherpas. They also have produced and installed all the Smokejumper equipment supplemental type certificates (STCs) which missionize the aircraft for aerial delivery of firefighters to accomplish the USFS Smokejumper and Para cargo missions. When deployed as Smokejumper aircraft with smokejumpers, these aerial-delivered firefighters are a critical part of the National wildfire response. Neptune has provided these services over the last four years and has maintained a Short Brothers SD3-60 Sherpa-qualified staff that has produced aircraft, ahead of schedule, in order to meet wildfire support needs. 6. A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by FAR Subpart 5.2 and, if not, which exception under 5.202 applies: Federal Aviation Regulations and USFS policy require that aircraft be maintained in accordance with the aircraft manufacturer's program, the same as when this aircraft was used in commuter airline service. Each aircraft requires numerous inspections and component changes based on calendar time, so even if the aircraft do not fly, maintenance is still accruing on the ten operational aircraft. The qualifications, experience, and workload capacity are unavailable within the current USFS maintenance contracts. Short Brothers SD3-60 Sherpa-trained mechanics are becoming extremely hard to find, making it very difficult to find a contractor that can do the work without it costing the Government much more in the end due to ferry flights. Due to other contractors being unable to provide Short Brothers SD3-60 Sherpa-trained mechanics, and the fast-approaching fire season, no other contractor has the capability to meet the requirements. In accordance with FAR Subpart 5.2, a notice of intent to contract by other than full and open competition will be posted through the Governmentwide Point of Entry for a minimum of fifteen days. The posting will include this JOFOC. 7. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable: The Contracting Officer has already deemed prices to be fair and reasonable pursuant to FAR Subpart 15.4, as this is an ongoing contract. 8. A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was not conducted: Market research was performed in accordance with FAR Part 10. Market research was conducted by exploring all maintenance contractors in the Missoula, Montana area. No contractors were identified as having experience maintaining the Short Brothers SD3-60 Sherpa, except for Neptune. Given the location, urgency, and qualifications necessary to accomplish this work, Neptune is the only known contractor in Missoula with the experience and capability to perform maintenance on the Short Brothers SD3-60 Sherpa. 9. Any other facts supporting the use of other than full and open competition: The Government is operating ten Short Brothers SD3-60 Sherpas for the delivery of aerial firefighters (Smokejumpers), which is a critical National resource in the Federal response to wildfires across the nation. Critical maintenance is required for the upcoming fire season and requires an increase to the Neptune maintenance contract as soon as practicable. 10. A listing of the sources, if any, that expressed, in writing, an interest in the acquisition: N/A 11. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for the supplies or services required: The USFS is currently preparing to make awards as a result of solicitation 1202SA21R0005.
