Contract Depot Logistics Support (CDLS)

Title of Procurement This is a proposed sole-source contract with Eaton Corporation for Contract Depot Logistics Support (CDLS) to provide depot level repair, sparing, full maintenance and engineering support for Air Traffic Control Center (ARTCC) Critical and Essential Power Systems (ACEPS). Program Office and Point of Contact The FAA Logistics Center Automation/ Communications Product Division, AML-L800 has been designated by the Federal Aviation Administration (FAA) to be the office of prime responsibility for the logistics support of Critical and Essential Power Systems for the National Airspace System (NAS). Nature of Procurement ActionThe Federal Aviation Administration (FAA) has selected Eaton Corporation, 8609 Six Forks Road, Raleigh, North Carolina as a single source for a follow-on contract to contract 6973GH-18-D-00108 with Eaton Corporation, which expires September 30, 2023. The proposed contract type is an Indefinite Delivery/Indefinite Quantity contract with Firm Fixed

Priced (FFP), Labor Hour (LH), and Cost Reimbursable (CR) Fixed Fees/No Fees. Eaton has supplied this type of ACEPS service support since 1999. A 1-year base period with 4 additional option year periods will be used for this acquisition.Description of Supplies/Services The FAA Logistics Center Automation/Communications Product Division, AJW-L800 has a requirement for continued CDLS and field maintenance/repair/overhaul support for ACEPS systems and products via an Indefinite Delivery/Indefinite Quantity contract. The current ACEPS CDLS contract provides in-house and on-site repair and parts support for the ARTCC Critical and Essential Power Systems (ACEPS), National Exide/IPM Uninterruptible Powe Systems (NEIUPS), the Dual Redundant Power Distribution System (DRPDS), Critical Redundant Power Distribution Systems (CRPDS), Critical Power Distribution Type Systems (CPDS) and Combined Center Radar Approach sites (CERAP). Under the scope of this follow-on contract, the vendor will provide FAA with CDLS support to include the following:Parts storage, distribution, and order fulfillment for field requisitions to include all necessary labor, equipment, and facilities to meet field priority requirementsFull CDLS and field support required to maintain, repair, overhaul, and inspect Uninterruptible Power Supplies (UPS) and aging/obsolete NAS power systems to ensure continuity of operations throughout the systems remaining lifecycleWork includes in-house and on-site support for complete restoration and integration of fielded assets and to ensure current configurationsOn-site support for inspections and diagnosis to maintain aging equipment due to size and/or Environmental Protection Agency (EPA) restrictionsSupport for limited/restricted access to hardware, firmware, and service software tools developed and owned by Eaton Corp. that are of a proprietary nature and necessary for troubleshooting and repair. These tools facilitate the capability to continue integration of fielded assets with UPS developed by Eaton with other Commercial-Off-The-Shelf (COTS) power products within the NASSpecialized knowledge and skills required for identification and acquisition of replacement products and/or re-engineering, re-qualification, sub-contracting, and cannibalization services when necessitated due to unavailable replacementsMaintenance and updates to the FAA’s web based commercial database designed for FAA personnel to access technical documentation for 2nd level engineering support and to check inventoriesData entry into FAA Logistics Center’s web based CDLS interface tool to support FAA CDLS reporting requirementsAuthorityThe FAA’s authority for entering into this contract is the FAA’s AMS policy section 3.2.2.4 – the FAA may contract with a single source when it is determined to be within the best interest of the FAA.Rationale Supporting Use of a Single Source A Single Source Award to Eaton Corporation is deemed to be in the best interest of the government due to the following reasons:Impact. Eaton’s knowledge and experience of site-specific requirements; working relationship with approved vendors to ensure site specific baseline equipment configuration, specifications, and standardization of components, allows for quick parts availability/resolutions and reduced lead times. Their past performance has demonstrated their capability to consistently respond to requirements in a manner that meets and often exceeds contractual timeframes and expectations. The have demonstrated their ability to communicate effectively with the field customers as well as program officials when approved by the Contracting Officer (COR) / Contracting Officer Representative (COR). This support posture has led to consistent and cost-effective pricing resulting in increased product confidence. Their established relationships with suppliers who manufacture UPS related equipment have been leveraged to allow Eaton to utilize buying power and negotiate reduced equipment lead times, ultimately shortening delivery schedules for the Government. Past proposals have proven to be fair and reasonable, and often offer suggestions for lower cost on task orders under the current contract. Obsolescence and re-engineering issues continue to create major logistical support issues, i.e., constant parts changes, upgrades, and replacements. The Logistics Center has not organically supported the ACEPS/CPDS systems/products since late 1990 and has made no provisions to try and resume this support. Bringing the system and/or a part of its other vendor support products in-house would create logistical hurdles and result in unacceptable delays. Unless provision is made to provide for the continued support of these assets, the FAA will be presented with both monetary and safety risks. The risk not only applies to increase burden to the government (additional costs), but life safety risks will be realized, with impact to the flying public.Specialized Expertise. Eaton is the only vendor with the knowledge to perform the planning, management, and execution of the integrated logistics required for this program. Repair, overhaul, and maintenance (off-site/on-site) require specialized knowledge to plan and mobilize support for preventive and emergency repairs and/or oversight for the integration of aging equipment. Few original equipment manufacturers (OEM) exist; therefore, obsolescence is a major issue in the continuity of operations. Eaton will purchase new items and repair services on the behalf of the FAA where they are not the OEM, this is in the best interest of the FAA because it provides the best means of meeting configuration management requirements. Other vendors, who have been tasked with specific segments of upgrades to the ACEPS, cannot be trained in the hardware, firmware, and software support tools to support upgrades that integrate this system, nor do they have access to the limited/restricted rights. Eaton will only train government personnel to perform software upgrades on their products.Follow-on Contract. Open competition of this requirement would require other vendors to contract with Eaton for the integration of the hardware, firmware, and software service tools. The sale of required data and tools is not currently offered by Eaton on the open market. Competitors would also need to acquire specialized skills and necessary expertise to support various pieces of this equipment and to establish partnerships and sub-contracts with suppliers to ensure availability of parts. Failure to do so would create an extremely high risk of unacceptable delays in repair and maintenance resulting in longer and more frequent power outages, with significant risk of lost air traffic service and flights. Warehouse/storage/order fulfillment support provided under this contract currently includes 21,500 square feet of space in a bonded/fenced multi-level storage facility that houses FAA owned spares, repaired assets, cannibalized equipment, and other critical/essential materials required to manufacture, refurbish, and requalify parts. Older equipment from decommissioned sites such as ACEPS cabinets, breakers, UPS, engine generator parts, and various other spares are utilized to ensure continued support well beyond the system’s planned life cycle. Space and layout for ACEPS inventory and sparing locations are already established at Eaton. Continued use of Eaton warehousing services would not result in any additional outlays of funding for startup. Moving assets from the Eaton facility to the FAALC in Oklahoma City would result in additional cost, as well as considerable time delays and/or interruptions to mission-critical logistics and engineering response time would be jeopardized during the transition. These delays would be considered unacceptable. Standardization. Replacement parts acquisition for legacy assets purchased decades ago requires specialized knowledge and skills for parts identification, and manufacturing, to ensure continued integration for the ACEPS, Engine Generators (EG), and UPS products. The form, fit, and function determination, acquisition or manufacturing of these products is challenging to ensure that parts meet configuration management specifications. Eaton tests new and/or re-utilized parts/products daily for compatibility, functionality, and inter-operability. Without the resident legacy knowledge of Eaton’s staff to perform timely research and re-engineering analysis, the FAA will not be able to ensure the same level of emergency backup power availability/reliability support at NAS facilities, or uninterrupted service to the flying public. Duplicate costs that could not be recovered include the following: transitioning test beds from the field, employee training and learning curves, and transportation for the transition of depot spares. The only test beds available are in the field and could not be pulled until/unless sites were decommissioned. Relocating a test bed facility is estimated to cost more than $10M.Patents, Proprietary Data, and Unique Items. The hardware, firmware, and service software tools provided by Eaton for integration of UPS products are limited and/or restricted from publication, and are only available from one source. These rights are required for repair and on-site maintenance. The FAA does not own the software source code required to maintain, modify, and/or update this software. Eaton’s UPS, components, and software were developed by Eaton at their sole expense. Use, duplication, or disclosure for or by the FAA, including without limitation any of its agencies or instrumentalities, is subject to restrictions set for in the Data Rights clauses in FAA regulations. In order to properly accomplish preventive, emergency breakdown maintenance and performance calibrations, in-house maintenance personnel must utilize Eaton’s service software tools. The sale of such data and tools is not currently offered on the open market. It is Eaton’s policy to only train government personnel to program software code to support the integration of this equipment. Considering impacts and risk, it is in the best interest of the government to maintain current power availability/reliability, which is attributed to Eaton’s ability to supply parts, repair parts and to retain specialized expert personnel necessary to ensure continued operations. FAA does not currently have the staff available or the financial resources to acquire this same level of knowledge and technical expertise to develop the repair specifications/drawings necessary to permit organic support or open competition for ACEPS repair operations.Market AnalysisA market survey (FAA Posting 6973GH-23-M-CDLS) was accomplished in March 2023, with one response from Eaton Corporation. The government did not receive any responses from other vendors indicating they could meet the government’s requirements.Other Facts Supporting Use of Single SourceThe government believes all reasonable attempts to identify alternate sources of services have been made. There will be no additional measures taken to identify alternate sources because there are none.