A.02.05 Limited Source Determination - Keys and Cores 2024 FINAL.pdf

Control No. 24-0042

LIMITED SOURCE DETERMINATION

Far Subpart 13.106-1(b)

1. CONTRACTING AGENCY:

US Army Corps of Engineers, Directorate of Contracting, Walla Walla District (CECT-NWW).

2. DESCRIPTION OF ACTION: This action is for the purchase of new keys and cores for the locks on the entire Mill Creek Project. The new keys and cores will replace the existing keys and cores in the Best Locks on the Project.

3. DESCRIPTION OF THE SERVICES/SUPPLIES: The US Army Corps of Engineers, Mill Creek Project, requires a firm fixed price brand name supply contract to purchase new Best Locks and Cores for the entire project office. The Estimated cost for this requirement is $13,936.

The estimated value of this procurement is under the SAT.

4. AUTHORITY CITED: FAR 13.106-1 (b) Soliciting from a single source. (1) For purchases not exceeding the simplified acquisition threshold, contracting officers may solicit from one source if the contracting officer determines that the circumstances of the contract action deem only one source reasonably available (e.g., urgency, exclusive licensing agreements, brand name, or industrial mobilization).

FAR 11.105-(a)(l): the particular brand name, product, or feature is essential to the Governments' requirements, and market research indicates other companies' similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet, the agency's need.

5. REASON FOR AUTHORITY CITED:

a. JUSTIFICATION:

(1) The Corps of Engineers is required to change out lock cores every five years.

Changing out only the cores is significantly more cost effective for the Corps than changing out the locks themselves. The locks used on the Mill Creek Project are Best Locks, and only Best Lock cores can be used in these locks. The Existing locks are installed with 6-pin Standard Restricted Best lock cores and will require replacement with 6-pin Standard Restricted Best Lock cores. 7-pin may be used if in the best interest of the Government. The Best Lock replacement cores are the only ones available to integrate with the existing locks. The also provide the highest quality locks and cores.

(2) Failure to procure Best Lock Cores will require substantial cost in replacing not only the cores but all the locks as well.

b. IMPACT: Corps Projects are required by Regulation to replace keying every five years. This is required to maintain security of the property. Failure to replace the cores/keys will result in the Mill Creek Project being out of compliance. Additionally multiple keys have been lost over the years, failure to replace the keys leaves the project vulnerable to entry by unauthorized personal and the potential for significant loss of Corps property.

To lower costs Mill Creek uses removable cores to allow for just core replacement as opposed to the more expensive whole lock replacement. The lock brand used is Best Locks.

Best Locks will only accept Best cores/keys. Failure to purchase Best cores would require the Project to purchase brand new locks. Locks used on the Project are specially hardened to comply with the required security level. New locks would be approximately $500 dollars per lock and result in an additional unneeded expenditure of nearly $150,000 dollars.

c. ALTERNATIVES:

• No purchase. This alternative is not feasible as it would mean that the key access to the Project was not updated as required by federal regulation.

• Purchase a different brand. There are no core/key alternatives to Best brand cores for the nearly 300 Best lock bodies currently used on the Project. The only alternative is to purchase new lock systems that would be significantly more expensive at around $150,000 dollars. This alternative would not be in the best interest of the Corps nor meet federal financial fiduciary requirements.

6. DETERMINATION OF FAIR AND REASONABLE COSTS: A price analysis will be completed after receipt of quotation based on historical pricing and the IGE. No award will be made unless prices may be determined fair and reasonable.

7. EFFORTS TO OBTAIN COMPETITION: No effort was made to obtain brand competition as only Best Lock cores and associated keys will fit in the Best Locks already used on the Project.

Multiple physical security vendors who sell locks sell the Best Lock brands. A preferred vendor is RAE Security 3902 West Valley Hwy N, Suite 100, Auburn, WA 98001 J.Littleworth@raesecurity.com

8. MARKET RESEARCH: See paragraph 5.

9. 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.

Name/Title: Ben Morris, Lead Ranger Signature: ____________________

Prepared by: Ben Morris Title: Lead Ranger Signature: ____________________

DETERMINATION: In accordance with the authority of 10 U.S.C. 2304(c)(1), as implemented by FAR 13.106-1(b) and based upon the foregoing, I hereby determine that a brand name procurement is authorized and is in the best interest of the Government.

Approved by:

Sara Edwards Contracting Officer

Reviewed For Legal Sufficiency by:

Michaela Murdock Attorney-Advisor