A02.14 SSJ Under the SAT - FEM Systems Analyst Support dated 2026.09.01 - SAM.docx

CUI

SOLE SOURCE MEMORANDUM FOR ACTIONS UNDER THE SAT

IAW RFO 13.101(b)

1. Contracting Activity: The United States Army Corps of Engineers (USACE), Mission Support Battalion (UMSB)

2. Description of Action: This approval is for a new sole source Operations and Maintenance contract for comprehensive Facilities and Equipment Maintenance (FEM) system optimization, data analytics, and technical support. This anticipated action is a sole source firm fixed price noncommercial service contract with Battelle Memorial Institute (Battelle), a non-profit 501(c)(3) entity, SAM UEI: F125YU6SWK59; CAGE code: 77986, to assist the USACE in optimizing, expanding, and analyzing its FEM system.

3. Description of Supplies/Services: FEM Systems Analyst Support. The services include comprehensive contractor assistance to support the USACE in optimizing, expanding, and analyzing its FEM system. The contractor, Battelle, shall provide expert data management, advanced analytics, and technical support to enhance FEM capabilities. The Period of Performance is two (2) years from the date of award, with an estimated Level of Effort of approximately 940 hours per year at a cost to the USACE of $xxx,xxx.xx.

4. Authority Cited: 41 U.S.C. 3304 as implemented in as implemented in RFO 13.101(b)

5. Reason for Authority Cited:

The required services for FEM system optimization, structural integration, and advanced analytics are highly specialized and tightly bound to a legacy environment customized exclusively for the USACE. Battelle is the only source capable of performing this work without introducing unacceptable risk and cost to the government. This unique position is the direct result of Battelle's 20+ years of continuous engineering, development, and cybersecurity management of the USACE FEM ecosystem.

Specifically, Battelle possesses the following irreplaceable qualifications, historical engineering custody, and proprietary-level technical expertise that no other contractor can provide:

· Proven Civil Works Asset Register Implementation: Battelle possesses the sole, demonstrated experience of having successfully implemented the Civil Works Asset Register into the Operational Condition Assessment (OCA) system. This was a highly complex and difficult technical task that in-house USACE personnel were unable to achieve without Battelle’s direct, specialized assistance, proving their unique capability in integrating critical asset data into core USACE operational platforms.

· Urgent ASA Modernization Mandate & Schedule Adherence: The Assistant Secretary of the Army (Civil Works) expects the complete modernization of USACE Flood Risk Management and Navigation O&M programs by FY28. Meeting this non-negotiable, high-visibility deadline requires an expert contractor with immediate, pre-existing familiarity with USACE information systems and the Asset Register. Battelle’s unique, specialized expertise is critical to executing this modernization on an accelerated schedule, as any other vendor would require a multi-year learning curve, causing USACE to fail this critical directive.

· Two Decades of Continuous FEM Engineering Custody (20+ Years): Battelle has experience of over 20 years managing the complete capabilities, backend database schema, and operational interfaces of the USACE FEM system. This uninterrupted lifecycle management has given Battelle an exhaustive knowledge of the source code and custom table structures that cannot be acquired through standard technical manuals.

· Exclusive USACE-Customized Maximo Modernization: The USACE FEM implementation is not an "off-the-shelf" installation. Battelle has historically designed and deployed the highly customized IBM Maximo updates tailored strictly to USACE’s operational workflows. No other contractor possesses the structural baseline knowledge required to modernize FEM without systematically breaking legacy integrations.

· Deep Civil Works & Legacy Information Systems Integration: Battelle has a decades-long, institutionalized understanding of USACE’s complex Civil Works environment. They are the sole contractor with the structural expertise to design, develop, and maintain the complex data objects that bridge and synchronize FEM maintenance data with USACE's legacy Automated Information Systems and the Enterprise Data Warehouse.

· End-to-End Cyber Security and DoW Information Assurance Management: Over their 20-year tenure, Battelle has engineered and managed the complete cybersecurity posture of the FEM system, including custom continuous monitoring scripts and Risk Management Framework (RMF) documentation designed exclusively for USACE's environment.

· Disproportionate Onboarding and Transition Time: Bringing on a new contractor lacking Battelle's established familiarity with the USACE FEM architecture would require a significant onboarding period. A new vendor would need to obtain necessary DoW network access, complete requisite cybersecurity and continuous monitoring training, and spend months analyzing the existing large-scale Oracle environment before they could begin providing meaningful optimization and analytic support. This learning curve would consume an unacceptable portion of the two-year period of performance.

· Unacceptable Delays and Duplication of Cost: Utilizing a source other than Battelle would result in unacceptable delays in fulfilling the agency's critical system optimization requirements. Furthermore, it would result in a substantial duplication of cost to the Government—in the form of lost productivity and the labor hours required for USACE personnel to train a new vendor on the bespoke system architecture—that is not expected to be recovered through competition.

Summary of Sole-Source Reality: While other contractors may possess general Maximo certifications, no other vendor has the 20+ years of custom engineering custody of USACE's legacy interfaces, the proven experience integrating the Asset Register, or the institutional knowledge required to meet the ASA's urgent FY28 modernization mandate. Forcing a competitive procurement would introduce extreme risk of mission failure, severe security vulnerabilities, and a complete loss of data integration across the USACE Civil Works enterprise.

6. Efforts to Obtain Competition:

Market research was conducted by the HQ USACE Asset Management team utilizing automated search algorithms and enterprise AI-assisted market research tools to survey GSA Schedules, SBA Dynamic Small Business Search (DSBS), and historical FPDS-NG contract actions. The findings from these queries were reviewed and verified by USACE subject matter experts and to assess commercial market capabilities against the unique FEM system requirements. As detailed in Section 8, Battelle is uniquely positioned to execute this requirement due to their proven, specific expertise with implementing the USACE Civil Works Asset Register and FEM/Maximo CMMS within a large-scale Oracle environment, combined with their established familiarity with the USACE organizational structure and Enterprise Data Warehouse. No other sources were identified that possess this specific combination of technical proficiency and operational knowledge within the required DoW continuous monitoring and cybersecurity framework.

7. Actions to Increase Competition: While this is a new standalone contract action, the specialized technical tasks represent a modernization phase of the USACE FEM architecture where Battelle has proven expertise on a similar USACE information system.

To increase competition for any future iterations of this requirement, the Government will take active steps to mitigate reliance on a single vendor. During the period of performance, the Government will ensure that Battelle provides comprehensive documentation of all system optimizations, data models, analytical scripts, and reporting dashboards developed. By securing this technical data and ensuring thorough knowledge transfer to USACE personnel, the Government will reduce the barrier to entry for other potential vendors.

8. Market Research: Market research was conducted by the Government technical team and the Contracting Office between January 2026 and July 2026 to identify potential sources capable of fulfilling this requirement. The research was conducted in accordance with RFO Part 10 and DFARS 210.001.

The market research efforts included:

Reviewing historical acquisition data and FPDS-NG for similar database optimization and Maximo CMMS/EAM support services within the Department of War (DoW) and USACE.

Consultation with internal USACE subject matter experts regarding the specific technical landscape of the current Facilities and Equipment Maintenance (FEM) system.

Results:

The market research revealed that while several vendors possess general capabilities in Maximo CMMS administration, Oracle SQL, and business intelligence reporting, the requirement demands a highly specialized convergence of skills that are unique to the current USACE operating environment.

Specifically, no other vendor demonstrated the required immediate familiarity with the USACE Enterprise Data Warehouse, the specific DoW continuous monitoring processes, and the bespoke architecture of the USACE FEM implementation. Market research concluded that introducing a new contractor without this established institutional knowledge and specific DoW/CUI handling experience would result in substantial duplication of cost and unacceptable delays in system optimization, as a new vendor would require extensive time to gain the necessary access, understand the complex internal data structures, and navigate the specific federal cybersecurity protocols required for this effort.

Therefore, based on the market research conducted, Battelle was identified as the only responsible source capable of providing the comprehensive technical support and advanced analytics required without unacceptable delays or risks to the agency's mission.

9. Interested Sources: To date, no other sources have written to express an interest in this acquisition. In accordance with RFO 5.201, a Notice of Intent to Sole Source will be published on SAM.gov. The notice will provide an opportunity for interested parties to submit capability statements demonstrating their ability to meet the government's requirements. Any capability statements, bids, or proposals received in response to this notice shall be fully considered by the Contracting Officer prior to award.

10. Other Facts: None

11. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable, based on comparison to an independent Government cost estimate in accordance with RFO 15.404-1(b)(5). Additionally, per RFO 15.403-2(a), certified cost and pricing data is not required.

David A. Kaplan Procuring Contracting Officer Phone: 703-428-8487

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

Procuring Contracting Officer

Approval

Based on the foregoing justification, I hereby approve award of a firm fixed price contract to Battelle Memorial Institute for the services titled “Facilities and Equipment Maintenance System Analyst Support” in the amount of $xxx,xxx.xx on an other than full and open competition basis pursuant to the authority of RFO 13.101(b), subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Procuring Contracting Officer

Prepared by:

Kerry Lowman Asset Management Program Manager Phone: 202-761-4166

-and-

Shanti Singh Contract Specialist

CUI

(Source Selection information - See RFO 2.101 and 3.104-4)