A16_-_Limited_Sources_Justification_(FAR_Part_8)_NOI_1.pdf

FWS Form 3-0058 (Rev. 5/2024) U.S. Fish and Wildlife Service

Limited Sources Justification

JOINT ADMINISTRATIVE OPERATIONS

Acquisition Operations

In accordance with FAR 8.405-6, the Contracting Officer may restrict consideration of sources for orders placed or BPAs established under Federal Supply Schedules (FSS) under the condition that the restricted consideration be justified in writing.

Instructions: The information in the text boxes are provided as sample language or to indicate a needed fill-in. Sample language shall be removed from the final document. All text boxes require information and shall not be left blank.

1. Agency and Contracting Activity:

Department of the Interior, U.S. Fish and Wildlife Service (FWS), Joint Administrative Operations, Acquisition and Property Operations.

2. Nature and/or Description of the Action Being Approved:

This request is to purchase satellite tracking devices and associated service for FWS wildland fire vehicles, as part of an interagency effort to improve safety and meet the requirements of the Dingell Act. These devices must operate in remote settings where cellular service is not available, and be capable of reporting vehicle information, near real-time, via an online web portal. The devices will transmit the location of FWS fire vehicles anywhere in the country, and can alert managers of vehicle accidents, provide strategic information, and track vehicle data. FWS is partnering with Bureau of Land Management (BLM) Fire, who is already using this system on over 700 fire vehicles. This partnership necessitates use of the same products and system BLM uses, but there are cost-saving benefits in program management and vehicle installation (described below).

3. Description of the Supplies or Services Required to Meet the Agency’s Needs (including estimated value):

See attached A04.2024 LBS Statement of Requirements and SkyMira bid for additional information.

Request is to purchase 135 Orbcomm ST6100 terminals in FY24. The fire program will install these terminals on fire vehicles in early FY25, and activate them in spring of 2025. The terminals will need to be activated after install and an annual service fee is required to backhaul the data and display it on a web-based portal. Activation and service is provided by SkyMira, who is also an Orbcomm dealer.

4. a. Authority Cited (Select One):

FAR 8.405-6(a)(1)(A) – “An urgent and compelling need exists, and following the procedures would result in unacceptable delays.”

FAR 8.405-6(a)(1)(B) – “Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.”

FAR 8.405-6(a)(1)(C) – “In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule (FSS) order provided that the original order was placed in accordance with the applicable FSS ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.”

FAR 8.405-6(b)(1) – Items Peculiar to One Manufacturer. “The particular brand name, product, or feature is essential to the Government’s 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 needs.”

b. Supporting Rationale:

BLM Fire has a well established program utilizing Orbcomm ST6100 terminals and the SkyMira Vehicle Tracking Portal (VTP). BLM Fire also manages interagency fire vehicle production and pre-wires new fire vehicles for the Orbcomm terminals. Orbcomm terminals are required to complete this investment. Finally, BLM Fire has a dedicated fire vehicle tracking position on staff, who will help FWS stand up and manage this program, train our users, and serve as a subject matter expert in the Skymira VTP. SkyMira VTP is required to establish and maintain this interoperability. SkyMira has demonstrated experience, authority to operate, and are an approved GSA sole-source vendor with an existing BLM Fire contract.

There is also an advantage to displaying FWS fire vehicles on the same portal as BLM fire vehicles.

Interagency dispatch centers will be able to track both using one screen, login, etc. which is much more efficient that having to use two separate systems.

See Question 6 on market research conducted. It does not appear another company offers this capability.

5. Best Value Determination:

The BLM contract is evidence of a determination or fair and reasonable cost, and their continued use displays the success of the program. We are not aware of another product/service that meets these needs. The primary value in using the same product as the BLM is that we can tap into their staff and expertise to manage this system for FWS. It will negate the need for us to build and staff our own system. Finally, since BLM Fire manages the fire vehicle contracts, all new Working Capital Fund fire vehicles come pre-wired for the Orbcomm ST6100. This will reduce the cost of installs.

6. Market Research:

Market research was conducted during 2022 and 2023, with the assistance of a Radio Systems Engineer who did similar work at the US Forest Service. FWS Fire received presentations from Verizon and Samsara vendors who offer products and service similar to the BLM system. Region 2 purchased, tested, and is still using some Samsara products. Region 7 has been using Verizon products for two years. We learned that neither Verizon or Samsara has the ability to back haul vehicle data if the vehicle is not in cell service, so those products are not capable of notifying us of a vehicle accident outside of cellular range (such as on a remote fire). We need a product and service capable of satellite data back haul so it's always reporting vehicle status. As best we can tell, the Orbcomm ST6100 GPS terminal is the only product that links to satellites. It's a common product used by multiple vendors, but it only has true satellite functionality when connected to a company with access to the satellites. SkyMira appears to be the only company capable of satellite back haul. SkyMira also has the software and web dashboard to view fire vehicles in real time (reports every 7 seconds) and they have experience with BLM Fire programs and vehicles, so they understand our needs. Since BLM Fire has also done market research, we believe this is the best, and likely only, option.

7. Any Other Facts Supporting the Justification:

As budgets allow, FWS plans to equip the entire fire fleet. Technology is evolving to be able to use this system for additional information, such as linking to radios carried by firefighters, connecting to TAK servers used by multiple firefighting agencies, and reporting vehicle maintenance information. Establishing this as our baseline system will allow us to utilize future technology.

8. Statement of Actions to Remove Barriers:

Without full understanding of the market and technology, we assume the main barrier to competition is access to satellites. Verizon and Samsara do offer similar web portals to SkyMira, just not the real-time, anywhere satellite capability.

A barrier for us to use a different system is that interagency dispatch centers would have to learn, gain access to, and track different agencies’ fire vehicles on separate systems. It’s much more efficient to use the same system, login, etc. Barriers with installation, training and staffing also exist if we don’t use the same system as BLM (as described above).

Time would be a barrier if a new company were to develop a similar system. Our goal is to purchase the devices in FY 2024, install them over the winter, and have them functional by spring/summer of 2025. It appears unlikely another company could establish a similar system within that timeframe.

9. Technical/Requirements Personnel Certification I hereby acknowledge that the supporting data that forms justification is my responsibility and certify that the basis for this justification is complete and accurate.

Program Partner Signature

10. Contracting Officer Certification I hereby certify that this justification is accurate and complete to the best of my knowledge and belief and approve the use of limited sources procedures pursuant to FAR 8.405-6.

Contracting Officer Signature

11. Approval by the Chief of the Contracting Office (>SAT) Based on the foregoing justification, I hereby approve this procurement.

EDWARD

FRANSTED

Digitally signed by EDWARD

FRANSTED

Date: 2024.07.25 14:48:48 -06'00'

MELISSA MARCHAND

Digitally signed by MELISSA

MARCHAND

Date: 2024.07.30 08:00:54 -05'00'

Chief of the Contracting Office Signature

12. Approval by Senior Chief of Contracting Office (>$750k) Based on the foregoing justification, I hereby approve this procurement.

Senior Chief of the Contracting Office Signature

13. Approval by Head of Contracting Activity (>$750k) Based on the foregoing justification, I hereby approve this procurement.

Head of the Contracting Activity Signature