A2 - JKSE 262401 RPR D-21 Fire Alarm Controls_Limited Competition Justification - KO Review_Redacted.pdf

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CUI//SP-SSEL

Operational Disruption: A base-wide replacement would cause significant disruption to base operations and compromise the safety and security of personnel and assets during the transition.

Lack of Interchangeability: No other manufacturer's equipment can integrate with the installed Monaco D-21 system.

Given these constraints, it has been determined that no other sources are capable of meeting this requirement. Therefore, no actions can be taken to increase competition for this specific repair requirement without undertaking a complete and cost-prohibitive replacement of the base's fire alarm system.

The government will, however, continue to conduct market research for future requirements to identify new and emerging technologies that may provide opportunities for competition in the long term.

g. If previously used "Full and Open Competition" explain what changes causing this to now have limited sources.

Not previously obtained through full and open competition

h. Provide an explanation of any unusual patterns that may be revealed by the history, e.g., several consecutive, urgent buys.

No unusual patterns have been noted

i. If a justification was prepared to support the procurement made before this one, briefly describe the circumstances justifying the procurement and whether there have been any significant changes.

The justification previously used has not changed

j. Provide any other facts necessary to justify limiting competition that were not previously stated.

No other factors to note that haven't already been stated

6a. AUTHORITY CITED 41 U.S.C. 1901 as implemented in FAR 13.106-1(b)(1) Soliciting from a single source.

b. Reason for Authority Cited ⋯

Describe how this action requires the use of the authority cited. If applicable, identify the proposed or potential contractor(s) and include a discussion of the proposed contractor's unique qualifications for fulfilling the contract requirements.

The use of the authority under 41 U.S.C. 1901, as implemented in Federal Acquisition Regulation (FAR) 13.106-1(b)(1), is required for this acquisition due to the proprietary nature of the D-21 Fire Alarm Control Panels and the existing infrastructure at the base. This authority permits soliciting from a single source when the contracting officer determines that only one source is reasonably available.

Proposed Contractor and Unique Qualifications The proposed contractor for this requirement is Monaco Enterprises. Monaco Enterprises is uniquely qualified to fulfill the contract requirements for the following reasons:

Sole Manufacturer and Proprietary System: Monaco Enterprises is the original equipment manufacturer (OEM) and the sole source for the D-21 Fire Alarm Control Panels and their components.

The system is proprietary, meaning no other company possesses the requisite knowledge, technical data, or parts to perform the required repairs.

Existing Infrastructure and Compatibility: The base has standardized its fire alarm and mass notification systems with Monaco Enterprises' equipment.

This creates a closed system where only Monaco's own parts and services are compatible.

Any attempt to use a different contractor would be impossible without a complete and cost-prohibitive replacement of the entire system.

Specialized Expertise: As the OEM, Monaco Enterprises possesses an unparalleled understanding of the D-21 system's design, functionality, and intricacies. Their technicians are factory-trained and have the specific expertise needed to diagnose and repair the equipment correctly.

GSA Contract Holder: Monaco Enterprises holds a General Services Administration (GSA) Federal Supply Schedule contract (47QSWA19D003J), which further streamlines the procurement process.

In conclusion, the combination of a proprietary system, an established and standardized infrastructure, and the manufacturer's exclusive expertise makes Monaco Enterprises the only responsible source capable of meeting the government's needs for this specific repair requirement. Any other course of action would lead to unacceptable delays and a substantial duplication of costs that would not be in the government's best interest.

7. POSTING REQUIREMENTS

None.

8. CONTRACTING REQUIREMENTS

a. Efforts to Obtain Competition ⋯

Describe the efforts to solicit offers 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 FAR 5.202 applies.

Efforts to Solicit Offers

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Market research was conducted to identify potential sources for the repair of the D-21 Fire Alarm Control Panels. This research confirmed that Monaco Enterprises is the sole manufacturer and the only source capable of providing the necessary proprietary parts and repair services for this equipment. Due to the proprietary nature of the D-21 system and the established, base-wide infrastructure, it was determined that soliciting offers from other sources would be impractical.

No other potential sources with the requisite capabilities, certifications, and access to proprietary parts were identified. Any attempt to engage with other vendors would be futile, as they would be unable to perform the required repairs without access to Monaco's proprietary technology and components.

Publicizing and FAR Subpart 5.2 A notice for this proposed contract action was not publicized in the Government-wide Point of Entry (GPE). The decision to forego publicizing the notice is based on the exception outlined in FAR 5.202(a)(8).

This exception applies when a proposed contract action results from the acceptance of an unsolicited research proposal that demonstrates a unique and innovative concept, and where publication of a notice would improperly disclose the originality of thought or innovativeness of the proposed research, or would disclose proprietary information associated with the proposal.

In this case, publicizing a notice would invariably disclose Monaco Enterprises' proprietary information related to the D-21 system.

Given that only one source was identified as capable of fulfilling the requirement, publicizing a notice of the proposed contract action would not have increased competition and would have served no practical purpose. The government's needs can only be met by the specific services and supplies provided by Monaco Enterprises, and therefore, soliciting competition would only result in an unnecessary and wasteful administrative burden.

b. Actions to Increase Competition ⋯

If this is a follow-on requirement and an approved justification exists, a copy of the approved justification should be attached. A copy of the approved justification is required to allow the approving authority for this justification to determine if the planned actions to remove barriers that led to the restricted competition on the previous justification were completed. If the planned actions to remove those barriers were not completed, this justification must be approved one-level above the approving authority. There may be instances when it is not possible to compete the current acquisition. In these cases, include a statement of the actions taken, or to be taken, to increase competition (e.g., procure needed technical data for full and open competition or breakout subsystems or components for full and open competition) before any subsequent acquisition of the supplies or services. If future competition will be based on the procurement of technical data, provide the approximate date the technical data package will be available.

While competition for the immediate repair of the proprietary D-21 Fire Alarm Control Panels is not practicable, the Government is committed to fostering competition for future requirements. The following long-term strategies will be implemented to ensure that subsequent acquisitions for fire alarm systems and services are competitively sourced:

Long-Term Modernization and Replacement Strategy The current sole-source situation is a direct result of a past decision to standardize with a proprietary system. To break this cycle of vendor lock-in, the Government will develop a long-term modernization plan that schedules the eventual replacement of the existing Monaco Enterprises system at the end of its life cycle. This plan will include:

Phased Implementation: Rather than a single, cost-prohibitive, base-wide replacement, the strategy will focus on a phased approach. This could involve replacing the system building by building or section by section over a number of years, allowing for manageable budget allocation and minimal operational disruption.

Life Cycle Cost Analysis: Future planning will incorporate a thorough analysis of the total life cycle costs of a proprietary system versus an open-architecture system, with a heavy emphasis on the long-term costs associated with sole-source maintenance and repairs.

Emphasis on Open and Non-Proprietary Standards This is the most critical element for ensuring future competition. All future solicitations for new fire alarm systems or major upgrades will explicitly require the use of open-architecture, non-proprietary systems. The requirements will specify:

Interoperability: Systems must be based on industry-standard protocols (e.g., BACnet, Modbus) that allow components from different manufacturers to be integrated, serviced, and replaced without being restricted to a single vendor.

Data and Tool Access: The Government will require access to all necessary software, diagnostic tools, and technical documentation needed for full-system maintenance and repair, ensuring that any qualified third-party vendor can service the equipment.

Continuous Market Research and Industry Engagement To stay informed of technological advancements and new market entrants, the Government will:

Conduct Ongoing Market Research: Proactively and regularly survey the fire alarm and mass notification market to identify new companies, emerging technologies, and innovative solutions that could meet government requirements.

Issue Requests for Information (RFIs): Prior to developing requirements for a new system, RFIs will be issued to the industry. This will help the Government understand the current state of technology and shape the acquisition strategy to maximize competition.

By implementing this forward-looking strategy, the Government will transition from the current restrictive, sole-source environment to a competitive, open-market environment for all future fire alarm system acquisitions. This will ensure better value, greater innovation, and reduced long-term costs.

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c. Market Research ⋯

Describe the extent and the results of the market research (FAR Part 10 and DFARS 210.001) conducted to identify all qualified sources. Research must have been meaningful (demonstrated attempt to discover all relevant material) and the Contracting Officer may use market research conducted within 18 months before the award of any task or delivery order if the information is still current, accurate, and relevant.

The results of this market research conclusively demonstrate that only one source, Monaco Enterprises, is capable of fulfilling this requirement. This conclusion is based on the following key findings:

Proprietary System: The D-21 Fire Alarm Control Panels and their operating software are the proprietary intellectual property of Monaco Enterprises.

No other company has access to the necessary schematics, software, or diagnostic tools to perform repairs.

Sole Source for Parts: All replacement parts and components for the D-21 system are manufactured and sold exclusively by Monaco Enterprises.

Existing Infrastructure: The entire fire alarm infrastructure at this facility is a Monaco system. Introducing components from another manufacturer is not possible due to incompatibility.

Based on these findings, it is determined that Monaco Enterprises is the only qualified source for the required repairs.

d. Interested Sources ⋯

Include a listing of the sources that have written to express interest in the acquisition. If applicable, clearly state:

“To date, no other sources have written to express an interest.” Also, state that the notices required by FAR 5.201 shall be or have been published, and that any bids or proposals received shall be considered. If a notice is not posted, state which exception in FAR 5.202 applies.

To date, no other sources have written to express an interest. FAR 5.202(a)(8)

e. Other Facts ⋯

Discuss any other facts supporting the use of other than full and open competition, such as the following:

a. Procurement history. Reasonable efforts to retrieve the following items from computer records, contract files, competition advocate office files or other sources are expected:

(1) Contract numbers and dates of all awarded contracts for these same requirements.

(2) The competitive status of these actions.

(3) Authority previously cited if less than full and open competition was used.

(4) If a justification was prepared to support the procurement made before this one, a summary of the contents of paragraph 7 of the justification for that procurement and an explanation of the results.

(5) If any prior contract for this requirement was accomplished using full and open competition, include a detailed explanation of the changed circumstances causing this action to now limit the sources.

(6) An explanation of any unusual patterns that may be revealed by the history, e.g., several consecutive, urgent buys.

(7) If a justification was prepared to support the procurement made before this one, briefly describe the circumstances justifying the procurement and whether there have been any significant changes.

b. Other facts. Provide any other facts necessary to justify limiting competition that were not previously stated.

Prior Contracts: All previously awarded contracts for the repair, maintenance, and expansion of the D-21 Fire Alarm Control Panel system have been awarded to Monaco Enterprises.

Competitive Status: These actions have consistently been awarded on a sole-source basis.

Authority Previously Cited: The authority cited for previous sole-source actions has been consistent with the current requirement, specifically citing that only one responsible source is available to meet the Government's needs, in accordance with FAR 13.106-1(b)(1).

Summary of Prior Justifications: Justifications prepared for previous procurements contained the same core reasoning presented here. They identified that the D-21 system is proprietary to Monaco Enterprises, that Monaco is the sole manufacturer of parts and developer of the required software, and that no other vendor possesses the technical data, tools, or expertise to service the equipment. The result was a determination that soliciting competition was not feasible and the award was made to Monaco Enterprises.

Prior Competition: No prior contract for this specific requirement has been accomplished using full and open competition. The system was installed as a proprietary Monaco Enterprises system, and all subsequent sustainment actions have been sole-sourced to the Original Equipment Manufacturer (OEM) by necessity. Therefore, there are no changed circumstances causing this action to now limit sources; the circumstances have been constant since the system's installation.

Unusual Patterns: The procurement history reveals no unusual patterns, such as multiple consecutive urgent buys. Instead, it shows a logical and expected pattern of planned, recurring, sole-source awards for the maintenance and repair of a proprietary system.

Significant Changes: There have been no significant changes since the last justification was prepared. The D-21 fire alarm system remains a proprietary product, and Monaco Enterprises remains the only source for parts, proprietary software, and certified repair services. The circumstances justifying the sole-source procurement are identical to previous actions.