Attachment 7 - JA AMRS Software REDACTED.pdf

Department of the Air Force: Justification for Other Than Full and Open Competition

CUI

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CERTIFICATIONS: CO certification serves as J&A approval < $10M, See J&A Template Guidance at https://usaf.dps.mil/sites/ AFCC/AQCP/KnowledgeCenter/SitePages/DAF-Contracting-Compass/Part-6---Competition-Requirements.aspx for completing the J&A sections and J&A Approval Guidance

APPROVALS ( RFO 6.104-2(a) Table 6-1 & R-DFARS 206.104-72 Table 206.1)

See J&A Template Guidance (https://usaf.dps.mil/sites/AFCC/AQCP/KnowledgeCenter/SitePages/DAF-Contracting-Compass/ Part-6---Competition-Requirements.aspx) - J&A Approval Guidelines

NOTE 1: A signature block will appear here (replacing these notes) based on the "Dollar Value of this Acquisition" selected above. Since most digital signatures that include date/time-stamps are redacted before they are made publicly available, always insert the date in the “Date” cell when affixing a digital signature to this document.

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I. Agency and Contracting Activity (RFO 6.104-1(a)(1)):

Air Force Installation Contracting Center, 772 Enterprise Sourcing Squadron/PKD 139 Barnes Drive, Panama City, FL, 32403

II. Nature and/or description of the action being approved (RFO 6.104-1(a)(2)):

The United States Air Force (USAF) has a requirement to limit Automated Meter Reading System (AMRS) software procurements to Schneider Electric brand Power Monitoring Expert (PME) 2020 software and software sustainment. This requirement will be procured as a new, firm fixed price (FFP) contract for the Air Force Civil Engineer Center (AFCEC).

III. Description of supplies/services required to meet agency needs (RFO 6.104-1(a)(3)):

The USAF requires the procurement of Schneider Electric Automated Meter Reading System (AMRS) Power Monitoring Expert (PME) software sustainment and Schneider AMRS PME software license suites.

Each suite uses modules of Schneider Eco Structure PME software to sample, calculate, display and archive data.

The FFP contract resulting from this brand name justification will provide: 1) annual software sustainment services for 46 existing government owned Schneider AMRS PME license suites (currently installed at multiple locations) and 2) the option to procure up to 30 additional Schneider AMRS PME license suites with annual sustainment. Software sustainment services include: new software releases, 24 hours telephone, e-mail, and web portal technical support to resolves issues and answer questions.

The contract period of performance will include a six-month base period and four (one) year options.

Option periods have been included as the requirement is expected to be funded yearly with operations and maintenance funds (3400) and the government has a reasonable expectation that the requirement will continue to exist. The projected period of performance is :

- Base Period: Sep 2026 - Mar 2027

- Option Year 1: Mar 2027 - Mar 2028

- Option Year 2: Mar 2028 - Mar 2029

- Option Year 3: Mar 2029 - Mar 2030

- Option Year 4: Mar 2030 - Mar 2031

- CLIN1: (qty: 46) Yearly PME software sustainment for existing licenses

- CLIN 2: OPTIONAL: New PME license suites (up to 30) -CLIN 3: OPTIONAL: PME software sustainment for new licenses

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The purchase of Schneider Electric PME software is a commercial item procurement. In terms of Intellectual property, the Government only orders technical data needed for the operation and maintenance of the software that is customarily provided to the public.

IV. Statutory Authority Permitting Other Than Full and Open Competition (RFO 6.104-1(a)(4)):

10 U.S.C. 3204(a)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.

V. Rationale for Use of Authority (RFO 6.104-1(a)(5)):

The authority to limit competition to Schneider Electric PME brand name only software and sustainment is required in accordance with RFO 12.201-1 and 41 U.S.C. 1901.

The required AMRS PME software system must have an Authority to Operate (ATO) and allow energy meters to be read and collect 16 points of data related to electric, water, natural gas, etc. These licenses are essential for sampling, calculating, displaying, and archiving data from energy meters across government installations. Collecting this data allows the Government to easily identify where problems exist across the power grid, reduce back-feeding (which increases electrical safety), manage the electrical load in times of a micro-grid, and allow for effective billing oversight.

Schneider PME is the only product that can meet the Government's minimum needs without causing unacceptable mission risk, incurring substantial duplicated costs, and creating significant schedule delays.

1) The government's current infrastructure utilizes Schneider licenses, which are only compatible with Schneider provided sustainment services. The Air Force has already made a significant capital investment in deploying the AMRS system, based on Schneider PME software, across 46 installations including training and software sustainment.

2) The Schneider PME software has an open-source architecture. The existing AMRS is a complex, integrated network of hardware and software, and Schneider's open architecture allows PME to communicate seamlessly with meters and devices from dozens of different manufacturers already fielded across the enterprise. Competing software brands (e.g., Eaton, SOCOMEC) utilize more proprietary systems that require "middleware" to translate data, which is not permitted by the program.

3) The current AMRS system, with its Schneider PME software core, has a full, enterprise-wide Authority

March 2026 Page 4 of 5March 2026 Page 4 of 5 to Operate (ATO) on the Air Force network. This ATO is our official certification that the system is secure and authorized for use. The Government actively encourages competition and provides a clear path for any software company to achieve an ATO through established federal processes, with instructions available via FedRAMP at https://www.fedramp.gov/agency-authorization/. However, despite the existence of this process, Schneider Electric is currently the only provider of advanced metering software that has successfully completed this certification process and holds an approved ATO for use on DoD networks for this purpose.

VI. Integrated Market Analysis and Efforts to Solicit Competition (RFO 6.104-1(a)(6), (8), and (10)):

As addressed in section V, the Government is bound by the Air Force's Authority to Operate (ATO) and therefore is required to utilize Schneider Electric software for AMRS PME licenses and sustainment. In FY 2024, the Government purchased Schneider PME licenses as a sole source 8(a) direct award to Dawson MCG, LLC (FA805124C0007). As a result, this requirement for AMRS PME software licenses and sustainment was accepted into the 8(a) program by the Small Business Administration (SBA). The Partnership Agreement between DoD and the SBA states "where a procurement is awarded as an 8(a) contract, its follow-on or renewable acquisition must remain in the 8(a) SB program unless SBA agrees to release it."

Therefore, this requirement must continue to be full-filled through the 8(a) program.

In August 2025, the Government contacted Schneider Electric and requested an all inclusive list of their 8(a) distributors.

Schneider Electric provided four 8(a) distributors: Seneca Strategic Partners, POI Federal Services, Tukuh TS, and Dawson MCG, LLC. However, on April 6th, 2026, the Dawson's SBA representative informed us that Dawson graduated the 8(a) program on January 29th, 2026.

In an effort to conduct thorough market research, the Government issued a Request for Information (RFI) on SAM.gov that concluded on February 6, 2026. The purpose of the RFI was to identify any potential 8(a) vendors authorized distributors of Schneider Electric products or compatible software that could interface with the Governments existing Schneider software.

The RFI did not reveal any compatible software brands.

VII. Determination of Fair and Reasonable Cost (RFO 6.104-1(a)(7)):

The Contracting Officer is responsible for evaluating, determining, and documenting the anticipated contract cost/price is

March 2026 Page 5 of 5 fair and reasonable in accordance with RFO Subpart 15.4, Contract Pricing.

VIII. Any Other Facts Supporting the Justification (RFO 6.104-1(a)(9)):

IX. Actions to Overcome Barriers to Competition (RFO 6.104-1(a)(11):

The USAF is continually seeking alternatives for the AMRS program and will continue to monitor the industry for any software that 1) provide tracking of power quality, 2) allows for the use of tailored suites, 3) utilizes open source access, and

4) has interest in being added to the ATO.

Industry- The industry has not changed in a way that provides an alternative at this time. Other options largely center on billing for "utility use" instead of "power quality." Other industry options also require the use of their full suite of products and do not allow for open source devices and software to identify and close vulnerabilities. Because of this the other options do not meet USAF requirements.

Prior to all future acquisitions, the Government will continue to conduct market including issuing RFI's.