B02-02-WBR_1406_303-1_JOTFOC_Brand_Name_32847_FINAL.pdf

Solicitation No. 140R6026Q0007 Page 1 of 6

WBR 1406.303-1 Template 1 eFile - B02

(04/2021)

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION

In accordance with FAR 6.302 or FAR 13.501(a), the proposed contractual action is pursuant to the statutory authority identified in paragraph 4. This template is required for actions over the Simplified Acquisition Threshold (unless the procurement is acquired as a limited source IAW FAR 8.405-6 or is an Exception to Fair Opportunity IAW FAR 16.505(b)(2)).

1. Agency and Contracting Activity (FAR 6.303-2(b)(1)):

U.S. Department of the Interior, Bureau of Reclamation, Missouri Basin Region, Acquisition Services (MB-5000)

2. Nature/Description of Action (FAR 6.303-2(b)(2)):

The contractual action will be a Firm-Fixed-Price supply contract utilizing a Brand Name source for Basler product, with no-year funds to be obligated.

3. Description of Supplies/Services (FAR 6.303-2(b)(3)):

The Canyon Ferry and Yellowtail Powerplant excitation systems require upgrades.

Both powerplants generating units utilize a static excitation system. The existing front-end hardware is beyond the serviceable life and is no longer supported. As such, a front-end retrofit upgrade is required for both powerplants’ generating units. The supplies will be delivered to 1) the Canyon Ferry Powerplant, located approximately 20 miles east of Helena, Montana, in Lewis & Clark County and 2) the Yellowtail Powerplant, located approximately 43 miles southwest of Hardin, Montana, in Bighorn County. The Canyon Ferry Powerplant has three generating units, and the Yellowtail Powerplant has four generating units.

The Canyon Ferry excitation system is an Eaton ECS-2100 model and was installed in 2011. The Yellowtail excitation system is a Cutler Hammer ECS-2100 model and was installed in 2005. Since the installation of Eaton and Cutler Hammer models, Basler has acquired and maintains the original designs of these systems and components. The Basler DECS-2100 model is the current and compatible system of the currently installed models. The front-end upgrade of the existing ECS-2100 voltage regulators to the Basler DECS-2100 voltage regulators includes retrofitting new control boards and human-machine interfaces (HMIs) on each generating unit.

This may include the bridge control module(s) (BCM). The existing BCMs for retrofit to the Basler BCM-2 will be identified at the time of award. As such, the BCM-2 will be identified as optional in the solicitation.

The delivery for this requirement will be one year (365 calendar days) from the receipt of award. This delivery period will allow sufficient time for the contractor to research the existing excitation systems, provide the current components for retrofitting, installation, configuration, implementation, and testing of the

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(04/2021) retrofitted components, and providing on-site turnkey training by Basler trained experts to the powerplant personnel. The estimated value of this requirement is $1,175,500.00.

4. Statutory Authority Permitting Other than Full and Open Competition (FAR 6.303-2(b)(4)):

Authority FAR Coverage Application ☐ 41 U.S.C. 1901 FAR 13.501 Only one responsible source using Simplified

Acquisition Procedures (above SAT but at or below $7.5M)

☐ 41 U.S.C. 1903 FAR 13.501 Special emergency procurement authority

☐ 41 U.S.C. 3304(a)(1) FAR 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements

☒ 41 U.S.C.

3304(a)(1)

FAR 6.302-

1(c)

Application for brand-name descriptions

☐ 41 U.S.C. 3304(a)(2) FAR 6.302-2 Unusual and compelling urgency

☐ 41 U.S.C. 3304(a)(3) FAR 6.302-3 Industrial mobilization; engineering, developmental or research capability; or expert services

☐ 41 U.S.C. 3304(a)(4) FAR 6.302-4 International Agreement ☐ 41 U.S.C. 3304(a)(5) FAR 6.302-5 Authorized or required by statute ☐ 41 U.S.C. 3304(a)(6) FAR 6.302-6 National Security ☐ 41 U.S.C. 3304(a)(7) FAR 6.302-7 Public Interest

5. Demonstration of Contractor’s Unique Qualifications (FAR 6.303-2(b)(5)):

Since the installation of the excitation systems at Canyon Ferry and Yellowtail Powerplants, Basler has acquired and maintains the original designs of these systems and components. For compatibility with the existing ECS-2100 systems, a Basler DECS-2100 and BCM-2 upgrade is the only brand name available.

No other equipment is compatible with the existing system and design. The existing front-end hardware is beyond the serviceable life and is no longer supported. Due to this, a full system replacement is not required as other components are still serviceable. If the Canyon Ferry and Yellowtail Powerplants were to change systems, this would increase costs significantly, requiring additional funding, time, labor, and loss of power generation during downtime.

a. In terms of funding, a full system replacement is estimated to be $5 million to

$15 million, as displayed in a similar solicitation’s disclosure of magnitude for a full excitation system replacement at the Hungry Horse Powerplant (four generating units). If this requirement were for a full replacement for all seven

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(04/2021) generating units (three for Canyon Ferry and four for Yellowtail), this estimated range could potentially double. The estimated value for this requirement is $1,175,500.00 for upgrading all seven generating units, which is significantly lower than bottom of the estimated range for replacing four generating units.

b. In terms of time and loss of power generation, a full replacement of the excitations systems could take months, whereas upgrading the front-end system is estimated to take two weeks per generating unit. Upgrading the generating units will also allow for one unit to be down (shutoff) at a time, minimizing impacts to power generation and revenue generation. This method helps ensure the powerplants continue to meet their power generation demands.

c. In terms of labor, full replacements require additional labor categories and increased hours for the duration of the replacement, which is longer than upgrading individual components.

Based on these considerations, a brand-name requirement for Basler is in the best interest of the Government.

6. Description of efforts made to maximize competition (FAR 6.303-2(b)(6)):

Basler maintains and trains a list of authorized distributors/suppliers for their components and systems, which allows for competition. In Fiscal Year 2025, under System for Award Management (SAM) Notice ID: 140R6025Q0047, several notices were posted to identify viable sources, including 1) a sources sought posted on 6/13/2025, with a response due date of 6/30/2025; 2) a pre-solicitation notice posted on 6/10/2025, (updated 7/7/2025) with a response due date of 7/21/2025;

and 3) a notice of intent to solicit a brand name requirement posted on 8/20/2025, with a response due date of 9/2/2025. Of these SAM postings, no formal responses were received. However, two small businesses did express interest through the SAM Interested Vendors List.

7. Determination of Fair and Reasonable Cost (FAR 6.303-2(b)(7)):

The approach to replacing only those components that have demonstrated a degradation in reliability is the most advantageous and cost-effective approach for this requirement. The Fiscal Year 2026 SAM Notice ID: 140R6026Q0007 will be issued as a Total Small Business set-aside to maximize competition. The solicitation will be issued competitively under Simplified Acquisition Procedures, in accordance with FAR parts 12 and 13. The Contracting Officer will conduct a price analysis using the techniques at FAR 15.404-1(b)(2), including (i) comparison of proposed prices received in response to the solicitation (adequate price competition, if received), (ii) comparison to historical prices paid, (v) comparison to the independent Government cost estimate, and (vi) comparison of prices obtained through market research for same or similar items. The basis of award will be Lowest-Price-Technically Acceptable.

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(04/2021)

8. Description of Market Research Conducted (FAR 6.303-2(b)(8)):

Market Research was conducted by the Contract Specialist and Contracting Officer between May to November 2025. The customer procurement package request included two potential small business sources with their brand name request for Basler products. Of these, one was not considered viable due to their expired SAM registration. Searches under mandatory and established sources resulted in zero results. An FPDS-NG search for similar requirements within the Bureau of Reclamation resulted in two potential small business sources, both of which can meet this requirement’s brand name need. A search in the Small Business Administration’s (SBA) Dynamic Small Business Search (DSBS), resulted in several small businesses, of various socio-economic types. However, their DSBS profiles did not confirm if they were authorized suppliers/trained by Basler. Of the three SAM postings for this requirement mentioned above, no formal responses were provided in writing to the Contracting Officer. Additional research in SAM shows there is a similar solicitation (Total Small Business Set-Aside) from the Pacific Northwest Region for the Hungry Horse Powerplant, Hungry Horse, Montana, in Flathead County. However, this solicitation is for the full replacement of the Hungry Horse excitation systems. Based on the results of the market research, the Contracting Officer determined it is in the Government’s best interest to issue the solicitation for this procurement as a Total Small Business Set-Aside to maximize competition.

9. Any Other Supporting Facts (FAR 6.303-2(b)(9)):

Basler acquired the Eaton and Cutler Hammer systems and maintains the original designs of the systems and components. No other known companies can provide all the required components (including software and hardware) that are compatible with Basler’s systems. The current systems utilize unsupported versions of Basler’s BESTCOMS™ Pro Controller configuration tool, where the upgrade will include the current version. Basler’s BESTCOMS™ is proprietary software for its products.

10. Listing of Interested Sources (FAR 6.303-2(b)(10)):

No sources expressed their interest in this requirement in writing to the Contracting Officer. However, on SAM the following vendors were shown on the Interested Vendors List from the sources sought and pre-solicitation notice posts:

a. Koontz Electric Company, Inc., 1223 E. Broadway Street, Morrilton, Arkansas, 72110

b. Hugana, LLC, 1154 Wilde Drive, Kissimmee, Florida, 34747

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Other potential sources identified in the market research that are known to be capable of meeting the brand name (but didn’t express interest) include the following:

a. Basler Electric Co, 12570 State Route 143, Highland, Illinois 62249

b. Basler Services, LLC, (subsidiary of Basler Electric), 8115 Shaffer Parkway, Littleton, Colorado, 80127

11. Actions Taken to Remove Barriers to Competition (FAR 6.303-2(b)(11)):

Based on the results of the market research and to maximize competition, SAM Notice ID: 140R6026Q0007 will be solicited as a Total-Small Business Set-Aside, in accordance with FAR 19.502-2(a). Since there were no responses to the SAM postings, a socio-economic set-aside could not be determined. However, market research indicated there are at least three small businesses that could satisfy the requirement. If no acceptable quotes are received from the Total-Small Business Set-Aside, the set-aside will be withdrawn, and the requirement will be resolicited as full and open. However, due to the compatibility and proprietary software, the re-solicitation will need to include a brand name request for Basler.

The market will continue to be monitored by the requesting office, as well as the Contracting Officer, to identify any new entrants into this market. Evaluation will continue and the contract file will be updated accordingly on any applicable findings.

SIGNATURES

PREPARED BY:

CONTRACTING OFFICER (CO) (FAR 6.304(a)(1) or FAR 13.501(a)(2)(i)): (All Values)

X Charlene Maurer

CO

X Sydney Oakes Contract Specialist

Solicitation No. 140R6026Q0007 Page 6 of 6 eFile - B02

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CHIEF of the CONTRACTING OFFICE (CCO) (DOI-AAAP-0024): (> $350K)

BUREAU COMPETITION ADVOCATE (FAR 6.304(a)(2) or FAR 13.501(a)(2)(ii)):

(>$900K)

HEAD of the CONTRACTING ACTIVITY (HCA) (FAR 6.304(a)(3) or FAR 13.501(a)(2)(iii)): (>$20M OR > $350K AND the CO is the CCO) – Also required for the award of any non-competitive enterprise contract, a contract vehicle where orders or calls can be placed by or on behalf of multiple DOI bureaus, or which will be a mandatory source for DOI.

Not Applicable.

SENIOR PROCUREMENT EXECUTIVE (SPE) (FAR 6.304(a)(4) or FAR 13.501(a)(2)(iv)): (>$90M) – IAW DOI-AAAP-0024, SPE signature is also required for the award of any non-competitive enterprise contract – regardless of value – where orders or calls can be placed by or on behalf of multiple DOI bureaus, or which is a mandatory source for DOI or single-award indefinite delivery vehicle.

Not Applicable.

X Brandon Collins

CCO

X Meagan Fyffe

BCA