B08_Attachment_12_Name_Brand_Justification_8_11_22.pdf

United States Department of the Interior

NATIONAL PARK SERVICE

NATIONAL CAPITAL AREA

1100 Ohio Drive S.W.

Washington, D.C., 20242

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8/8/2022

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN

COMPETITION- Brand Name Requirement Over $250,000 (FAR 6.303-2)

PR Number: 0040582849 This justification is covering only the portion of the acquisition which is brand-name or peculiar to one manufacturer, and the approval level requirements will then only apply to that portion.

1. Identification of the Agency and the Contracting Activity:

Agency: Department of Interior, National Park Service (NPS), National Capital Area (NCA), Construction, A&E and Strategics Major Acquisition Buying Office, 1100 Ohio Drive, S.W.

Washington, D.C. 20242. Prince William Forest Park (PRWI).

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

Prince William Forest Park (PRWI) is requiring specific brand name Enviroshake composite shake and Envirosheild BSA underlayment that are manufactured exclusively by Enviroshake Quality Engineered Roofing to be used for the Cabin Camp 4 and Cabin Camp 5 roof replacement project.

3. A Description of the Supplies or Services Required to Meet the Agency’s Needs, Including the

Estimated Value:

Prince William Forest Park is replacing the roofs on the historic dining halls in cabin camps 4 and 5 with brand-name specific Enviroshake composite shakes in the silvered cedar color and Enviroshield BSA underlayment which are exclusively manufactured by Enviroshake Quality Engineered Roofing (formerly Wellington Polymer Technology, Inc.).

The Government estimate for this project is:

PoP: 160 days after notice to proceed.

4. An Identification of the Statutory Authority Permitting Other Than Full and Open Competition:

FAR 6.302-1 (c) – Application for Brand-Name Descriptions. (1) An acquisition or portion of an acquisition that uses a brand-name description or other purchase description to specify a particular brand-name, product, or feature of a product, peculiar to one manufacturer.

5. A Demonstration That the Proposed Contractor’s Unique Qualifications or the Nature of the

Acquisition Requires Use of the Authority Cited:

Per the memorandum of agreement between the NPS and the Virginia State Historic Preservation Office, specifically Section 106 the NPS shall replace all deteriorated roofing systems that fall within 1936-1941 CCC construction era with a composite roof system that is exclusively manufactured by Enviroshake Quality Engineered Roofing. Key determining factors IAW Section 106 Compliance include: resemblance to cedar shake, life expectancy, recycled content, installation method, NPS-National Capital Area – USPP Disinfecting Page 2 of 4

Preserving unimpaired the natural and cultural resources and values of the national park system for the enjoyment, education, and inspiration of this and future generations.

maintenance, and cost. By selecting a substitute shingle that most closely resembles wood shake, the park remains in accordance with the Secretary of Interior’s Standards for Rehabilitation to match the visual qualities of the character defining features.

The specific products that make up the roofing system include the brand-name specific Enviroshake roofing tiles and Enviroshield BSA underlayment. The brand-name specific Enviroshake shingles in the silvered cedar color have been determined to be the only product that can meet the compliance requirement on CCC era buildings at Prince William Forest Park per the agreement. Enviroshake’s physical properties will not impair the existing structures or cause adverse effects. The shingles have the same weight as the previously used asphalt shingles and/or wood shake. In addition, the product has been improved with additives that bring UV stabilization, fungicide, insect, and mold resistance.

Enviroshake does not absorb moisture in excess of 3% and will not encounter freeze-thaw issues that are associated with wood shakes. It can also withstand 110 mph winds.

Further, the Secretary of Interior Standards for Rehabilitation & the Guidelines on Sustainability for Rehabilitation Historic Structures, Standard 5 states, “Distinctive features, finishes, and construction techniques or examples of craftsmanship that characterize a historic property shall be preserved.” The historic wood shake that contributed to the historic park architecture and rustic movement was replaced in the 1940s with asphalt shingles. The park aims to discontinue use of asphalt shingles on CCC era structures and use materials that would match the original historic fabric. The Government has determined that the brand-name specific Enviroshake product meets the original historic fabric with new and better technology. The Enviroshake product resembles the variation, color, and texture of weathered wood shake shingles that were on the original structures.

Additionally, the Enviroshake Quality Engineered Roofing system satisfies the Secretary of Interior’s guidelines for sustainability which is also required for the rehabilitation of historic structures. The product is composed of 95% recycled materials, including a mixture of postindustrial plastic, recycled rubber, elastomers, and natural wood fibers. Upon installation the shingle is dark grey and weathers to a silvery color within 3-9 months. The product also has a lifetime warranty and is fully transferable for up to 50 years when installed by a certified contractor.

Preservation Brief 16 also states “[substitute materials] must be compatible with the historic materials in appearance; their physical properties must be similar to those of the historic materials or be installed in a manner that tolerates differences; and they must meet certain basic performance expectations over an extended period of time.”The shingles are installed in the same manner as actual wood shake shingles.

The use of the aforementioned brand-named products equates to a lifetime 50-year warranty, which is also required per compliance considering it is more sustainable and maintenance free. The Government has limited staff and funds considering the number of CCC era structures that are located at PRWI.

While, wood shake shingles are still readily available and most contractors can install this material, it is not considered in the Government’s best interest to use anything other than the brand-name specific Enviroshake Quality Engineered Roofing as the park is unable to perform yearly topical maintenance that is required on actual wood shake roofs or sustain the costs of replacing these roofing systems every 10 years. The number of structures in the park contributing to the ECW architecture makes this material cost prohibitive. Additionally, the park replaced Cabin Camp Roofs 2 and 3 last year with the exact same product.

Other roofing materials were considered but dismissed include Cedar Shake, Asphalt, DaVinci, and EcoStar as they were not specifically identified in the agreement between NPS and the Virginia State Historic Preservation Office. They were found in the development of the agreement to not meet the specific requirements of the CCC era structures that are located at PRWI.

“Enviroshake” shingles and Enviroshield BSA underlayment are available from only a single

NPS-National Capital Area – USPP Disinfecting Page 3 of 4

Preserving unimpaired the natural and cultural resources and values of the national park system for the enjoyment, education, and inspiration of this and future generations.

manufacturer, Enviroshake Quality Engineered Roofing (formerly Wellington Polymer Technology, Inc.); however, the materials are available through multiple installers who a certified to sell and install Enviroshake Quality Engineered Roofing products. In order for the Government to secure the Lifetime and 50-year transferrable warranty that is offered, the product must be installed by a licensing and certified Enviroshake Quality Engineered Roofing contractor.

6. A Description of Efforts Made to Ensure That Offers Are Solicited 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:

No exception applies under FAR 5.202, and therefore will be synopsized through GPE (SAM.gov) as required by FAR 5.101 (a)(1). Additionally, NCA contractors that have successfully performed roofing work for the NCA will be advised of the requirement as well as any contractors that have been identified through market research that are small business concerns.

7. A Determination By the contracting officer That the Anticipated Cost to the Government Will Be Fair and Reasonable:

The intent is to use FAR 6.302-1(b)(i) Unique supplies or services available from only one source or only one supplier with unique capabilities to limit roofing material to Enviroshake shingles underlayment IAW Section 106 compliance. Only Enviroshake manufactures and provides factory training for required roofing shakes known as Envoroshake and underlayment Enviroshield to secure the required 50-year warranty on roofing

This approach limits competition only for the name brand materials required. Labor and other factors that make up the whole requirement should be competitive. The CO will be able to review online pricing for the name brand materials or obtain a quote direct from Enviroshake to determine fair market value. A Description of the Market Research Conducted (see FAR Part 10) and the Results or a Statement of the Reason Market Research Was Not Conducted:

8. A Description of the Market Research Conducted (see FAR Part 10) and the Results or a Statement of the Reason Market Research Was Not Conducted:

Market Research was conducted via SBA Dynamic Small Business Search and the knowledge of previous roofing contracts in the NCA all of whom should be able to satisfy this requirement.

Considering this is a brand name justification, there should be no impact on the ability of any of the contractors to become certified in order to install the name brand products required. It must be mentioned that any contractor has the ability to make a purchase from Enviroshake and any contractor wishing to be certified as an installer, can do so by following their Contractor Factor Training Process, which is free.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition (see FAR 6.302-2

(9) (i) – (iii) for some examples):

Enviorshake provided a letter on 6/6/2022 that indicated the brands Enviroshake® and Enviroshield® are brands proprietary to Enviroshake. Furthermore, the two aforementioned exclusive products must be used together and installed by an individual Factory Trained by Enviroshake to obtain the 50-year warranty needed by the park.

10. A Listing of the Sources, If Any, That Expressed in Writing, an Interest in the Acquisition:

None