Brand Name Justification Approval_Redacted.pdf

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Control Number:

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JUSTIFICATION REVIEW DOCUMENT

RFO Part 12 Justification and Approval

Acquisition of Commercial Products and Commercial Services

Program/Equipment: Three-phase 120/208V and single phase/backfed 120/240V panels for the powerhouse at Dworshak Dam, Idaho for the United States Army Corps of Engineers.

Authority:

Title 41 United States Code (U.S.C.) §1901(e)(2) as implemented in the Revolutionary Federal Acquisition Regulation Overhaul (RFO) 12.102(a), restricting competition under the authority of the acquisition of commercial products and commercial services.

Amount:

Prepared by: Phone:

Electrical Engineer Date: 4/1/2026 E-mail:

Contracting Officer: Phone:

Contracting Officer Date:

E-mail:

Technical: Phone:

Electrical Engineer Date: 4/1/2026 E-mail:

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Legal Counsel:

Phone:

Deputy District Counsel E-mail:

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5. Authority Cited:

Title 41 United States Code (U.S.C.) §1901(e)(2) as implemented in the Revolutionary Federal Acquisition Regulation Overhaul (RFO) 12.102(a), restricting competition under the authority of the acquisition of commercial products and commercial services.

6. Reason for Authority Cited:

a. Background: Dworshak Dam currently has CR panelboards and load centers that are either three-phase 120/208V or single phase/backfed 120/240V in the powerhouse that are original equipment. Fourteen (14) of these panels are no longer serviceable as the breakers are no longer manufactured.

The panelboards and load centers supplied under this brand name determination will be used to modernize the electrical distribution system at the Dworshak Dam powerhouse. In particular, these panelboards/load centers will be used to distribute power from the switchboards to a number of critical infrastructure components at the powerhouse. Schneider Electric/Square D NQ-style panelboards and QO-style load centers are the standard product used at the Dworshak Project. The Dworshak Powerhouse currently has one (1) panelboard and two (2) load centers currently (which use the same breakers and other components) of this same model installed throughout the facility.

Only one source is reasonably available, as it is in the Government’s best interest to standardize electrical distribution equipment wherever possible.

Standardization increases personnel efficiency and ensures electrical crews are familiar with the system, reduces training requirements, utilizes common test equipment, and ensures spare and replacement parts are available for emergency repair of critical systems.

The Dworshak Project maintains a limited assortment of spare parts for the Schneider Electric/Square D NQ type panelboards and QO type load centers in the powerhouse warehouse, such as circuit breakers, but this resource is not exhaustive.

Matching the newly installed equipment with the brand name, style, and ratings of existing panelboards/load centers provides for the ability to share components across systems at Dworshak project. The stock of spare parts referenced above is one potential source of shared components; borrowing components from a non-critical system to restore operation to a critical system is also another possibility.

b. Alternatives: One alternative is to replace all CR panelboards, load centers, and breakers in Dworshak Dam, and this would require extensive design and

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schedule impacts, which would leave the electrical distribution system at Dworshak Dam at significant risk of failure until completed.

Another alternative is to source panelboards from a different manufacturer.

Dworshak Dam would be required to maintain two different sets of parts for two different manufacturers, raising the cost of spare parts, labor, and training over the course of equipment life.

c. Impact if not approved: Selection of a different brand or model of panelboard/load center would introduce unnecessary and unacceptable risk to the reliable operation and timely repair of critical power generation and distribution systems.

Breakers and panelboard/load center parts can often be not easily acquired off-the-shelf items, particularly in the current environment, which is experiencing significant supply chain delays. The time required to locate and acquire such items for a different style panelboard/load center are likely to interrupt operation of critical systems for months.

Procurement of a different style panelboard/load center introduces additional costs to the Government and decreases efficiencies gained from standardization.

For instance, Dworshak personnel will require additional training and different test equipment to perform maintenance and repair of other systems, and a larger variety of spare parts will be required to be stored and tracked in Dworshak’s size-limited warehouse.

Estimated Additional Costs for Non-Standard Panelboard/Load Center Procurement:

Cost Category Estimated Amount Notes

Equipment Price Difference

Alternative brands may be more expensive or require custom features.

Spare Parts Inventory

New inventory for breakers, accessories, and replacement parts.

Design/Engineering Review

Additional design and compatibility checks.

Installation Modifications

Labor and materials for adapting infrastructure.

Training for Staff

Time and resources for retraining maintenance and operations staff.

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Potential Project Delay

Cost of schedule impact (e.g., labor, overhead, lost productivity).

Documentation Updates

Updating procedures, manuals, and drawings.

Risk of Incompatibility

Potential troubleshooting, downtime, and reliability issues.

Total Estimated Additional Cost:

1. Cost Implications:

Switching to a different style or brand of panelboard/load center would introduce additional costs to the Government. These costs include not only the price difference for the equipment itself, but also the need for new spare parts inventory, potential modifications to existing infrastructure, and increased maintenance complexity.

2. Schedule/Delay:

Integrating a non-standard panelboard would require additional design review, compatibility checks, and possibly rework of existing systems. This would result in project delays.

3. Training Requirements:

Maintenance and operations staff are currently trained on Square D equipment.

Introducing a new brand would require additional training, which has both time and cost implications.

4. System Integration and Risks:

The electrical distribution system at DWA is designed around Square D components. Using alternative parts could affect system reliability, complicate troubleshooting, and increase the risk of incompatibility.

7. Efforts to Obtain Competition: According to market research, Schneider Electric has multiple distributors of Square D products across the U.S. Competition is expected among the distributors and suppliers. See paragraph 8, “Market Research”, for further details and “Alternatives” as to why alternative brands of the CR Panelboards, Load Centers, and Breakers are not feasible to critical loads in Dworshak Dam.

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a. Effective competition: There are multiple distributors and suppliers of Square D NQ and QO Panelboard and Load Center equipment.

b. Subcontracting competition: N/A

8. Actions to Increase Competition: Sources Sought W912EF26RSS24 was released on April 16, 2026 and closed on April 23,2026. Two responses were received from Aponte Power Services and Virginia Energy and Lighting, both of which are small businesses under NAICS 335313. Competition among Schneider Electric distributors and suppliers across the U.S. is expected.

9. Market Research: Market research indicates that similar products are available from other companies; however, they would not yield the standardization efficiencies described above. It is essential to procure Schneider/Square D NQ panelboards and QO load centers for standardization, because the existing base parts and equipment at the powerhouse are Schneider Electric/Square D brand. Continuing use of this brand name would enable the powerhouse to use current base parts for maintenance and emergencies, if necessary. To swap the current setup from Schneider Electric/Square to another brand's product not only would be expensive, but also would require more time and training to repair or replace components, especially given the exceedingly long lead times that the market is currently experiencing.

10. Interested Sources: Aponte Power Services, Virginia Energy and Lighting, Stoneway Electric Company, Graybar Electric Company, and Madison Electric Company.

11. Other Facts: N/A

12.Technical Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Electrical Engineer

13. Requirements Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

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Electrical Engineer

14.Fair and Reasonable Cost Determination: I hereby determine that the anticipated price/cost to the Government for this contract action will be fair and reasonable. This determination will be made using price analysis by comparison of proposed prices to historical prices paid IAW RFO 15.404-1(b). Per RFO 15.403-2(b), certified cost or pricing data will not be required as this is a commercial supply acquisition.

Contracting Officer

15. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Contracting Officer