D.1 FAR 12 J&A For Use of Other Than Full and Open Competition FAR 12 - APC - RD.pdf

UNITED STATES MARINE CORPS

MARINE CORPS INSTALLATIONS NATIONAL CAPITAL REGION

MARINE CORPS BASE QUANTICO

3250 CATLIN AVENUE

QUANTICO, VIRGINIA 22134-5001

DISTRIBUTION: U/GENERAL

MEMORANDUM TO THE FILE

Subj: For Use of Other Than Full and Open Competition FAR 12 – Commercial Products and

Commercial Services Under the Simplified Acquisition Threshold (SAT)

1. Contracting Activity

The Contracting Activity is the Marine Corps Installations National Capital Region – Regional

Contracting Office (MCINCR-RCO), located at 2010 Henderson Road, MCB Quantico, VA. The requiring activity is the Marine Corps Installation Command (MCICOM) Installations System Branch

(ISB) located at MCB Quantico, VA.

2. Description of Action Being Approved

The action being approved is an exception to fair opportunity for a Third-Party Hardware Maintenance and Support for End-of-Service-Life (EOSL) Data Center Infrastructure requirement for 208 Rack PDUs

(AP8841), 16 In-Row Coolers (ACRC1000), 8 Sensor Pods (NBPD0150), 4 Sensor Pods (NBRK0570), 4

Transfer Switches (AP7723), and 8 Infrastructure PDUs (0M-5103) manufactured by American Power

Conversion Corporation (APC).

This action is intended to result in a brand-name award to a source capable of providing the required

American Power Conversion Corporation (APC) Third-Party Hardware Maintenance and Support through a competitive posting on SAM.gov.

3. Description of Supplies/Services

Headquarters Marine Corps, MCICOM-ISB, requires a Third-Party Hardware Maintenance and Support for End-of-Service-Life (EOSL) Data Center Infrastructure technical support for the APC by Schneider

Electric hot-aisle containment infrastructure currently operational within the Kansas City Information

Technology Center (KCITC) server cage. This service renewal covers a comprehensive suite of mission-critical power and cooling components, specifically 208 Rack PDUs, 16 In-Row Coolers, 12 integrated

Sensor Pods, 4 Transfer Switches, and 8 Infrastructure PDUs. To ensure continuity of operations, MCICOM-ISB specifically requires maintenance and support services that meet a Two Business Day plus

Field Engineer (2BD+FE) response level for all covered equipment.

These components collectively maintain a physical barrier between supply and return airflow, which is technically imperative for preventing the mixing of air and ensuring the thermal stability required for high-density server operations. Specifically, this architecture prevents hot exhaust from recirculating into server intakes, thereby eliminating localized hot spots. Maintaining this precise environmental control— supported by guaranteed 2BD+FE service—is critical to preventing thermal runaway and safeguarding mission-essential hardware from heat-related damage.

The Government intends to issue a single Firm-Fixed-Price (FFP) order with fixed-price CLINs under an open-market contract vehicle. This requirement is for one (1) twelve-month base period and two (2 ) twelve-month option periods. The required base delivery/performance start date is twelve (12) months on or before after date of award.

The estimated cost for this procurement is $325,458.00, inclusive of all option years. FY26 Marine Corps

Operations and Maintenance (O&M) appropriations will be used to fund the base year of performance as outline in the table below:

FY26 Total Period + 2 Option Periods

O&M $108,468.00 $325,458.00

Base Period

Part Number/Description Quantity

AP8841-Rack PDU’S 208

ACRC1000 - In-Row

Coolers

NBPD0150 - Sensor Pods 8

NBRK0570 - Sensor Pods 4

AP7723 - Transfer Switch 4

0M-5103 - Infrastructure

PDU’s

Option Period 1 & 2

Part Number/Description Quantity

AP8841-Rack PDU’S 208

ACRC1000 - In-Row

Coolers

NBPD0150 - Sensor Pods 8

NBRK0570 - Sensor Pods 4

AP7723 - Transfer Switch 4

0M-5103 - Infrastructure

PDU’s

4. Statutory Authority Permitting Other Than Full and Open Competition

This acquisition is conducted under FAR 12.201-1, which authorizes the use of simplified procedures for commercial products and commercial services below the Simplified Acquisition Threshold (SAT).

Limiting competition for this brand-name requirement is authorized under 10 U.S.C. 3204(a)(1), When

Procedures Other Than Competitive Procedures May Be Used. The head of an agency may use procedures other than competitive procedures only when (1) the property or services needed by the agency are available from only one responsible source or only from a limited number of responsible sources and no other type of property or services will satisfy the needs of the agency.

5. Rationale Justifying Use of the Cited Authority

The Marine Corps Information Technology Center (KCITC) currently operates an embedded, highly integrated Schneider Electric (APC) hot-aisle containment (HAC) architecture. The 208 Rack PDUs, 16

In-Row Coolers, and environmental Sensor Pods do not operate independently; they communicate via proprietary APC telemetry and firmware to form a closed-loop thermal management system.

Schneider Electric is the only manufacturer capable of fulfilling the hardware maintenance and extended warranty requirement at the necessary level of quality. MCICOM-ISB requires a strict Two Business Day plus Field Engineer (2BD+FE) service level. Third-party maintenance providers and competing manufacturers cannot provide certified Original Equipment Manufacturer (OEM) replacement parts or authorize firmware updates for this specific architecture. Introducing non-APC components into this tightly coupled ecosystem—such as a competitor's cooling unit or sensor—would disrupt the proprietary environmental communication protocols. This disruption would create "blind spots" in the thermal monitoring, immediately introducing an unacceptable risk of localized thermal runaway and subsequent server failure. Furthermore, utilizing third-party components or maintenance services would void the existing APC warranties on the surrounding infrastructure.

Because the APC containment chassis, cooling units, and power distribution components share specific, proprietary physical dimensions and interlocking mechanisms, piecemeal replacement with another brand is technically infeasible. Competitors such as Vertiv, Eaton, and Chatsworth utilize different physical footprints, mounting rails, and software management backplanes.

Specifically:

• Physical Footprints & Airflow Seals: APC’s In-Row Coolers (ACRC1000) and hot-aisle containment panels are engineered to precise physical dimensions that interlock to create an airtight seal. Competitor cooling units utilize different height, width, and exhaust dimensions.

Attempting to insert a Vertiv or Eaton cooler into the APC chassis would leave physical gaps in the containment barrier, allowing hot exhaust and cold supply air to mix and defeating the entire purpose of the containment architecture.

• Mounting Rails & Infrastructure: The existing APC 0U Rack PDUs (AP8841) utilize proprietary, toolless mounting pegs designed specifically to latch into the existing APC NetShelter server racks. Introducing competitor PDUs, such as those from Chatsworth or Eaton, would require custom retrofitting, drilling, or entirely new server racks to mount the power distribution safely.

• Software Management Backplanes: The APC environmental Sensor Pods

(NBPD0150/NBRK0570) and coolers communicate via APC’s proprietary Network Management

Cards (NMC) and ecosystem (e.g., EcoStruxure). Competitor management backplanes—such as

Vertiv’s iCOM or Eaton’s Brightlayer—cannot natively process APC sensor telemetry. Without this shared software language, the cooling units cannot automatically adjust fan speeds or cooling thresholds in response to temperature spikes, rendering the dynamic cooling system inoperable.

Transitioning to another manufacturer would necessitate a complete "rip-and-replace" of the entire

KCITC server cage cooling and power infrastructure. This effort would require:

1. Sunk Cost Forfeiture: The total loss of the significant capital and labor previously invested by

MCICOM-ISB to design, purchase, and install the current APC hot-aisle containment system.

2. Duplication of Cost: The procurement of hundreds of new hardware pieces (PDUs, coolers, sensors, and physical containment barriers) from a new vendor, which represents a substantial duplication of cost that the Government would not expect to recover through a competitive open-market solicitation for maintenance.

3. Unacceptable Mission Delay (Downtime): Replacing the infrastructure would require powering down mission-critical server racks to safely dismantle the existing power and cooling systems.

This would cause an extended, unacceptable disruption to continuity of operations and severely impact Marine Corps enterprise network availability.

When evaluating all features and characteristics, the Schneider Electric-APC brand-name requirement is essential to the Government's technical and business requirements. APC remains the only responsible source capable of providing the OEM-certified support necessary to satisfy MCICOM-ISB’s operational compliance, ensure thermal stability, and prevent catastrophic mission downtime.

6. Efforts to Obtain Competition

In accordance with FAR Part 12 (Acquisition of Commercial Products and Commercial

Services) and FAR 6.303, the Government exerted extensive efforts to obtain maximum competition for this requirement. The Contracting Activity initially sought to compete this acquisition as a 100% Small

Business Set-Aside on the NASA SEWP GWAC to leverage existing government contracts. The solicitation was open from 18 June 2026 to 26 June 2026 and subsequently extended to 17 July 2026 to maximize small business exposure and response times. Despite these efforts, zero (0) small business responses were received.

To further promote competition, the Contract Specialist targeted specific small business industry leaders on NASA SEWP, including Park Place Technologies and Service Express, requesting quotes for the end-of-service-life (EOSL) maintenance support. Neither vendor responded to the request.

To prevent a critical lapse in coverage for this mission-essential data center infrastructure, the

Government expanded its market research to the Open Market. This effort identified PivIT Global as a technically capable, authorized reseller. To ensure the Government obtains the best value and provides a fair opportunity to all qualified sources, the final solicitation will be posted on SAM.gov as an Open

Market, Unrestricted competition using the commercial procedures of FAR Part 12. This approach removes the restrictive SEWP small business constraints, inviting any capable, authorized third-party maintenance provider in the commercial market to compete.

7. Determination of Fair and Reasonable Cost

The Contracting Officer will determine the anticipated price to be fair and reasonable by comparing the quoted pricing against commercial market data, historical Government purchases, and pricing available from other authorized open-market sources. Because this requirement will be posted on SAM.gov, the

Contracting Officer will evaluate all quotes received to ensure pricing reflects current competitive market conditions. If pricing from other commercial vendors demonstrates a more advantageous value to the

Government, the Contracting Officer will rely on standard price analysis techniques under FAR Part 12 to ensure the Government obtains the best available price.

8. Actions to Remove Barriers to Future Competition

The Government will reassess market conditions prior to future acquisitions to determine whether alternative solutions can meet Marine Corps Installation Command (MCICOM) Installations System

Branch (ISB) requirements. Due to the proprietary nature of Third-Party Hardware Maintenance and

Support for End-of-Service-Life (EOSL) Data Center Infrastructure licensing and integration, no viable alternatives exist at this time, but this will be reevaluated during follow-on acquisition planning.