DJA-24-ASEP-PR-0202 - JOFOC - Redacted.pdf

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Attached to
FIPS Access Control System Installation Award Notice Federal contract opportunity
Solicitation number
15A00024PAQA00147
Issued by
Department of Justice Bureau of Alcohol Tobacco Firearms and Explosives

About this file

This document is a Justification for Other Than Full and Open Competition (JOFOC) for a contract to acquire services to install FIPS 201-2 compliant access control system components at the Columbia, SC field office of the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).

The services required include installation of low voltage technicians for one year at an estimated total cost of $45,777. The statutory authority cited for the limited competition is FAR 6.302-6 National Security, as the disclosure of details about the physical security systems and office layout could compromise national security. The JOFOC recommends limiting competition to three Lenel certified integrators - Securitas, Convergint Technologies, and Trilogy Secured Services - who have the required expertise and local presence to maintain consistency with the ATF's nationwide customized access control system. The related federal contract opportunity was awarded to Trilogy Secured Services for $36,133 on May 29, 2024.

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Text version

Version 20220201

Services: This action is to acquire services to include installation of the supply components to facilitate FIPS 201-2 compliance.

Low Voltage Technician 35 HR

Low Voltage Technician II 35 HR

Low Voltage Technician III 35 HR

Period of Performance: One (1) year from date of award.

Estimated total cost for all Supply and Services included in this procurement is: $45,777.00.

Columbia SC Field Office located at: 1835 Assembly Street Room 309, Columbia, SC 29201.

4. Identify statutory authority permitting limiting sources. Cite the authority under one of the exceptions listed under FAR 6.302.

FAR 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements.

FAR 6.302-2 Unusual and compelling urgency.

FAR 6.302-3 Industrial mobilization; engineering, developmental, or research capability;

or expert services.

FAR 6.302-4 International agreement.

FAR 6.302-5 Authorized or required by statute.

FAR 6.302-6 – National Security

FAR 6.302-7 Public Interest

5. A statement demonstrating the unique qualifications of the proposed contractor or the nature of the action requiring use of the authority.

In accordance with FAR 6.302-6 National Security:

“(2) Full and open competition need not be provided for when the disclosure of the agency’s needs would compromise the national security unless the agency is permitted to limit the number of sources from which it solicits bids or proposals.”

Execution of the Columbia project requires critical details of PSPB intrusion countermeasures and access to floorplans, surveillance techniques, and equipment. Although the components used for this project are publicly available, the equipment list itself is sensitive in nature because it provides adversaries with information which could be used to engineer methods to bypass physical security systems. Furthermore, this system requires specific installation practices that must be clearly defined and understood by the integrator so they can provide an accurate quote. The methodology used to install the components is also sensitive, as understanding the wiring and engineering behind the installation can also provide a means of bypassing the system. Finally, floorplans detailing the locations of physical security components, in conjunction with sensitive details of the office layout are critical for an integrator to calculate the installation cost. Floorplans could be used by an adversary for a variety of nefarious purposes ranging from engineering a method of intrusion, to designing potential attacks on ATF personnel and facilities. Therefore, publication of these details on a public forum compromises the security of PSPB facilities and personnel constituting a violation of ATF OPSEC policy. Therefore, PSPB is required to limit the number of integrators who have access to this information and provide disclaimers for the release of said information.

Although many companies can procure and install FIPS 201-2 equipment, it is complex work that frequently requires follow-up visits. Integrators must be authorized value-added resellers, must have a local presence, and cannot use unqualified subcontractors. LENEL, the manufacturer of the FIPS equipment used by ATF, has an internal certification process for vendors who install FIPS 201-2 equipment for Federal clients. To prevent unnecessary follow-up costs, downtime, and maintenance costs PSPB needs to solicit bids from Lenel certified integrators with local personnel.

This project interfaces with a much larger customized system. PSPB’s access control system is a nationwide customized system connecting all ATF facilities. The complexity of this system requires consistency in the methodology and procedures used to integrate new offices. For the sake of consistency in a complex system, it is important to limit the number of integrators working on the system. Soliciting bids to known 8E integrators whenever reasonable is critical to maintaining consistency in a highly complex system.

In conclusion, PSPB has determined Securitas, Convergint Technologies, and Trilogy Secured Services, are uniquely qualified and have met the vendor requirements. PSPB recommends limiting the disclosure of the required information to these 3 sources to mitigate the subsequent security risks inherent to disclosure, while still providing an acceptable level of competition.

6. Certifications.

Co-Prepared by:

As the Contracting Officer’s Representative (COR) or Government’s Technical Representative (GTR), I certify the above information is accurate to the best of my knowledge and contains complete data/information necessary to support the recommendation and the basis for this

David Harjo, Program Office Physical Security Specialist – ATF PSPB

As the Contracting Officer and based on the information presented by the program office, the information is complete and accurate to the best of my knowledge, and it is in the best interest of the US Government to pursue other than full and open competition for this requirement.

Brian Palmer, Contracting Officer Office of Management - Acquisitions

File details come from the government source that posted it. Updated .