J_and_A_Energy_as_a_Service.pdf

Justification and Approval (J&A) for Other Than Full and Open Competition

FOR OFFICIAL USE ONLY

March 2018 FOR OFFICIAL USE ONLY Page 2 of 4

I. Contracting Activity.

Altus Air Force Base 97th Contracting Flight

II. Nature and/or description of the action being processed.

This contracting action is to commission the Program Initiation Study, a detailed engineering and feasibility study to be conducted by Western Farmers Electric Cooperative (WFEC), the local regulated utility provider and potential Energy-as-a-Service (EaaS) provider. This study will enable a complete, robust, and executable response to a sole source Request for Proposals (RFP) for EaaS released in October 2018.

III. Description of supplies/services required to meet agency needs.

In order to support the broader EaaS pilot for the benefit of Altus Air Force Base (AAFB) and respond to the October 2018 RFP released by DLA Energy, WFEC seeks to gather a comprehensive dataset on AAFB utility infrastructure and equipment, primarily focused on the electric system. This Program Initiation Study will develop robust models of electrical system infrastructure and load flow based on a detailed system inventory, identify energy efficiency opportunities, examine options for achieving greater resilience and cybersecurity, and develop a technical library of updated maps and software. The study should be completed within 5 months of awarding the contract. Without this study, WFEC will lack the data to respond adequately to the sole source EaaS RFP.

At a minimum, the proposed deliverables are as follows:

- Baseline energy consumption and cost data by: (1) facility; and (2) key end use equipment category

- Electronic GIS map of the electric distribution system and underlying database of system inventory identifying: (1) GPS coordinates; (2) nameplate data; (3) point-to-point connectivity; (4) deficiencies or gross code violations; and (5) spare parts

- Electric distribution system engineering analysis load flow model

- Sectionalizing study of electric distribution system and arc-flash hazard analysis

- Recommendations for: (1) new distribution/transmission interconnects; (2) AMI meters and communication system;

(3) remedies to code violations, safety concerns and existing switchyard problems, along with cost estimates; and (4) sectionalizing devices

- Reliability and resilience evaluation to meet RFP core service standards

- Energy efficiency summary of findings and demand side management evaluation, including a detailed list of energy efficiency opportunities to reduce consumption and generate cost savings to meet RFP core service standards

- Economic analyses supporting energy efficiency determinations

- Cybersecurity risk assessment and compliance plan to meet RFP core service standards

- Final study report and presentation containing insights into EaaS concept feasibility

All deliverables will be made available to the Government in a digitized format that can be readily viewable. All data and models will be made available to the Government in a format that can be readily manipulated.

IV. Statutory authority permitting other than full and open competition.

FAR 6.302-1 – 10 USC 2304(c)(1), Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

As stated in the J&A for the EaaS effort (tracking number 18-0045), WFEC is a wholesale electric generation and transmission cooperative serving only members in its territory, of which AAFB is a part. All electricity consumers in the state of Oklahoma, including AAFB, are required to purchase electricity from the local utility provider servicing the consumer's geographic location. WFEC's bylaws require that AAFB shall purchase electric energy used from WFEC and may not permit third party services such as distributed generation, even behind the meter. Based on the Oklahoma

March 2018 FOR OFFICIAL USE ONLY Page 3 of 4 restrictions on the source of electric power, and the bylaws' governing restrictions on who can provide electric utility services, WFEC is the only responsible and available source, and no other type of supplies or services will satisfy the AAFB EaaS requirements. Furthermore, WFEC is the owner of a substantial portion of the electricity service/delivery/ distribution infrastructure on AAFB.

Under EaaS, WFEC will operate and maintain AAFB's electric system. Because WFEC is the sole provider suitable for the EaaS effort, and this engineering study will support WFEC's response to the EaaS RFP, WFEC is the only entity that the Government can logically support to conduct the Program Initiation Study. If another entity (not subcontracted by WFEC but directly funded by the Government) were to conduct the study, that entity's ability to obtain necessary information on WFEC-owned infrastructure would be limited, and the study would be incomplete.

Additionally, WFEC has stated that they will need to conduct their own due diligence and assessments in order to enter into a contract to meet the Government's EaaS performance standards in the RFP, while ensuring safety for their personnel, regardless of any third party information provided to them. The inefficiency associated with such duplicative actions would increase costs to the Government and result in a dataset delivered to the Government with unacceptably limited value to the EaaS effort.

For the reasons described above, FAR 6.302-1 applies to this effort as there is only one responsible source and no other supplies or services will satisfy agency requirements.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

As WFEC is the sole source provider for the EaaS pilot, no additional effort was put forth to solicit offers for the Program Initiation Study in support of EaaS.

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The prices for the Energy as a Service Study will be compared to other comparable studies in the region in order to determine the price fair and reasonable.

VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

Prior to identifying the need for an engineering study, market research was conducted for the EaaS effort via a Request for Information (RFI) released in July 2017. The RFI posed a question as to how respondents would address instances where only the regulated utility is permitted to provide certain aspects of EaaS at an installation. Among the entities that responded, none indicated they would be eligible to or interested in responding to a subsequent EaaS RFP as a prime contractor in such an environment as exists at AAFB, though many stated they would be interested in partnering with the regulated utility to sell their services or equipment, or becoming a subcontractor to the regulated utility.

Following analysis of the RFI results and consultation with Air Force legal personnel, DLA Energy issued a sole source J&A for the EaaS effort at AAFB with WFEC.

Therefore, as the end result of market research still led to a sole source procurement path for EaaS, additional market research for this Program Initiation Study was not performed.

IX. Any other facts supporting the use of Other Than Full and Open Competition.

Not applicable.

X. List of any sources that expressed, in writing, an interest in the acquisition.

None.

March 2018 FOR OFFICIAL USE ONLY Page 4 of 4

XI. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before making subsequent acquisitions for the supplies or services required.

WFEC is the locally regulated utility provider which creates the barrier for future competition in efforts involving electricity for AAFB. 97 CONF will assess any future requirements to ensure that WFEC is still AAFB's locally regulated utility provider.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. Certification by the technical/requirements personnel.

As evidenced by my signature above, I certify that any supporting data contained herein, which is my responsibility, is both accurate and complete.