J A Pelco.pdf

Control Number: LRE FY21-11

JUSTIFICATION AND APPROVAL (J&A)

FOR OTHER THAN FULL AND OPEN COMPETITION

Contracting Activity:

U.S. Army Corps of Engineers (USACE) Detroit District 477 Michigan Ave 7th Floor Detroit, Michigan 48226

Description of Action:

This Justification and Approval (J&A) New Lock (New Third Lock)

Though a contract will not be awarded directly to Pelco, Pelco products will be specified for construction of the

. The construction contract awarded under a full and open solicitation. Funds will be appropriated from the, funded by Lock Construction General (CG), Operations & Maintenance (O&M), and Major Rehab Evaluation Report (MRER) CG appropriations. The new lock will require camera equipment and software compatible with existing operations camera and security camera systems.

Pelco offers a selection of cameras designed for security surveillance in a wide variety of settings with supporting video management software. The contract action being approved is sole source of Pelco camera equipment and software to eliminate operational as well as support compatibility issues.

Description of Supplies/Services:

The contractor shall use Pelco components to add to the current camera systems; operational system and security system used for security and operations of the Soo locks. Equipment to be provided includes cameras, servers, software licensing, workstations, and support equipment to be fully functional and capable of being integrated with their respective systems; operating system or security system in the future. Full details of the equipment are included in specification section 28 10 05 08, Closed Circuit Television (CCTV). The contractor may have options that vary the prices in the project, but the equipment specified are expected to amount to approximately $ , which represents roughly % of the overall construction contract. Full breakdown of cost provided in the table below.

Model Number

Description Unit Price

Quantity Required

Total

S7230L-EW0 Cameras, Specra Enhanced pan-tilt-zoom (PTZ) 28

KBD5000 Keyboard and 3D Mouse 2

VXP P2-72-5T Server, VideoXpert Professional Power, RAID 5 level 4

VX-RKWKST Workstation, rack mounted VideoXpert Professional 2

VXP-1C-3Y Channel/Software License, VideoXpert Professional 22

4. Authority Cited:

1.

2.

3.

- Contracting Branch only applies to a portion of the Soo construction contact that uses the Pelco camera equipment brand name. The use of the brand name description is essential to the Government's requirement, thereby precluding consideration of a product manufactured by another company, because it will prevent operational compatibility issues within the Soo Locks complex as explained in this J&A.

for the contractor to procure the Soo Lock project located at St. Marys Falls Canal, Sault Ste. Marie, Michigan will be that's the facility's

New

10 United States Code (U.S.C.) 2304(c)(1), as implemented by Federal Acquisition Regulation (FAR) 6.302-1 nly one responsible source and no other supplies or services will satisfy agency requirements.� This authority is applicable to brand name justifications in accordance with FAR 6.302-1(c)(1).

Reason for Authority Cited:

Background-

The Soo Locks are situated on the St. Marys River at Sault Ste. Marie, Michigan. The St. Marys River, a water bridge connecting Lake Superior with Lake Huron, is a critical link in the Great Lakes/ St. Lawrence Seaway system. Over 80 million tons of commercial commodities pass through the Soo Locks annually. For example, in 2000 a total of 85,315,658 tons passed through the locks. The primary commodity group is iron ore and taconite, comprising more than 50 percent of the total annual tonnage. The Soo Locks consist of two canals and four locks. The North Canal contains the Davis and Sabin Locks, and the South Canal contains the MacArthur and Poe Locks. The North Canal locks were built during World War I. The two South Canal locks were built in 1943 and 1968, respectively. The Sabin Lock is in disrepair and is not operated. The dimensions of the Davis Lock essentially limit its use to recreational vessels, so the lock is minimally operated at this time.

Virtually all cargo vessels moving through the St. Marys River transit either the Poe or the MacArthur Lock.

The Poe Lock is the only lock capable of handling vessels with beams in excess of 76 feet. Included in this group are the Great Lakes system largest vessels. These Poe-restricted vessels account for nearly two thirds of the potential carrying capacity of the Great Lakes fleet. Any disruption of service at the Poe Lock would result in delays to these vessels, and depending on the length of time of the closure at the Poe, could cause serious problems for the industries and companies that rely on the Poe-restricted vessels for shipments of raw materials, especially iron ore and coal.

In 1985, due to the significant economic consequences of a disruption of service at the Poe Lock, the Detroit District conducted a feasibility study for the construction of a replacement lock at the site of the Davis and Sabin Locks. The Feasibility Report recommended replacement of the Davis and Sabin Locks with a single large (Poe-sized) lock. Since the Feasibility report several additional reports have been completed including a Limited Reevaluation Report (LRR) (April 2004) and a Validation Study (June 2018). Based on both reports, the Sabin and Davis lock chambers will be removed for construction of a new Poe-sized lock project, titled New Lock at the Soo (New Third Lock).

The Project Delivery Team (PDT) designed the new lock operations and security camera systems to mirror the existing facility systems for compatibility and to reduce future operations and maintenance costs.

b) Justification-

Specifically, agency requirements are as follows:

Compatible with Existing Operational Equipment The facility has a substantial amount of camera equipment used by security and operations to support two navigational locks, one flood control structure, one air compressor plant, a steam plant, a dewatering well, and two hydropower plants. Any equipment installed must

5.

(a)(2), "When the supply or services are available from o a)

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The Pelco products are available only from one responsible source and no other type of supplies or services will satisfy agency requirements. due to the current use of Pelco products at the Soo Locks facility, the use of any other products would result in operational compatibility issues and substantial duplication of costs to the Government. The applicable be compatible with existing equipment. In particular, any new equipment must be able to perform its primary purpose and communicate with existing camera controls equipment.

Compatible with Existing Support Equipment The organization has invested in equipment to support the maintenance of the existing camera system. The value of the equipment used for maintenance support work exceeds

Adding additional devices from other manufacturers to the inventory of equipment serviced would require the corresponding procurement of additional manufacture-specific support equipment estimated to be up to another . This would include spare cameras and camera mounts.

Compatible with Existing Training Program The organization has a substantial investment in training employees through manufacturer-specific courses. The level of sophistication of camera-related devices requires employees servicing these devices to be manufacturer-trained. Tuition costs per course range from to $ per employee, available virtually or in-person. A 4 day in-person course per employee easily exceeds for tuition, airfare, per diem and lodging, and does not include labor costs. Assuming the classes are taken virtually to eliminate travel costs you could still exceed 4 days labor plus tuition. There is a minimum of 4 employees that work with camera O&M at this facility. The financial burden to support a trained workforce across multiple manufacturers of these devices becomes prohibitive and is clearly not cost effective or sustainable.

Risk Management Framework (RMF) Compliance with RMF is required to maintain cybersecurity. The cybersecurity requirement has been mandated for all DoD per the Risk Management Framework (RMF) compliance for an additional system would require additional staff, ¼ the time of a full-time employee (FTE). Employees are testing and verifying software and firmware updates to all equipment in lab bench-tests prior to updating field devices. Some update frequencies, as mandated by the facilities RMF Policies, are as short as every three months.

The facility has a total of eighteen RMF Policies that are audited every time the Authority- To-Operate (ATO) is renewed. Additional manufactures, other than Pelco, would significantly increase this effort because employees would be required to verify the new equipment and the existing Pelco equipment. The cost estimate for ¼ the time of a FTE is based on per hour, 2,080 work hours in a year, with ¼ that time amounting to approximately per year, included in the cost estimate table as an annual cost.

c) Cost Analysis- Below is a table summarizing the cost analysis for this document. Market research has shown that acquisition of equipment of this type, on a competitive basis, can result in a cost reduction of up to 10% as compared to non-competitive purchases. Research has also shown vendors to have comparable support and maintenance agreements and prices. It is therefore reasonable to infer the training, software, maintenance, and support costs to essentially double if a second system is introduced that would need to be maintained in parallel and harmony with the existing primary system. It should be noted these are annually recurring costs. Annual costs are projected to 10 years to show the long-term effect. The cost analysis predicts an increase standards in accordance with the DoD Instructions 8500.01 "Cybersecurity" and 8510.01 "RMF for DoD IT" both updated and released in March 2014. Compliance with the RMF requirements have proven to be a substantial effort. It's estimated that maintenance and of of indirect costs over a 10-year period if sole source of this equipment is not approved.

Cost Element Sole-Source

Price Competitive

Price Benefit/Cost of

Competition Pelco Camera System Equipment Manufacturer-Specific Maintenance and support equipment Training Tuition, 4 Employees, $700 per System per Person Annually for 10 Years Training Labor, 4 employees, $110 per hour, 32 hours per year, annually for 10 years

Compliance with RMF, ¼ FTE added to SAO staff

TOTAL

In summary, under the reason for the authority cited, sources of supplies have been through market research, technical compatibility, and support requirements

d) Impact- For every different manufacturer tens of thousands of dollars in indirect costs for support equipment, software, training, test documents, and spare parts are required. The existence of differences of data, patent rights, copyrights, and manufacture design and processes limit the ability to operate and maintain multiple manufacturers with one common set of support assets.

Therefore, it is extremely likely that an award to any source other than Pelco, for camera equipment, would result in a substantial duplication of cost to the Government that would not be recovered through competition.

e) Alternatives- Pelco actually tested multiple 3rd party camera manufacturers for compatibility with their VideoXpert software and has published this information with details on what features of the software are compatible. Multiple manufacturers make compatible equipment but if equipment other than Pelco is installed, all of the increased costs indicated in the above cost analysis would still be expected.

6. Efforts to Obtain Competition:

Market research was conducted to determine if other sources were available for potential competition. Corps of Engineers personnel conducted internet searches, catalog research, reviews of past projects, telephone interviews with potential sources, and meetings with vendors. To date, no other sources have expressed an interest and ability to support the contract action as needed.

The Corps of Engineers also publicized a notice of intent to sole source to the beta.sam website to invite participation and comment on the subject sole-source procurement. The notice was posted on 19-Feb-2021 with a suspense to respond by 02-Mar-2021. Any party potential analyzed

Due to operational compatibility needs and the substantial duplication of cost that would result from using other supplies, it has been determined that no other supplies will satisfy agency requirements pursuant to FAR 6.302-l(a)(2).

that responds to the notice will be considered as a potential service provider; however, USACE has received no responses to date to express interest or to otherwise present information with respect to this contract action. Competition will be obtained during solicitation of the overall construction contract through the use of competitive procedures used to promote and provide for full and open competition.

7. Actions to Increase Competition:

Market research as described in paragraph 8 was conducted to determine if other sources were available for potential competition. The USACE does not need to do any additional actions to increase competition for this specific equipment because there is already adequate competition within the market and the lack of competition is not the reason for this sole source. This J&A will be posted during the solicitation and additional sources will be considered if brought during the solicitation period.

8. Market Research:

USACE personnel conducted market research to determine the availability of open market sources for the procurement. Efforts included the following:

A. Contacting knowledgeable individuals in Government and industry regarding market capabilities to meet requirements.

B. Reviewing the results of recent market research undertaken to meet similar or identical requirements.

C. Reviewing catalogs and other generally available product literature published by manufacturers, distributors, and dealers or available on-line.

D. Publicized a notice of intent to sole source to the beta.sam website for additional comments on the procurement, as described in paragraph 6.

Market research indicates that multiple vendors produce similar camera equipment but the specified equipment described herein is required for this project. The use of other products would lead to substantial duplication of cost that would not be recovered through competition.

9. Interested Sources:

No other sources have expressed either a written or verbal interest in this procurement.

10. Other Facts:

None. All pertinent facts are stated in the paragraphs above.

11. 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.

Darin H. White, P.E.

Lead Project Engineer

Darin H. White, P.E.

12. 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.

Mickey R. Awbrey Chief, Soo Lock Integrated Project Office

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable based on published list prices for commercial off the shelf items and previous use of the same components. At time of evaluating proposal price, the overall proposed price will be evaluated for fair and reasonableness. Certified cost or pricing data will not be required based on the exception in FAR 15.403-1(b)(3) for commercial items.

Travis J. Specht Contracting Officer

14. Legal Review and Concurrence: I hereby determine that the information herein is legally sufficient, and I concur with the sole source procurement.

Kyle T. Shaw District Counsel

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

Travis J. Specht Contracting Officer

Mickey R. Awbrey Chi f S L k I t

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Approval

Based on the foregoing justification, I hereby approve this brand name specification for Pelco equipment pursuant to the authority of 10 U.S.C. § 2304(c)(1), as implemented by FAR 6.302-1 in the amount of $ , subject to the availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Travis J. Specht Contracting Officer

SPECHT.TRAVIS.J