J A Rockwell.pdf

Control Number: LRE FY21-10

5. Reason For Authority Cited:

a) Background

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 construction contract is planned to be awarded under a full and open solicitation. Funds will be appropriated from the Lock Construction General (CG), Operations & Maintenance (O&M), and Major Rehab Evaluation Report (MRER) CG appropriations.

The new lock will be interconnected with an existing network of existing systems and facilities. The industrial control systems for the new locks were designed to mirror the existing facility systems for compatibility and to reduce future operations and maintenance costs.

b) Justification- Only the listed responsible sources and no other sources of supply will satisfy agency requirements for the function applications of this procurement without substantial duplication of cost to the Government. The primary justification for the use of Rockwell is reduced cost to the government. A secondary benefit is risk of interoperability between equipment is reduced when equipment is from the same manufacturer.

Compatible with Existing Operational Technology Equipment (OT) The facility has a substantial amount of embedded industrial controls to support two navigational locks, one flood control structure, one air compressor plant, a steam plant, a dewatering well, and two hydropower plants. New industrial control equipment must be compatible with the existing industrial control systems. In particular, new equipment must be able to perform its primary purpose and communicate with the existing embedded industrial control equipment in order to minimize downtime and reduce complexity of the collective IC System. While some manufactures make equipment that they would say is technically compatible, there is always increased complexity in understanding the integration between two manufactures which creates unnecessary risks and increased training requirements. Interoperability is dependent on all of the programs and hardware working together and there are continued risks throughout the long-term integration of a system when there are components from multiple manufacturers. If equipment from different manufacturers is installed and the interoperability fails it can lead to equipment further down the line failing and causing damage to the facility or harm to personnel. Even if all issues are identified up front there is also an additional cost to making equipment from different manufacturers compatible because additional software and equipment, such as communication programs and hardware, are required. This cost is not captured in the below cost estimates because it is manufacturer specific.

Compatible with Existing Support and Development Equipment The organization has invested in equipment to support the maintenance of existing embedded controls. The value of the equipment used for development, maintenance, and the additional testing for Risk Management Framework (RMF) work exceeds $50,000.

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 be a one-time additional O&M cost after completion of the contract.

Compatible with Existing Training Program

The organization has a substantial investment in training. The level of sophistication of PLC-related devices requires employees servicing these devices to be highly trained.

These technical training courses are offered by the respective device manufacturers (Rockwell in this case) to familiarize employees with the technology, resulting in increased productivity, reduced downtime, and how to work with the devices without causing damage to the machine and injuring personnel. Tuition costs per course range from to $ per employee. A one week course per employee easily exceeds for tuition, airfare, per diem and lodging, not including labor cost. There are a minimum of 10 employees that work with embedded controls 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.

Compatible with Existing Support Software The organization uses product specific software to support the operation and maintenance of existing seven embedded controls systems.

range from $ for a standard license to $ for a fully optioned professional license and require recurring annual licensing costs. The software tools to maintain a machine level Human Machine Interface (aka: Panelview) and the Facility level SCADA HMI are $ per license. The Facility level SCADA HMI servers are $ per license, with the facility currently having five licenses. These costs are combined and included in the below cost estimate table to an annual average cost of $ for the sole-source price and increase to $ per year if not sole sourced. Adding additional devices from other manufacturers to the inventory would require the corresponding procurement and maintenance of additional manufacture-specific support. This scenario will replicate for every new manufacturer brought onto the facility and, thus, continually add to the indirect overhead costs of maintaining the facility.

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) standards in acc

Compliance with the RMF requirements have proven to be a substantial effort.

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 Rockwell, would significantly increase this effort because employees would be required to verify the new equipment and the existing Rockwell equipment. The cost estimate for ¼ the time of aFTE 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

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 market research notice was posted on 03-Feb-2021 with a suspense to respond by 23- Feb-2021. Only one response was received with a firm expressing interest but they were only offering engineering support and did not offer alternate equipment to the sole sourced product. It was determined that this response did not represent a reasonable alternative source for the requirements presented.

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 plan to do anything 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. Manufacturers of this type of equipment are aware of compatibility issues with other manufacturers and have attempted to make them more compatible for integration. However, using alternate equipment still represents an unacceptable level of risk to efficiency and compatibility as well as increased O&M costs.

8. Market Research:

Prior to the development of the proposed action, USACE personnel conducted market research to determine the availability of open market sources for the procurement. Efforts included the following:

A. Contacting knowledgeable individuals within the Government that are familiar with this type of equipment and work on it regularly and individuals within the 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 controls equipment but none of that equipment addresses the increased cost and decreased efficiency outlined above. The use of other products would lead to substantial duplication of cost that would not be recovered through competition.

9. Interested Sources:

Only one source expressed interest:

Name of Firm: infoEdge LLC Cage Code: 8C9X6

As discussed in paragraph 6, this source only offered engineering support and did not offer alternate equipment to the sole sourced product.

10. Other Facts:

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