JA 24-10 Cisco IE 3400_FINAL redacted.pdf

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Attached to
RM18-1025 Repair UH Building 230, NCTAMS, Wahiawa, HI
Solicitation number
N62478-25-R-PC03
Issued by

About this file

This is a Justification and Approval (J&A) document requesting approval for other than full and open competition to use Cisco IE 3400 Series managed Industrial Ethernet switches for a HVAC system repair project at Building 230 Hayden Hall, Naval Computer and Telecommunications Area Master Station Pacific (NCTAMS PAC) in Wahiawa, Hawaii.

The J&A cites 10 U.S.C. 2304(c)(1) as authority, arguing that only Cisco switches will satisfy requirements due to standardization of equipment maintenance and cybersecurity Authority to Operate (ATO) considerations. The project involves installing new HVAC systems and connecting them to an existing central chilled water plant, requiring direct digital control (DDC) system integration. A Sources Sought notice published on August 23, 2023 received six responses, but none were considered viable as they were from distributors/suppliers rather than manufacturers of compatible switches. The document justifies sole source by citing training cost avoidance, cybersecurity requirements, and system integration efficiencies gained by maintaining standardization with existing Cisco infrastructure. NAVFAC Hawaii commits to monitoring the industry for future competition opportunities but currently plans to proceed with Cisco switches.

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DEPARTMENT OF THE NAVY

NAVAL FACILITIES ENGINEERING SYSTEMS COMMAND, HAWAII

400 MARSHALL ROAD

JBPHH, HAWAII 96860-3139

J&A No. 24-10

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION WORK ORDER NUMBER , SPECIAL PROJECT

RM18-1025, REPAIR Q4 UNACCOMPANIED HOUSING BLDG 230 HAYDEN HALL,

NAVAL COMPUTER AND TELECOMMUNICATIONS AREA MASTER STATION PACIFIC

(NCTAMS PAC), WAHIAWA, HAWAII

1. Contracting Activity.

Naval Facilities Engineering Systems Command, Hawaii (NAVFAC HI), Architect-Engineer Contracts Branch, Joint Base Pearl Harbor- Hickam (JBPHH), Hawaii.

2. Description of the Action Being Approved.

Request approval for the use of a managed Industrial Ethernet switch (Industrial Ethernet (IE) 3400 Series) by Cisco Systems, Inc. for special project RM18-1025 Repair Q4 Unaccompanied Housing Bldg. 230 Hayden Hall, NCTAMS PAC, Wahiawa, Hawaii. The brand name description is essential to the activity’s requirements, and will not provide for full and open competition for the portion of the acquisition that relates to this brand-name specification only.

3. Description of Supplies/Services.

The construction project requires the repair of Unaccompanied Housing Building 230 Hayden Hall at NCTAMS PAC. This repair work includes a new HVAC system throughout Bldg. 230 and connecting the new Bldg. 230 system to the existing central chilled water plant.

The new Bldg. 230 HVAC system, the existing Bldg. 229 HVAC system, and the existing central chilled water plant will require a new direct digital control (DDC) system to connect to NAVFAC HI’s control system platform enclave (CSPE) for cybersecurity of facility-related control systems (FRCS). A managed IE switch is used in a DDC system to connect devices using telecommunications cables and allows each connected device to interface with the other devices. This project will require the Cisco IE switch to be installed in the new DDC system.

The estimated procurement costs of the Cisco IE 3400 Series switch is approximately

4. Statutory Authority Permitting Other Than Full and Open Competition.

This request is submitted pursuant to the authority of 10 U.S.C.

2304(c)(1), only one responsible source and no other supplies or services will satisfy agency requirements.

5. Rationale Justifying Use of Cited Statutory Authority.

The Cisco IE 3400 Series Switch should be used because of the following:

a. Standardized Equipment for Maintenance.

(1) Avoid the significant operational burden and additional training costs for NAVFAC HI Command Information Office (CIO) maintenance and engineering staff to have to become proficient with the interfaces and configuration files of managed IE switches from different manufacturers. NAVFAC HI CIO personnel currently maintain and are familiar with the existing Cisco IE switch hardware and interfaces that are installed in existing JBPHH DDC systems. If a switch from a different manufacturer is used for this project, it will require additional effort to train personnel in how to maintain and configure the switch.

Maintaining switches from multiple manufacturers, each with their own unique hardware and interfaces, is inefficient and increases the total cost of ownership and manpower costs associated with maintenance, resulting in a substantial duplication of cost to the Government. It also increases the risk of user error during maintenance, since it is more challenging for personnel to become adept at utilizing the interfaces and configuration files of multiple manufacturers rather than a single manufacturer and will cause unacceptable delays to the mission.

b. Cybersecurity Authority to Operate (ATO) Requirements.

(1) The DDC system is required to meet UFC 4-010-06 cybersecurity requirements and maintain its existing ATO through the Risk Management Framework process. The existing DDC system ATO and the existing CSPE ATO both cover the cybersecurity authorization of the system. The Cisco IE 3400 Series switch is currently included within the existing CSPE ATO. The Cisco IE 3400 switch is authorized per the ATO and provide for the following:

(a) Cost-effectively reduce Government information technology cybersecurity risks. NAVFAC HI CIO expects that use of the Cisco IE 3400 Series switch in this project will require a Use Case 2 Memorandum for Record (MFR) strategy, versus a Use Case 3 MFR for use of a different manufacturer of switches. A Use Case 2 MFR strategy requires significantly less effort from NAVFAC HI CIO during construction when compared to a Use Case 3 MFR or new ATO strategy and will avoid significant costs and delays. The process of obtaining a new ATO would unacceptably delay the operational use of the central chilled water HVAC system at B230, resulting in significant degradation in accomplishment of the mission. Obtaining an ATO is also not the end of the process; and maintaining an ATO is also very resource intensive and the effort increases exponentially when additional hardware or software from different manufacturers is added to the system (i.e. requires maintaining cybersecurity controls, vulnerability management, system scans/tests, etc.).

Assuming other brand name IE switches could be integrated into the installation’s DDC system so as to be fully functional, the significant cyber security risks, operational challenges, added costs (including the costs of re-procurement) and other disadvantages arising from the use of different brands of switches outlined above are not expected to be recovered through competition.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

A Sources Sought notice (No. N62478CON33FY2306) was published in the System for Award Management (SAM.gov) on 23 August 2023 to identify other potential sources of supply compatible to the Cisco IE 3400 Series switch. Six responses were submitted in response to the Sources Sought notice; however, all companies were not considered as they were either a distributor, supplier or installer and not an alternate manufacturing source of an IE switch that is compatible with the Cisco IE 3400 switch.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer has determined the anticipated cost to the Government of the supplies/services covered by this J&A will be fair and reasonable.

8. Actions taken to remove barriers to future competition.

For the reasons set forth in Paragraph 5 above, NAVFAC HI has no plans at this time to compete future contracts for the types of supplies/services covered by this document. However, NAVFAC HI will continue to monitor the IE switch industry to determine if other compatible alternatives become available, and if another potential manufacturer emerges, NAVFAC HI will assess whether competition for future requirements is feasible. Should any other potential sources of supply become available during the source selection process, the Government will evaluate submissions, as applicable.

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS/FUNCTIONAL LEAD CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein, are complete and accurate to the best of my knowledge and belief.

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