JA_Bentley_Oasis_20260326_Redacted.pdf

CUI HNC Control #:

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Controlled by: Army.

Controlled by: USACE - CEHNC CUI Category: General Procurement and Acquisition Distribution/Limited Dissemination Control: FEDCON POC: Aquiller Cole, JUSTIFICATION REVIEW DOCUMENT

FAR Part 6 Justification and Approval for Other than Full and Open Competition

Program/Equipment: The United States Army Corps of Engineers, Huntsville Center (CEHNC) is the Assigned Responsible Agency (ARA) for providing Oasis Montaj software licenses and training for CEHNC supporting the Military Munitions Response Program (MMRP) for analysis of advanced geophysical classification (AGC) and non-AGC digital geophysical mapping (DGM) data.

Authority: Title 10 United States Code (U.S.C.) §3204(a)(1) as implemented by Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) Part 6.103-1 – Only one responsible source and no other supplies or services will satisfy agency requirements.

Amount:

Period of Performance (POP):

Base: 30 March 2026 – 29 March 2027 Option Period 1: 30 March 2027 – 29 March 2028 Option Period 2: 30 March 2028 – 29 March 2029 Option Period 3: 30 March 2029 – 29 March 2030 Option Period 4: 30 March 2030 – 29 March 2031

Prepared by:

Contracting Officer: Aquiller Cole Contracting Officer, FTI-GEN Email: Aquiller.E.Cole@usace.army.mil

Technical:

Requirement:

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HUNTSVILLE ENGINEERING AND SUPPORT CENTER REVIEWERS

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Project Manager:

Legal Counsel:

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On April 11, 2016, the Office of the Assistant Secretary of Defense, Installations, Energy, and Environment (ASD (IE&E)) issued a policy memorandum Subject:

Department of Defense Advanced Geophysical Classification Accreditation Program (DAGCAP) https://www.denix.osd.mil/mmrp/advanced-geophysical-classification-accreditation-and-other-tools/. ASD (IE&E) established the DAGCAP to accredit organizations that use AGC at Munitions Response Sites (MRS). The DAGCAP provides a unified program for organizations performing AGC to demonstrate competency and document conformance to minimum quality systems requirements based on the International Organization for Standardization and the International Electro-technical Commission standards.

On April 24, 2017, HQUSACE published an interim guidance document, Subject:

Advanced Geophysical Classification (AGC) Implementation at Formerly Used Defense Sites (FUDS) Military Munitions Response Program (MMRP) Projects, which was implemented in Engineer Manual (EM) 200-1-15, Technical Guidance for Military Munitions Response Actions, dated October 30, 2018. While this guidance effectively mandated use of AGC whenever technically feasible, non-AGC digital geophysical mapping (DGM) methods are still required on some terrestrial MRSs and is the predominant technology used in the underwater environment. EM 200-1-15 also mandated that Quality Assurance (QA) and Quality Control (QC) processes for each feature of work be defined to ensure performance metrics and project objectives are met.

As part of the DAGCAP, the DoW developed a funding strategy that outlined each service’s annual contribution to implementing the program. Since Oasis Montaj is a critical component, the Army, Navy, and Air Force, as well as USACE provide funds for the software subscriptions. USACE has been the agency responsible for the acquisition and contract management.

The Naval Surface Warfare Center (NSWC), Panama City Division (PCD) has spent several years developing complex magnetic gradiometric algorithms capable of accurately detecting, classifying, and localizing relatively small ferrous targets of interest in the underwater environment laying both on the seabed, as well as fully buried. The signal processing and analysis for Navy-developed magnetic gradiometers was typically accomplished using custom algorithms developed for these specific systems, requiring specific NSWC personnel to accompany these sensors.

The DoW contracted with Geosoft, Inc. for the customization of the Oasis Montaj UX-process software to incorporate the NSWC algorithms which would allow all DoW agencies to use them without requiring deployment of NSWC personnel or equipment.

This adaptation of the software was evaluated by DoW geophysicists working on the MMRP for further enhancement. This resulted in software packages named UX- Analyze and UXO-Marine, which contain over 80 menu items and provide tools for geophysical data analysis and QA/QC in support of this program.

Geosoft, Inc. was acquired by Bentley Systems, Inc. in June 2021, and Bentley now owns the data rights and source code to the required software.

ii. Justification. DoW must validate all software used for AGC accreditation in accordance with section 7.2 of the Department of Defense Quality Systems Requirements for Advanced Geophysical Classification. The DAGCAP defines validated software as software that DoW either used successfully on a previous Environmental Security

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Research and Development Program demonstration, or software that has produced equivalent or better results.

The DAGCAP validated advanced classification software programs are:

UXAnalyze— developed by Bentley Systems, Inc. (Part of Oasis Montaj) UXOLab— developed by Black Tusk Geophysics BTField— developed by Black Tusk Geophysics EMCLASS— developed by White River Technologies UX-Classify— developed by Acorn SI

MMRP is required to use AGC on munitions response sites to the maximum practicable extent to safely classify identified MEC prior to exclusion or remediation. In cases where AGC is not technically feasible, non-AGC DGM methods are used.

EMCLASS, BTField, and UX-Classify are only able to process data from AGC sensors and do not provide QA/QC functionality. UXOLab, developed and used by Black Tusk Geophysics, is their in-house software. It is not commercially available for rental or purchase.

Oasis Montaj is the only commercial software that can integrate raw sensor data for both AGC and non-AGC DGM sensors and present this data in a mapping solution with tool sets needed to analyze the findings to identify MEC. Additionally, the Oasis Montaj software suite is enhanced with QA/QC tools.

Bentley owns the data rights and source code to the required software. They are the sole provider of the required subscription licenses and the sole developer and provider of the required training for the software. The software necessary to analyze both AGC and non-AGC DGM and provide QA/QC tools is not available from any source other than Bentley. If this sole-source award is not favorably considered, the current license subscription will expire, and DoW will be unable to perform mission critical functions until a replacement is in place. Given the fact that it is in the best interest of the Government to issue a contract to Bentley Systems, Inc., upon approval of this J&A, a Request for Quote (RFQ) as a sole-source requirement will be issued to Bentley Systems, Inc. with a Statement of Work (SOW) describing the requirements.

b. Alternatives: Although there are four additional AGC software products validated by DAGCAP, three are unable to integrate raw sensor data for both AGC and non-AGC DGM sensors and do not include QA/QC support. UXOLab is Black Tusk Geophysics’ in-house software that is not available for purchase or rent. (See additional information above in 6(a)(ii).)

In addition, Market research, performed 6 February 2026 – 19 February 2026 (see Section 8 below for details), confirmed that no vendors are capable of providing the required software.

None of the other three commercially available software products validated by DAGCAP are able to process non-AGC data. If one of those options were pursued, the Government would be required to purchase two separate software products. This would increase costs to the Government by requiring the purchase of two different software products as well as subsequent training costs. In addition, there is not a software product that strictly processes non-AGC data that has been validated by DAGCAP. The capability to process and QA non-AGC data is built into the costs of the Bentley Oasis Montaj software which would not increase costs and is validated by DAGCAP.

The customer hosts three separate meetings per year regarding general mission requirements

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to include the Bentley requirement. The intent of these meetings is to communicate these mission needs to industry partners to produce a competitive environment or at least allow for cross-platform usability. Thus far, no vendor has developed a comparable commercial tool.

c. Impact if not approved: The FUDS MMRP program spends approximately $125-$175 million per year collecting AGC and non-AGC data. Without this software, USACE, the Army, Navy, and Air Force would not be able to analyze and conduct QA/QC on the collected data;

and DoW could not meet the requirements of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), section 120 Federal Facilities Agreement, nor the Resource Conservation and Recovery Act (RCRA), to protect human health and the environment at munitions response sites across the United States.

The MMRP would come to a halt until new software could be developed and USACE geophysicists trained in its use. The program would essentially lose 17 years of development and training and be forced to start over resulting in significant costs. Furthermore, if MRSs are not properly remediated, a significant hazard and risk to human health and safety from unexploded ordnance will remain on site across the nation.

7. Efforts to Obtain Competition:

a. Effective Competition: Bentley Systems, Inc. owns the data rights, the source code is proprietary, and they are the sole developer and provider of training, maintenance, and support services (to include bug fixes and testing). Only this software along with its training, maintenance, and support services will satisfy the current government needs and meet requirements.

Based on market research (see section 9), no additional sources were identified.

b. Subcontracting Competition: Software licenses are a supply. The source code is proprietary to Bentley, and they are the sole developers and providers for training and maintenance (to include bug fixes and release testing). Subcontracting opportunities do not exist.

8. Actions to Increase Competition: MMRP evaluates the state of the commercial market and the maturity of any other DoW software to determine if any are capable of meeting the requirements. MMRP coordinates with industry by attending three events per year; the National Association of Ordnance Contractors (last attended December 2023; no meeting in 2024 due to the Military Munitions Support Services Stand-Down hosted by USACE), Strategic Environmental Research and Development Program’s Environmental Security Technology Certification Program Symposium (last attended December 2024) and Symposium on the Application of Geophysics to Engineering and Environmental Problems (last attended March 2024). USACE employees could not attend in 2025 due to travel restrictions. These meetings allow MMRP the opportunity to meet with industry, and discuss needs, requirements, and upcoming changes in the industry. It also provides the opportunity to discuss their requirements so that any commercial software publisher may determine if they will or can develop a comparable solution using their proprietary systems. The Government has an interest in finding a new solution; however, market research has demonstrated that no other commercial sources currently exist that satisfy the requirement to integrate both AGC and non-AGC raw sensor data as well as include QA/QC tools. There are other companies with similar software capabilities;

however, it is required the Government contract with them directly as a service provider where they conduct an analysis using their proprietary software to deliver a solution. The current Bentley solution allows the Government to use the software via a license at which point the

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b. Competitive status of these actions: Other than full and open.

c. Authority previously cited if less than full and open competition was used:

10 USC 3204 (a)(1) as implemented by FAR Part 6.302-1(a)(2) – Only one Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

d. If a justification was prepared to support the procurement made before this one, a summary of the contents of paragraph 7 of the justification for that procurement and an explanation of the results: The rationale used in prior J&A’s, the first of which was approved in 2008, is the same rationale used in this J&A. There have been no significant changes to occur to this requirement or the supporting sections. As identified in 11a above, the initial Geosoft procurement was awarded as a Cooperative Agreement. The follow-on was a sole-source purchase order citing the same rationale used herein. If a proprietary system is already in place at a garrison/base/installation and it has a significant footprint of installed controls, it is not fiscally prudent to replace the entire system as the garrison/base/installation already has a significant investment in the system. The implications against such a replacement are identified in Section 6c-Impact.

e. If any prior contract for this requirement was accomplished using full and open competition, include a detailed explanation of the changed circumstances causing this action to now limit the sources: Full and open competition was not used previously.

f. An explanation of any unusual patterns that may be revealed by the history, e.g., several consecutive, urgent buys: No unusual patterns exist.

g. If a justification was prepared to support the procurement made before this one, briefly describe the circumstances justifying the procurement and whether there have been any significant changes: The justification to sole source on six previous occasions was that Geosoft (now Bentley) owns the data rights. The source code is proprietary, and they are the sole developer and provider of training, maintenance, and support services. There have been no significant changes because the software is continually being improved and updated.

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12. 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.

13. 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.

14. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price/cost to the Government for this contract action will be fair and reasonable. Basis for fair and reasonable price determination will be conducted through historical prices, a cost/price analysis comparison of commercially available prices and the independent government estimate. In accordance with RFO 15.403-2(b)(3) certified cost and pricing data will not be required as a commercial item is being acquired.

AQUILLER COLE

Contracting Officer

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

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Approval

Based on the foregoing justification, I hereby approve the sole source procurement of Oasis Montaj subscription licenses directly from Bentley Systems, Incorporated in the amount of in support of the Military Munitions Response Program (MMRP) using a Justification and approval for other than full and open competition pursuant to the authority of RFO 6.103-1 – Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements. The approval is subject to availability of funds and provided that the services and property herein described have otherwise been authorized for acquisition.