JA_IMCOM Bentley_Redacted.pdf

CUI

Control Number:

Source Selection Information (See FAR 2.101 and 3.104-4)

JUSTIFICATION REVIEW DOCUMENT

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

Program/Equipment: U.S. Army Corps of Engineering Research and Development Center (ERDC), Computer- Aided Design/Building Information Modeling (CAD/BIM), Information Technology Laboratory (ITL) for the Bentley Subscription Licenses.

Authority: Title 10 U.S.C. 3204(a)(1) as implemented by Revolutionary 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): 01 April 2026 – 31 March 2027 Option Year 1: 01 April 2027 – 31 March 2028 Option Year 2: 01 April 2028 – 31 March 2029

Prepared by:

Contracting Officer:

Technical:

Requirements:

Controlled by: Army Controlled by: USACE - CEHNC CUI Category: General Procurement and Acquisition Distribution/Limited Dissemination Control: FEDCON

POC:

HUNTSVILLE ENGINEERING AND SUPPORT CENTER REVIEWERS

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

Program Manager:

Legal Counsel:

models developed in one platform cannot be viewed or edited in another platform. Industry standards mandating interoperability among CAD/BIM software vendors within the competitive marketplace do not exist. As a result, each CAD/BIM vendor's software application remains proprietary in nature. It is not feasible to mix the product line of different vendors. Functionality and the ability to view or edit existing models would be lost.

EPS 365 is manufactured by Bentley. Army projects rely on Bentley products, and there is substantial historical data that has been created using Bentley products. The Army’s investment in the Bentley line of products represents a significant amount of accrued costs. During the previous year, the Army used Bentley products for approximately 2.3 million hours. The investment in Bentley products includes human capital, training time, the development of specialized skills, and the development and implementation of workflows. This usage represents a significant number of users and projects that rely on Bentley licenses. For these reasons it is imperative that the Army continue to have access to data created using Bentley products to support its projects.

b) Alternatives: There are currently three manufacturers (Bentley, Autodesk, and Graphisoft) that supply the full spectrum of CAD/BIM products and services. Autodesk and Graphisoft have an exclusive reseller agreement with a single reseller to gain access to CHESS or GSA GWACS, but there are no other resellers.

Within IMCOM, the majority of the deployed CAD/BIM software is Bentley. Converting from Bentley to Autodesk or Graphisoft product lines would require a significant start-up investment and result in a loss of historical data and productivity without providing any tangible advantage to the Government. A multiple year process is required for this transition at which time continued use of Bentley for all ongoing projects as well as continued purchase of licenses for access to historical documents would be required. Prior investments in training, file and database development, and other related implementation costs would be lost.

Approximately 3,500 copies of Bentley's flagship CAD product, MicroStation, is used throughout IMCOM.

Labor costs for training users on a new system for a two-week fundamental course is estimated at $30.8 million (3,500 x 80 hrs x $110/hr). The typical user would not be able to achieve their current productivity level on a new system in only two weeks. These estimates are provided as a real-world scenario estimate. No other method exists whereby the workforce could receive the required training. With the cost of training alone exceeding $30M, it is determined that converting to a different product line is not a feasible alternative or in the best interest of the Government.

c) Impact if not approved: The cost to the Government for training and implementing a new software system would far outweigh any potential cost savings realized with the initial purchase of the software.

The Government would also lose productivity during the down time associated with the deployment of the new software and the training time to become familiar with the new software. Given the current extent to which Bentley CAD/BIM software is deployed by the Army, the total cost, transition, and loss of institutional knowledge, productivity associated with changing vendors, and loss of access to files for ongoing projects cannot be recovered using competition to drive down costs. A review of Autodesk and Graphisoft product line pricing is comparable to Bentley's, as such the Government would not gain any benefit cost wise in switching to another CAD/BIM manufacturer. Switching from the established Bentley CAD/BIM platform would introduce unacceptable delays and catastrophic risks to critical IMCOM missions for their customers including Warfighters, military commanders, and the American public.

Beyond the significant financial costs, forcing a transition to a non-interoperable CAD/BIM platform would directly and negatively impact mission execution as all current projects with work items in Bentley products would be inaccessible without active licenses for the Benley software products. The loss of productivity would translate to project delays, increased safety risks, and a degraded ability to support their customers as ongoing project documentation would be completely inaccessible.

7. Efforts to Obtain Competition: The Contracting Officer published the notice required by RFO 5.101 on 03

March 2026. Any bids or proposals received shall be considered. An RFI (Reference No: 551619) was posted on CHESS from 12 December 2025 to 12 January 2026. The RFI yielded 26 no bids. Two vendors did not respond. The statement of non-availability (SONA) was received on 17 March 2026.

a) Effective competition: Effective competition is not applicable. This contract will be with Bentley Systems Inc. to provide access to EPS 365, a proprietary Bentley software product. Bentley Systems Inc. is the sole provider for the EPS 365 software used by IMCOM.

b) Subcontracting competition: Subcontracting opportunities do not exist for this procurement. An approved

Determination and Findings for no subcontracting opportunities is located in PCF cabinet PANHES-26-P- 0000 02798.

8. Actions to Increase Competition: This action is a follow-on to call order W912DY24F0070 under BPA

W912DY19A0002. Under the previous Limited Source Justification (LSJ) (Control No. HNC-18-8145-F), the paragraph, “Actions to Increase Competition”, states that efforts to increase competition will include monitoring industry standards that promote interoperability among CAD/BIM software vendors in the marketplace, as well as tracking whether Bentley expands its reseller network.

Since award of the previous BPA, no technological developments aimed at CAD/BIM platform neutrality have been discovered, so full and open competition has not been pursued on this current requirement.

Bentley has a single reseller that was identified on National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP). This reseller acts as a pass-through entity, providing access to Bentley products for NASA SEWP customers. Contracting with this pass-through entity would result in higher costs for the Government, which is not in its best interest. As a result, effective competition through alternative resellers is not feasible at this time. .

IMCOM HQ and USACE will remain proactive in tracking future technological developments focused on CAD/BIM platform neutrality. Full and open competition will be pursued to the maximum extent practicable when it becomes viable. For future requirements, CEHNC will continue to monitor Department of Defense (DoD) Enterprise Software Initiative (ESI) agreements and the open market to assess whether Bentley expands its reseller network. When that occurs, fair opportunity will be provided to all vendors.

9. Market Research: In accordance with (IAW) Defense Federal Acquisition Regulation Supplement (DFARS) 205.205-71, DFARS 206.302-1(d), and DFARS Procedures, Guidance and Information (PGI) 206.302-1(d), a Request for Information was posted to CHESS from 12 December 2025 to 12 January 2026 with no positive responses received. CHESS is the Army’s mandatory source for commercial IT (Information Technology) hardware and software purchases. Considering no responses were received and no Department of Defense (DoD) Enterprise Software Initiative (ESI) vehicle exists for this software; a SONA was obtained on 17 March 2026 to procure these licenses outside of CHESS. A Notice of Intent to Sole Source was posted on SAM.gov from 3 March 2026 to 18 March 2026. To date, no response has been received.

10. Interested Sources: To date, no other sources have written to express interest in the acquisition.

11. Other Facts:

a. Procurement history. The first large-scale deployment of Bentley CAD/BIM technology in the Army and USACE resulted from a competitively awarded USACE-wide contract in the mid-1980's.

Subsequent contracts resulted in a sole source environment. No further information is available regarding the intervening contracts. The first BPA, W912HZ-08-A-0032, was awarded on 19 Sep 2008 with a $35M ceiling for a five-year performance period. The BPA awarded in 2019, W912DY19A0002, was issued for 5 years totaling $45M. The current call order, W912DY24F0070, under BPA W912DY19A0002 was awarded on 31 March 2024 for $3.5M.

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.

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

Approval

Based on the foregoing justification, I hereby approve the sole source procurement of Computer-Aided Design/Building Information Modeling (CAD/BIM) Licenses directly from Bentley Systems Incorporated in the amount of in support of HQ IMCOM 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.