JA26-46_Aclara kV2c Elec Smart Meter P-2001_signed - REDACT.pdf

DEPARTMENT OF THE NAVY

NAVAL FACILITIES ENGINEERING SYSTEMS COMMAND, HAWAII

400 MARSHALL ROAD

JBPHH, HAWAII 96860-3139

J&A No. 26-46

JUSTIFICATION AND APPROVAL

FOR OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION WORK ORDER NUMBER (WON) , P-2001 C40 AIRCRAFT

MAINTENANCE HANGAR AND PARKING APRON, MARINE CORP BASE HAWAII (MCBH),

KANEOHE, HAWAII (HI)

1. Contracting Activity.

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

2. Description of the Action Being Approved.

Request approval for the use of the Aclara KV2c Electric Smart Meter with soft switches E, K, Q, T, and V and TWACS UMT-C, manufactured by Aclara Technologies LLC, 77 West Port Plaza Drive, Suite 500, St. Louis, MO 63146-3126 for P-2001 C40 Aircraft Maintenance Hangar and Parking Apron, MCBH, Kaneohe, HI.

3. Description of Supplies/Services.

The general scope of work for P-2001 is to construct a Type-III high-bay aircraft maintenance hangar at MCBH to provide a weather protected shelter for inspection, service and maintenance for the C-40 and P- 8A aircraft. The hangar will also provide Support Equipment (SE) maintenance and storage space for the P-8A Detachment. The project also includes site improvements and utilities work.

The current electric metering system at MCBH is monitored via an existing advanced metering infrastructure (AMI) Aclara TWACS system using power line carrier communication to a central Aclara human-machine interface (HMI). For the new maintenance hangar, MCBH requires the new smart meters and metering transponders to be compatible with the existing AclaraONE software front-end interface.

The Aclara kV2c, CL series advanced meter with Aclara UMT-C TWACS module will be configured and programmed using existing government-licensed AclaraONE software. The Installation needs to standardize around the Aclara kV2c, CL series advanced meter with Aclara UMT-C TWACS module.

Standardizing on this advance meter is essential to support the installations goal to obtain an Authority to Operate (ATO) for their AMI System, uniform capture and analysis of electricity, and advance metering capabilities necessary for the Installation’s Facility Energy Branch. To date there are a total of approximately 397 existing meters installed at the Installation, and of that total approximately 282 meter are Aclara kV2 meters. The Aclara kV2 meters represent more than 50% of the total meters, which reflects the Installation’s ongoing commitment to obtaining an ATO.

The estimated procurement cost of three Aclara KV2c Electric Smart Meters with soft switches E, K, Q, T, and V and TWACS UMT-C metering transponders is $ , which is % of the estimated construction cost of $ for P-2001.

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

This request is submitted pursuant to the authority of FAR 6.302-1 and Title 10 U.S.C. 3204(a)(1) – Only one responsible source and no other supplies or services will satisfy the agency requirements.

5. Rationale Justifying Use of Cited Statutory Authority.

The existing electric metering system at MCBH is monitored via existing advanced metering infrastructure (AMI) Aclara TWACS system using power line carrier communication. Applicable United States Government Accountability Office (GAO) Comptroller General decisions have acknowledge the authority of a federal agency to use other than competitive procedure when there is a reasonable need for standardization or interoperability with existing agency equipment of software. GAO has concluded that the government may use other than competitive procedures when there is a reasonable need for standardization or interoperability with existing equipment or software, and when it is likely that award to other sources would result in, among other things, substantial duplication of cost to the government that is not expected to be recovered through competition.

To assess the need for standardization and interoperability, NAVFAC Atlantic performed a rigorous business case analysis in August 2021 on the existing and future advance energy meters connected to the AMI system. This business case analysis evaluated the standardization of advanced energy meters and quantified the annual cost associated with procurement, sustainment of operation and maintenance, and establishment and sustainment of Department of Navy cybersecurity requirements. The results of this business case analysis demonstrated that in order to minimize cost and potential cyber vulnerabilities, the use of Aclara kV2c, CL series advanced energy meter with Aclara UMT-C TWACS module will be required for all projects that require a connection to the AMI system. To date, NAVFAC HAWAII concurs with the analysis and has no reason to believe that there has been any changes in their conclusions.

MCBH requires that the Aclara kV2c, CL series advanced energy meter with Aclara UMT-C TWACS module, be provided in order to meet its needs for, and achieve the benefits of, standardization and interoperability. NAVFAC HI is requesting approval to use Aclara for the following reasons:

a. MCBH is working on obtaining an ATO for the Aclara meter on their existing MCBH AMI system. If there is two different brand of meters it will make it that much harder to achieve ATO. Adding more Aclara meters onto their AMI network will get the Installation closer to that goal.

b. Maximize utilization of existing government-licensed AclaraONE software to configure and program the advanced energy meters. Other contractors do not offer advanced energy meters that can be configured/programmed with AclaraONE software.

c. Maintain a single installation networked facilities control and monitoring system so that all advanced energy meters can be programmed from a single central station versus a hybrid system composed of many different advanced energy meters and associated configuration/programming software. This will further increase operational efficiency and decrease installation, maintenance, repair, and energy costs. Utilizing hardware products from the same vendor that produced the configuration/programming software eliminates multi-vendor disputes regarding conflicts, standards, protocols, or performance characteristics should the advanced energy meter not function as required.

d. Avoid the significant operational burden and cost of having maintenance and engineering staff become proficient with the configuration, programming, commissioning, operation, and maintenance of advanced energy meters from different manufacturers.

Standardization reduces personnel training costs and decreases procurement costs related to additional equipment, maintenance, and support contracts for another manufacturer's hardware and software, as well as the maintenance of an additional parts inventory.

Maintaining multiple solutions is inefficient and creates unnecessary work and overhead that increases the total costs of ownership and manpower costs.

Assuming other brand name advanced energy meters, such as L+G FOCUS® AX Polyphase and Elster A3 Alpha meters, could be integrated into MCBH's AMI system so as to be fully functional, the significant cyber security risks, operational challenges, added costs (including the costs to re-procure MCBH’s existing inventory), and other disadvantages arising from the use of different brands of advanced energy meters outlined above are not expected to be recovered through competition.

e. Establish and maintain a defensible cybersecurity posture. The rapid emergence of cyber incidents on critical Industrial Control Systems (ICS), which include FRCS, with the potential to debilitate our installation mission critical assets has catalyzed the need to establish a defensive cybersecurity posture across the shore enterprise. With an approved ATO, it will provide the following benefits:

(1) Cost-effectively reduce government information technology cybersecurity risks. The process of obtaining an ATO would unacceptably delay the operational use of advanced energy meter for the affected facility and connection of the facility to the AMI system, resulting in a significant degradation in accomplishment of mission. Similarly, if different manufacturers other than Aclara were added to the AMI system, the associated cybersecurity costs to sustain the inventory of equipment and software would increase and obtaining an ATO would significantly get more difficult. Additionally, minimizing the different types of equipment and software avoids incurring additional risks to system operational availability should the Naval Facilities Engineering Command (NAVFAC) Functional Authorizing Official (FAO) determine that the additional equipment or software has security vulnerabilities precluding obtaining or maintaining an ATO.

(2) Control Systems (such as networked FRCS) are classified as Platform Information Technology (PIT) systems. Department of Defense Instruction 8500.01 requires that all PIT systems have their cybersecurity controls documented and validated prior to operation and/or deployment. All PIT systems must maintain an ATO from the FAO. ATOs remain valid for three years as long as the cybersecurity posture of the system does not change. A cybersecurity posture change includes, but is not limited to, system architecture changes or any other changes that increase risk or degrade the security posture. Any cybersecurity posture change must be provided to the FAO that approved/authorized the ATO for impact review on that risk approval. When a cybersecurity posture changes, the PIT system normally will be required to complete the authorization process again to obtain a new ATO for the new configuration. The use of different brand advanced energy meters or associated configuration or programming software on the AMI system, results in an undesirable, higher number of changes to the cybersecurity posture of the system. Obtaining an ATO is not the end of the process; maintaining an ATO is also very resource intensive and the effort increases exponentially when additional hardware or software is added to the system (i.e. requires maintaining cybersecurity controls, vulnerability management, system scans/tests, etc.).

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

A Sources Sought Notice (No. N62478CON33FY2420) was posted on 6 June 2024 on the System for Award Management (SAM.gov) website to determine if there were any manufacturers who could provide compatible products to the Aclara kV2 electric smart meter with soft switches E, K, Q, T, and V and TWACS UMT-C metering transponder. There were no responses to the sources sought notice for this requirement.

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 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. Should another potential source emerge, NAVFAC HI will assess whether competition for future requirements is feasible.

CERTIFICATIONS AND APPROVAL

TECHNICAL AND REQUIREMENTS 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.

TECHNICAL COGNIZANCE:

REQUIREMENTS COGNIZANCE:

LEGAL SUFFICIENCY REVIEW:

CONTRACTING OFFICER CERTIFICATION/APPROVAL

I certify that this Justification is accurate and complete to the best of my knowledge and belief.

Upon the basis of the above justification, I hereby approve, as Contracting Officer, the solicitation of the proposed procurement(s) described herein using other than full and open competition pursuant to the authority of 10 U.S.C. 3204(a)(1).