JAs N6274222R1308.pdf

J&A No. 21-0016

JUSTIFICATION AND APPROVAL FOR

OTHER THAN FULL AND OPEN COMPETITION

FOR ONLY ONE RESPONSIBLE SOURCE

SOLICITATION WON 1641920

FY22 MCON PROJECT P-3000

AIRFIELD DAMAGE REPAIR WAREHOUSE

ANDERSEN AIR FORCE BASE, GUAM

1. CONTRACTING ACTIVITY.

Department of the Navy, Naval Facilities Engineering Systems Command (NAVFAC), Pacific, Joint Base Pearl Harbor-Hickam, Hawaii.

2. DESCRIPTION OF THE ACTION BEING APPROVED.

The purpose of this Justification & Approval (J&A) is to include proprietary specifications for the following brand name item in Solicitation Work Order Number 1641920, Fiscal Year 2022 Military Construction Project P-3000, Airfield Damage Repair Warehouse, Andersen Air Force Base, Guam.

a. One (1) Schneider Electric PowerLogic ION8650B 64MB meter

3. DESCRIPTION OF SUPPLIES/SERVICES.

a. Fiscal Year 2022 Military Construction Project P-3000, Airfield Damage Repair Warehouse, Andersen Air Force Base, Guam will construct a new one-story warehouse facility. The building will include drive-through storage areas, fire pump room, and supporting access pavements, grading and drainage improvements, and support utility infrastructure. As part of the project, a Schneider Electric PowerLogic ION8650B 64MB meter will be installed on the exterior of the building.

b. The estimated cost for the meter is which comprises less than of the total project cost of This J&A covers only the portion of the acquisition that is brand name/peculiar to the Schneider ION8650B 64MB meter.

c. Fiscal Year 2022 Military Construction funds will be used to fund the Schneider Electric PowerLogic requirement.

d. The Contractor shall be required to commence work within 15 calendar days after the notice to proceed (30 calendar days after award) and complete the contract within 480 calendar days after the notice to proceed. The meters will be delivered and installed within the 480-day construction time.

Subj: JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION FOR

ONLY ONE RESPONSIBLE SOURCE; SOLICITATION WON 1641920, FY22 MCON PROJECT P-3000

AIRFIELD DAMAGE REPAIR WAREHOUSE, ANDERSEN AIR FORCE BASE, GUAM

4. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION.

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.

As explained more fully below, award to another source would result in substantial duplication of cost to the Government that is not expected to be recovered by competition.

The use of only the Schneider ION8650B 64MB meter for Andersen Air Force Base is required because of the following reasons:

The government has a reasonable need for standardization and interoperability of its existing building control systems that will require a connection to the identified installation networked facilities control and monitoring system commonly referred to as the Data Acquisition System (DAS) at Naval Base Guam (NBG). Applicable United States Government Accountability Office (GAO) Comptroller General decisions have acknowledged the authority of a federal agency to 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.

Advanced Metering Infrastructure (AMI) is an integrated system of utility revenue meters, communications networks, and data management systems that enables automated remote reading of meters. The AMI meters are required to be connected to the base-wide energy and utility monitoring and controls system using the installation’s advance metering protocols. The system operates through the DAS at NBG, which is responsible for acquiring the meter data from the AMI meters located throughout NBG, Marine Corps Base Camp Blaz, and Andersen Air Force Base. The existing AMI meters and DAS utilized by NBG is the ION8650B 64MB meters and the ION Enterprise DAS, both being products/software of Schneider Electric. Only one responsible source and no other suppliers or services will satisfy current agency requirements because the existing AMI system can only fully communicate with meters manufactured by Schneider, particularly ION8650B 64MB meters. This meter can provide the connectivity and functionality to the existing ION Enterprise DAS software metering and billing system utilized by Andersen Air Force Base.

Replacement of the existing system with non-compatible meters would cost approximately

(cost of the entire DAS system and existing meters connected at Andersen Air Force Base) which will significantly increase the cost and budget allocated for this project.

NAVFAC Instruction 11000.2, Facility Related Control System Standardization requires standardization of Facility-Related Control Systems, including utility control systems. AMI falls under utility control systems. Standardization is required to incorporate cybersecurity measures, which benefit operational effectiveness, maintenance efficiency and improved cybersecurity by creating a standardized environment where authorization, scanning, testing, monitoring, and patching can be conducted more effectively for cyber defense and response. To assess the need for standardization and interoperability, NAVFAC Pacific’s Design and Construction branch performed a rigorous business case analysis on the existing inventory of building control systems connected to the DAS system at NBG (Attachment 1). This business case analysis evaluated the standardization of AMI meters and quantified the cost associated with procurement and sustainment of operation and maintenance. The results of this business case analysis demonstrate that in order to minimize costs and potential cyber vulnerabilities, the use of Schneider Electric PowerLogic ION8650B 64MB meters will be required for all projects that require a connection to the DAS system.

In order to minimize costs and potential cyber vulnerabilities, the use of Schneider Electric

ION 8650B (64MB) electricity utility revenue meter programmable controllers and associated application software will be required for all projects that require a connection to the DAS in order to meet its need for, and achieve the benefits of, standardization and operation as follows:

a. Establish and maintain a defensible cybersecurity posture. The rapid emergency of cyber incidents on critical Industrial Control Systems (ICS), which includes 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. A Risk Management Framework (RMF) Authority to Operate (ATO) is pursued per Department of Defense Instruction 8510.01.

(1) Cost-effectively reduce government information technology cybersecurity risks.

Avoid the significant costs and delays associated with obtaining a new ATO for the DAS, which due to government information technology cybersecurity risks, is required when additional nonconforming hardware or software is added to the system with resultant changes in the security posture of the system. The process of obtaining a new ATO would unacceptably delay the operational use of programmable controllers for the affected facility and connection of the facility to the DAS, resulting in a significant degradation in accomplishment of mission.

Similarly, if additional non-conforming equipment and software were added to the DAS, the associated cybersecurity costs to sustain the inventory of equipment and software and to maintain the ATO would significantly increase. Additionally, minimizing the different types of equipment and software permitted on the DAS avoids incurring additional risks to system operational availability should the 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. Additionally, connection or integration into the Communications System Planning Element and subsequently Smart Grid requires that the FRCS obtain an ATO from the NAVFAC 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 programmable controllers or associated configuration or programming software on the DAS, 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.).

b. Be able to maximize utilization of existing government-licensed Schneider ION

Enterprise DAS software to configure and program the controllers. Other contractors do not offer programmable controllers that can be configured/programmed with Schneider ION Enterprise DAS software. Although the Building Automation and Control Network open protocol is the required communications protocol for all manufacturers’ controllers, it only allows for different manufacturers’ equipment to share basic point data. It does not allow for configuration and programming functions to take place between different manufacturers’ controllers. For example, manufacturer A’s software cannot be used to program manufacturer B’s controller. Each manufacturer’s proprietary software tools must be used to configure or change the program within a controller.

c. Maintain a single installation networked AMI facilities control and monitoring system so that all controllers can be programmed from a single central station versus a hybrid composed of several different brands of meters from different manufacturers, each requiring its own configuration/programming software. This further increases operational efficiency, decreases installation maintenance, repair, and energy costs and enables technicians to more effectively troubleshoot, repair, and maintain the AMI system. As a result, Andersen Air Force Base PWD utilities will achieve greater operational efficiencies and effectiveness.

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 controllers from different manufacturers.

Standardization reduces personnel training costs and decreases procurement costs related to additional equipment, maintenance, and support contracts for another manufacturers’ 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.

The use of ION8650B 64MB meters will avoid substantial duplicative costs, described above, that are not expected to be recovered through competition. Assuming other brand name meters could be used so as to be fully functional, the significant cyber security risks, operations challenges, added costs (including the costs to re-procure the Installation’s existing inventory), and other disadvantages arising from the use of different brands of meters outlined above are not expected to be recovered through competition.

6. DESCRIPTION OF EFFORTS MADE TO SOLICIT OFFERS FROM AS MANY

OFFERORS AS PRACTICABLE.

On 8 April 2021, an announcement was published on beta System for Award Management (SAM) in accordance with DFARS 206.302-1 to identify other potential sources of supply that can provide AMI Electric Meters with equal performance and listing/approval requirements as the Schneider Electric PowerLogic ION8650B, 64MB Memory Meter system. No responses were received in response to this announcement. As such, it can interpreted that the Schneider Electric PowerLogic ION8650B, 64MB Memory Meter is the only meter that is currently compatible with the existing ION enterprise DAS software utilized by Andersen Air Force Base. Therefore, there are currently no known manufacturers of AMI meters, other than the Schneider Electric PowerLogic ION 8650B 64MB Memory Meter, that can meet the Government’s requirements at Andersen Air Force Base.

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 TO REMOVE BARRIERS TO FUTURE COMPETITION.

This is a one-time procurement. Although the utilization of a brand name in this project is indicated by this J&A, each future project that includes a Schneider Electric PowerLogic ION 8650B 64MB Memory Meter, outside one year of the 22 April 2021 closing date of the announcement, referenced above, will conduct the same market survey to ascertain the availability of new technology that may provide for other sources to meet the Government’s needs. Should any other offers for a compatible AMI electric meter be submitted during the source selection process, the Government will consider each as applicable.

TECHNICAL AND REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this justification and its supporting Acquisition Plan and which form a basis for this justification are complete and accurate. [FAR 6.303-2(b)]

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient

CONTRACTING OFFICER CERTIFICATION/APPROVAL

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

APPROVING OFFICIAL (NFAS 6.304)

Upon the basis of the above justification, I hereby approve 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. 2304 (c)(1).

J&A No. 21-0017

JUSTIFICATION AND APPROVAL FOR

OTHER THAN FULL AND OPEN COMPETITION

FOR ONLY ONE RESPONSIBLE SOURCE

SOLICITATION WON 1641920

FY22 MILCON PROJECT P-3000

AIRFIELD DAMAGE REPAIR WAREHOUSE

ANDERSEN AIR FORCE BASE, GUAM

1. CONTRACTING ACTIVITY.

Department of the Navy, Naval Facilities Engineering Systems Command (NAVFAC), Pacific, Joint Base Pearl Harbor-Hickam, Hawaii.

2. DESCRIPTION OF THE ACTION BEING APPROVED.

The purpose of this Justification & Approval (J&A) is to include proprietary specifications for the following brand name item in Solicitation Work Order Number 1641920, Fiscal Year 2022 Military Construction Project P-3000, Airfield Damage Repair Warehouse, Andersen Air Force Base, Guam.

a. One (1) Monaco Fire Alarm Radio Transmitter

3. DESCRIPTION OF SUPPLIES/SERVICES.

a. Fiscal Year 2022 Military Construction Project P-3000, Airfield Damage Repair Warehouse, Andersen Air Force Base, Guam will construct a new one-story warehouse facility. The building will include drive-through storage areas, fire pump room, and supporting access pavements, grading and drainage improvements, and support utility infrastructure. As part of the project, a new addressable fire alarm system will be installed in the new building and the Monaco radio fire alarm transmitter will provide fire alarm reporting capability to the base fire department via the Monaco radio fire alarm receiver.

b. The present fire alarm system employed by the Government uses a Monaco fire alarm radio receiver, which operates only with Monaco fire alarm radio transmitters. The Government needs to add one (1) Monaco radio transmitter to operate with the existing Monaco radio fire alarm receiver installed at Andersen Air Force Base, Guam. The estimated cost for one Monaco transmitter is which comprises less than of the total construction cost of . The transmitter is part of the military construction project funds. The price of the Monaco transmitter has been determined fair and reasonable in comparison to similar projects.

c. Fiscal Year 2022 Military Construction funds will be used to fund the Monaco fire alarm radio transmitter requirement.

Subj: JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION

FOR ONLY ONE RESPONSIBLE SOURCE; SOLICITATION WON 1641920, FY22 MCON

PROJECT P-3000 AIRFIELD DAMAGE REPAIR WAREHOUSE, ANDERSEN AIR FORCE BASE,

GUAM

d. The contractor shall be required to commence work within 15 days after the notice to proceed (30 days after award) and complete the contract within 480 calendar days after the notice to proceed. The fire alarm radio transmitter will be delivered and installed within the 480-day construction time.

4. STATUTORY AUTHORITY PERMITTING OTHER THAN FULL AND OPEN

COMPETITION.

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.

As explained more fully below, award to another source would result in substantial duplication of cost to the Government that is not expected to be recovered by competition.

The use of only the Monaco fire alarm radio transmitter is required for the following reasons:

a. In accordance with National Fire Protection Association (NFPA) Code 72, a maximum of

512 transmitters is allowed to be connected to a receiver station. The existing radio fire alarm system at the Andersen Air Force Base Fire Station Building 17002 is a Monaco D-21 radio fire alarm system comprised of one Monaco radio fire alarm receiver. A Monaco D-500 radio fire alarm system serves as a back up to the Monaco D-21 radio fire alarm system. Approximately 158 transmitters are currently on line with the radio fire alarm receiver and an additional 354 transmitters can be added on line to the existing radio fire alarm receiver before the maximum capacity of 512 transmitters is reached.

b. Specification Section 28 31 63.00 20, Analog/Addressable Interior Fire Alarm System, paragraph 1.6.1 requires the devices and equipment for fire alarm service to be listed by Underwriters’ Laboratories (UL), or approved by FM Global (FM). The purpose of the UL listing or FM approval requirements is to ensure quality, suitability, and reliability of the equipment. The UL listing states that either the equipment or material meet appropriate standards or has been tested and found suitable for use in a specified manner.

New manufacturers of fire alarm systems require a minimum of two years to be UL listed and offer no assurance that their transmitters will be compatible with a Monaco receiver.

FM Global approval is based on testing a complete fire alarm system comprised of a fire alarm receiver and transmitter. A fire alarm system of mixed manufacturer’s equipment is unacceptable because no mixed system has been approved to date. Only Monaco fire alarm components in a Monaco fire alarm system are FM approved and therefore, Monaco transmitters are required to operate with a Monaco receiver. The possibility of using non-Monaco transmitters with a Monaco receiver may diminish fire protection capabilities, and therefore, endanger life and property. The requirement for Monaco transmitter ensures reliable fire alarm protection for the new P-3000 Airfield Damage

Repair Warehouse facility.

c. Installation of non-Monaco radio fire alarm transmitters will result in substantial duplication of cost to the Government that is not expected to be recovered through competition and unacceptable delays in fulfilling the agency’s requirements. Installation of non-Monaco radio fire alarm transmitters will require purchasing of new and compatible radio fire alarm receiver and any incidental work to accommodate this new radio fire alarm receiver. A new radio fire alarm receiver is approximately or the cost of procuring one (1) Monaco transmitter for the new building. In addition, the relocation of existing equipment and upgrade of existing supporting utilities would be required to accommodate the new radio fire alarm receiver. Fire department dispatchers are the operators of the Monaco receivers. The dispatchers are required to perform two years of on-the-job training to be fully qualified. A fully qualified operator on a non-Monaco transmitter and receiver will not be possible at the time of installation.

Alarm Shop maintenance workers are factory trained to maintain and repair existing Monaco transmitters and receivers. Thus, a trained Alarm Shop worker would not be available to maintain a non-Monaco transmitter at the time of installation. Installation of a non-Monaco transmitter may endanger life and property until the system is proven reliable. A non-Monaco radio fire alarm system will have cost, operator training, and maintenance implications that will exceed the government's minimum needs.

6. DESCRIPTION OF EFFORTS MADE TO SOLICIT OFFERS FROM AS MANY

OFFERORS AS PRACTICABLE.

In accordance with DFARS 206.302-1, an announcement was published on Opportunities, beta System for Award Management (SAM) website on 8 April 2021 to determine if other potential sources can provide a fire alarm transmitter that has equal performance and listing/approval requirements as the Monaco Radio Fire Alarm Transmitter. No responses were received in relation to this announcement; therefore, there are no other known manufacturers of radio fire alarm transmitters other than Monaco that could meet the FM approval 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 TO REMOVE BARRIERS TO FUTURE COMPETITION.

This is a one-time procurement. Although the utilization of a brand name in this project is indicated by this J&A, each future project that includes a Monaco Fire Alarm Radio Transmitter, outside one year of the 22 April 2021 closing date of the announcement, referenced above, will conduct the same market survey to ascertain the availability of new technology that may provide for other sources to meet the Government’s needs. Should any other offers for fire alarm radio transmitters be submitted during the source selection process, the Government will consider each as applicable.

TECHNICAL AND REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this justification and its supporting Acquisition Plan and which form a basis for this justification are complete and accurate. [FAR 6.303-2(b)]

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient

CONTRACTING OFFICER CERTIFICATION/APPROVAL

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

APPROVING OFFICIAL (NFAS 6.304)

Upon the basis of the above justification, I hereby approve 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. 2304 (c)(1).