JOFOC_Redacted.pdf

Administration Building 180 Andrews Street Massena, NY 13662 Tel: (315) 764-3200 www.greatlakes-seaway.com www.seaway.dot.gov

Great Lakes St. Lawrence Seaway Development Corporation (GLS)

GREAT LAKES ST. LAWRENCE SEAWAY DEVELOPMENT CORPORATION

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

Miter Gate Drive Gearbox Rebuild

1. Identification of the agency and contracting activity.

Program Office:

Office of Engineering and Maintenance 251 Fregoe Road Massena, NY 13662

Contracting Activity:

Great Lakes St. Lawrence Seaway Development Corporation

Massena, NY 13662

2. Nature and/or description of the action being approved.

GLS proposes to enter a contract on a basis other than a full and open competition for the full replacement of internal gearing and components, reassembly and testing of the complete assembly, for two (2) miter gate drive operating gearboxes. These gearboxes are used to operate miter gate leaves weighing up to 275 tons at GLS’s navigational locks in Massena, New York.

The existing gearbox casings will be retained, refurbished, and reused as part of this effort. The internal components must be replaced to restore full operational capability.

This justification is being issued in accordance with FAR Part 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements. GLS intends to award a sole source, firm-fixed price contract to Timken Gears & Services, Inc. (formerly Philadelphi Gear), .

The period of performance for this contract will be through April 30, 2027. Both gearboxes shall be completed by this date.

3. Description of the supplies or services required to meet the agency’s needs, including the estimated value.

Timken Gears & Services. (formerly Philadelphi Gear), Inc., shall provide all labor, materials, and expertise necessary to:

Replace all internal gearing and associated components Reassemble the complete gearbox assemblies Perform inspection and testing to ensure operational readiness

Massena, NY 13662 Tel: (315) 764-3200 www.greatlakes-seaway.com www.seaway.dot.gov

Great Lakes St. Lawrence Seaway Development

The requirement includes two (2) custom miter gate drive gearboxes. Existing gearbox castings will be refurbished and reused, requiring all replacement components to meet exact dimensional and performance requirements to integrate with the existing infrastructure.

4. Identification of the statutory authority permitting other than full and open competition.

The authority to enter the contract award for this effort without full and open competition is FAR 6.302-1 Only One Source Responsible and No Other Supplies Or Services Will Satisfy Agency Requirements.

5. Demonstration that the unique qualifications of the proposed contractor or nature of the acquisition requires use of the cited authority.

The Government does not possess the technical data package required to support full and open competition for this requirement. Specifically, the Government lacks:

Engineering drawings Detailed specifications Material requirements Manufacturing tolerances

The existing gearbox castings will be reused and cannot be modified due to their integration within the lock infrastructure. As a result, all replacement components must meet exact form, fit, and function requirements to ensure compatibility with the existing housing and associated mechanical systems.

Timken Gears & Services., Inc., (formerly Philadelphia Gear) is the original equipment manufacturer (OEM) and designer of the gearboxes and retains proprietary design knowledge necessary to produce components that meet these requirements. This includes knowledge of:

Precise dimensional tolerances Load-bearing characteristics Vibration and performance requirements Design features necessary to achieve expected service life

While other manufacturers may possess general gear fabrication capabilities, the absence of Government-owned technical data prevents them from producing compliant components without reverse engineering.

Massena, NY 13662 Tel: (315) 764-3200 www.greatlakes-seaway.com www.seaway.dot.gov

Great Lakes St. Lawrence Seaway Development

Reverse engineering would require extensive engineering analysis, measurement, redesign, validation, and testing. This process would introduce:

Significant schedule delays Substantial additional costs Increased technical and performance risk

These gearboxes are critical to the operation of the miter gates, which are essential to lock operations. Failure or improper performance could result in operational disruption and potential safety hazards.

Accordingly, due to the lack of Government-owned technical data, the requirement for exact form, fit, and function compatibility with existing, non-modifiable infrastructure, and the unacceptable cost, schedule, and performance risks associated with reverse engineering, Timken Gears & Services., Inc., is the only responsible source capable of meeting the Government’s requirement.

6. Description of efforts to ensure offers were solicited from as many potential sources as practicable, including whether a notice will be publicized and, if not, which exception applies.

A notice of this justification will be posted on the GPE. Based on market research and the Government’s lack of access to proprietary OEM technical data, there are no other sources expected to be capable of meeting the requirement.

7. Determination by the CO that the anticipated cost to the government will be fair and reasonable.

GLS will ensure that all costs associated with this proposed contract are fair and reasonable. GLS will analyze historical pricing for similar efforts, comparison to prior procurements, and evaluation of the contractor’s price proposal.

8. Description of market research conducted and results, or a statement of the reason why market research was not conducted.

Market research included consideration of commercial gear manufacturers and repair facilities with general gear fabrication capabilities.

Market research determined that while other manufacturers may have general gear manufacturing capabilities, no alternate sources were identified that could meet the requirement without access to the OEM’s proprietary technical data.

Massena, NY 13662 Tel: (315) 764-3200 www.greatlakes-seaway.com www.seaway.dot.gov

Great Lakes St. Lawrence Seaway Development

The Government does not possess the drawings or specifications necessary to support competition. Any attempt to compete this requirement would require reverse engineering and requalification of the components, resulting in unacceptable cost, schedule delays, and performance risk.

9. Any other facts supporting use of other than full and open competition.

Not applicable.

10. Listing any sources that expressed a written interest in the acquisition.

Not applicable.

11. Statement of any actions the agency may take to remove or overcome any barriers to competition before any subsequent acquisition for services/supplies.

To promote future competition, the Government will consider obtaining technical data drawings, and associated data rights to the maximum extent practicable to support competitive procurements for similar requirements.

12. Certification and Approvals Signature Page

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