Justification and Approval USCGA Siemens for Satterlee Hall_Redacted.pdf

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JUSTIFICATION AND APPROVAL FOR

OTHER THAN FULL AND OPEN COMPETITION

10 U.S.C. § 3204(a)(1)

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-111) and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows:

1. Agency and Contracting Activity.

Department of Homeland Security (DHS), U.S. Coast Guard, CEU Providence proposes to award a firm fixed price (FFP) construction contract which includes a requirement for a brand name item which is only available from one source.

2. Nature and/or Description of the Action being Approved.

This Justification and Approval covers only a portion of the acquisition that is brand name or peculiar to one manufacturer. The purpose of the project is to remove and replace existing AHU (Air Handling Unit), Ventilation Unit, VAV (Variable Air Volume), FC (Fan Coil) and associated sensors and controls located in Satterlee Hall at United States Coast Guard Academy, New London, CT. This requirement will provide for a specific brand name product. Siemens Desigo Building Automation System (BAS) is required for the compatible interoperability of the Direct Digital Controls (DDC) system used to control building Heating, Ventilation, and Air Conditioning (HVAC) systems for the entire campus, and thus, integral to the replacement of HVAC system at Satterlee Hall. Siemens materials are utilized throughout the entire campus-wide Building Automation System.

(a) Nature of the action: USCG intends to procure Siemens Desigo Building

Automation System (BAS) components and materials on a sole source basis

(b) Name and address of the contractor:

Siemens Desigo Building Automation System (BAS) 104 Sebethe Drive Cromwell, CT 06416 Tel: 860 636-4113 Cell: 860 301-2014

(c) Contract Type: Firm Fixed-Price Contract

(d) Estimated total value (including options): Estimate of Siemens Construction Materials:

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(e) Type of funding: DLM-CSO

(f) Year of funding: Fiscal Year 2026

(g) Solicitation number: 70Z0G126RCGA0SL01

(h) Background information about the requirement:

This requirement includes all equipment, materials, labor and supervision necessary to replace the HVAC system for Satterlee Hall. The CGA currently uses the Siemens Desigo BAS throughout Satterlee Hall. Siemens Desigo materials are compatible for the efficient functioning and interoperability of this system.

3. Description of Supplies/Services.

One aspect of the project is to remove and replace the existing Air Handling Unit (AHU), Ventilation Unit, Variable Air Volume (VAV), Fan Coil (FC) and associated sensors and controls in Satterlee Hall. The manufacturer, Siemens Desigo BAS, is the only compatible source to provide this upgrade to support and ensure system interoperability campus wide.

Market research conducted identified other companies, e.g., Johnson Controls and Honeywell, that provide HVAC systems. However, they do not contain specific materials and features to meet the compatibility with the Siemens Desigo BAS.

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

The statutory authority permitting other than full and open competition is 10 U.S.C. § 3204(a)(1) implemented by the RFO Subpart 6.103-1 entitled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.”

5. Identification of Exception to the Buy American Statute. Not applicable

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

The U.S. Coast Guard Academy (CGA) currently uses Siemens Desigo BAS manufactured by Siemens. The BAS operates the Direct Digital Controls (DDC) system used to control the building heating, ventilation and air conditioning (HVAC) systems for the entire campus.

The existing Siemens Desigo BAS resides within the CGA server room and will require Siemens to utilize existing control platforms (e.g., IT server, software, controllers, programming, graphics, etc.)

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Siemens Desigo BAS unique features are essential to the USCG Academy (USCGA) Building Automation System. Within the USCGA campus, Siemens' uniqueness is not about a single feature but its status as the sole, fully integrated technology standard. The entire campus-wide BAS was built and has been maintained as a single, homogenous Siemens system. Key "unique" features are:

• Proprietary & Secure Software: The system's software resides on the secure, non-public Coast Guard server network, which includes security measures. The existing Siemens platform has been vetted and is trusted to operate within this secure environment.

• Established Interoperability: All existing controllers, sensors, and actuators are already proven to be 100% interoperable because they are from the same manufacturer. This eliminates the risk of system conflicts.

• Unified Maintenance & Expertise: The facility has an established maintenance contract and the on-site or contract staff possess deep, specific expertise in Siemens systems. Introducing a new brand would dilute this expertise and require costly and duplicative training.

The compatibility concern is comprehensive, involving both software and physical hardware layers.

• Software Incompatibility: The existing Siemens Building Automation System (BAS) operates on a proprietary protocol. This means the system software, programming language, and engineering tools are unique to Siemens. Introducing another brand, like Honeywell, would be akin to trying to run Apple's iOS on a Windows PC.

• Hardware & System Inconsistency: The physical controllers and devices are designed to function as a cohesive unit. A new brand would have different hardware specifications, control logic, and operational parameters. This would lead to inconsistent system performance, erratic control of HVAC and other systems, and create significant difficulties in troubleshooting and maintenance.

Introducing products other than Siemens (such as Honeywell) would require new control platforms, architecture, programming, equipment and support. Additionally, this would create immediate and significant warranty and service contractual problems.

• Voiding of Warranties: Siemens would likely no longer warranty the overall system's performance if third-party components were introduced. If a system-wide failure occurs, it would be nearly impossible to determine the root cause, and Siemens would not be liable for failures potentially caused by incompatible hardware.

• Fragmented Service Responsibility: The existing maintenance contract is with Siemens. Adding a second vendor would create a scenario with two separate service providers. During an outage, this leads to delays and "finger-pointing," with each vendor blaming the other for the problem. This would severely compromise the ability to get rapid, effective service and would result in slower incident response and increased downtime.

7. Description of Efforts Made to Ensure that Offers are Solicited from as Many

Potential Sources as is Practicable.

The Contracting Officer made the decision to solicit this requirement as a total small

Last Updated 12/16/25 4 business set-aside utilizing the National Multiple Award Construction Contract (NMACC III, Pool #2: NMACC III Small Business Pool East) which contains 8 small businesses capable of fulfilling this requirement. This is a 100% small business set aside.

The APFS record (F2025071582) was published provide on August 29, 2025.

8. Determination by the Contracting Officer that the Anticipated Cost to the

Government will be Fair and Reasonable.

The contracting officer determined that the anticipated price(s) will be fair and reasonable based on the NMACC III IDIQ establishing fair opportunity and competition. Also since Siemens Desigo Building Automation System is being installed and utilized campus-wide, the Coast Guard Academy has sufficient historical data to calculate the IGE amount appropriately.

9. Description of Market Research.

U.S. Coast Guard Academy Facilities Engineering conducted market research on other products including Johnson Controls and Honeywell. The results of the market research indicated other companies offer similar products but due to significant compatibility issues, other products do not meet, or cannot be modified, to meet the needs of the CGA’s existing BAS, to include network architecture, maintenance platforms and physical configurations.

The Market Research confirmed, as discussed in section 6, that introducing products other than Siemens, would result in interoperability, security, maintenance and vendor servicing, and warranty issues. All of which would drive up costs and reduce the effectiveness of one integrated system.

The current BAS is a comprehensive, campus-wide platform, not a collection of independent building systems. By including Siemens BAS components, CGA will continue to have a campus-wide system with the following characteristics:

• Centralized Control: The central computer, or BAS server

• Integrated Network: This central server monitors and controls all major buildings across the campus.

• Shared Infrastructure: All buildings share the same software, network infrastructure, and are managed by the same team. Treating any single building as a standalone project would fragment this unified system, creating security vulnerabilities, operational inefficiencies, and significantly increasing long-term costs for maintenance and training.

The system compatibility issue can only be satisfied with the Siemens brand name materials and equipment. Any other manufacturer or representative would jeopardize the functionality of the BAS System.

10. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

The proprietary requirements are satisfied with the brand name materials (Siemens) and ensure proper communication and compatibility with the existing system used to control

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11. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the Acquisition.

None

12. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome

Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

The USCG is currently utilizing existing controls platform within the Siemens Desigo

Building Automation System. Only one source is able to provide compatible equipment with the correct proprietary software required.

13. Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Sean E. Waldron Date Contracting Officer

14. Technical/Requirements Personnel Certification.

I certify this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for this justification, is complete and accurate.

LT Kathryn Marcenelle Date Technical Representative

APPROVAL

Final approver if total estimated value does not exceed $900K:

Sean E. Waldron Date Contracting Officer