Limited_sources_J_and_A_AB TRANE Controls Upgrades_20240903.pdf

Limited Sources Justification and Approval (J&A)

April 2024 Page 1 of 6April 2024 Page 1 of 6

Contracting Activity: 628th Contracting Squadron, Joint Base Charleston, SC 29404

Purchase Request / Local ID Number: F1M3E24208A001

Program / Project (and PE, if applicable): A/C Controls Upgrades

Program Type (PEO or Other Contracting): Other Contracting

Authority: Multiple Award Schedule Program (FAR 8.405-6)

Estimated Contract Cost (including options): $2,060,950.61

Is this a Bridge Action? Yes No

Description of Limitation:

Trane U.S. Inc. is the sole manufacturer of this equipment and software and only certify their own technicians for installation. The required supplies are available on Trane's Federal Supply Schedule 47QSWA20D002A. No other Federal Supply Schedule contract provides the supplies required. The only way for this this requirement to be competed would be to have another contractor sub-contract all work to Trane U.S. Inc. outside of the GSA Multiple Award Schedule Program. This would not be in the best interest of the government because it would increase the cost of the requirement by $300K-$400K for a General Contractor causing duplication of costs.

COORDINATION (DAFFARS 5306.304(a)) ** To remove a row, click the "X" next to the signature block.

** To restore the row, click the appropriate link to the right: CSO Legal COCO CA SCO PEO AQC AQ Blank-1 Blank-2PM CO

Date

03 Sep 2024

Project Lead / Program Mgr / Requiring Activity William Wilson

628 CES/673-1479

Signature X

Date

03 Sep 2024

Contracting Officer Matthew Michel

628 CONS/ 673-5157

Signature X

Date

03 Sep 2024

Local Legal Reviewer Robert E. Beyler

628 ABW/JA; 843-963-6209

Signature X

Date

03 Sep 2024

Chief of the Contracting Office (COCO) Barbara Bonnette

628 CONS DBO/963-3328

Signature

X

APPROVAL (DAFFARS 5306.304(a)) ** To remove a row, click the "X" next to the signature block.

** To restore the row, click the appropriate link to the right: COCO CO CA SPEPEO Blank

Date

04 Sep 2024

Competition Advocate Susan Madison, NH-IV, DAFC Director of Contracting, OL-AMC Air Force Installation Contracting Center (AFICC) Command Competition Advocate (AMC)

OL-AMC/ 779-0233

Signature

X

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Remove guidance pages.

I. Contracting Activity.

628th Contracting Squadron, 101 E. Hill Blvd, Bldg 503, Joint Base Charleston, SC, 29404 Contracting Officer: Matthew B. Michel, 843-963-5157 Purchase Request: F1M3E24208A001

II. Nature and/or description of the action being processed.

This is a new FFP delivery order awarded to Trane U.S. Inc. under GSA schedule number 47QSWA20D002A.The delivery requirement is for all 51 controls upgrades to be completed no later than 365 days after receipt of the order.

III. Description of supplies/services required to meet agency needs.

This requirement is to provide and install new A/C controllers and related software in 51 facilities at Joint Base Charleston Air Base (JB CHS-AB) The work to be performed consists of replacing all remaining outdated building automation system front end controllers with new Trane Tracer SC+ controllers and integrating them with the existing base-wide energy management control system (EMCS) ensuring full compatibility with the base's Trane Tracer Ensemble system. There are currently 38 Trane BCUs, 6 Trane SCs, 7 Trane ILONs, and 11 JCI Network Attached Engines/Field Servers that are acting as building level controllers. The installation also involves the removal of critical obsolete unit controllers, like chilled water plant controllers, and integration of remaining unit controllers, like VAV box controllers. This will allow for the remaining devices to continue to run and be replaced at failure. All beyond-end-of-life software and firmware that communicate on the base's network will be removed or upgraded within the EMCS network and insecure protocols (NTLM v2, Telnet, HTTP, N2, and Metasys Private Message) will be replaced with secure and DISA approved communication protocols (BacNet, Secured Fox, HTTPS, Kerberos, SMTP, and SSL Platform Daemon). The majority of the remaining unit controllers communicating directly with corresponding building controllers, but not on the base's network, will remain. Upon completion, the JB CHS- AB EMCS will be entirely consolidated into one system and fully migrated to BACnet over IP protocol. The existing Trane Summit system communicating with most of these controllers will be able to be decommissioned. The contractor shall provide all products and incidental installation services required.

The delivery schedule for these items is 365 days to include delivery and installation for all 51 buildings.

628 CES has a Bona Fide Need for A/C Control systems for this fiscal year (FY24). However, the current lead time and installation for many of the products is 365 days and may result in delivery in the fiscal year subsequent (FY25) to the year in which the bona fide need for this item exists. IAW US Code, Title 31, Section 1502, we are permitted to "consider normal production lead-time in determining bona fide need for a purchase". Based on the fact this a FY 24 need, the products required have a lead time and installation schedule of 365 days and that no other vendor can manufacture this product prior to the ensuing fiscal year (FY24) the lead time exception applies. As such, it is my determination that this requirement is a Bona Fide Need for the current 2024 fiscal year. Also, it should be noted that although this requirement is for parts of an existing overall base wide ECMS system, these controllers primarily work independently as individual building controls. The new controls do not add significant new capabilities to the existing base-wide ECMS system. Rather, they upgrade outdated legacy components in order to maintain the functionality, safety, security and efficiency of the existing system. Therefore, 3400 O&M funds are appropriately being utilized to fund the requirement.

This is a new requirement. The AC controls for other buildings on JB CHS-AB have been replaced as part of large construction projects and chiller replacements in the past. This requirement replaces the legacy controllers within the remaining facilities with new controllers and integrates them into the newer Trane Tracer Ensemble system allowing the legacy Trane Summit system to be decommissioned. 628 CES estimates the 51 installs should be completed within 1 year.

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Not fulfilling this need will have a significant negative impact on JB CHS-AB. The equipment intended to be replaced and upgraded are largely in legacy status preventing migration to the Trane Tracer Summit control system. Repair materials are increasingly unavailable for the existing controllers and associated equipment, and the Tracer Summit system traffic is blocked by the firewall across the COINv2 domain. The Tracer Summit operating system currently remains off the COIN domain while residing on the COIN VLAN, introducing a significant vulnerability and preventing compliance with current cyber security policies, particularly DAFGM 2023-3201 CE Control Systems Cybersecurity memorandum. Once the remaining building controllers are converted to Trane Tracer SC+ , the remaining Tracer Summit workstations can be joined to COINv2 and full ECMS functionality will be capable at the associated buildings through the Trane Ensemble Platform.

The items to be acquired are building controllers, bridges and graphics cards, device licenses, and incidental installation services of all items:

SIN Items Unit Cost Quantity Total

334512 Tracer SC+ controllers $ 2,090.00 53 $ 110,770.00

334512 Symbio500 $ 542.00 59 $ 31,978.00

334512 Bridges & Graphics $ 3,000.00 50 $ 150,000.00

511210 Device Licenses $ 1,133.00 100 $ 113,300.00

511210 SMP Licenses $ 1,767.00 50 $ 88,350.00

238910 Installation $ 1,252,170.31 1 $ 1,252,170.31

Grand Total: $2,060,950.61

These items being purchased will have regular maintenance and software updates and will be phased out when building HVAC systems are being upgraded. This will allow the base to keep up on the technology front and the new units to work to industry standards.

The need to upgrade these controllers systems, is so the existing ECMS system of the base can work properly.

Without the upgrade to these controllers, each of these 51 buildings would not be able to centrally controlled. The purpose of the Air Force Standardization initiative was to save cost on personnel and training. By purchasing and installing these new controllers, it would enable the 628 CES to take advantage of the technology and divert manpower to other areas of need.

The products provided under this requirement meet the definition of commercial products at FAR Part 2 as they are products, other than real property, that are of a type customarily used by the general public or by nongovernmental entities for purposes other than governmental purposes, and have been sold and offered for sale to the general product. The incidental installation services provided under this requirement are commercial as they are in support of the commercial products provided and Trane provides the same/similar services contemporaneously to the general public under terms and conditions similar to those offered to the Federal Government.

All products are readily available from Trane under their GSA Multiple Award Schedule 47QSWA20D002A. Delivery and installation of these items will take approximately 365 days after receipt off order.

The unique aspect to this acquisition is that only Trane can manufacturer these items, and for their commercial size

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HVAC and Coolers, they only certify their own technicians. Concerns with the size of the units and buildings that the company deals with on their commercial products, leads to undo risk if installation of equipment and software are not completed by Trane.

All installation shall be accomplished in accordance with all Federal, State, Local Regulations and applicable guidelines & requirements to include but not limited to the following codes and standards:

1. International Building Code

2. International Mechanical Code

3. National Electrical Code (NFPA 70)

4. National Fire Code (NFPA 1)

5. Unified Facilities Criteria (UFC)

Trane's terms and conditions for products and incidental installation services under their GSA Schedule were reviewed and there are no significant differences between the terms and conditions offered to the government and commercial customers. Trane provides a limited warranty for all equipment and parts for 12 months from initial start-up. Maintenance support is available; however, is not within the scope of this contract. Trane provides Prompt Payment Terms of 0.5% 10 days, NET 30. Quantity discounts can be negotiated at the order level. 628th CES will be responsible for inspection/acceptance of each installation. All items are available on Trane's GSA Schedule at established prices to include fully burdened labor rates for installation related services. Trane provides commercial general liability of $2,000,000 per occurrence and Automobile Liability of $2,000,000 for installation of products, along with Workers Compensation insurance within statutory limits.

IV. Identification of the justification/rationale for limiting sources and demonstration of the contractor's unique qualifications to provide the required supply/service.

FAR 8.405-6 requires an ordering activity to justify its actions when restricting consideration of schedule contractors to fewer than required in FAR 8.405-1 or 8.405-2.

In accordance with FAR 8.405-6(a)(1)(i)(B) "Only one source is capable of responding due to the unique or specialized nature of the work". In effort to standardize HVAC chillers across USAF facilities, a class Brand Name J&A is in place covering all HVAC chiller purchases for USAF installations. Each installation was standardized to one brand, and Joint Base Charleston's brand was identified as Trane. Trane is the only manufacturer of the equipment and software for this requirement, and Trane technicians are the only certified technicians to perform the installation and set up of the new controllers. No other schedule holders carry these Trane items and services on their Federal Supply Schedule. Competing this requirement would only lead to increased costs to the government as all of the items would have to be procured from Trane and all installation services would have to be subcontracted to Trane.

The standardization effort and the brand name class J&A for A/C and chillers across the Air Force causing Trane to be the only manufacturer with the unique qualifications to provide this requirement. It would not be possible to buy any controller system that would work with the A/C and chillers on base except for Trane equipment because of proprietary equipment and software. In addition, Trane does not certify anyone outside its workforce to install items and software on its equipment. If this J&A is not approved it would lead to estimated duplication of costs of $300K-$400K to pay profit and overhead to a general contractor who would add no value as 100% of the work would be subcontracted to Trane.

Not fulfilling this need will have a significant negative impact on JB CHS-AB. The equipment intended to be replaced and upgraded are largely in legacy status preventing migration to the Trane Tracer Summit control system. Repair materials are increasingly unavailable for the existing controllers and associated equipment, and the Tracer Summit system traffic is

April 2024 Page 5 of 6April 2024 Page 5 of 6 blocked by the firewall across the COINv2 domain. The Tracer Summit operating system currently remains off the COIN domain while residing on the COIN VLAN, introducing a significant vulnerability and preventing compliance with current cyber security policies, particularly DAFGM 2023-3201 CE Control Systems Cybersecurity memorandum. Once the remaining building controllers are converted to Trane Tracer SC+ , the remaining Tracer Summit workstations can be joined to COINv2 and full ECMS functionality will be capable at the associated buildings through the Trane Ensemble Platform.

V. Determination by the ordering activity Contracting Officer that the order represents the best value consistent with FAR 8.404(d).

A proposal will be requested on a sole source basis from Trane under their GSA Federal Supply Schedule contract. In accordance with FAR 8.404 prices for supplies and services offered on GSA schedules have already been determined fair and reasonable; however, in order to negotiate a fair and reasonable price, the government will seek discounts due to high volume of items in the order following FAR 8.405-4, and evaluate the proposed level of effort and labor proposed for all of the incidental installation services in accordance with FAR 8.405-2(d) using the independent government estimate.

VI. Description of the market research conducted and the results, or explain why market research was not conducted.

Market research revealed there are no mandatory sources for this requirement; however, Trane is the only authorized manufacturer of the equipment and software of this requirement based on AFICC Launchpad, where an Air Force wide class J&A for brand name set-aside is in place under an initiative to standardize installation AC/Chiller equipment for the purpose of saving money on training of AF personnel that conduct maintenance on this equipment.

Further market research gathered by speaking with Trane government representative, it would not be possible to buy any controller system that would work with the A/C and chillers on base except for Trane equipment because of proprietary equipment and software. In addition, Trane does not certify anyone outside its workforce to install items and software on its equipment. Furthermore, it would lead to duplication of costs of $300K-$400K to pay profit and overhead to a general contractor who would add no value as 100% of the requirement would be subcontracted to Trane.

A sources sought was placed on SAM.gov for 15 days on 17 July 2024, and yielded no interest from any vendors.

Further, an intent to sole source to Trane was issued on SAM.gov for 15 days on 12 Aug 2024 with no responses received.

A search of Business Intelligence tool "Procurement IQ" revealed no relevant results under NAICS 334512 (Automatic Environmental Control Manufacturing for Residential, Commercial, and Appliance Use). A Procurement IQ report was generated for NAICS 333415 (HVAC and Commercial Industrial Refrigeration Equipment Manufacturing)and indicated a buyer power score of -1.0 "Buy Now" indicating current buying power is above the average for 2021-2024 and is expected to fall next year resulting in harsher negotiating conditions. Although an individual chiller system being replaced would normally include low switching costs, this is not the case for this requirement as only controllers are being replaced and the government's need to standardize across a large number of facilities makes the government captive to Trane and in a weaker negotiating position.

A review of the GSA Multiple Award Schedules program revealed Trane has an established MAS Contract for all Products and Installation required under contract 47QSWA20D002A and they are available withing the ordering period and ceiling amount. All prices have been negotiated by GSA; however, the government will seek discounts due to the large volume of this order.

VII. Other facts supporting the justification.

A sources sought was placed on SAM.gov on 17 July 2024 for 15 days, with no interested vendors responding to the posting.

Further, an intent to sole source to Trane was issued on SAM.gov for 15 days on 12 Aug 2024 with no responses received.

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VIII. Actions the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services.

Currently there is a Brand Name Class J&A across the Air Force mandating Trane as the only manufacturer allowed for JBCHS installation. Unless the Class J&A is removed or subsequent maintenance is added to the Class J&A or Trane gets certified resellers and installers outside their own, sole source to Trane for continued maintenance repairs and etc. on the mandated Trane HVAC systems is inevitable.

IX. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

X. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.

April 2024 Page of Authority: Multiple Award Schedule Program (FAR 8.405-6) Is this a Bridge Action?

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( See guidance at the end of this document for completing the following sections. ) I. Contracting Activity.

II. Nature and/or description of the action being processed.

III. Description of supplies/services required to meet agency needs.

IV. Identification of the justification/rationale for limiting sources and demonstration of the contractor's unique qualifications to provide the required supply/service.

V. Determination by the ordering activity Contracting Officer that the order represents the best value consistent with FAR 8.404(d).

VI. Description of the market research conducted and the results, or explain why market research was not conducted.

VII. Other facts supporting the justification.

VIII. Actions the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services.

IX. Certification by the Contracting Officer.

X. Certification by the technical/requirements personnel.

GUIDANCE

I. Contracting Activity.

Fully identify the contracting activity responsible for the proposed contracting action. Include the name/phone number of the Contracting Officer. Specifically identify as a “Limited Sources” Justification. Identify purchase request number, if applicable.

II. Nature and/or description of the action being processed.

State whether the action is a new order or by modification to an existing order. Identify the GSA schedule number, the Blanket Purchase Agreement (BPA) number, the order number for the current action, and the Contactor(s). Indicate the Period of Performance (PoP). Also identify the type of the order/line items on the order (e.g. Firm Fixed Price, Labor Hour, etc).

III. Description of the supplies/services required to meet agency needs.

Specifically describe the supplies and/or services to be acquired including the price and quantity of each item in the order and state the total estimated value of the order. For services, state whether the services are performance-based and, if not, provide rationale for not being performance based. Also state the delivery/performance schedule/period for the items under the order.

IV. Identification of the justification/rationale for limiting sources and demonstration of the contractor's unique qualifications to provide the required supply/service.

This section is normally the most detailed part of the justification. To assist you in preparing this justification, an introductory sentence and the four circumstances of FAR 8.405-6 that justify restricting the number of schedule holders are provided below. Select the appropriate cite, then provide, in narrative form, a detailed explanation supporting the specific circumstance cited for limiting the number of schedule holders.

(Introductory sentence) FAR 8.405-6 requires an ordering activity to justify its actions when restricting consideration of schedule contractors to fewer than required in FAR 8.405-1 or FAR 8.405-2.

After selecting the appropriate cite, next select one of the four sentences below and provide a detailed explanation supporting the specific circumstance cited.

FAR 8.405-6(a)(1)(i)(B), “Only one source is capable of responding due to the unique or specialized nature of the work”. (Provide a detailed justification with supporting documentation, as evidence of the “unique or highly specialized” nature of the procurement. The user/customer typically provides this supporting information. Recommend attaching supporting documentation to the back of the document. General statements are not acceptable.)

FAR 8.405-6(a)(1)(i)(C), “The new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures.” The original order was not issued under sole source or limited source procedures. (Provide details on the previously competed order and explain how this order is a logical follow-on to that order. Explain fully the connection between the previous work/order and the current one. The user/customer typically provides this supporting information. General statements are not acceptable.)

FAR 8.405-6(a)(1)(i)(A), “An urgent and compelling need exists, and following the ordering procedures would result in unacceptable delays.” (Provide a detailed justification with supporting documentation that explains the exact urgency of the requirement and the schedule impact if time were to be taken to follow FSS ordering procedures. The user/customer typically provides this supporting information. Recommend attaching supporting documentation to the back of the document. General statements of urgency are not acceptable.)

FAR 8.405-6(b)(1), “The item is peculiar to one manufacturer. A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer.” (Brand name specifications should not be used unless the particular brand name, product or feature is essential to the Government's requirements. Therefore, explain why the particular brand item is essential to the Government's requirements, and why other companies' similar items, or products lacking the particular feature, do not meet, or cannot meet, or cannot be modified to meet, the agency's need. The user/customer typically provides this supporting information. General statements are not acceptable.)

V. Determination by the ordering activity Contracting Officer that the order represents the best value consistent with FAR 8.404(d).

This section needs to be tailored based upon whether the order is for supplies/services not requiring a statement of work (FAR 8.405-1) or if the order is for services requiring a statement of work (FAR 8.405-2).

For FAR 8.405-1 orders the best value determination needs to be based upon the supply or service offered under MAS contracts by surveying at least three schedule contractors through the GSA Advantage! on-line shopping service, or by reviewing the catalogs or price lists of at least three schedule contractors. The ordering Contracting Officer's review of the Contractor's price list(s) and any price reductions sought is also required. (Contracting Officer should seek additional price discounts/concessions based on the specific order requirements on all orders over the micro-purchase threshold.) In addition to price, when determining best value, the ordering activity may consider, among other factors, past performance, special features of the supply or service required for effective program performance, trade-in considerations, probable life of the item selected as compared with that of a comparable item, warranty considerations, maintenance availability, environmental and energy efficiency considerations, and delivery terms.

When an order contains brand name specifications, the Contracting Officer shall post the Request for Quote (RFQ) along with the basis of the justification as required by FAR 8.405-6(b)(3).

For FAR 8.405-2 orders for services requiring a statement of work, FAR 8.405-2(d) requires that an evaluation be performed based on the criteria provided to the schedule contractors. Therefore, the justification must address how the FAR 8.404(d) requirement for an evaluation of the proposed level of effort and mix of labor will be conducted and include a statement that the Contracting Officer will perform a price reasonableness determination as part of the best value determination.

VI. Description of the market research conducted and the results, or explain why market research was not conducted.

Discuss market research that was conducted among schedule holders and the market research results that led to the conclusion to go sole source or to limit the number of schedule holders to be solicited. The narrative in this section should provide a high level of confidence that the requirements of FAR 8.405-1 and FAR 8.405-2 could not be met. If no market research was conducted, state so and provide the rationale.

VII. Other facts supporting the justification.

When FAR 8.405-6(a)(1)(i)(C) is cited for an follow-on acquisition as the basis for the justification, include an estimate of the cost that would be duplicated and the basis and derivation of the estimate, or provide details on why a delay to solicit additional schedule holders would be unacceptable.

Provide any other facts supporting the Limited Sources Justification.

VIII. Actions the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services.

Describe all efforts to be taken to remove or overcome any barriers that preclude the agency from meeting the requirements of FAR 8.405-1and FAR 8.405-2 before any subsequent acquisition for the supplies or services is made. If no actions are planned, so state and provide reasons.

IX. Certification by the Contracting Officer.

The contracting officer's signature on the signature page evidences that he/she has determined this document to be both accurate and complete to the best of his/her knowledge and belief.

X. Certification by the technical/requirements personnel

As evidenced by their signatures on the signature page, the technical/requirements personnel have certified that any supporting data contained herein which is their responsibility is both accurate and complete.

9.0.0.2.20120627.2.874785

628 CES/673-1479

Name: Matthew Michel

628 CONS/ 673-5157

Name: [ Name ] [ Office Symbol / Phone Number ] Name: Robert E. Beyler

628 ABW/JA; 843-963-6209

Name: Barbara Bonnette

628 CONS DBO/963-3328

Name: [ Name ] [ Office Symbol / Phone Number ] Name: [ Name ] [ Office Symbol / Phone Number ] Name: [ Name ] [ Office Symbol / Phone Number ] Name: [ Name ] [ Office Symbol / Phone Number ] Name: [ Name ] [ Office Symbol / Phone Number ] Name: [ Name ] [ Office Symbol / Phone Number ] Name: [ Name ] [ Office Symbol / Phone Number ] Name: Susan Madison, NH-IV, DAFC Director of Contracting, OL-AMC Air Force Installation Contracting Center (AFICC) Command Competition Advocate (AMC)

OL-AMC/ 779-0233

Name: [ Name ] [ Office Symbol / Phone Number ] Name: [ Name ] [ Office Symbol / Phone Number ]