LSJ_Redacted.pdf

CUI//SP-PROCURE//FEDCON

Control Number: 26-022

CUI//SP-PROCURE//FEDCON

JUNE 2025

FAR Part 8 Limited Sources Justification

1. Requiring Activity: Directorate of Emergency Services-Fire Department

2. Contracting Activity: 411th Contracting Support Brigade

3. Description of Action: Request approval to award a new limited sourceFire-Fixed Priced (FFP) purchase order to Monaco Enterprises, Inc., CAGE:

1MD67, 147 N. 500 E. St, Spokane, Washington 99202. The purchase order will be fully funded using appropriate Fiscal Year (FY) 26 funds.

4. Description of Supplies/Services: The D-21 ECC Technology Upgrade requirement is necessary to support the USAG Humphreys life-safety mission by mitigating critical cybersecurity vulnerabilities and ensuring the operational readiness of the installation's primary fire alarm and mass notification system. The requirement involves a highly specialized upgrade to the proprietary Monaco D-21 system, which is essential for the Directorate of Emergency Services to provide uninterrupted fire alarm monitoring and emergency reporting capabilities to the Camp Humphreys community.

The total period of performance is 360 days with an estimated value of

Description Duration Cost Technology Upgrade for D-21 ECC System

Within 360 days from award

5. Authority Cited: The statutory authority permitting other than full and open competition is 41 United States Code 4106(c) as implemented in Federal Acquisition Regulation 8.405-6(a)(1)(i)(B), Only one responsible source and no other supplies or services will satisfy agency requirements. The services required for the technology upgrade of the Monaco D-21 ECC system are unique and highly specialized, and only one source can provide them at the required level of quality. The requirement is to upgrade an existing, proprietary life-safety system. Monaco Enterprises, Inc. is the Original Equipment Manufacturer (OEM) and is the only company with the legal rights, proprietary software, and specialized expertise to perform this work. This uniqueness stems from the fact that Monaco Enterprises, Inc. exclusively possesses the software source code, diagnostic tools, and technical data necessary to modify, integrate, and perform cybersecurity hardening on the D-21 system. This intellectual property is not available to the Government or any other contractor. As such, no other source can meet the Government’s need to upgrade this system without creating unacceptable technical and security risks, which makes this service unique to the OEM.

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6. Reason for Authority Cited:

a. Background: The Directorate of Emergency Services (DES) requires a complete technology upgrade for the existing Monaco D-21 Alarm and Mass Notification System, which serves as the primary life-safety system for USAG Humphreys. The current system is operating on obsolete hardware and an unsupported operating system, which has resulted in critical cybersecurity vulnerabilities and an unacceptable risk of system failure. A technical data package suitable for full and open competition is not available because the underlying software, source code, and system architecture are the proprietary intellectual property of the Original Equipment Manufacturer (OEM), Monaco Enterprises, Inc.

This justification cites 8.405-6(a)(1)(i)(B) because the services are unique and highly specialized. The required services are peculiar to one manufacturer, Monaco Enterprises, Inc., for the following reasons:

1. Proprietary System: The requirement is an upgrade of an existing, installed proprietary system. Only Monaco Enterprises, Inc., possesses the legal rights and technical ability to modify, integrate with, and perform cybersecurity hardening on its own proprietary software and hardware.

2. Compatibility: The Monaco brand is essential because no other manufacturer's products or services can interface with the installed Monaco D-21 backbone. The upgrade requires new components to be fully compatible with the existing proprietary infrastructure, which only the OEM can guarantee.

b. Alternatives: Several alternatives were considered, but none were found to be viable or in the best interest of the Government:

1. Conducting a Full and Open Competition: This alternative is not viable. Due to the proprietary nature of the D-21 system, no other vendor would be capable of performing the work. Competitive solicitation would yield no responsible sources and would only serve to delay the mitigation of a critical security risk.

2. Use of In-House Resources: This alternative is not viable. Government personnel lack the proprietary software, source code, diagnostic tools, and factory-certified training required to perform the upgrade. Attempting this work in-house would violate the manufacturer's data rights, void all system warranties, and transfer an unacceptable level of technical and cybersecurity risk to the Government.

3. Suspension of Contract Action Support (No Action): This is not a viable alternative.

Taking no action would mean continuing to operate a mission-critical life-safety system with known, unmitigated cybersecurity vulnerabilities and a high risk of failure, which would seriously injure the Government's ability to protect the installation and its personnel.

CUI//SP-PROCURE//FEDCON

JUNE 2025

The only acceptable alternative is the approval of this justification and contracting with the OEM, Monaco Enterprises, Inc.

c. Impact if not approved: Disapproval of this justification would prevent the award of the contract and have immediate and severe negative impacts. The Government would be forced to continue operating a critical life-safety system that is non-compliant with DoD cybersecurity mandates and is at high risk of complete operational failure. A system failure would leave the installation without a centralized fire alarm or mass notification capability, directly jeopardizing the safety of all personnel on USAG Humphreys and significantly harming the installation's mission readiness and emergency response posture.

7. Efforts to Obtain Competition: Market research confirmed that this requirement is for the upgrade of a proprietary system, the Monaco D-21. Efforts to obtain competition included reviewing technical documentation and public industry sources, which verified that only the Original Equipment Manufacturer (OEM), Monaco Enterprises, Inc., possesses the legal data rights and proprietary software to perform the work. Due to the proprietary nature, soliciting offers from other sources was not practicable as no other sources could be identified that would be capable of meeting the Government’s requirements. The Contracting Officer will publish the notices required by the Federal Acquisition Regulation. Any bids or proposals received shall be considered.

a. Effective competition: No effective competition is anticipated for this acquisition. As this is a sole-source action for a highly specialized service on a proprietary system, it is expected that only one offer will be received from the OEM, Monaco Enterprises, Inc.

8. Actions to Increase Competition: This action is not a direct follow-on to a previously justified limited-source service contract. This is a one-time capital upgrade project for an existing proprietary system. It is not possible to compete the current acquisition because the Government does not own the proprietary data rights for the Monaco D-21 system. The primary barrier to competition is the proprietary nature of the system's software and hardware architecture. To overcome this barrier for future acquisitions, the Requiring Activity, in coordination with the Contracting Office, will take the following actions:

During the life cycle of the newly upgraded system, the Government will conduct market research to identify potential non-proprietary, open-architecture alarm and mass notification systems. For the next full system replacement, the Government will develop requirements that are not peculiar to a specific manufacturer and instead focus on performance-based standards. This will allow for full and open competition among multiple manufacturers for the next-generation system, thereby removing the current barrier to competition.

9. Market Research: Market research was conducted in February 2026 in accordance with FAR Part 10 to identify all qualified sources capable of meeting this requirement.

CUI//SP-PROCURE//FEDCON

JUNE 2025

The research methods included reviewing existing system technical documentation and conducting extensive internet searches for "Monaco D-21," "Monaco Enterprises service," and "fire alarm system integrators."

The results of the market research are as follows:

a. The existing D-21 alarm system was confirmed to be a proprietary system designed, manufactured, and sold exclusively by Monaco Enterprises, Inc., who holds all intellectual property and data rights.

b. Research confirmed that while other major fire alarm manufacturers exist (e.g., Siemens, Johnson Controls, Honeywell), their systems are also proprietary and are not compatible with the installed Monaco D-21 infrastructure. They could not perform an upgrade; they could only propose a full system replacement, which is not the Government’s requirement.

c. Specific research to identify third-party vendors capable of servicing or upgrading the Monaco D-21 system yielded no results. No authorized service providers or integrators with the necessary proprietary software, tools, or expertise could be found.

Therefore, the market research definitively concludes that only the Original Equipment Manufacturer, Monaco Enterprises, Inc., can meet the Government's requirement to upgrade the existing proprietary D-21 system.

10.Other Facts:

a. Ensuring Cybersecurity Accreditation (Authority to Operate - ATO): The existing system is non-compliant with current DoD cybersecurity mandates. Only the Original Equipment Manufacturer (OEM) can be held contractually responsible for successfully hardening its own proprietary code to meet RMF/STIG requirements. This is a prerequisite for the system to obtain and maintain its network ATO. Failure to use the OEM would place the cybersecurity accreditation, and thus the entire system's viability, at risk.

b. Preservation of Existing Warranties: The current D-21 system components are covered by the manufacturer's warranty. Any attempt by an unauthorized third party or in-house personnel to perform the required upgrades would immediately void all existing and future warranties. This would transfer the full financial risk of any subsequent system failures to the Government.

c. Mitigation of Unacceptable Technical Risk: Using the OEM is the only way to guarantee seamless integration and interoperability between the new components and the existing proprietary infrastructure. This significantly mitigates the technical risk of system failure, data loss, or degraded performance that would likely occur if an unauthorized source attempted the work.

CUI//SP-PROCURE//FEDCON

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d. Continuity of Operations: This upgrade ensures the continued, uninterrupted operation of the installation's primary life-safety system. A competitive "rip and replace" action with another manufacturer's system would require a much longer and more disruptive transition period, creating a dangerous gap in emergency response capability.