25Q0056-Brand Name JA_Redacted.pdf

UNITED STATES MARINE CORPS

MARINE CORPS INSTALLATIONS PACIFIC-MCB CAMP BUTLER

OPC 557 BOX 10

FPO AP 96371-9001

J&A No. 25-SSBN-03

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity.

Marine Corps Installations Command Pacific, Marine Corps Base Camp Butler (MCIPAC – MCBB) Regional Contracting Office (RCO).

2. Description of the Action Being Approved.

MCIPAC-MCBB RCO is seeking to procure ASSA ABLOY Classic RFID locks for the Unaccompanied Housing Division of MCIPAC-MCBB GF. This model represents the most current and up-to-date locking technology from ASSA ABLOY and is fully compliant with current security standards. This procurement is part of our effort to standardize door locks across the Marine Corps Camps on Okinawa Japan by simplifying the number of lock types, supporting software, hardware and training requirements. Currently over 80% of our existing lock infrastructure is composed of ASSA ABLOY products, restricting procurement brand-name specifications ensures consistency and compatability with existing ASSA ABLOY products.

3. Description of Supplies/Services.

Estimated Dollar Value

FY25

Total

O&MN $1.6 mil Total $1.6 mil

a. Supplies and Services to Be Acquired This acquisition is for brand-name ASSA ABLOY Classic RFID new lockset and upgrade kits to include supporting components that are fully compatible with the Visionline access control software. The procurement includes approximately 3,661 locking mechanisms and peripheral items necessary to upgrade the current access control architecture. These items are required to restore and modernize physical access to government-owned unaccompanied housing and other mission-critical facilities.

Major items and associated quantities include:

• Classic RFID locking mechanisms – 3,161 units

• Mifare UL AES locking mechanisms – 500 units

• Visionline version 1.30 software licenses – 7

• Visionline server software – 7

• Key encoders – 7

• Lock service packages – 7

• Compatible controller modules

• Electronic strike plates and mounting hardware

• Ancillary installation hardware and support services

These components represent a comprehensive modernization effort intended to restore full access control functionality and ensure continuity with the installed software and hardware infrastructure.

b. Delivery Schedule Upon award, the contractor shall deliver all required hardware and software within 180 calendar days. Following delivery, the contractor shall complete installation training and technical support activities within 45 calendar days.

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

41 U.S.C. 1901(e)(2) – a sole source acquisition (including brand name requirments) under the authority of the simplified procedures for certain commercial items, as implemented by FAR 13.501(a).

5. Rationale Justifying Use of Cited Statutory Authority.

The required RFID locking mechanisms must be ASSA ABLOY Classic RFID components that meet strict interoperability requirements with the Government’s current access control software—Visionline. ASSA ABLOY hardware and software are deployed in over 80% of the affected facilities, forming the foundation of the centralized access control architecture. As is standard in the electronic security industry, the associated software, credentialing technology, and keying architecture are proprietary and engineered specifically for the ASSA ABLOY platform.

No other brand has been identified that offers guaranteed compatibility with the currently fielded locking mechanisms and software. Introducing another brand would necessitate a complete overhaul of the credentialing system and backend access management infrastructure, resulting in a new and separate Authority to Operate (ATO) package and cybersecurity review. This would cause an estimated implementation delay of 8 to 12 months. The estimate is based on past transitions of similar IT-enabled control platforms that required full recertification and RMF boundary reassessment.

Furthermore, transitioning to another brand would result in substantial duplicative costs. These include procurement of new hardware, engineering design, removal of legacy mechanisms, installation labor, integration costs, cybersecurity reauthorization, and retraining of housing management personnel.

This acquisition is conducted under the authority of FAR 13.106-1(b)(1), which permits soliciting from a single source when the contracting officer determines that the circumstances of the contract action deem only one source reasonably available. Due to the proprietary nature of the locking mechanisms and supporting software, and the significant operational and financial risk associated with deviating from the established platform, ASSA ABLOY is the only known source that can meet the Government’s minimum technical and operational requirements.

No adequate performance specification, technical data package, or engineering description is available that would support full and open competition without requiring extensive reverse engineering and validation testing. Development of such a specification would exceed the schedule, budget, and scope of the requirement.

Therefore, ASSA ABLOY Classic RFID mechanisms and Visionline-compatible components are the only known solution that can meet the Government’s needs within the required timeframe and without substantial duplication of cost.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

A comprehensive market research effort was conducted in accordance with FAR Part 10 to identify potential sources capable of meeting the Government’s requirement for a brand-name electronic access control solution based on ASSA ABLOY’s Vingcard product line.

On 17 June 2025, a Request for Information (RFI) was distributed to 27 GSA Schedule holders.

Four responses were received; none of the respondents confirmed that Vingcard products were available on their respective GSA contracts. One vendor suggested a potential NASA SEWP procurement path but could not confirm availability or compliance.

A Sources Sought Notice was posted to SAM.gov from 26 June to 15 July 2025. Responses were received from five vendors:

• BHPE LLC expressed general interest but provided no further detail

• E.L. Jones, a U.S. distributor of Vingcard products, raised concerns regarding inconsistent country-of-origin markings on delivered products but expressed willingness to supply Vingcard products contingent on verified compliance with the Trade Agreements Act (TAA).

They also proposed Dormakaba RT+ locks as an alternative.

• ASSA ABLOY Global Solutions (Japan) provided formal assurance of TAA compliance, stating that Vingcard products are substantially transformed at their Texas facility and confirmed the availability of non-China manufactured items beginning October 2025.

• Allegion (US) raised concerns regarding certification requirements (CSEIP) and the use of encryption standards that may no longer align with NIST/FIPS 140-3 for new procurements.

Allegion did not submit an offer but advocated for consideration of equal products.

• KOTRACK Inc. (South Korea) submitted a detailed technical inquiry, requesting additional information on legacy lock compatibility and upgrade scope but did not submit a product proposal.

Based on the results of the sources sought and vendor discussions, the Contracting Officer reviewed all feedback and determined that no other vendor offered a product guaranteed to be fully interoperable with the installed Vingcard infrastructure. The introduction of an alternative brand would require extensive replacement of locking mechanisms, credentialing software, backend system architecture, and cybersecurity recertification, all of which were determined to be operationally prohibitive as detailed in paragraph 5.

A solicitation will be posted to SAM.gov to promote competition to the maximum extent pratical from authorized distributors or resellers of the brand name hardware and software that will meet the Government’s need. This J&A document will be posted alongside the solicitation.

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.

For the reasons outlined in Paragraph 5, there is no current reasonable likelihood of achieving full and open competition for the required locking mechanisms and associated components, as only ASSA ABLOY products are fully interoperable with the existing Visionline software and installed infrastructure. However, this requirement is being structured to promote competition to the maximum extent practicable by soliciting quotes from distributors capable of supplying the brand-name items. This approach allows the Government to leverage competitive market forces on price, delivery, and terms within the constraints of the brand-name requirement.

To encourage future competition, the requiring activity will continue to assess emerging access control technologies, track developments in non-proprietary credentialing standards, and evaluate the feasibility of migrating toward open-architecture solutions during future lifecycle replacement cycles. Should another vendor develop a solution that meets the Government’s interoperability, cybersecurity, and operational continuity requirements, the Contracting Officer will reassess the market to determine whether full and open competition is viable for subsequent procurements.

J&A No. No. 25-SSBN-03

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.

Technical Cognizance:

Signature Name (Printed) Date

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

CONTRACTING OFFICER CERTIFICATION

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

Upon the basis of the above justification, I hereby approve, as Chief of the Contracting Office (CCO), the solicitation of the proposed procurement(s) described herein using other than full and open competition, pursuant to the authority of 41 U.S.C. 1901(e)(2).