JA 24-02 Cisco IE 3400_r.pdf

DEPARTMENT OF THE NAVY

NAVAL FACILITIES ENGINEERING SYSTEMS COMMAND, HAWAII

400 MARSHALL ROAD

JBPHH, HAWAII 96860-3139

J&A No. 24-02

JUSTIFICATION AND APPROVAL

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

SOLICITATION WORK ORDER NUMBER , FY24 MCON PROJECT

P-875 WATER RECLAMATION FACILITY, MARINE CORPS BASE HAWAII,

KANEOHE, HAWAII

1. Contracting Activity.

Naval Facilities Engineering Systems Command, Hawaii (NAVFAC HI), Architect-Engineer Contracts Branch, Joint Base Pearl Harbor-Hickam (JBPHH), Hawaii.

2. Description of the Action Being Approved.

Request approval for the use of a managed Industrial Ethernet switch (Industrial Ethernet (IE) 3400 Series) by Cisco Systems, Inc. for P-875 Water Reclamation Facility (WRF) project at Marine Corps Base Hawaii (MCBH), Kaneohe, Hawaii.

The brand name description is essential to the activity’s requirements, and will not provide for full and open competition for the portion of the acquisition that relates to this brand-name specification only.

3. Description of Supplies/Services.

The P-875 construction project is for a compliance upgrade to the WRF to meet requirements of the National Pollutant Discharge Elimination System permit, where a portion of the construction involves an expansion of the Supervisory Control and Data Acquisition (SCADA) system. The current WRF’s SCADA system is installed in the HI1634M project and utilizes the Cisco IE 3400 Series network switches.

The SCADA expansion in the P-875 construction project will need to follow the established standard for control system components and implement a design that meshes well with existing infrastructure. A managed IE switch is used in a SCADA system to connect devices using telecommunications cables and allows each connected device to interface with the other devices. This project will require the Cisco IE switch to be installed and integrated with the existing WRF SCADA system that utilizes the same equipment.

The estimated procurement costs of the Cisco IE 3400 Series switch is approximately

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

This request is submitted pursuant to the authority of 10 U.S.C.

3204(a)(1), only one responsible source and no other supplies or services will satisfy agency requirements.

5. Rationale Justifying Use of Cited Statutory Authority.

The Cisco IE 3400 Series Switch should be used because of the following:

a. Standardized Equipment for Compatibility and Maintenance.

(1) This project will require modification of and expansion to the existing SCADA system. All new equipment procured under this construction project will need to be connected to the existing GeoSCADA system. Integration of system components with and operability of the base-wide system justify why this brand name equipment is necessary. In order to ensure compatibility with existing equipment, the proprietary Cisco Systems equipment must be installed as part of this project. Inconsistencies and incompatibilities between new and existing SCADA systems can result in inefficient, complex, and non-functioning building systems. This is due to the inability of different proprietary elements of software systems to interoperate with each other.

Due to proprietary elements of this system, interoperation is not possible. The Cisco IE 3400 Series network switch is essential to the Government’s minimum construction standards and thereby precludes selection of a SCADA system manufactured by another company.

(2) Not utilizing the Cisco IE 3400 Series would have a detrimental effect on critical mission elements of the agency’s infrastructure. Use of incompatible equipment will create several problems. The principal and critical problem will be the inability to integrate the control of the new equipment with the existing equipment, preventing timely response to critical changes within a wastewater reclamation system. In addition, specification of incompatible equipment will cause an increased need of both maintenance and personnel requirements.

b. Department of Defense Information Network (DoDIN) Approved

Products List (APL).

(1) The DoDIN APL provides a single, consolidated list of products that have met cybersecurity and interoperation certification requirements. Cisco IE 3400 Series with Ring Management Capability manufactured by Cisco Systems Inc. is listed on the APL.

c. Cybersecurity Authorization to Operate (ATO) Requirement.

(1) The SCADA system is required to meet UFC 4-010-06 cybersecurity requirements and maintain its ATO through the Risk Management Framework process. The existing SCADA system ATO covers the cybersecurity authorization of the system. The Cisco IE 3400 Series switch is currently included within the existing SCADA system ATO. The new Cisco IE 3400 switch will be authorized per the ATO and provide for the following:

(a) Cost-effectively reduce government information technology cybersecurity risks. NAVFAC HI CIO expects that use of the Cisco IE 3400 Series switch in this project will require a Use Case 2 Memorandum for Record (MFR) strategy, versus a Use Case 3 MFR for use of a different manufacturer of switches. A Use Case 2 MFR strategy requires significantly less effort from NAVFAC HI CIO during construction when compared to a Use Case 3 MFR or new ATO strategy and will avoid significant costs and delays. The process of obtaining a new ATO would unacceptably delay the operational use of the SCADA system at the MCBH WRF, resulting in significant degradation in accomplishment of the mission. Obtaining an ATO is also not the end of the process;

and maintaining an ATO is also very resource intensive and the effort increases exponentially when additional hardware or software from different manufacturers is added to the system (i.e. requires maintaining cybersecurity controls, vulnerability management, system scans/tests, etc.).

Assuming other brand name IE switches could be integrated into the installation’s SCADA system so as to be fully functional, the significant cyber security risks, operational challenges, added costs (including the costs of re-procurement) and other disadvantages arising from the use of different brands of switches outlined above are not expected to be recovered through competition.

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

A Sources Sought notice (No. N62478CON33FY2306) was published in the System for Award Management (SAM.gov) on 23 August 2023 to identify other potential sources of supply compatible to the Cisco IE 3400 Series switch. Six responses were submitted in response to the Sources Sought notice; however, all companies were not considered as they were either a distributor, supplier or installer and not an alternate manufacturing source of an IE switch that is compatible with the Cisco IE 3400 switch.

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 taken to remove barriers to future competition.

For the reasons set forth in Paragraph 5 above, NAVFAC HI has no plans at this time to compete future contracts for the types of supplies/services covered by this document. However, NAVFAC HI will continue to monitor the IE switch industry to determine if other compatible alternatives become available, and if another potential manufacturer emerges, NAVFAC HI will assess whether competition for future requirements is feasible. Should any other potential sources of supply become available during the source selection process, the Government will evaluate submissions, as applicable.

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.