Redacted Limiting-Competition-under-SAT_ACC.docx

Control No: W45N7V926701ZP

Memorandum for Record – Limiting Competition at or below the Simplified Acquisition Threshold

1. Contracting Activity: Army Contracting Command – Redstone Arsenal – Corpus Christi Army Depot, Contracting Office (CCAM-ALC)

2. Description of Action:

Nature: New Requirement Follow-on Requirement

Order #_______ against a single award IDC Contract Modification # _______ to existing PO/TO/DO/Call Order #________________

Pricing/Contract Type: Fixed Price Time & Materials/Labor Hours Cost Reimbursable Hybrid

Funds: Operations & Maintenance, Army (OMA) Other Funds: Army Working Capital Funds

FY: 2020

Name of Proposed Contractor(s) and Address:

Rockwell International 3354 Nacogdoches Road San Antonio, Texas 78217-3323

Brand Name Buy: Yes No

3. Description of Services or Supplies:

Technical Support for Tech Connect Automation Control Software. This requirement is to renew the TechConnect Allen Bradley Programmable Logic Controller (PLC) support. All critical production equipment, such as the whirl towers and engine test cells, contains a PLC which includes the cyanide alarms. Elements of this support consist of Automation Control Hardware Product Support, Application Software Product Support, and HMI Software Product Support. This support is required in order to provide immediate assistance in the event one of the PLCs becomes nonoperational.

CLIN 0001 Tech Connect Software CLIN 1001 Option Tech Connect Software CLIN 0002 Enterprise Manpower Contractor Reporting

Total:

4. Authority:

FAR 13.106-1(b)(1): For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

5. Reasons for Authority Cited:

Mid Coast Electric Inc has been identified as the only vendor capable of meeting the Government’s requirements because the software is proprietary in nature and the original equipment manufacturer (OEM), Rockwell International own all rights to the software and the support. Rockwell does not sell directly to the users of Rockwell products. They will only deal through the authorized distributor which is Mid Coast Electric Inc. The only option available for use of another product is to replace the PLCs with another brand. This would result in a significant additional cost to the Government. In addition, there would be a significant decrease in operational availability of Industrial Automation systems such as: Engine Test Cells, Transmission Test Cells, Plating Lines, Cyanide Alarms, Water Processing Plants, Air Scrubbers, HVAC, Whirl Towers, Shot Peens, Cooling Towers, and other Automated Test Equipment (ATE).

If not funded, production shop areas containing PLCs will be rendered nonoperational in the event an issue occurred with the TechConnect software. This software is critical for the immediate assistance required to return the PLCs to a fully operational status. In addition, without TechConnect software, the building 340 cyanide alarms would not function, which would pose a significant life threatening health risk to personnel working within this facility.

6. Publicizing Contract Actions: For FAR Part 13 actions, the public display and synopsis requirements of FAR 5.101 and FAR 5.203 do not apply due to the $ threshold, apply and will be followed, or do not apply due to an exception at 5.202 ______________________.

Requirement to post justification in accordance with FAR 8.405-6(b)(3), FAR 13.105(c), or FAR 16.505(a)(4)(iii)(A) Action is NOT a brand name restriction and is under $150K, no posting required Action is a brand name restriction, under $25K, no posting required Action is a brand name restriction, over $25K. It will be redacted and posted with the solicitation.

Action is a brand name restriction over $25K but will not be posted due to exception:

FAR 8.405-6(b)(3)(iii)(B)

7. Market Research:

In accordance with FAR Part 10, market research has been conducted for this acquisition by Jonathan Rogers, IT Specialist and Terry Clark, Contract Specialist from 02 August 2019 through 14 January 2020.

The following market research techniques were used:

Mr. Rogers’s personal knowledge in procuring supplies/services of this type.

He has been assigned as the COR for the TechConnect PLC software support contract for a period of 10 years. He performed the market research and generated the procurement package for this requirement beginning with the FY11 contract. He obtained the original information for this requirement from reading the end user requirements list, performing an Internet search for TechConnect to determine specifications and estimated costs as well as to determine possible sources of supply. Mr. Rogers repeated these processes each year, with expanded research prior to each base year.

Contact with knowledgeable persons in Government and Industry regarding the commercial nature of this requirement as follows: Lyndon Ploeger, Chief, IT Industrial Automation Branch, April 2019, Amy Lee, Mid Coast Electric, April 2019. Mr. Rogers learned from Mr. Ploeger that support for the TechConnect software is still required by the depot Industrial Automation Branch and is still an integral factor in the operation of the Allen Bradley PLCs. He also learned from Ms. Lee that Mid Coast Electric is the sole authorized distributor for the TechConnect software and that the manufacturer, Rockwell, does not permit procurement or support from any other distributors.

Results of recent market research review for similar or identical supplies/services:

Mr. Rogers reviewed all of his prior market research conducted for this requirement starting with the MRR from FY11. Also conducted Internet search to determine if any other sources were, in fact, available. Also contacted several CHESS vendors to ascertain possible availability. No other sources were identified.

Publication of a formal Request for Information: CHESS RFI # 638302795 was submitted on 27 March 2019. All responses were "No Bid".

Terry Clark, Contract Specialist performed market research on 14 January 2020, but no other companies were found as shown on the following link below except Rockwell International who own all rights to the software and the support. Rockwell does not sell directly to the users of Rockwell products. They will only deal through the authorized distributor, which is Mid Coast Electric Inc.

https://www.google.com/search?source=hp&ei=H9kdXtfmKIid_QaerbzYBw&q=+TechConnect+Allen+Bradley+Programmable+Logic+Controller+%28PLC%29+software+&oq=+TechConnect+Allen+Bradley+Programmable+Logic+Controller+%28PLC%29+software+&gs_l=psy-ab.3...12484.12484..13918...0.0..0.273.484.2-2....2..0....2j1..gws-wiz.....6..0i362i308i154i357.WB7054Kjm6w&ved=0ahUKEwiX8q2Sr4PnAhWITt8KHZ4WD3sQ4dUDCAs&uact=5#spf=1579014446687

8. Other Facts: Previous Awards:

W912NW-16-P-0143: Awarded to Mid Coast Electric Supply Inc. (Cage Code: 57D53), Small Business, 05 August 2016. Period of Performance 01 Nov 2016 through 31 Oct 2019: Total Contract Value: $39,860.10

9. Technical/Requirements Certification: *** See Sole Source Justification Memorandum, dated 06 September 2019 for technical/requirements certification.

10. Contracting Officer Certification/Approval:

I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable based upon price analysis, I certify that this justification is accurate and complete to the best of my knowledge and belief, and that completing this purchase as a sole source is in the best interest of the Government. Additionally, I approve this justification to limit competition subject to the availability of funds and provided that the services or supplies herein described have otherwise been authorized for acquisition.

Typed Name: Christopher Chapple Title: Chief

Signature:

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