Sole Source Justification-SNL Energy Data Feed.pdf

CUI//PROCURE

JUSTIFICATION FOR

OTHER THAN FULL & OPEN COMPETITION

PROJECT NAME:

SNL Energy / S&P Global Data Feed

The following Justification for Other than Full & Open Competition (JOFOC) is prepared in accordance with FAR Subpart 6.302.

1. ORGANIZATION:

Federal Energy Regulatory Commission Office of Executive Director Acquisition Services Division 888 1st Street, NE Washington, DC 20426

2. NATURE AND/OR DESCRIPTION OF ACTION BEING APPROVED:

Gas Surveillance requires an understanding of shipper-specific information to analyze market activity for anomalies and incentives. While our current databases provide spot and financial market data, we lack database access to firm transaction reporting, capacity release awards, scheduled flow data, tariff rates, etc. SNL's' data feed provides database access with sources and quality that no other vendor provides.

The Commission requires that certain information be publicly posted in order to serve transparency in jurisdictional markets. However, the Commission allows each company to post on its own proprietary system without a standard format. Further, the Commission mandates only a three-month retention requirement. Through arrangements and contracts with the Commission’s third-party data vendors, FERC already has database access to publicly posted power market-information. We lack the same for gas. The SNL data feed brings those disparate postings into one structured, updating, database.

3. DESCRIPTION OF REQUIREMENT & VALUE:

DESCRIPTION: Information from pipeline informational postings and tariffs is needed for the Office of Enforcement to perform more effective Gas Surveillance. That data would enable us to analyze flows and pipeline capacity markets and would provide us a better picture of market participants' activities. SNL's data feed provides a structured real-time feed of critical public postings in the gas market that we currently do not have in database form. Additionally, SNL's data feed provides a host of other gas, power, and corporate identification data sources which will likely find other uses throughout OE and the Commission.

Without a single, constantly updated, consistent database with scheduled flows, firm transactions, capacity release awards, tariff rates, and rate calculations, analysis requires a significant investment of time by staff. We have to pull these data from different vendors, adjust them for consistency and in some cases, manually conduct research for missing data. Time savings can be achieved through having a common, structured source for this data, updated in real-time. The breadth of data we can analyze will be expanded;

for example, with this data because we currently cannot perform cross-temporal cross-pipeline analysis of scheduled flow data. Finally, this data will illuminate currently-dark areas, as we lack structured feeds of transaction data in the primary market.

ANTICIPATED DOLLAR VALUE: $292,285 (Includes Base and 4 Option Years)

4. STATUTORY AUTHORITY:

The statutory authority permitting other than full and open competition is 41 U.S.C. 253(c)(2) in accordance with:

[ ] FAR 6.302-1, only one responsible source and no other supplies and services will satisfy Agency Requirements;

[ ] FAR 6.302-2, Unusual and compelling urgency;

[ ] Other, define below:

5. DEMONSTRATE PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS:

SNL is the only vendor that scrapes the primary market for gas capacity, the most prompt with respect to delivery of the Index of Customers data and can provide tariff rate costs for any pair of points on the pipeline grid. Additionally, they are the only vendor offering backend data access for these applications. Any other vendor would need to develop these capabilities from scratch.

6. DETERMINATION OF FAIR & REASONABLE PRICING:

SNL's Energy Data Feed provides far more in service than can be provided by an FTE at far less than the cost of an FTE. Existing contracts for data-from other Commission third-party data vendors are at far greater cost than SNL's feed.

7. DESCRIPTION OF MARKET RESEARCH CONDUCTED & RESULTS:

SNL's Energy Data Feed provides transactional reporting for the primary market for pipeline capacity, reporting of tariff transportation rates by path, scheduled flow data, capacity release data, and Index of Customers data. No other vendor besides SNL provides transactional reporting for the primary market for pipeline capacity.

Bentek and Velocity Suite provide some of the data sources that SNL does, but Bentek is useless because of its lack of backend access and Velocity Suite does not have primary market transaction reporting nor rates by a cross-pipeline path.

Bentek's RouteBuilder product, to which we do not subscribe, is similar to the Rate Calculator portion of the SNL offering, but Bentek is much more restrictive in its access to the backend data behind the product, and therefore, is useless for analytic purposes. Velocity Suite, a competing vendor with which we have a subscription, provides similar scheduled flow, capacity release, and Index of Customers data, but does not provide rates by path nor primary market transactions. Additionally, Velocity Suite's data structure, coverage, and accuracy in reporting the timing of capacity release award transactions has been less reliable based on our past use of the data. We have found SNL to be more-timely in the publication of Index of Customer data.

8. ANY OTHER FACTORS SUPPORTING THE USE OF OTHER THAN FULL AND

8PEN COMPETITION:

There is a limited space of vendors with commercially available natural gas data solutions. Because the Commission purchases services from many of the vendors in the space, we understand what is currently available in the market. The time required for new development of a product would inhibit surveillance needs and would realistically create costs well exceeding those on a commercially available product.

Consideration of those products commercially available rather than new development projects is prudent from both a perspective of schedule and budget.

9. A LISTING OF THE SOURCES, IF ANY, THAT EXPRESSED, IN WRITING, AN

INTEREST IN THE ACQUISITION.

N/A

10. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO

REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE ANY

SUBSEQUENT ACQUISITION FOR THE SERVICES REQUIRED:

N/A

11. CERTIFICATIONS & APPROVALS: (Signatures are required)

Technical & Requirements Certification:

I certify that the supporting data under my cognizance that are included in this document are accurate and complete to the best of my knowledge and belief.

Contracting Officer’s Representative Date CIO, IT Policy and Resource Management

Contracting Officer Certification:

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

Contracting Officer Date Acquisition Services Division

Competition Advocate Certification:

I have reviewed the Justification and find the document adequately addresses the requirements of FAR Subpart 6.203-1.

Competition Advocate Date Acquisition Services Division