Sutron LSJ F - Post Award Synopsis Redacted.pdf

Version 3.0

LIMITED SOURCE JUSTIFICATION

FOR A BLANKET PURCHASE AGREEMENT EXCEEDING

THE SIMPLIFIED ACQUISITION THRESHOLD

(AUTHORITY: FAR 8.405-6)

This acquisition is conducted under the authority of the Multiple Award Schedule Program.

1. Agency and contracting activity.

Department of Commerce, NOAA Acquisition and Grants Office (AGO), Eastern Acquisition Division and National Ocean Service (NOS), Center for Operational Oceanographic Products and Services (CO- OPS), Engineering Division.

2. Nature and/or description of the action being approved.

This is a limited source justification to issue a firm-fixed-price (FFP) Blanket Purchase Agreement (BPA) under the General Services Administration (GSA) Schedule, GS-07F-002DA, to procure Sutron Data Collection Platform equipment and repair services on existing Sutron equipment from OTT HydroMet. These supplies and services are proprietary to one manufacturer, OTT HydroMet Corporation .

3. Description of the supplies or services required to meet the agency’s needs (including the estimated value).

CO-OPS requires new Sutron Data Collection Platform equipment and repair services on existing Sutron equipment that is used for remote environmental sensing and monitoring to maintain its operational requirement to monitor, assess, and distribute tide, current, water level, meteorological, and other coastal oceanographic products and services that support NOAA’s mission of environmental stewardship, environmental assessment, and prediction.

Sutron Equipment to be purchased and repaired under this action includes, but is not limited to, Sutron Xpert Data Loggers, Xlite Data Logger's, Satlink Transmitters and Logger/Transmitters, Iridium Data Telemetry Short-Burst-Data (SBD) Modems, NOS G3 Main Stations, NOS G3 Redundant Gauges, NOS G3 Hydrographic Gauges, Compact Constant Flow Bubbler, Xpert Digital and Analog I/O Modules, Xpert Voice Modem Modules, Accubar Barometric Pressure Sensors, and Analog, Digital, RS232, SDI-12, Phone, and Power Termination Modules, Accubar bubbler gauges, IP Modems, and other Sutron manufactured equipment integrated into the CO-OPS inventory of sensors and platforms.

These supplies and services are proprietary to one manufacturer, OTT Hydromet Corporation.

This requirement is for a BPA consisting of one, 12-month base period with four, 12-month option periods. The Independent Government Cost Estimate (IGCE) for the base period and option periods is

. The IGCE is based on technical expertise and historical contract pricing.

critical to complete a series of thorough and rigorous testing in order to fully understand how the sensors will perform over the wide range of environmental conditions experienced at field locations.

Tests are performed to ensure the quality of the data and the durability of the equipment. Further Government resources would need to be allocated for the testing, approval, acceptance, and interfacing of the new equipment with existing equipment. When introducing a new sensor technology into a pre-existing operational ocean observatory, it is critical to complete a series of thorough and rigorous testing in order to fully understand how the sensors will perform over the wide range of environmental conditions experienced at field locations. Tests are performed to ensure the quality of the data and the durability of the equipment. CO-OPS standard lab testing of new equipment is required to be a completed for a minimum of 80 hours with an additional six to 12 months of field testing. The testing is completed by the CO-OPS Ocean Systems Test and Evaluation Program (OSTEP). OSTEP provides quantifiable and defensible justifications for the use of existing sensors and methods for selecting new systems. This facilitation of new equipment requires additional time and resources testing, preparation, and installation.

Furthermore, CO-OPS specific ingestion and processing software would require updates for use with any non-Sutron, specific (proprietary) data formatting protocols. This software development would include GOES formatting to the CO-OPS standard message format, a critical component of data ingestion using the NOAA National Environmental Satellite, Data, and Information Service data telemetry system. Data ingestion formatting alone would be anticipated to take up to 12 months and over 1,600 staffing resource hours to complete and prep for operational use.

Based on the above information, it is not in the best interest of the Government to purchase new sensors.

The depth of testing requirements and resources needed for integration of any new component into the network of environmental monitoring stations is too great. Integration sensors with the current equipment being utilized is estimated to cost over $3 million in testing, labor, and training. To completely replace the systems currently used to collect data for CO-OPS, the total cost for equipment, training, and labor would cost approximately $15 million. Compatibility with existing systems and system components is essential to meet mission needs; therefore, only OTT Hydromet Corporation can meet the needs of the Government. If CO-OPS does not procure Data Collection Platform components and sensors from OTT Hydromet Corporation, it risks disrupting the integrity and functionality of its extensive network of environmental monitoring stations, which support NOAA’s mission-critical real-time data collection.

Sutron components are integral to over 600 stations across NWLON, PORTS, and NCOP observatories, ensuring compatibility, interchangeability, and reliable data transmission for essential programs like tsunami monitoring and tidal datum updates. Transitioning to non-Sutron components would require significant investment in testing, integration, and system modifications, projected to take more than 12 months and over 1,600 staffing hours, potentially compromising data reliability and operational efficiency across CO-OPS' mission areas. As a result, at this time, only Sutron equipment, from OTT Hydromet Corporation, can meet the needs of the Government. CO-OPS’ long-standing standardization of this equipment is critical to the continued data reliability and data quality that support NOAA’s Tides and Currents mission.

5. Determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

GSA has already determined the prices of supplies and services fair and reasonable. Therefore, ordering activities are not required to make a separate determination of fair and reasonable pricing. However, in accordance with FAR 8.404(d) and 8.405-2(d) the Contracting Officer will conduct a price evaluation in order to determine the pricing provides the best value. In addition, in accordance with FAR 8.405-4, the Contracting Officer will seek additional discounts prior to placing the call order.

Market research conducted among schedule holders (or reason market research was not conducted).

Market research was conducted by the requiring activity and contracting activity by reviewing the acquisition history and similar sensors and equipment offered by other manufacturers. A letter was issued from OTT Hydromet Corporation on October 11, 2024 that stated OTT Hydromet Corporation is the only manufacturer and service provider of Sutron equipment. Therefore, no other manufacturer is authorized to manufacturer or perform services on Sutron equipment, see Attachment 1, Letter from OTT Hydromet Corporation. Additional potential sources were sought by posting a Sources Sought Notice on SAM.gov for 14 days from September 5, 2024 to September 20, 2024 with no responses received.

Additionally, review of similar sensors and equipment offered by other manufacturers concluded that using another manufacturer’s sensors or system components would necessitate extensive system integration that would be required to install non-brand specific sensors in the 600+ stations in the NWLON and PORTS observatories. Sensor and instrumentation compatibility and interchangeability are critical to the operations and maintenance of the systems. This helps to ensure that the data gathered at the observatories is suitable for real-time dissemination, post analysis, assessment, and use in updating tidal datum, currents tables, and navigational charts. Furthermore, the system interoperability helps to ensure robust and reliable operations, and reduces the cost of maintenance through ease of replacement and component upgrade. The Sutron sensors and systems will help to ensure and support safe navigation in commercial ports in the United States and its territories.

Based on the market research performed, it is in the best interest of the Government to solicit and award a FFP BPA against GSA Schedule GS-07F-002DA to OTT Hydromet Corporation in accordance with FAR 8.405-6(a)(1)(i)(B).

Any other facts supporting the justification.

All supporting facts have been documented herein.

Actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for supplies and services is made.

NOAA CO-OPS undertakes a system analysis and evaluation of standardized equipment and sensors every three to five years and re-evaluates requirements and other manufacturer’s systems. If equipment or a sensor representing a better value to the government that meets CO-OPS’ requirements is identified, CO-OPS will take action to begin procuring the newly identified equipment or sensor for integration into the NWLON and PORTS observatories. In 2022 there was a market survey for Sutron equipment that did not identify viable alternatives for several reasons. Sutron components are fully standardized across over six-hundred CO-OPS stations, ensuring compatibility, data accuracy, and proven reliability in diverse environmental conditions.

CO-OPS found that transitioning to a new provider would require extensive modifications to infrastructure, including costly updates to software, diagnostic tools, and data protocols, without yielding significant benefits. Sutron components have also been rigorously calibrated to meet NOAA’s data quality standards, whereas alternatives would require substantial testing to ensure compliance. These factors led CO-OPS to conclude that no alternative currently meets its operational needs as effectively as the existing Sutron equipment.

Attachments 1 – Letter from OTT Hydromet Corporation