Justifcation and Approval_CAT 22-02.pdf

DEPARTMENT OF THE ARMY AND AIR FORCE

NEW HAMPSHIRE NATIONAL GUARD

JOINT CONTRACTING OFFICE

302 NEWMARKET STREET

PEASE ANGB NEW HAMPSHIRE, 03803-0157

NGNH-PFO-PCD 29 March 2022

Control No: CAT 22-02

Justification and Approval for Other Than Full and

Open Competition Justification

1. Contracting Activity: New Hampshire National Guard Joint Contracting Office

2. Description of Action: The Justification and Approval document is for Pease AFB Utility Control Management System (UMCS) climate and control system including software. The UMCS provides the operator with a singular, integrated interface for the various control systems in the building that provides plant visualization, system control, alarm notification, and data collection.

3. Description of Supplies/Services:

The existing base wide control system is EcoStruxure Platform, formerly known as EcoStruxure, by Schneider Electric. This system is replacing the decade old UMCS system, which can’t be maintained any longer due to its age and the unavailability of spare parts.

4. Authority Cited: FAR 6.302-1(c)

5. Reason for Authority Cited:

Background:

Pease is transitioning to EcoStruxure Platform base wide UMCS system since their decade old system can no longer be maintained due to its age and the unavailability of spare parts. Several buildings within the base have been upgraded into this new platform.

The EcoStruxure Platform provides unhindered transfer and remote viewing of mechanical information, alarming, trending, and performance monitoring from all existing and new workstations and view nodes.

Every critical environmental and equipment-generated alarm at the occupied buildings is annunciated to the main central alarm control and the operations alarm monitoring centers.

Air National Guard Engineering Technical Letter (ANG ETL) 15-01-04 stipulates requirements for a single base wide UMCS for utility monitoring and any new system or major upgrades of an existing system must be fully integrated and be fully compatible with the base wide UMCS. Schneider Electric UMCS EcoStruxure is fully compliant with US Department of Defense Information Assurance Risk Management Framework (DIARMF) Category 1 vulnerability to meet the project Cybersecurity requirements and has been adopted by Pease as the base-wide system. During the design, the engineer of record contacted Schneider Electric to inquire and confirm that, currently, there are no other systems that meet DIARMF category 1 vulnerabilities while remaining fully compatible with the EcoStruxure. This system must operate as a wholly integrated system to ensure a reliable operation to critical equipment, safety alerts, security notifications, and data collection of emergency events and transfer to the data collector. The integrated UMCS must be able to fully coordinate, monitor, and alarm any inconsistencies from a common command/viewpoint and initiation request in the event an anti-terrorism threat occurs on site which requires immediate annunciation and shutdown of outside air intakes, etc.

A separate system cannot be custom tied into the base wide EcoStruxure workstation, as it cannot be guaranteed that the platform can continue to achieve cybersecurity requirements and obtain the Authority to Operate (ATO) using a third-party control system. The ATO, formal authorization that the information system is secure, requires formal documentation on conformance with the requirements, the formation of installation Information System Security Officer(s) (ISSO) and an independent audit by Government Agency to validate the process and the system. Having a different UMCS system that passes points to the existing EcoStruxure UMCS may result in security breaches that would invalidate the entire base wide DIARMF Category 1 compliance.

Alternatives:

There are no viable alternatives that meet the mission requirements.

A proprietary patch can be interface allowing communication with base wide EcoStruxure to monitor, collect, and share data. This arrangement, however, carries a significant risk that it would not provide a seamless interface between these two systems. Any non-compatibility between systems could result in alarms not being properly transmitted to the master alarm system, a delayed response to the problem, hazardous conditions occurring that affect personnel and operation, as well as information security updates that will not be fully implemented across all systems.

Impact:

If the J&A is not approved, there is risk that the construction contractor will install an alternative product that cannot provide the immediate notification with the requisite level of specificity. Installing equipment from other manufacturers would limit the information transmitted to the Central Monitoring Station.

Incomplete information would result in a delayed response, which increases risk for personnel and property damage as well as the risk of invalidating the entire base wide DIARMF Category 1 compliance

6. Efforts to Obtain Competition: The JA approval will have no overall effect on the competition for the construction project. Prime construction contractor either offeror their customers systems they have installed, or ask which system the customer uses.

7. Actions to Increase Competition: NA

8. Market Research: Research was conducted to select a Base Wide UMCS. While there are many vendors to select from, Schneider Electric’s EcoStruxure was selected as the bases UMCS.

9. Interested Sources: To date, no other sources have written to express an interest

10. Other Facts: N/A

11. Technical and requirements Certification:

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

Name: Eugene Mozzoni, Lt Col Date:

Title: PIO/KC-46A/DoE Signature:

13. Fair and Reasonable Cost Determination:

I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable. Proposed prices for the product will be compared to the independent government estimate that will be developed. Certified cost or pricing data will be requested if determined to be necessary.

Typed Name: Sean Connolly Date:

Title: Contracting Specialist Signature:

14. Contracting Officer Certification:

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

Typed Name: Scott Ballweg Date:

Title: Contracting Officer Signature:

29March2022