PARC_J A_Memo_17_July_2014_-_MacArthur_Lock_Electrical_Modernization_Power_and_Controls_Project_.pdf

CECT-ATL

DEPARTMENT OF THE ARMY

U.S. ARMY CORPS OF ENGINEERS

REGIONAL PRINCIPAL ASSISTANT RESPONSIBLE FOR CONTRACTING- ATLANTA

60 Forsyth Street, S.W., Room 10M35

ATLANTA, GA 30303-8801

17 July 2014

MEMORANDUM FOR Buffalo District Contracting Chief, Attn: Jeffrey Ernest, Buffalo District, (CELRB-CT), 1776 Niagara Street, Buffalo, New York 14207-3199

SUBJECT: Justification and Approval (J&A) for MacArthur Lock Electrical Modernization Power and Controls Project, Detroit District

1. Approval is granted by the Special Competition Advocate to limit sources (the Rockwell Automation company and Schweitzer company) for the procurement of needed upgrade equipment, Control Number LRE-14-0020, in support ofthe MacArthur Lock at St. Mary's Falls Canal Facility, Michigan. This approval letter is provided for your file.

2. You are reminded that the documents supporting the justification and approval (J&A) for limited competition (brand-name items restriction) for a portion of the subject acquisition is required to be released with the solicitation in accordance with Federal Acquisition Regulation (FAR) 6.302-1(c)(1)(ii)(C). Please ensure the J&A is included as an attachment to the solicitation.

3. Release of this J&A does not compel the disclosure of information that would otherwise be exempt from disclosure under the Freedom of Information Act (FOIA). Prior to release the Contracting officer shall carefully review the J&A for contractor proprietary data and remove all such data, and such references and citations as are necessary to protect the proprietary data.

4. A copy of the FedBi&Ops posting must be provided to our office for file retention within two working days of the actual posting. If additional information is needed you may contact Ronnell Booker at (404) 562-5084.

Encl as Speci Comp tio ~dvocate

Regional Principal Assistant Responsible for Contracting -Atlanta

Control No: LRE-14-0020

Justification Review Document for Other than Full and Open Competition

Program/Equipment: MacArthur Lock Modernization/Motor Controllers Schweitzer Engineering Laboratories Components and Rockwell Automation

Components

Authority: FAR 6.302-1 (a)(2)(ii)(A)- Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements for the listed equipments.

Amount: $20,000 of Schweitzer Engineering Laboratories Components; and $655,000 of Rockwell Automation Components; with a total anticipated cost of $675,000

Prepared by:

Typed Name: James D. Tapp

TAPP JAMES.D.137928533 g~~~~~;,';:~dsb~~~=~!':'::,'~~~~~~:~!~"'·

Signature:

Q ou=USA, en= TAPP.JAMES.D. 1379285330

Date: 2014.06.20 12:01:05 -Q4'00'

Contracting Officer:

Typed Name: Sandra M. Kenzie

Signature:

Digitally signed by

KENZIE.SANDRA.MARIE.1384380553

ON: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=USA, cn=KENZIE.SAN DRA.MARIE.1384380SS3 j" /;.~.- ");f;i,__ ky

- -=~'=e:20=14.0=6.20=13:1=8:19=·04'0~0--------

Technical Representative:

Typed Name: James D. Tapp

Signature: 30 ou .. USA,Cil"'TAPP.JAMES.D.1379285330 Date:2014.06.20 12:01:26-04'00'

Requirements Representative:

Typed Name: David L. Wright

Signature: 480920 ou=USA, cn=WRIGHT.DAVID.L.l 230480920 Oate:2014.06.2012:39:30-04'00'

Telephone:

Date Reviewed:

Telephone:

Date Reviewed:

Telephone:

Date Reviewed:

Telephone:

Date Reviewed:

313.226.2384

20 June 2014

313.226.2134

20 June 2014

313.226.2384

20 June 2014

313.226.3573

20 June 2014

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Deputy for Small Business

Name: Priscilla P. Abeyta-Perez

ABEYTA-

Signature: PEREZ.PRISCILLA.PATRICIA.1239555680

Program Manager

Name: James D. Tapp

Signature:

District Contracting Chief

Name: Jeffery G Ernest

Signature:

District Office of Counsel

Name: 40

Signature: Gary W. Segrest

Field Competition Advocate

James L. Booth Major, US Army

Date: 2014.06.20 12:01 :so ·04'00' ou=USA, cn=SEGREST.GARY.W.1230473540 Date: 2014.06.20 13:07:11 -04'00'

Name: Deputy Commander, Detroit District

Signature:

BOOTH.JAMES.LAFA YETIE.l 186925935

Digitally signed by BOOTH.JAMES.LAFAYETTE.1186925935 DN: c=US, o=U.S. Government, ou=DoD, ou"'PKI, ou=USA, cn=BOOTH.JAMES.LAFAYETTE.1186925935 Date: 2014.06.2016:46:40 -04'00'

PARC Council

Name:

Digitally signed by HEBEL. BAR BAR HEBELBARBARA.N.122B746874 ON: c-US a-U.S. Government au-DoD

Signature:

A.N.12287 4687 4 ~~=~~~~L~;~~:ARAN1228746874

Date: 2014.07.08 13:50:03 -04'00'

Telephone:

Date Reviewed:

Telephone:

Date Reviewed:

Telephone:

Date Reviewed:

Telephone:

Date Reviewed:

Telephone:

Date Reviewed:

Telephone:

Date Reviewed:

312-246-5565

20 June 2014

313.226.2384

20 June 2014

716.879.4173

20 June 2014

313.226.2215

20 June 2014

313.226.6572

1. Contracting Activity:

USAGE - Detroit District- Contracting Division 477 Michigan Avenue, Room 700 Detroit, Michigan 48226

2. Description of Action:

The contractual action for which approval is requested is for only one responsible source; no other supplies or services will satisfy agency requirements. This contractual action is in support of the Mac Arthur Lock Electrical Modernization Power and Controls Project located at the USAGE, Detroit District, St. Marys Falls Canal Facility located in Sault Ste. Marie, Michigan. Funds have been appropriated for this contract through the O&M appropriation. The project is solicited under RFP number W911XK-14-B0013.

The contractual action is a follow-on contract to a larger effort of upgrading highly specialized equipment across the Soo Locks and Hydropower complexs.

Replacing this equipment is critical to the safety and reliability of operating the Mac Arthur Lock. Usage of these product lines eliminates operational as well as support compatibility issues. These product lines are the only equipment compatible with the existing equipment procured under the ongoing upgrade. In addition, these product lines are only available from the manufacturers'.

Schweitzer Engineering Laboratories Components (Schweitzer).

Rockwell Automation provides industrial automation control and information products. Rockwell brands include Allen-Bradley and Rockwell Software.

The overall project is valued at approximately $7,000,000 and will be competively bid via invitation for bid (IFB), however, this justification is only for a subset of project requirements valued at $675,000 which includes the purchase of embedded controllers, motor control centers (MCCs), protective relays, and associated electrical equipment.

The total cost of Schweitzer Engineering Laboratories components to be procured as part of the contract work is estimated at $20,000 and the total cost of Rockwell Automation components to be procured is estimated at $655,000.

3. Description of Supplies/Services:

The contractor shall use Rockwell components to perform embedded control functions associated with controlling equipment, breakers, and power monitoring.

The Allen-Bradley process control equipment, manufactured by Rockwell Automation (Rockwell), shall include the 480V CENTERLINE 2100 lntelliCENTER motor control center family of power equipment, corresponding software, and all associated material necessary for complete integration of the MCCs into the

MacArthur Lock. The total cost of Rockwell Automation components to be procured is estimated at $655,000.

The contractor shall use Schweitzer digital protective relays to protect equipment and reduce risk of personnel injury. Since the design is not yet complete, the contractor may have options that vary the prices in the project, but the supplies and programmable components specified are expected to amount to approximately $20,000.

4. Authority Cited:

The statutory authority permitting other than full and open competition is 10 U.S.C.

2304(c)(1), as implemented by FAR 6.302-1(a)(2)(ii)(A), Only one responsible source and no other supplies or services will satisfy agency requirements -- it is likely that award to any other source would result in substantial duplication of cost to the Government that is not expected to be recovered through competition.

5. Reason for Authority Cited:

Only the listed responsible source and no other sources of supply will satisfy agency requirements for applications of this procurement without substantial duplication of cost to the Government. Specifically, these agency requirements are as follows:

Compatible with Existing Operational Equipment The facility has a substantial amount of electrical equipment and embedded controls to support the four navigational locks and two hydropower plants on site.

The contractual action is a follow-on contract to a larger effort of upgrading highly specialized equipment across the Soo Locks complex. Any equipment installed must be compatible with existing equipment. In particular, any new equipment must be able to perform its primary purpose and communicate with existing embedded controls equipment. Rockwell and Schweitzer product lines are the only product lines compatible with the existing equipment procured under the ongoing upgrade.

Compatible with Existing Support and Development Equipment The organization has invested in equipment to support the maintenance of existing equipment and embedded controls. The value of the equipment used for development and maintenance support work exceeds $50,000.00. Adding additional devices from other manufacturers to the inventory of equipment serviced would require the corresponding procurement of additional manufacture-specific support equipment estimated to be up to another $25,000.00.

Compatible with Existing Training Program The organization has a substantial investment in training employees through manufacture-specific courses. The level of sophistication of PLC-related devices requires employees servicing these devices to be manufacturer trained. Tuition costs per course range from $1,200.00 to $1,700.00 per employee. A one week course per employee easily exceeds over $4,000.00 for tuition, airfare, per diem and lodging, and does not include labor costs. There are a minimum of seven employees that work with electrical equipment and embedded controls at this facility. The financial burden to support a trained workforce across multiple manufacturers of these devices becomes prohibitive and is clearly not cost effective or sustainable.

Compatible with Existing Support Software The organization has manufacturer-specific software to support the operation and maintenance of existing equipment. The software tools for the existing embedded controls cost approximately $2,000.00 each and require recurring annual licensing costs. Adding additional devices from other manufacturers to the inventory would require the corresponding procurement and maintenance of additional manufacture-specific support. This scenario will replicate for every new manufacturer brought onto the facility and, thus, continually add to the indirect overhead costs of maintaining the facility.

Prescribed Load List of Parts The Sao Area Office maintains a prescribed load list of float devices and spare parts to support the facility's 24/7 operations. One specific make/model may be used as a float for several like devices in service. The float allows rapid replacement of modules that have failed or require service. Rapid replacement is required to support the 24 hour/7day operations of commercial shipping through the two navigation locks, the Poe and MacArthur. Standardizing on a make of device allows one float device to cover multiple devices in service of the same type. An added expense is incurred when acquiring a new make of devices to the facility's prescribed load list of float devices and associated spare parts if future procurements of like devices are not of the same make.

Compliance to the Federal Information Security Management Act of 2002

(FISMA):

The existing embedded controls are undergoing DIACAP certification. DIACAP (DoD Information Assurance Certification and Accreditation Process) is an accreditation process that ensures computers systems and data networks address cyber vulnerabilities. Significant cost will incur if using comparable equipment from multiple manufactures. The SAO has to support these systems at a very high technical level; to include installation of software patches and firmware upgrades in a timely manner per DoD requirements. Using multiple manufactures places an insurmountable burden upon SAO resources.

In summary, under the reason for the authority cited, sources of supplies have been deemed through market research, technical compatibility, and support requirements to be available only from the original source. The sources and supplies specified are the only sources and supplies compatible with the existing equipment procured under the ongoing upgrade. The actual purchase cost between reputable manufacturers of electrical equipment, motor control centers, and associated equipment is, in itself, comparable. However, the burden to support devices from multiple manufacturers becomes prohibitive.

For every different manufacturer tens of thousands of dollars in indirect costs for support equipment, software, training, test documents, and float and spare parts is required. The existence of differences of data, patent rights, copyrights, and manufacture design and processes limit the ability to operate and maintain multiple manufacturers with one common set of support assets. Therefore, it is extremely likely that an award to any other source other than Rockwell (for electrical equipment, MCCs, embedded controls, and associated equipment) and Schweitzer (for digital protective relays) would result in a substantial duplication of cost to the Government that would not be recovered through competition (Ref. FAR 6.302- 1(a)(2)(ii)(A)).

6. Efforts to Obtain Competition:

Market research as described in paragraph 8 was conducted to determine if other sources were available for potential competition. Although established competition within this market field exists, equipment differences of data, patent rights, copyrights, and manufacture design and processes limit the ability to operate and maintain multiple manufacturers with one common set of support assets making equipment from competing manufacturers as incompatible.

7. Actions to Increase Competition:

Market research as described in paragraph 8 was conducted to determine if other sources were available for potential competition. In order to provide fully compatible and remotely accessible systems with minimal downtime, the specified components would be required.

8. Market Research:

Techniques used in conducting the market research for this document included the following:

(i) Contacting knowledgeable individuals in Government and industry regarding market capabilities to meet requirements.

(ii) Reviewing the results of recent market research undertaken to meet similar or identical requirements.

(iii) Reviewing catalogs and other generally available product literature published by manufacturers, distributors, and dealers or available on-line.

In addition, an intent to sole source notice specifing brand name products on a sole source basis under the authority of FAR 6.302-1(a)(2)(ii)(A) for this equipment was posted to FedBizOpps on 30 May 2014. This notice invited persons who may have interest or capability to provide similar equipment to respond accordingly. No responses were received to that notice as of 17 June 2014.

9. Interested Sources:

To date, no other interested sources have been identified.

10.0ther Facts:

N/A

11. Technical 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.

Typed Name: James D. lapp

Title: Chief, Technical services Branch

Signature:

TAPP.JAMES.D.13 Dlgltolly•lgoedbyTAPPJAMES.D.1379285330

ON: c=US, o=U.S. Government, ou=DoD, ou=PKI, 7 9 2 8 53 3 Q ~~~e~;~·, ~~0=6~;6~ ~~~~~·~~·~7285330

12. Requirements Certification:

Telephone:

Date Reviewed:

313.226.2384

20 June 2014

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.

Typed Name: David L. Wright

Title: Chief, Operations

Signature: WRIGHT.DAVID. DlgltallysignedbyWRIGHT.DAVID.L1230480920 ON: t=US, a= U.S. Government, ou=DoD, ou=PKJ, L.1230480920 __ ~:_;~;_~.~_'.;;",~_:'~~-;i~_;:'g_,~;;._~304_809_20 ----

13. Fair and Reasonable Cost Determination:

Telephone:

Date Reviewed:

313.226.3573

20 June 2014

I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable. The estimated price of $675,000.00 is considered fair and reasonable on the basis of public pricing data, established GSA Schedules, and historical purchases.

Typed Name: Sandra M. Kenzie

Title: Contracting Officer

Signature:

Digitally signed by

KENZIE.SANDRA.MARIE.1384380553

ON: c=US, o=U.S. Government, ou=DoD, ou=PKI, ou=USA, cn=KENZIE.SANDRA.MARIE.1384380553 Date: 2014.06.20 13:19:08 -04'00'

Telephone:

Date Reviewed:

313.226.2134

14. Contracting Officer Certification:

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

Typed Name:

Signature:

Sandra M. Kenzie

Digitally signed by

KENZIE.SANDRA.MARIE.1384380553

DN: c,us, o:=:U,S. Government, oueeDoD, ou-,PKI, ou,USA, cn,KENZIE.SANDRA.MARIE.1384380553 Date: 2014.06.20 13:20:08 -04'00'

Telephone:

Date Reviewed:

313.226.2134

Control No: LRE 14-0020

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

Macarthur Lock Modernization/Motor Controllers

Schweitzer Engineering Laboratories and Rockwell Automation

APPROVAL

Based on the foregoing justification, I hereby approve the procurement of Schweitzer Engineering Laboratories Components and Rockwell Automation Components on an other than full and open competition basis pursuant to the authority of 1 0 U.S.C.2304(c), FAR 6.302-1 (a)(2)(ii)(A), subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Date:

pecial Competition Advocate

Regional Principal Assistant Responsible for Contracting - Atlanta