A.02_J&A_Determination_for_FBO.pdf

Other than Full and Open Competition –

Brand Name Determination

1. Contracting Activity

U.S. Army Corps of Engineers (USACE) – Portland District (NWP), Supplies and Services Branch (CECT- NWP-S), located at 333 SW 1st Avenue – Portland, OR 97204.

2. Description of Action

Request for approval, a Firm-Fixed-Price (FFP) commercial supply sole-source for the acquisition of Prosoft Modbus Controllogix modules (Brand Name) for the Lookout Point Dam, Oregon and the ACCS Logistics Warehouse. Contract will be for the following items in the table below.

3. Description of Supplies/Services

The supplies listed below are to be implemented into current control systems for the Generic Data Acquisition Control Systems (GDACS).

ITEM

NO. SUPPLIES/SERVICES QTY UNIT

0001 Prosoft Modbus Module MVI56E-MCM 4 Each

4. Authority Cited

FAR 13.106-1(b) (1) – Soliciting from a Single Source.

(1) For purchases not exceeding the simplified acquisition threshold.

(i) Contracting officers may solicit from one source if the contracting officer determines that the circumstances of the contract action deem only one source reasonably available (e.g., urgency, exclusive licensing agreements, brand-name or industrial mobilization).

(ii) Where a single source is identified to provide a portion of a purchase because that portion of the purchase specifies a particular brand-name item, the documentation in paragraph (b)(1)(i) of this section only applies to the portion of the purchase requiring the brand-name item. The documentation should state it is covering only the portion of the acquisition which is brand-name.

5. Reason for Authority Cited

Background: The Willamette Valley (WV) has standardized on Allen-Bradley Programmable Logic Controllers (PLC) for hydroelectric generation systems. The GDACS Lookout Point Dam project has a requirement for the Allen-Bradley PLCs to communicate directly with the GDACS SoftPLCs. The only protocol currently available for this is a Modbus Serial. Allen-Bradley does not offer a Modbus Serial PLC communication module, however there is a Modbus Serial PLC communication module that is compatible with an Allen-Bradley Controllogix chassis that is available from Prosoft that would satisfy this requirement.

Justification: This Brand Name equipment is the only Modbus module available that is compatible with the ControlLogix chassis. Since Allen-Bradley ControlLogix PLC equipment is being installed as part of the Unit Control and GDACS Upgrade project and Modbus communication is required, the Prosoft module is also required. It is required for continued security of critical infrastructure or protected systems to resist interference, compromise, or incapacitation, including any planned or past assessment, projection, or estimate of the vulnerability of critical infrastructure or a protected system, including security testing, risk evaluation thereto, risk management planning, or risk audit.

Impact: Other brand name equipment is not be compatible with a ControlLogix chassis and would have to be an external device. An external device would introduce design and programming that would cause significant delays to the design and installation schedule for this upgrade project. Any disruption of GDACS would cripple the Pacific Northwest power supply network, managed by the BOR, BPA, and COE through the common Federal Columbia River Power System (FCRPS). As a result, access to GDACS cannot be legally offered to a wide range of competitors for GDACS support services. The interfaces between GDACS and other software, such as GE software currently in use, are also protected by GE’s legal proprietary rights. The cost and time of any effort to build an alternative GDACS system from a competitor’s hardware or software is prohibitive and contrary to essential operational needs of the FCRPS. Not to purchase is not feasible because we need to ensure the reliability of GDACS installed at the twelve NWD Projects.

6. Efforts to Obtain Competition

Market research indicates that there are numerous other-than-small business and small business distributors that are capable of offering the required equipment. The Army's Computer Hardware Enterprise Software and Solutions (CHESS) is one method of obtaining vendor information. CHESS is a mandated source and will be utilized for this purchase IAW AFARS Part 5139.101 and DA MFR dated 4 May 09. In addition, numerous vendors on the General Services Administration "GSA Advantage" website can provide the required equipment.

7. Actions to Increase Competition

This action will be competed through CHESS per AFARS Part 5139.101-90(a)(1). Efforts to solicit a separate like product would prove incompatible with the existing USACE equipment. In accordance with CHESS ordering guidelines, Fair Opportunity shall be given to all responses from ITES-3H multiple award contract holders using the CHESS Request for Quote (RFQ) process.

8. Market Research

Purchasers of commercial hardware and software must satisfy their IT requirements by utilizing CHESS contracts and DOD Enterprise Software Initiative agreements first, regardless of dollar value. CHESS is the mandatory source for commercial IT purchases per AFARS Part 5139.101-90(a)(1). ProSoft Brand Name hardware equipment was found to be available under these contract vehicles. USACE has standardized on Allen Bradley equipment. While other vendors provide similar equipment, it is not compatible and would require significant rework to recreate all of the current processes and procedures required by DOD 8500.2 and RMF

(NIST 800-53).

9. Interested Sources

Market research indicates that there are numerous other-than-small business and small business distributors that are capable of offering the required equipment.

10. Other Facts

Procurement History:

The previous procurements are summarized in the table below:

Delivery Information:

Sydney COU Foster Lookout Point Dam 40386 West Boundary Road Lowell, OR 97452

Contract Number Date of Award W9127N18F0008 6-Dec-17

W9127N-14-P-0165 9 Oct 2014 W9127N-13-F-0010 11 Jan 2013 W9127N-12-P-0200 18 May 2012 and

Logistics warehouse ATTN: Lindsay Ergenekan- ACCS

8010 NW ST HELENS

Portland, Oregon 97210