Limiting-Competition-under-SAT_REDACTED.PDF

Control No: 029-19

Version – February 2017

Memorandum for Record – Limiting Competition at or below the Simplified Acquisition Threshold

1. Contracting Activity: 410th CSB

4130 Stanley Rd STE 320 JBSA Ft Sam Houston TX 78234

2. Description of Action:

Nature: New Requirement Follow-on Requirement

Contract Vehicle: Purchase Order Number

Blanket Purchase Agreement (BPA) Number Order/BPA# against FSS Contract # TBD Order # against Multiple Award IDIQ Contract Name or #

Order # against a single award IDC Contract

Modification # to existing PO/TO/DO/Call Order

Pricing/Contract Type: Fixed Price Time & Materials/Labor Hours Cost Reimbursable Hybrid

Funds: Operations & Maintenance, Army (OMA) Other Funds:

FY:

Name of Proposed Contractor(s) and Address:

_Not yet solicited

Brand Name Buy: Yes No

3. Description of Services or Supplies:

The estimated value of the proposed action is

Product Qty

4U 19” Rack Mount Fiber Optic Patch Panel, LGX ‐ 23

This is a lifecycle replacement of Tyco/Commscope keyed Mechanical Transfer Registered Jack (MTRJ) connector modules to keyed Multi-fiber Push-On (MPO) fiber connectors.

ARSOUTH requires the new infrastructure standard of Tyco/Commscope keyed LC (Lucent Connector) connectors to keyed MPO fiber connectors.

Specifications for each module: Connector Manufacture: Tyco/Commscope, Module Format:

LGX, Fiber Count: 24, Fiber Polarity: A, Fiber Type: OM3, Front Connector: Tyco/Commscope Keyed (Secure) LC Duplex (Color), MPO Type: Tyco/Commscope Keyed (Secure) MPO Pinned (Color)

LGX Fiber Distribution System is a set of modular interface products used for terminating fiber cables and connecting optical circuits. The system consists of LGX Fiber Distribution Shelves, the LGX Fiber Distributing Frame (FDF), and associated fiber connecting apparatus and equipment. The LGX Fiber Distribution System is a complete set of modular hardware, with application guidelines, and operating procedures for implementing any size fiber installations.

MPO is the industry acronym for “multi-fiber push on.” It was developed to provide a multi-fiber connectivity in one connector to support higher bandwidth and higher density applications. The most common fiber counts are 12 and 24 currently. 48 to 72 are possible but with limited applications.

LC is a small form factor connector that uses a 1.25 mm ferrule, half the size of the SC.

Otherwise, it's a standard ceramic ferrule connector, easily terminated with any adhesive

4. Authority:

FAR 13.106-1(b)(1): For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

Or

FAR 8.405-6(a)(1)(i)(B) and 8.405-6(b)(1)Brand Name FAR 8.405-6(a)(1)(i)(A) Urgency FAR 8.405-6(a)(1)(i)(B) Only One Source is Capable FAR 8.405-6(a)(1)(i)(C) Logical Follow-on

Or

FAR 16.505(b)(2)(i)(B) Only One Awardee is Capable FAR 16.505(a)(4) Brand Name FAR 16.505(b)(2)(i)(A) Urgency

FAR 16.505(b)(2)(i)(C) Logical Follow-on FAR 16.505(b)(2)(i)(D) Minimum Guarantee

5. Reasons for Authority Cited:

US Army South (ARSOUTH) has made substantial investments in the existing JWICS/SIPRnet networking infrastructure, which consists of Tyco/Commscope keyed MPO fiber connectors to keyed MTRJ connectors. MTRJ connectors are no longer made, and are obsolete. The new infrastructure standard is keyed LC connectors.

ARSOUTH needs to replace current Keyed MTRJ to Keyed MPO fiber modules with Keyed LC to Keyed MPO fiber modules. Because of security, it is required to have secure or keyed connectors. If ARSOUTH has to go to another keyed connector and away from Tyco/Commscope it would cost more than $500K to replace all the current viable Tyco/Commscope keyed fiber infrastructure and require the purchase of $20K of new patch cords for the new keyed connectors. Plus, the 5th floor during last renovation was converted to Tyco/Commscope LC keyed connectors. ARSOUTH must maintain one standard throughout building 1000 to prevent having to maintain multiple patch cords from different brands of keyed connectors saving ARSOUTH annual cost of replacing fiber patch cords.

This is a Lifecycle replacement of existing US Army South (ARSOUTH) secure network infrastructure. The required modules must meet Information Assurance (IA) accreditation in accordance with (IAW) DODI 8100.3. The designed Tyco/Commscope keyed fiber connectors identified in this justification meet this accreditation. In addition, the latest TIC and JITC approved version of code for Assured Services Voice Application Local Area Networking (ASVALAN) must be implemented. Code available from the designated Tyco/Commscope keyed fiber connectors meets these requirements. The same Cisco proprietary parts are necessary to remain compatible with existing Cisco equipment already installed at Army South and to avoid malfunction or delay. In addition, Tyco/Commscope provides required quality of service (QOS) options not available from other vendor solutions, thus utilizing brand name Tyco/Commscope is in the government’s best interest and provides the best value for tax dollars spent.

ARSOUTH has made substantial investments in the existing secure network infrastructure within building 1000, which consists of Tyco/Commscope keyed network infrastructure. Maintaining network operational availability is a critical component of the network support provided to the command. ARSOUTH mission includes significant requirements to support a broad range of Department of Defense (DoD) missions and maintaining network operational availability with SIPRnet, BICES-X, and JWICS is a critical component of that support.

For these reasons, the Contracting Officer has determined there exists a compelling need to specify the brand-name Tyco/Commscope connector in the requested modules.

The estimated cost does not exceed the simplified acquisition threshold, thus the authority in FAR 13.106-1(b)(1) is cited.

6. Publicizing Contract Actions: For FAR Part 13 actions, the public display and synopsis requirements of FAR 5.101 and FAR 5.203 do not apply due to the $ threshold, apply and will be followed, or do not apply due to an exception at

5.202 (a)(06) .

Requirement to post justification in accordance with FAR 8.405-6(b)(3), FAR 13.105(c), or FAR 16.505(a)(4)(iii)(A)

Action is NOT a brand name restriction and is under $150K, no posting required

Action is a brand name restriction, under $25K, no posting required Action is a brand name restriction, over $25K. It will be redacted and posted with the solicitation.

Action is a brand name restriction over $25K but will not be posted due to exception:

FAR 6.305(f) FAR 8.405-6(b)(3)(iii)(A) FAR 8.405-6(b)(3)(iii)(B) FAR 8.405-6(b)(3)(iii)(C) FAR 16.505(a)(4)(iii(C)

7. Market Research:

Upon receipt of the ARSOUTH G6 requirement package for Keyed Fiber Modules it was determined the requirement contained a specification for a cable connector that is proprietary to a single manufacturer, Commscope/Tyco.

The ARSOUTH G6 requirement package contained the results of their market research, which indicated the existence of two vendors capable of manufacturing and delivering the modules: and

When questioned about the brand-name connector type, ARSOUTH G6 stated the connector is required in order to remain compatible with the existing connectors and patch cables already in use in the network. ARSOUTH G6 further stated they were unaware of any ‘generic’ Commscope/Tyco connectors available in the marketplace.

The Contract Specialist (KS), placed a Request for Information (RFI) on the CHESS website seeking sources that could provide the requested keyed fiber modules, either with the Commscope/Tyco connectors or with a generic version meeting identical specifications. The RFI was posted on 5 Feb 19 and ended on 8 Feb

19. Eight of the ITES-3H vendors responded negatively. The remaining nine vendors did not respond at all.

The KS researched the issue online and found no evidence of the existence of a ‘generic’ version of the Commscope/Tyco connector.

The Contracting Officer (KO) emailed and to enquire whether they were registered in SAM. replied in the affirmative. replied they would research the issue and have not responded again.

The KS posted a Sources Sought notice on FBO.gov requesting interested vendors contact the KS and KO with their capability to provide the requested modules, either with the Commscope/Tyco connectors or with a generic version meeting identical specifications. The Sources Sought was posted 15 Feb 19 and closed 20 Feb 19. The KS emailed and to advise them of the posting. By the closing of the Sources Sought, the sole response was from response indicated that there is no generic version of the Commscope/Tyco connector. independently confirmed the ARSOUTH G6 assertion that connector types should be kept the same within a network. advised they can manufacture and deliver the modules with the requested connector type.

AR 25-1 states that all IT hardware and software must be purchased through CHESS.

Upon receiving zero interest from the RFI posted on CHESS, the KO contacted the CHESS helpdesk to enquire whether this specific hardware must be purchased on CHESS. The helpdesk responded that this module is out of scope of CHESS and may be purchased outside of CHESS.

The KO intends to post a Request for Quote on FBO.gov for the requested keyed fiber module with the brand-name requirement for the Commscope/Tyco connector.

8. Other Facts: N/A

9. Technical/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.

Typed Name:

Date: 21 FEB 2019 Title: ARSOUTH G6 Network Engineer Signature:

10. Contracting Officer Certification/Approval:

I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable based upon IGCE and Competition

I certify that this justification is accurate and complete to the best of my knowledge and belief, and that completing this purchase as a Brand Name purchase is in the best interest of the Government. Additionally, I approve this justification to limit competition subject to the availability of funds and provided that the supplies herein described have otherwise been authorized for acquisition.

Typed Name:

Date: 21 FEB 2019 Title: Contracting Officer

Signature: