WON1674991_JA DDC_CON-22-001_Redacted.pdf

JUSTIFICATION AND APPROVAL FOR

OTHER THAN FULL AND OPEN COMPETITION

1. Contracting activity.

Naval Facilities Engineering Command Marianas

2. Description of the Action Being Approved.

Work Order Number 1674991, P-052 Guard Army National Guard (GUARNG) Readiness Center at Barrigada Guam will specify the Direct Digital Controls (DDC) system for the HVAC system by brand name “Delta”, which will not provide for full and open competition. The brand name description is essential to the activity’s requirements, thereby precluding consideration of a product manufactured by any other company.

3. Description of supplies/services.

GUARNG compound currently uses the brand “Delta” and the use of other brands are incompatible with the compound’s central Energy Management Control System. In addition, this action will ensure standardization of cybersecurity requirements and installation wide HVAC services contract.

The estimated cost for the DELTA DDC system is . This total cost comprises of the total project cost of . A DDC system comprises of software and hardware equipment; a central computer workstation, and programmable logic controllers that are networked to various HVAC system sensors and other building lighting systems in order to monitor, control, and automate functions of the building’s mechanical and electrical systems. Additionally, DDC systems collect data in order to measure variables within the building, such as the temperature, humidity, energy usage, etc., which allows the operator in real-time, to respond to issues quickly and increase system efficiency.

4. Statutory Authority Permitting Other Than Full and Open Competition:

This request is submitted pursuant to Title 10 U.S.C. 2304(c)(1); FAR 6.302-1 - Only one responsible source and no other supplies or services will satisfy agency requirements.

5. Rationale Justifying Use of Cited Statutory Authority.

GUARNG has a reasonable need for standardization and interoperability of its existing building control systems that will require a connection to the compound’s central Energy Management Control System

(EMCS).

It requires that the Direct Digital Controller be Delta brand name in order to:

a. Maintain a single, area-wide energy management system so that all controllers can be programmed from a single central station versus a hybrid system composed of many different controllers and associated configuration/programming software. This will further increase operational efficiency and decrease installation, maintenance, repair, and energy cost. Utilizing hardware products from the same brand name, Delta, that produce the configuration/programming software eliminates disputes regarding incompatibility, conflicts, standards, protocols, or performance characteristics should the controller not function as required.

a. Although the BACnet open protocol is the required communications protocol per UFGS 23 09 23.13 20, and for all manufacturers' controllers, it only allows for different manufacturer’s equipment to share basic point data. It does not allow for configuration and programming functions to take place between different manufacturers' controllers.

Each manufacturer’s proprietary software tools must be used to configure or change the program within the controller. Therefore, programing and configuring controllers alike increases operational efficiency and decreases installation costs.

b. Henceforth, Delta hardware and software products are required to fully program, configure, and operate the system at a sustainable operational efficiency.

b. Avoid the significant burden of having maintenance and engineering staff become proficient with the configuration, programming, commissioning, operation, and maintenance of equipment from different manufacturers. This would also require additional personnel training costs and the procurement of additional equipment, maintenance and support contracts for another manufacturer’s hardware and software, as well as the maintenance of an additional parts inventory. Maintaining multiple solutions is inefficient and creates unnecessary work and unproductive or low-value-added overhead, which increases the total cost of ownership and manpower cost.

c. Establish and maintain a defensible cybersecurity posture. The rapid emergence of cyber incidents on critical Industrial Control systems, which include Facility Related Control Systems (FRCS), with the potential to debilitate our installation mission critical assets has catalyzed the need to establish a defensive cybersecurity posture across the shore enterprise. DoD Instruction

8500.01 requires that all Platform Information Technology (PIT) systems, (Control Systems such as networked FRCSs) have their cybersecurity controls documented and validated prior to operation and/or deployment. When connected to local EMCS and RMF is pursued per DoD Instruction 8510.01, non-conforming hardware or software added to the local EMCS will increase cybersecurity risk and costs associated with changes to the security posture. Therefore, standardizing programmable controllers is beneficial to maintaining a defensible cybersecurity posture.

a. Per NAVFACINST 11000.2 Facility Related Control System Standardization dated 3Jun19, referencing UFC 4-010-06 19 Sep16 and DoDI 8510.01 Department of Defense Information Risk Management Framework for DoD Information Technology 28 July 17, all Navy and Marine Corp installations for all new construction and renovation projects going forward, standardize FRCS per function and eliminating disparate systems in order to improve cybersecurity, increase operational effectiveness and consistency and reduce ownership costs by eliminating multiple disparate systems and associated authority to operate certifications, and achieve maintenance efficiency by eliminating duplicative training, parts, certificates and support contracts.

b. All efforts referenced in NAVFACINST 11000.2 are aligned with the factors stated in this J&A for standardization of programmable logic controllers.

d. Currently the GUARNG compound has nine (9) operational buildings utilizing Delta programmable logic controllers, operated and maintained under a single service contract.

Additional two (2) new construction projects are currently in design and GUARNG requires that programmable building controller to be Delta in order to meet interoperability with existing equipment and software, and achieve the benefits of standardization. The cost of the programmable building controllers for this new construction projects represents 1.5% of the project cost and is a miniscule percentage of the total cost. Assuming other brand name controllers could be integrated into the compound’s EMCS, so as to be fully functional, the cybersecurity risks, operational and maintenance challenges and other disadvantages arising from different brands of controllers are substantial costs not expected to be recovered through competition.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

A sources sought notice was published on www.SAM.gov on 14 April 2022 with a response date of 28 April 2022. It was determined that no other product other than the “Delta” brand could address the GUARNG’s requirement of connecting to exiting DDC system. The Government prepared a technical evaluation report (enclosure (1)), reporting inconclusive results. No companies have been identified in the market capable of connecting Delta Controls to an existing DDC system. One (1) contractor, , responded to this published sources sought. merely provided a copy of their company’s capabilities profile, company resume with past projects and company brochure of their capabilities and company ratings. Additionally, the contractor provided a list of projects, demonstrating a variety of projects completed. Overall, did not provide information of their capabilities regarding the published requirement of connecting Delta Controls to an existing DDC system. Based on the sources sought published, it is determined that no other available companies and/or brand, other than Delta, displays the technical capability to provide direct digital controllers that utilize or integrate seamlessly with the existing Delta Control software for their configuration/programming and to maintain Department of Defense cybersecurity requirements.

7. Determination of fair and reasonable cost.

The Contracting Officer has determined the anticipated costs to the Government of the supplies/services covered by this justification will be fair and reasonable based on adequate price competition that exists through market research results and the expectation of at least two responsible offerors, competing independently, will submit offers.

8. Actions taken to remove barriers to competition.

Although the utilization of a brand name in this project is indicated by this J&A, each future project that includes DDC systems, outside of the one year of the approval of this J&A, will conduct the same market survey to ascertain the availability of new technology that may provide for other sources to meet the Government’s needs. Should any other offers for compatible transmitters be submitted during the source selection process, the Government will consider each as applicable.

CERTIFICATIONS AND APPROVAL

TECHNICAL AND REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this justification and its supporting Acquisition Plan and which form a basis for this justification are complete and accurate. [FAR 6.303-2(b)]

Technical Cognizance:

Phone Date

Requirements Cognizance:

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient

CONTRACTING OFFICER CERTIFICATION/APPROVAL

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