Repair Electrical System on Alcatraz Islands, Golden Gate National Recreation A

JUSTIFICATION AND APPROVAL FOR OTHER THAN FULL AND OPEN COMPETITION

Over $150,000 (FAR 6.303-2)

PR Number 004048871

1. Identification of the Agency and the Contracting Activity:

Agency: Department of Interior/National Park Service

Contracting Unit: National Park Services, Interior Regions 8, 9, 10, and 12, Golden Gate Major

Acquisition Buying Office

2. Nature and/or Description of the Action Being Approved: Award to only one responsible

source (Alcatraz Island Services, LLC) for Repairs to the microgrid electrical system on Alcatraz

Island, San Francisco County, California.

3. A Description of the Supplies or Services Required to Meet the Agency¿s Needs, Including

the Estimated Value:

a) Total estimated Value: $XXXXXX

b) The work consists of system evaluation/troubleshooting/tuning and repairs to the stand alone

microgrid on Alcatraz Island. Components requiring repair include EMOS (Energy

Management Operating System) and BMS (Battery Management System) tuning, 2 system

generators, generator priming systems, 8 system inverters, photovoltaic panels, system

wiring/conduit and numerous safety improvements.

4. An Identification of the Statutory Authority Permitting Other Than Full and Open

Competition:

FAR 6.302-1 Only one responsible source and no other supplies or services will satisfy agency

requirements.

5. A Demonstration That the Proposed Contractor¿s Unique Qualifications or the Nature of

the Acquisition Requires Use of the Authority Cited:

Alcatraz has one of the largest stand alone microgrid systems in the United

States https://www.energy.gov/eere/articles/welcome-alcatraz-one-largest-microgrids-unitedstates.

This microgrid system has been in operation since 2012 and has no power connection to

the mainland. The system is complex and work on it is highly technical. Each element -- the

generators and their controller modules/priming systems, the inverters associated with the battery

and PV components, and the EMOS (Energy Management Operating System) that monitors and

switches between PV, battery and generator power. Alcatraz Island Services (AIS) has

maintained the system since 2012 under a Preventative Maintenance and Custodial contract and

worked with Princeton Power Systems as the subcontractor responsible for the inverters and

proprietary EMOS controller system. AIS was again awarded the Preventative Maintenance and

Custodial Contract in November of 2018 and expanded their knowledge base and relationship

with Princeton Power Systems (PPS). In late 2018, the battery system failed and was replaced by

AIS, who also held an IDIQ contract for repairs to the various island systems. At that time it was

noted that the remaining system components were also demonstrating significant age related

distress.

In late summer of 2019 PPS filed for bankruptcy and liquidated a number of their proprietary

system components to AIS. Additionally, they entered an agreement with Shawn Terrell,

previously employed by Princeton, to have exclusive rights to Princeton proprietary information

including manuals, technical drawings, wiring diagrams, test results and software/firmware. This

License Agreement made this company, Off Grid Electric (OGE), the exclusive provider of repair

services for Princeton Power Systems Equipment. AIS, by virtue of their purchased proprietary

PPS system parts, their exclusive contractual relationship with OGE for repair work on the

system and their extensive experience with coordinating system maintenance for over 8 years, is

the only responsible vendor to carry this work forward.

OGE informed the National Park Services that they were not currently offering services directly

to government institutions. Being a small company, they did not have the bandwidth to deal with

the bureaucracy of government contracts. OGE recommended we work with AIS as they had the

parts to replace the microgrid system and OGE only provides the support to AIS.

6. A Description of Efforts Made to Ensure That Offers Are Solicited From as Many Potential

Sources as is Practicable, Including Whether a Notice Was or Will Be Publicized as

Required by FAR Subpart 5.2 and, If Not, Which Exception Under FAR 5.202 Applies:

On June 9, 2020, the Contracting Officer posted a Source Sought on beta.SAM. The purpose of

the notice was to obtain information regarding the availability and capability of all qualified

sources to perform a potential requirement. Responses to the information would assist the

Government in determining the appropriate acquisition method. On June 15, 2020, the Sources

Sought closed with no responses received.

In accordance with FAR part 5.203, Publicizing and Response Time, ¿Whenever agencies are

required to publicize notice of proposed contract actions under 5.201, they must proceed as

follows:

(a) An agency must transmit a notice of proposed contract action to the GPE (see 5.201). All

publicizing and response times are calculated based on the date of publication. The

publication date is the date the notice appears on the GPE. The notice must be published at

least 15 days before issuance of a solicitation, or a proposed contract action the

Government intends to solicit and negotiate with only one source under the authority

of 6.302¿

No Exceptions under FAR 5.202 apply to this requirement, therefore, IAW FAR Subpart 5.2 a

notice of intent to award a sole source contract will be posted for 15 calendar days. Any responses

received will be considered before an award is made.

7. A Determination By the Contracting Officer That the Anticipated Cost to the Government

Will Be Fair and Reasonable: The Independent Government Estimate was created based on the

labor categories from a previous IDIQ 140P8618D0004 for Alcatraz Island Repair Services that

included costs for electricians, heavy equipment mechanic, general maintenance worker, and

pipefitter. Once pricing is obtained from the prospective contractor the government will review

to determine fair and reasonable over the level of effort required for the completion of work under

the contract.

8. A Description of the Market Research Conducted (see FAR Part 10) and the Results or a

Statement of the Reason Market Research Was Not Conducted:

A Sources Sought was posted on beta.SAM on June 9, 2020 with a closing date of June 15, 2020.

The purpose of the notice was to obtain information regarding the availability and capability of

all qualified sources to perform a potential requirement. Responses to the information would

assist the Government in determining the appropriate acquisition method. On June 15, 2020 no

responses were received from the Sources Sought.

Off Grid Electric (OGE), is the only subcontractor able to work on the EMOS (Energy

Management Operating System, the computerized microgrid system controller) and elements of

the system inverters. OGE is comprised of a former employee from Princeton Power Systems, the

now bankrupt firm that developed the controller hardware/software. Alcatraz Island Services also

holds a contract for Preventative Maintenance and Custodial services and OGE are currently

subcontracted to them for the preventative maintenance of the electrical system. As a result of

this exclusive contractual agreement between AIS and OGE, OGE is prohibited from

subcontracting out to another prime contractor for work on the island¿s microgrid system.

Therefore the only method of procuring the services of OGE is through AIS as the prime

contractor.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition (see FAR

6.302-2 (9) (i) ¿ (iii) for some examples

In October of 2019, the system experienced a failure which required that it be taken off of EMOS

control and power provided exclusively by the 2 system generators. On January 26, 2020, the

system generators failed and an emergency generator was mobilized. As a result, Alcatraz Island

is currently running on a single source of power via this temporary rental generator. In systems

without a direct connection to the mainland power grid, it is never recommended to operate

without a second backup power generation system in place. The island's life safety based

systems, in the form of fire alarms/suppression must be maintained at all times. Additionally, the

lighthouse is tied into the island's electrical system, is a USCG aid to maritime navigation and

must be maintained to ensure maritime safety on San Francisco Bay.

10. A Listing of the Sources, If Any, That Expressed in Writing, an Interest in the Acquisition:

No sources expressed interest for this acquisition when the Source Sought was posted on June 9,

2020.

11. A Statement of the Actions, If Any, the Agency May Take to Remove or Overcome Any

Barriers to Competition Before Any Subsequent Acquisition for the Supplies or Services

Required: In order to make this repair work competitive, the next contract for the microgrid

system that system software is non proprietary and that and system components can be readily

purchased from a variety of sources. Awarded contract 140P8620C0017 to unknown vendor for unknown amount on 2020-09-23.