Comment on FR Doc # 2026-12560
Roger WestermeyerSupportOther
Summary: The commenter, likely a government employee or contractor involved in defense acquisition, argues for an exception to full and open competition for "enterprise" requirements. They contend that standardizing equipment like HVAC systems and IT across the DoD reduces total cost of ownership, simplifies maintenance, and improves cybersecurity.
In Part 6 there needs to an exception to full and open competition for "enterprise" requirements that provide a standard solution across a large enterprise such as the United States Air Force or DoD. Examples include equipment supporting installations like generators, HVAC systems and chillers, Fire Alarm systems, Land Mobile Radios (LMRs) and their networks, as well as laptops, PCs, etc.
Study after study has shown that standardizing equipment like this across installations reduced total cost of ownership though savings in maintenance, training of technicians, supply chains, and leverage buys. Across dozens of acquisition reports over the past two decades, GAO repeatedly identifies excessive customization as a contributor to: higher sustainment costs, fragmented contracts, duplicate inventories,
increased training requirements, additional software baselines, higher maintenance costs, and reduced buying leverage
GAO generally recommends: common requirements, standardized specifications, category management, enterprise acquisition strategies and common configurations
Additionally, Office of Management and Budget's Category Management guidance promotes standardized requirements to leverage government-wide buying power. Further, Defense Acquisition University guidance on Total Ownership Cost explicitly states that commonality and standardization reduce logistics, maintenance, training, and support costs.
Standardizing IT also reduces cyber-security risks, which is a major concern.
Currently we have contracting officers competing these requirements individually because there is not a CICA exemption they can easily use, resulting in installations having a mosaic of systems on installations making it difficult and costly for civil engineers to maintain and for communicators to protect.