Direct Drive Generator

Waiver Rationale Summary

The original Utility Energy Service Contract task order Scope of Work required the replacement of three (3) existing 225 kilowatts (kW) wind turbine generators with three to five (3–5) new 500 kW wind turbine generators located at San Clemente Island, CA. SoCalGas faced challenges locating available American-made wind turbines that could meet the task order requirements, which necessitated acquisition of wind turbines that could be erected on a remote island such as San Clemente Island. After intensive research and discussions with different wind turbine suppliers, SoCalGas determined that two (2) 900 kW wind turbine generators would be sufficient for San Clemente Island’s power needs. However, it was determined that EWT Americas, Inc. was the only source that could provide the wind turbines to meet San Clemente Island’s power needs. Subsequently, EWT Americas, Inc. made its new one (1) Mega Watt (MW) wind turbines available for production, which included parts that were presumably Trade Agreement Act compliant. The customer preferred these newer models and NAVFAC SW concurred. However, after task order award, it was discovered that EWT Americas, Inc.’s product includes a small portion of parts, the direct drive generators, sourced from China. The source of the direct drive generators was not disclosed prior to award and was not known until receipt of the Procurement Product Plan on June 17, 2024.