Request
Action: Notice, request for comments.
Web posting date: 04/06/2011
Federal Register Notice of Finding Publication Date:
08/02/11
Effective Date of Federal Register:
08/03/11
Close of public comment period:
08/18/11
Summary:
The Federal Highway Administration (FHWA) is seeking comments on whether a waiver of the Buy America requirements of 23 CFR 635.410 should be granted to permit the use of non-domestic RuggedCom RS900G, RS800L, and RS930L network controllers in the state of Oregon.
FHWA will only consider a Buy America waiver when the conditions of 23 CFR 635.410( c) have been met: (1) when the application of the provision would be inconsistent with the public interest; or (2) when steel and iron products are not produced in the United States in sufficient and reasonably available quantities, which are of a satisfactory quality.
The FHWA will consider all comments received in the initial 15-day comment period during our evaluation of the waiver request. Comments received after this period, but before notice of our finding is published in the Federal Register, will be considered to the extent practical. Follow-up coordination on the comments received may result in a delay in the publication of our waiver finding in the Federal Register. Comments received during the 15-day comment period after notice of our finding is published in the Federal Register will be reviewed, but the finding will continue to remain valid. Comments received during the comment period after the effective date of the finding will be reviewed, and may influence the FHWA's decision to terminate or modify a finding.
Oregon State DOT contacts: William Edmunson (503)641-8712 ext. 254, William.E.EDMUNSON@odot.state.or.us; Doug Spencer (503)856-6528, Doug.L.SPENCER@odot.state.or.us
Comments
| Megan Manjerovic 04/07/2011 |
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From the research that I have done, it seems like there is a company called Optelecom-NKF, that makes similar products and most of their products are made right in Maryland. If they have a product that is comparable then we should Buy American where possible!
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| john papandrea 04/11/2011 |
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It is requests for waivers such as this that facilitate off-shoring by vendors who find it more profitable to out-source in low wage countries. This shortchanges our government in many ways, as choices for future purchases are reduced. Government spending should be 'percolating' through local economies with local workers and business returning taxes to the treasury. Instead, business are idled and millions are unemployed with much collateral damage to families and communities. Every job counts. There is no rocket science in the manufacture of these cabinets, nor should they have to travel thousands of miles to get here. They should be made locally in the USA.
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| Eric Anderson 04/12/2011 |
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From my experience and understanding the RuggedCom switches are the most durable and long lasting outdoor rated switches on the market. As much as it is important to buy American products for our economy, it is also important to buy the most cost effective and lasting products in order to use our tax dollars wisely.
Is it worth spending the same amount of money on an American switch that malfunctions after only a few years causing the system it was meant to support to shut down, when a more dependable foreign switch could have been purchased?
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| Doug Spencer 05/02/2011 |
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In response to Megan Manjerovic's comment, the Oregon Dept. of Transportation has Optelecom-NKF video equipment. Though they have a sales staff in Maryland, I believe their equipment is manufactured in Europe. Regardless, I believe the issue is the amount of foreign steel used on the project and not where the equipment was assembled. ODOT issued a Request for Proposal for industrial networking equipment for traffic signal and Intelligent Transportation Systems. Optelecom-NKF did not bid. Unfortuantely, IT equipment (PC's, servers, routers, switches, firewalls, etc.) these days are assembled with parts that come from Asia. Even if the IT supplier is a US company, until you ask them to complete a Certificate of Material Origin do you know for sure if they use foreign steel and the US dollar amount.
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| Doug Spencer 05/02/2011 |
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In response to John Papandrea's comment, I think Mr. Papandrea is commenting on the original posting by FHWA that inaccurately reported that ODOT was seeking a waiver for steel traffic cabinets. This is not the case. ODOT is only asking a waiver for networking equipment.
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| Doug Spencer 05/02/2011 |
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In response to Eric Anderson's comment, I agree that the state should be considering the life cycle costs of ownership. The Oregon Dept. of Transportation manages thousands of networked field devices with a limit staff and budget. We cannot afford, operationaly or financially, to allow this equipment to fail. It is imperative that network equipment used outdoors in support of Intelligent Transportation Systems meet the same performance standards and specifications as the traffic signal controllers they communicate with.
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