04.06_LSJ_Redacted.pdf

OFFICE OF ACQUISITION MANAGEMENT

ICE Acquisition Manual 3006.301-90

LIMITED-SOURCES JUSTIFICATION

ORDERS OR BPAS EXCEEDING THE SIMPLIFIED ACQUISITION THRESHOLD

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4. Authority and supporting rationale and a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

Authority:

Select only one of the following circumstances justifying limiting sources pursuant to FAR 8.405-6(a)(1)(i) below and demonstrate the proposed contractor’s unique qualifications to provide the required supply or service.

8.405-6(a)(1)(i)(A) An urgent and compelling need exists, and following the ordering procedures would result in unacceptable delays.

8.405-6(a)(1)(i)(B) Only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

8.405-6(a)(1)(i)(C) In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order provided that the original order was placed in accordance with the applicable Federal Supply Schedule ordering procedures. The original order or BPA must not have been previously issued under sole-source or limited-sources procedures.

Rationale:

ICE/OAQ intends to procure software support services for the Horus system pursuant to the authority selected above.

Task Order 70RSAT20FR0000147 was awarded to Noblis against DHS Systems Engineering Technical Assistance (SETA) III Indefinite Delivery/Indefinite Quantity Contract 70RSAT19D00000003. We are currently receiving these services through this task order.

ICE is not authorized to place orders against this vehicle; as a result, ICE will utilize Noblis’ FSS for augmentation and operations and maintenance (O&M) support services.

Under Task Order 70RSAT20FR0000147, awarded to Noblis against DHS Systems Engineering Technical Assistance (SETA) III Indefinite Delivery/Indefinite Quantity Contract 70RSAT19D00000003, the Horus software, which serves as a platform for the Janus algorithm was developed and integrated into the ICE HSI Innovation Lab Repository for Analytics in a Virtualized Environment (RAVEN). This was done with subject matter expertise from the DHS Office of Science and Technology (S&T) after an extensive evaluation of alternatives for facial identification and extraction software by DHS. The Defense Advanced Research Projects Agency DARPA and S&T conducted extensive evaluations to determine the best solution for the Department of Homeland Security. ICE is not authorized to utilize any alternate algorithms. As a result, it is in the best interest of the Government to utilize the same resources and development requirements.

The government owned Janus facial recognition algorithm was selected for integration after it was consistently highly rated, and importantly, tested by the National Institute of Science

LIMITED-SOURCES JUSTIFICATION

- 3 -and Technology (NIST). DHS S&T has also invested over $1,000,000 integrating the Noblis software suite incorporating the Janus algorithm into the complex RAVEN platform with the Innovation Lab and has conducted over nine upgrades to the software to date within

RAVEN.

Development of the proprietary software included creating a unique user interface for ICE customers based on extensive interaction with HSI Agents and Analysts, integrating with RAVEN security, auditing, file mapping and messaging services and collaborating with multiple forensic offices in the Government including the DHS Office of Biometric Identity Management, Federal Bureau of Investigation and the DoD Defense Forensic Science Center.

Noblis is uniquely qualified to continue to provide operations, integration, and enhancement support of the Horus software to the HSI Innovation Lab. The vendor has unique and extensive experience with the Government Off the Shelf (GOTS) Janus algorithms (7+ years) and designing, developing & integrating the Horus platform (3+ years) for U.S. Government partners.

Through Research, Development, Test, & Evaluation (RDT&E) support to DHS S&T, under Task Order 70RSAT20FR0000147, Noblis developed a unique technical understanding for how Horus, the Janus algorithms, the RAVEN / Innovation Lab environment, and the operational end users of ICE HSI work together. This combination is a substantial benefit to Government and reduces risk of schedule delays and higher costs associated with onboarding a team not familiar with the algorithms/technology, the Horus platform, the RAVEN infrastructure, processes, and team, and most importantly the operational users and needs.

The unique experience and expertise provides low-risk and value-add services to deliver operational and enhancement support for the Horus software to the Innovation Lab and HSI operational users.

Some of the Horus capabilities ICE currently utilizes and requires moving forward were developed Task Order 70RSAT20FR0000147. ICE will not be placing an order against that contract and will utilize Noblis’ FSS for augmentation and operations and maintenance (O&M) support services.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with FAR 8.404(d).

The contracting officer has determined that issuing a task order to Noblis Inc. for software services represents the only viable option to support the complex Horus software and Janus integration into RAVEN due to the unique and highly specialized services required and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs.

This order will be placed in accordance with FAR 8.404, “Use of Federal Supply Schedules.”

The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates. Discounts to these GSA schedule rates will be requested. Additionally, prior

LIMITED-SOURCES JUSTIFICATION

- 4 -to issuance of the task order, the ordering activity will consider the level of effort and the mix of labor proposed to perform the specific task being ordered in order to determine that the total price is reasonable. The contractor’s labor mix and level of effort will also be compared to the Independent Government Cost Estimate (IGCE).

6. A description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

HSI interfaced with DARPA and S&T regarding the initial selection of the Janus Algorithm and Noblis to develop the systems required to integrate into the RAVEN platform. DARPA and S&T conducted extensive evaluations to determine the best solution for the Department of Homeland Security. ICE is not authorized to utilize any alternate algorithms. As a result, it is in the best interest of the Government to utilize the same resources and development requirements. As this is a proprietary Government Off the Shelf System (GOTS), only Noblis has the required expertise to provide these services. A review of GSA MAS IT schedules showed that no other commercial Federal Supply Schedule vendors have the required, specialized experience needed to continue the development of this system.

7. Any other facts supporting the limited-sources justification. Additional facts may be stated in this section. If there are no additional facts, you must state that here.

HSI is currently receiving these critical development and maintenance services through Task

Order 70RSAT20FR0000147 against DHS Systems Engineering Technical Assistance (SETA) III Indefinite Delivery/Indefinite Quantity Contract 70RSAT19D00000003. This current task order, 70RSAT20FR0000147 was awarded to Noblis Inc. on September 25, 2020 through full and open competition.

The Horus system is in a critical stage in the development process. There are multiple dependencies on the Horus system which would critically affect ICE’s ability to conduct its investigative mission. To proceed with the development and deployment of the system, ICE needs to ensure that the system will be maintained in accordance with strict security and operational requirements, as defined in the current requirement’s Statement of Work (SOW).

Currently, ICE does not have the in-house expertise to ensure these standards are maintained.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made.

ICE will continue to evaluate facial recognition algorithms and software user suites in an analysis of alternatives from commercial and government sources with the assistance of the DHS S&T. When an alternative viable and cost-effective facial recognition tool suite is available, the services from Noblis, Inc will no longer be required and the need for any subsequent limited source acquisition to this vendor will be eliminated.

9. DHS intends to post this requirement on the Government Point of Entry (GPE)

SAM.gov pursuant to FAR 8.405-6(a)(2).