04_ID07210009_Redacted Exception to Fair Oppty Final Signed 12.21.20.pdf

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T-6, C 130 support AFLCMC has a mission to provide LCMP-IDE
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Justification for an Exception to Fair Opportunity

1) Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for an Exception to Fair Opportunity.”

Procurement Office Agency: General Services Administration, Federal Acquisition Service, Assisted

Acquisition Services Division, Region 7

Task ID: ID07210009 Description of Requirement: United States Air Force (USAF) T-6 and C-130 Weapon Systems

Program Offices (PO) Information Assurance (IA), Mission Assurance (MA), and information/mission systems security improvements

Total Estimated Value of the Action: $18,434,030.72

Period of Performance (PoP): One (1) 1-Year Base Period and Four (4) 1-Year Option Periods, 19

January 2021 – 18 January 2026

Vendor Name: Booz Allen Hamilton, Inc.

Procurement Vehicle: GSA Alliant 2 Government-Wide Acquisition Contract (GWAC)

2) Nature and description of action being approved:

Upon approval to use the exception to fair opportunity procedures of FAR 16.505, GSA will enter into a task order under the GSA Alliant 2 GWAC contract with Booz Allen Hamilton, Inc. (BAH) to procure continued support for Information Assurance (IA), Mission Assurance (MA), and information/mission systems security improvements to Airborne and Ground systems/platforms involving secure systems, mechanical, structural, electrical, aerospace engineering, and technical research/analysis in support of the T-6 and C-130 Weapon Systems POs, located at Tinker AFB and

Robins AFB. BAH, Cage Code 17038, is located at 8283 Greensboro Drive, McLean, Virginia 22102.

This severable, non-personal services task order is anticipated to be Time and Materials (T&M).

Initially, it is anticipated that all labor will fall under the T&M Contract Line Item Number (CLIN) due to the fact that it is not possible to reasonably estimate usage at the time of task order award. Before the exercise of each option period, burn rates will be researched to determine if any level or predictable labor usage could be moved to the FFP Labor CLIN. Travel and Other Direct Costs (ODCs) will allow for necessary ancillary services.

3) A description of the supplies or services required to meet the agency’s needs (including the estimated value):

Under this effort, the vendor will provide Information Assurance (IA) Mission Assurance (MA) and information /mission security improvements to ground/airborne systems and platforms. Support will encompass securing subject matter expertise and functional area support for data management systems and lifecycle management programs, strategic planning and IA/MA analysis, capability gap and requirements, vulnerability, authenticity and continuity assessments of IA/MA systems and studies and analysis.

For the C-130 program the vendor will develop workforce development and training programs and provide program support services for Lifecycle Management Process – Integrated Data Environment

(LCMP-IDE) sustainment, compliance, infrastructure support, software maintenance and support, user support, LCMP-IDE applications system analysis and on site SME support.

DocuSign Envelope ID: 5E11D63C-B427-4DAE-BEE7-C96681870CDD

For the T-6 program the vendor will provide program support services for secure data management systems and life cycle management programs. They will further conduct LCMP sustainment to include compliance, infrastructure support, software maintenance and support, user support, incident response, IDE applications system analysis, and provide LCMP-IDE enhancements, In addition they will provide support to the Acquisition Tracking Module, provide Air Force Form 1067 enhancements, assess the vulnerability, authenticity and continuity of IA/MA systems and conduct research and analysis to assist the T-6 PO in it assessment of priorities and strategies for strategic planning, interoperability and secure architectures in its fielding of IA/MA capabilities. Optional tasks in support of the T6 program include mission execution through strategic planning and IA/MA analysis and analyzation and identification of

IA/MA capability gaps and requirements

Necessary support for the T-6 and C-130 Weapon Systems POs platforms includes and is greatly dependent upon BAH’s LCMP-IDE system which is a highly integrative program management tool and software system that provides a detailed chronology of known and forecasted events in the lifecycle of the different aircraft platforms for the Air Force (AF). Additionally, the system provides for tracking and supporting program management processes across the acquisition, modernization, and sustainment phases of the aircraft platform lifecycles. LCMP-IDE has become a standard tool across multiple AF organizations and is currently used by thirty-six (36) AF organizations/divisions including, but not limited to, LCMP Propulsion Directorate, E-4B (AFLCMC/HBS), Battle Management PEO

(AFLCMC/HB), E-6B, C-40B/C PIT (AMC), C-4B/C PIT (AFRC), C-37A/B, C-32A, KC-135, E-4

NAOC/MCC, B-52H (AFLCMC/WVV), B-1, EW IA Support, C-130, B-52H CERP, KC-46, SMC, AFLCMC, T-6 Trainer Aircraft (AETC 37 FTS), KC-10, IUID, AFLCMC IT/XZZ, PDM, FHOL, Open Skies, T-6 Supply Chain, and C-21A.

LCMP-IDE includes the full spectrum of programmatic, engineering, financial analysis, Long Range

Planning (LRP), complex data visualization, and logistics process management/visualization at all levels within the system execution and management construct. Continued support also includes testing, Certification & Accreditation (C&A) of LCMP-IDE software, and system sustainment to maintain system software to Department of Defense (DoD) Risk Management Framework (RMF) standards.

LCMP-IDE is a high priority Air Force leadership and is crucial for risk management of the T-6 and C-

130 Weapon Systems POs aircraft platforms. Collaborative design and adoption of system capabilities across multiple aircraft platforms allows for a standardized, process-driven operation of each individual

PO, while allowing the opportunity for cross-leveraging of feature sets. LCMP-IDE consists of a unique architecture that allows significant Government cost avoidance through the reuse of modules.

Modules are procured by one organization and then employed across the LCMP-IDE user community.

This unique architecture allows consistency of functional processes, while allowing customization for each organization’s uniquely configured adaptation of LCMP-IDE. The LCMP-IDE application must continue to be a flexible program, data, and asset management environment for a wide range of DoD organizations, all utilizing the shared framework to realize significant cost avoidance. Each LCMP-IDE module is made available to all organizations needing access to the model without incurring additional development costs. As a safeguard, although modules are made available, the information input from each organization in their respective version of the module is partitioned to safeguard sensitive information. The LCMP-IDE architecture allows for this partitioning of data to ensure data is not leaked from one organization’s application to another, while maintaining the capacity to share capabilities and logic across multiple organizations.

The estimated award date will be in the first quarter of 2021 (as early as possible, but no later than

January 15, 2021) and the task order Period of Performance (PoP) if all four option periods are exercised will be 19 January 2021 through 18 January 2026. The task order will include a one-year base period, four one-year option periods, and one six-month optional extension. A five year task order is in the best interest of the Government to minimize the cost and efforts necessary to re-accomplish a recurring task order while sustaining T-6 and C-130 Weapon Systems POs platform support including

LCMP-IDE, which requires specialized expertise and knowledge.

4) Identification of Statutory Authority Permitting a Fair Opportunity Exception:

FAR 16.505(b)(1)(i) requires the Contracting Officer to provide each awardee under a multiple award contract, a fair opportunity to be considered for each order exceeding $3,000 unless a statutory exception applies. The specific exceptions set forth in 16.505(b)(2) that preclude the fair opportunity process are listed below. The authority pertaining to this specific acquisition is marked accordingly.

______16.505(b)(2)(i)A) The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

__X___16.505(b)(2)(i)(B) Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

______16.505(b)(2)(i)(C) The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

______16.505(b)(2)(i)(D) It is necessary to place an order to satisfy a minimum guarantee.

______16.505(b)(2)(i)(E) For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.

_______16.505(b)(2)(i)(F) In accordance with section 1331 of Public Law 111-240 (15 U.S.C. 644(r)), contracting officers may, at their discretion, set aside orders for any of the small business concerns identified in 19.000(a)(3). When setting aside orders for small business concerns, the specific small business program eligibility requirements identified in part 19 apply

4.a) Supporting rationale for the authority cited in 4 above, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited:

BAH is the original and sole vendor responsible for the proprietary design, implementation, and maintenance of the LCMP-IDE capability, and is the only option to allow the T-6 and C-130 Weapon

Systems POs to receive uninterrupted LCMP-IDE support. BAH is the current vendor supporting this requirement and has been providing LCMP-IDE services for the AF since 2001. Over successive years, BAH developed the process for coordinating system administration, software engineering, user support, training, and system integration processes to provide holistic LCMP-IDE synergies across multiple aircraft platform systems. BAH possesses the system architects (who are the authors of the LCMP-IDE code), and their staff has the in-depth knowledge of the software and hardware components of the

LCMP-IDE application. This enables BAH to provide an immense level of support for making modifications and maintaining system functionality at the most efficient cost to the Government and without delays and mission disruptions. BAH is the only firm that can accomplish this requirement due to its expertise in providing the highly specialized modifications and unique capabilities required without duplication of cost or unacceptable schedule delays. When LCMP-IDE was implemented, the http://farsite.hill.af.mil/reghtml/regs/far2afmcfars/fardfars/far/16.htm#P399_69627

Government chose to procure an item capability, and for affordability purposes did not purchase the documentation and architecture information behind creating that capability. The Government owns the

Government Purpose Rights to the data within LCMP-IDE, but does not own the accredited operating environment, and the BAH proprietary test, development, and staging environments. This means that

BAH owns the back-end processing and development data. If procured through a different vendor, the result would be dramatic cost increases and unacceptable delays to mission schedules due to the new vendor needing to create environments, connectivity’s, certifications, approvals, modules, and functionalities of the current AF-wide LCMP-IDE environment. Also, if a new vendor is utilized, it is anticipated that it would be multiple years away from obtaining a Defense Information Systems Agency

(DISA) Certification and the necessary cloud capabilities currently possessed by BAH. There are currently nineteen (19) active AF CDAD acquisition and sustainment programs managed in LCMP-

IDE. Management of programs in LCMP-IDE allows program managers to store all status updates, risk data, correspondence, and documentation on their program page. Program managers can also generate standardized charts and graphs for Program Management Reviews, maintaining standardization across multiple AF programs.

The LCMP-IDE database is able to synergize development modules across AF aircraft platforms including VC-25, B-52H, C-32, C-37, C-40, E-4B, RC-26, C-12, and C-21. Each current operating module and any future models that are developed can be utilized by any of these programs without additional development costs. Only the costs associated with the back-end support and module tailoring would be required. This approach to providing cost avoidance and capability sharing with seamless interoperability of system capabilities cannot be provided by another vendor without significant additional costs to the Government.

LCMP-IDE is not a classified information system, but is categorized as a Data Impact Level IV system by DISA, and must comply with security requirements mandated under the Risk Management

Framework (RMF) to ensure LCMP-IDE undergoes complete application security review prior to the release of any modified or new functionality to the end user community. BAH has provided support in the certification and accreditation (C&A) process, hosting, and maintenance of the LCMP-IDE application at the DISA Defense Enterprise Computing Center (DECC), and as of July 2017, at

Amazon Web Services (AWS) GovCloud. Since the initial Department of Defense Assurance

Certification and Accreditation Process (DIACAP) approved LCMP-IDE release, BAH has developed strategies to manage evolving regulations which has provided the DoD with the most cost effective, and productive system release strategy. This strategy includes robust and highly effective maintenance operations as well. Upon transitioning to AWS, BAH successfully completed all RMF C&A requirements for a seamless transition with no downtime to LCMP-IDE users. BAH demonstrated its technical expertise with DoD computer networking requirements and LCMP-IDE system architecture by being the first vendor to successfully migrate a DoD information system to AWS GovCloud at Data

Impact Level IV. This migration greatly improved the performance reliability of LCMP-IDE; however, it would be highly difficult, costly, and time consuming for a new vendor to perform a similar function which would cause significant schedule delays.

BAH provides all LCMP-IDE clients the opportunity to share the cost of C&A for their system releases by packaging their system updates into a single BAH-executed system release, which includes updates from each of the other Government LCMP-IDE systems. Currently, LCMP-IDE supports 19 platforms and over 15,000 users. Since the Government does not own the LCMP-IDE platform, any vendor other than BAH would be required to create a new platform and then import all the Government owned data currently in the LCMP-IDE system. The time and cost for another vendor to develop, tailor, and roll out a new platform with the required functionalities is prohibitive.

BAH built and continues to maintain a proprietary test, development, and C&A environment for the

LCMP-IDE software application, equipping it with the unique ability to sustain and enhance LCMP-

IDE while providing significant savings in the form of leveraging and cost sharing. BAH has also developed a suite of proprietary support tools that are tightly integrated with the application to perform testing, version control, and manage the custom configuration of each organization’s adaptation of the site. BAH possesses highly specialized capabilities and experience specific to the T-6 and C-130

Weapon Systems POs. The integration of BAH team members with extensive T-6 and C-130 Weapon

Systems POs and LCMP-IDE experience is critical to the T-6 and C-130 Weapon Systems POs acquisition processes, financial analysis, and long range planning. These strategic processes allow greater utilization of LCMP-IDE to accomplish AF strategic goals, and incorporate advanced

Information Assurance technologies, to ensure the T-6 and C-130 Weapon Systems POs mission is accomplished as efficiently and effectively as possible throughout the lifecycle of the T-6 and C-130

Weapon Systems POs platforms. The utilization of one firm to fulfill various requirements is beneficial to the Government due to its internal processes, and allows for cross-utilization of other BAH modules with minimal cost. LCMP-IDE is required to comply with RMF standards and maintain a Government-provided Authority to Operate (ATO), which can take up to two to three (2-3) years to establish. BAH is the only supplier with the necessary understanding of how a change request is routed through the

C&A process for LCMP-IDE. They have nineteen (19) years of expertise in managing the LCMP-IDE

SharePoint site and custom ASP.net web application while remaining compliant with all applicable

DoD information technology and cybersecurity requirements. Throughout this time period, BAH has proven its expertise in developing secure and compliant code for the LCMP-IDE application.

An award to any other source would create substantial duplication of cost to the Government that is not expected to be recovered through competition, and would result in unacceptable delays in fulfilling AF requirements. If this requirement, including its necessary LCMP-IDE component, were contracted to another source, it would require that a new development, staging, and production environment be created, which would then need to go through the entire RMF C&A process before receiving an ATO.

Additionally, the over 15,000 current users would need to be certified and profiles created in the new system. Companies potentially competing for these requirements must have the knowledge and capability to review and analyze current code to understand the overarching system and architecture based on existing supporting documentation. The same review process would then be accomplished for each of LCMP-IDE's software modules. This is a lengthy process and could take up to an additional six

(6) months per module after the time required for the initial system development, driving additional program cost and potential breaks in support. A Government cost and schedule analysis for this process was completed on 7 August 2018, to assess the level of effort from a technical and labor perspective to develop and deploy a system with capabilities necessary to replace LCMP-IDE.

The analysis results indicated that if LCMP-IDE were contracted to another source, it would cost approximately $8.3M in labor, and require up to thirty-six (36) months to develop and deploy a system with capabilities to meet the AF’s requirements. The results of analysis, although obtained in 2018, are still valid in determining that the cost and time required for any new vendor to develop and roll out a new system is prohibitive, and not in the best interests of the Government. Any vendor other than BAH would also be required to continue software design, development, sustainment and enhancement capabilities once their new system was fully operational. Leveraging the software development efforts of other LCMP-IDE clients presents a significant cost savings and force multiplier for the AF, and for the T-6 and C-130 Weapon Systems POs. Under the current configuration, BAH has the ability to enable software modules developed by other LCMP-IDE clients at little to no cost to T-6 and C-130

Weapon Systems POs. In addition, their existing business arrangement and third-party licenses which took years to establish and coordinate are essential to the interconnectivity of the multiple system platforms being supported by the overarching LCMP-IDE. Since the ability to leverage is provided only by BAH, if the task order was awarded to any other source the T-6 and C-130 Weapon Systems POs would no longer be able to leverage existing modules developed by BAH in LCMP-IDE without significant additional cost. Additionally, due to the complexity of LCMP-IDE, with over 40 million lines of code, high levels of competency in the system's design and functionality are required to support the system.

Supporting LCMP-IDE requires a software development and testing infrastructure, multiple software licenses, and an RMF-certified production environment. Companies competing for these requirements would need to purchase or lease hardware, develop new test and certification software, and establish working relationships with the C&A authorities to perform these functions. Additional program cost and an increased risk of interrupted service would be incurred. In addition to the current proprietary test, development, and C&A environment, BAH has also built development, testing, staging and future architecture test beds that would have to be reproduced by another vendor to satisfy the LCMP-IDE technical roadmap requirements. Without these test capabilities, development of new features, technical refreshes, and evaluation of security patching for production releases would be at risk. In order to meet the demands of increased capabilities and a continuously growing user base, a technical roadmap is required to sustain and modify the system to ensure conformity with industry standards and multiple evolving PO requirements. Because the system is actively in use, all efforts must be designed and implemented to be non-intrusive to the existing architectures, providing backwards compatibility to ensure continuous, undisturbed system operation during the integration phase until they are fully phased out.

Based on the facts presented herein, BAH is the only vendor capable of providing the services described in this document, which involve and are dependent upon BAH’s proprietary LCMP-IDE system.

5) Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable

The cost of this acquisition will be fair and reasonable. Actions anticipated to ensure fair and reasonable pricing will be in accordance with the procedures and criteria contained in the FAR under

FAR 15.4 Contract Pricing to include technical evaluations and audits, as appropriate. The Alliant 2

GWAC contract was awarded pursuant to full and open competition and is an Office of Management and Budget (OMB) designated best-in-class (BIC) solution. Market research, including utilizing current Alliant 2 GWAC pricing tools and historic prices paid, will be utilized to ensure that the prices awarded under the new acquisition are considered fair and reasonable. Also, the Alliant 2 GWAC contractual ceiling rates will be used to evaluate the proposed price to ensure that all labor rates are at or below the ceiling rates established for the contract for BAH. This ceiling rate analysis provides assurance that any awarded labor rates will be at or below those that have already been determined to be fair and reasonable on the vendor’s Alliant 2 GWAC contract. This justification shall be posted on beta.sam.gov, in accordance with the requirements at FAR 16.505(b)(2)(ii)(D). The final Award

Decision Document (ADD) will be prepared and will contain all of the appropriate detailed documentation and justification for the fair and reasonable price decision.

6) Any other facts supporting the justification

The Government does not anticipate that more than one (1) qualified vendor is capable of providing an acceptable proposal for this requirement, as BAH is the only vendor which can offer its proprietary

LCMP-IDE system, a required component of the necessary support. In October of 2019, the E-4B/E-

6B Information/Mission Assurance (E-4B/E-6B IA/MA) task order was awarded to BAH for similar requirements involving LCMP-IDE and was previously included in the Tinker CDAD IA/MA task order. The E-4B/E-6B requirement was solicited to all OASIS U (Pool 3) vendors and received only one (1) proposal, from BAH. Additionally, when competed on Alliant in 2015, the current Tinker

CDAD IA/MA task order which included similar requirements involving LCMP-IDE received only one

(1) proposal, from BAH. Both of these situations as well as subsequent research indicate that only one vendor is capable of performing all requirements, which include and are dependent upon the LCMP-

IDE system.

7) A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made

GSA will continue to encourage the Air Force to research options available for competing the LCMP-

IDE system in whole or in part, in its long-term planning for continuing support of multi-platform database and lifecycle management requirements. Looking into options for competing the requirement would allow future support of this need to garner the benefits of greater competition.

An official posting will be performed on beta.sam.gov within 14 days after placing the order in accordance with FAR 16.505(b).

8) The Contracting Officer’s certification that the justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief.

The Contracting Officer’s signature on the Signature/Approval page evidence that she has determined this document to be both accurate and complete to the best of his knowledge and belief.

9) Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for an exception to fair opportunity) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

See Technical Representative’s signature on Signature/Approval page.

10) Written determination by the approving official that the noted exception above applies to this order.

The Contracting Officer’s statement and signature on the Signature/Approval page evidence that she has determined that the statutory authority for the exception noted in section 4 applies to this task order.

SIGNATURE/APPROVAL ROUTING

Task ID# ID07210009

* Technical Representative’s Certification: By signature below, I state that I have read, understand, and agree with the technical information/representation made herein. I have provided the Agency and site specific technical information expressed herein, which is current and accurate to the best of my knowledge.

Mark Morton, JPATS Ops Management Lead Date

By signature(s) below, I state that I determine the statutory authority as cited herein and expressed in

FAR 16.505(b)(2)(i)(B) applies to this justification, and the justification is hereby approved on its merits as noted. Technical information was presented as being accurate and complete as received from the client and was fully relied upon to document the request for “exception to fair opportunity,” described herein.

Contracting Officer’s Certification/Approval:

Elizabeth A. Crawford Date

Branch Chief, Assisted Acquisition Services Coordination/Review/Approval:

Zach Rich Date

Legal Counsel Review/Approval:

Amy Cook Date

Director, Assisted Acquisition Services Coordination Review/Approval:

Latasha Goines Date

Acting Competition Advocate Coordination Review/Approval:

Mike McDaniel Date

Head of Contracting Activity Coordination Review/Approval:

MORTON.MARK.C.108379

Digitally signed by

MORTON.MARK.C.1083793526

Date: 2020.12.17 14:35:03 -06'00'

DocuSign Envelope ID: 5E11D63C-B427-4DAE-BEE7-C96681870CDD

12/17/2020

12/17/2020

12/17/2020

12/17/2020

12/17/2020

12/21/2020

George Prochaska Date

Certificate Of Completion Envelope Id: 5E11D63CB4274DAEBEE7C96681870CDD Status: Completed

Subject: Please DocuSign: 04 ID07210009 Exception to Fair Opty Justification Final 12.17.2020 (3).pdf

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Branch Chief

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US General Services Administration

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US General Services Administration

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