2. J&A Flash Array; redacted.pdf

Purchase Request No.: 5700-0002-26/1301362686 J&A No. 12.201-26-TS10

DEPARTMENT OF THE NAVY

NAVAL RESEARCH LABORATORY

4555 OVERLOOK AVE SW

WASHINGTON, DC 20375-5320

Purchase Request No.: 5700-0002-26/1301362686 J&A No.: 12.201-26-TS10

Estimated Cost: $

Justification for Other than Full and Open Competition Under Simplified Procedures for Certain Commercial Items in Accordance with Federal Acquisition Regulation (FAR) 12.201

On the basis of the following, I, as the Contracting Officer, hereby approve the use of a brand name contractual action pursuant to the authority of: 41 U.S.C. 1901 41 U.S.C. 1903

1. Contracting Activity

The Naval Research Laboratory (NRL), Contracts Division, Code 1320, proposes to include brand-name specifications for the acquisition of two (2) Pure Storage flash array storage systems on behalf of the requiring activity, Tactical Electronic Warfare Division (TEWD), Code 5700. This action will be executed in accordance with FAR Subpart 12.2.

2. Description of the Action Being Approved

This action requests approval for the use of other than full and open competition, on a brand name basis, as implemented by FAR 12.201 for the procurement of two (2) Pure Storage C50R5 flash array storage systems, an extended service agreement, and on-site installation. These systems will provide Code 5700 with high-availability, mission-critical data storage. The arrays will be integrated into the existing storage network to serve as synchronous fail-over nodes, ensuring data resiliency and operational continuity for TEWD systems. This procurement will enhance the existing infrastructure's redundancy, a capability that is not currently achievable with the single-node configuration.

3. Description of Supplies/Services

The Government requires the procurement of two (2) Pure Storage C50R5 flash array storage systems, which include the physical hardware chassis, flash storage media, necessary physical connections (QSFP56 transceivers and 100Gb Ethernet SFPs), and all associated operating software. In addition to the hardware, the procurement requires standard Original Equipment Manufacturer (OEM) warranty support, an extended service agreement for a period of 36 months, and on-site physical installation by a cleared technician.

The independent government cost estimate for these items and associated services is $ .

4. Statutory Authority Permitting Other Than Full and Open Competition

The authority for permitting other than full and open competition is 41 U.S.C. 1901(e)(2), implemented by FAR 12.102(b).

41 U.S.C. 1901 41 U.S.C. 1903

5. Rationale Justifying Use of Cited Statutory Authority

Market research was conducted in accordance with FAR Part 10 to identify potential sources capable of meeting the Government’s technical needs for high-availability flash storage. This research confirmed that only the Pure Storage-branded C50R5 flash array system, provided by the Original Equipment Manufacturer (OEM) or its authorized resellers, can meet the Government's minimum requirements. The two new flash array systems are required to serve as synchronous, high-availability fail-over nodes for an existing Pure Storage array that is currently in operational use by the Tactical Electronic Warfare Division (TEWD). For the system to function as intended, the new arrays must integrate seamlessly into the existing Pure Storage management fabric and data replication architecture.

Only a matching C50R5 model can meet these critical redundancy and interoperability requirements.

Attempting to integrate a different brand of storage array would introduce substantial technical and programmatic risks. A non-Pure Storage system cannot natively integrate with the proprietary Purity Operating System, which manages the automated fail-over, data deduplication, and snapshotting services. This would force a complete re-architecture of the existing storage network and would require the procurement of additional third-party software to attempt to bridge the two disparate systems, with no guarantee of success.

Furthermore, integrating a different system would necessitate extensive testing and recertification of the entire storage infrastructure, effectively duplicating the labor and costs associated with the initial system's deployment. This would result in significant, unacceptable delays to ongoing mission support and would require NRL personnel to be trained on an entirely new and dissimilar system. The estimated duplication of effort is approximately 480 labor hours for configuration, testing, and training, resulting in an estimated and unrecoverable cost of $72,000 and a projected schedule delay of 3 months.

Therefore, to mitigate unacceptable risks of data loss, ensure mission continuity during a fail-over event, and avoid a substantial duplication of costs and schedule delays, it is essential that the Government procures the specified Pure Storage brand name equipment.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable

Market research was conducted in accordance with FAR Part 10 to identify sources capable of providing the required flash array storage systems. This research, which included a review of the recent procurement for an identical system, determined that only Pure Storage-branded equipment can meet the Government’s minimum requirements for interoperability and technical compatibility as described in Paragraph 5.

Further market research will be conducted via a Sources Sought Notice posted to SAM.gov to identify all capable resellers of the required brand-name product and to determine if a small business set-aside is appropriate. The Non-Manufacturer Rule (NMR) applies to this acquisition; however, the Small Business Administration (SBA) has granted a class waiver for NAICS 334112, which allows small businesses to provide the product of a large business manufacturer (Pure Storage).

Based on this, the Government's acquisition strategy is to pursue a total small business set-aside, provided that market research confirms the existence of two or more capable small business resellers who are authorized to provide the required equipment.

7. Determination of Fair and Reasonable Cost

The Contracting Officer will determine that the proposed price for the supplies/services covered by this J&A is fair and reasonable prior to award. This determination is anticipated to be based on adequate price competition among the authorized resellers identified through market research. Should adequate price competition not be realized, the determination of price reasonableness will be made using other price analysis techniques as described in FAR 12.204(a). This may include, but is not limited to, a comparison of the proposed price to the Independent Government Cost Estimate (IGCE) and a comparison to the price paid for the identical system procured in the previous fiscal year.

8. Actions to Remove Barriers to Future Competition

For the reasons set forth in Paragraph 5, the Government has no plans at this time to compete future contracts for the specific supplies/services covered by this justification. However, the agency will re-evaluate the market for fully competitive solutions when the entire storage system infrastructure is due for its next major technology refresh. The NRL routinely monitors the commercial marketplace to stay informed on current, state-of-the-art storage solutions that could be used to support future requirements.

In accordance with FAR 12.202, this brand name justification will be made publicly available with the solicitation.

CERTIFICATION AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance, which are included in this Justification and its supporting acquisition planning documents, except as noted herein, are complete and accurate to the best of my knowledge and belief.

LEGAL SUFFICIENCY REVIEW

I have determined that this Justification is legally sufficient.

CONTRACTING OFFICER CERTIFICATION

I certify that this Justification is accurate and complete to the best of my knowledge and belief.