47QFWA24K0027 Exception for Fair Opportunity Signed Redacted.pdf

CUI//SP-SSEL

Exception to Fair Opportunity

FAR Part 16

General Services Administration

Federal Acquisition Service

1. Requiring and Contracting Activity

a. Requiring Activity: Program Executive Office (PEO) Digital Directorate

75 Vandenberg Drive

Hanscom MA 01730

b. Contracting Activity General Services Administration

Federal Acquisition Service

APEX 2, Division 1, Sector 3, Branch C

c. Contracting Officer:

d. Acquisition ID: 47QFWA24K0027

e. Estimated Value of This Action: $17,034,180.24

f. Contract Vehicle: Alliant 2

g. Period of Performance or Delivery Date:

Base Year/Period: 01/17/2025 - 01/16/2026

Option Year/Period 1: 01/17/2026 - 01/16/2027

Option Year/Period 2: 01/17/2027 - 01/16/2028

Option Year/Period 3: 01/17/2028 - 01/16/2029

Option Year/Period 4: 01/17/2029 - 01/16/2030

52.217-8 : 01/17/2030 - 07/16/2030

2. Description of Action:

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 with Booz Allen Hamilton, Inc. (BAH) to procure continued support for the Lifecycle Management Process

Integrated Data Environment (LCMP-IDE) system, supporting PEO Digital Directorate located at Hanscom AFB, MA. LCMP-IDE is a United States Air Force (USAF)

Docusign Envelope ID: 72B9A033-295B-436D-BFE1-23646EAD2FB9

Automated Information System (AIS) requiring IA (Information Assurance) process compliance and documentation. This task shall include generation, monitoring, and updates to all required IA documentation, compliance status data, infrastructure support, software maintenance and support, user support, incident response, and hosting environment support. BAH, Cage Code 17038, is located at 8283 Greensboro Drive, McLean, Virginia 22102. The severable services task order will be awarded as a Time and Materials (T&M) order. Initially, all labor will fall under the T&M Contract Line

Item Number (CLIN) due to the fact that it is not currently possible to reasonably estimate usage at the time of task order award. However, before the exercise of each option period, burn rates will be researched to determine if any level or predictable labor usage could be moved from the T&M to a Firm Fixed Price (FFP) Labor CLIN. Travel and Other Direct Costs (ODCs) will allow for necessary ancillary services.

Under the contemplated task order, BAH will provide continued support for LCMP-IDE, 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 and provides critical information to battle management programs for the PEO Digital Directorate. The system provides for tracking and supporting program management processes across the acquisition, modernization, and sustainment phases of Command and Control (C2) mission software applications.

LCMP-IDE has become a standard tool across multiple USAF organizations and is currently used by thirty six (36) AF organizations/divisions including, but not limited to, LCMP Propulsion Directorate, E-4B, PEO Digital (previously 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-52 (AFLCMC/WVV), B-1, EW IA Support, C-130, B-52

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 for PEO Digital and is crucial for execution management of

C2 mission software application programs affecting every Air Operations Center and touching every Air Force mission. Collaborative design and adoption of system capabilities across multiple organizations allows for a standardized, process-driven operation of each individual Program Office, 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 Department of Defense (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 total cost for this requirement is estimated to be $15,588,419.84 over a five (5) year period, with an additional $1,445,760.40 if the six (6) month extension is utilized by the

Government in accordance with FAR 52.217-8. The anticipated appropriation funding type is Air Force Appropriation Code 3080.

The estimated award date will be in January of 2025, and the task order POP will be 17

January 2025 – 16 July 2030. The task order will include a one (1) year base period, four

(4) one (1) year options, and a six (6) month optional FAR 52.217-8 extension. A five (5) 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 LCMP-IDE, which requires specialized expertise and knowledge.

3. Exception to Fair Opportunity:

FAR 16.505(b)(2) states, “The contracting officer shall give every awardee a fair opportunity to be considered for a delivery-order or task-order exceeding the micro-purchase threshold unless one of the following statutory exceptions applies:

______16.505(b)(2)(i)A) The agency's 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.

_______16.505(b)(2)(i)(G) For DoD, NASA, and the Coast Guard, the order satisfies one of the exceptions permitting the use of other than full and open competition listed in 6.302 ( 10 U.S.C. 3406(c)(5)). The public interest exception shall not be used unless Congress is notified in accordance with 10 U.S.C.

3204(a)(7).

4. Justification Rationale:

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

PEO Digital to receive uninterrupted LCMP-IDE support. BAH is the current vendor supporting this requirement and has been providing LCMP-IDE services for the USAF since 2001. 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 platforms and mission planning systems.

Because BAH possesses the system architects who are the authors of the LCMP-IDE code, their staff has 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 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 back-end processing environment and development data. This means that BAH owns the LCMP source codes, back-end processing and development data. If procured through a different vendor, the result would be dramatic cost increases and delays to mission schedules due to the new vendor needing to create the LCMP-IDE environments. Also, if a new vendor is utilized, it is anticipated that they would be multiple years away from obtaining a Defense Information Systems Agency

(DISA) Certification and the necessary cloud capabilities on the Amazon Web Services

(AWS) GovCloud currently possessed by BAH. 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 USAF programs. The LCMP-IDE database is able to synergize development modules across multiple aircraft platforms including VC-25, C-32, C-37, C-40, E-4B, RC-26, C-12, and C-21. Additionally, the LCMP-IDE framework synergizes the management and execution of software development programs across multiple organizations. 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 AWS GovCloud.

Since the initial DIACAP-approved LCMP-IDE release, BAH has developed strategies to manage evolving regulations which has provided the Department of Defense (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 will 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 25 platforms and over 35,000 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 LCMP-IDE. The integration of BAH team members with extensive Commercial Derivative Aircraft Division (CDAD) and

LCMP-IDE experience is critical to the PEO Digital acquisition processes, financial analysis, and LRP. These strategic processes allow greater utilization of LCMP-IDE to accomplish USAF strategic goals, and incorporate advanced IA technologies, to ensure the PEO Digital mission is accomplished as efficiently and effectively as possible throughout the lifecycle of C2 mission software applications. 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. BAH has nineteen (19) years of expertise in managing the LCMP-IDE SharePoint site and custom ASP.net web applications, specifically, while remaining compliant with all applicable DoD information technology and cybersecurity requirements. Throughout this performance period, BAH has proven their expertise in developing secure and compliant code for the

LCMP-IDE application.

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 program office requirements. Because the system is actively in use, all efforts must be designed and implemented to be non-intrusive to the existing architectures, providing reach back capabilities 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 without PEO Digital experiencing a substantial duplication of costs that could not be expected to be recovered through competition, as well as unacceptable delays in fulfilling PEO Digital requirements.

5. Contracting Officer Determination – Fair and Reasonable Cost:

The cost of this acquisition will be fair and reasonable. Actions anticipated to ensure fair and reasonableness 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 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 on the current order, will be utilized to ensure that the prices awarded under the new acquisition are considered fair and reasonable. Also, the Alliant 2

Benchmark Labor Rates will be used to evaluate the proposed price. Additionally, this justification shall be posted on 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. Other Supporting Facts:

Market research revealed that there are no known sources besides BAH that can provide the required services without unacceptable delays or performance risk. BAH maintains the proprietary rights to several aspects of the LCMP-IDE program as listed in previous paragraphs. Market Research was still conducted via Industry Day, Requests for

Information, and in-person meetings with BAH, to determine if barriers to competition could be overcome. No other sources can execute this requirement without unacceptable delays or performance/cost risk.

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 their 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) vendor is capable of performing all requirements, which include and are dependent upon the LCMP-IDE system. However, follow-on requirements that do not include LCMP-IDE support will be competed to the highest extent practicable. On

3 January 2024, a Virtual Industry Day was hosted by GSA and PEO Digital in an attempt to identify other potential vendors capable of executing LCMP requirements (as well as answering any LCMP-specific questions). GSA was unable to identify any vendor other than BAH, capable of executing PEO Digital’s LCMP requirements due to the information contained in Paragraph 4 of this justification. A final Request for

Information (RFI), with a draft copy of the PWS, was posted to GSA EBuy on 29 May

2024 with responses due on 7 June 2024. The RFI was intended as a final effort to find capable sources of executing PEO Digital’s LCMP requirement. The Government received two (2) responses from vendors that stated they would be interested in submitting offers in response to the solicitation (these vendors who did not attend the 3

January 2024 Virtual Industry Day). Upon conducting “fact-finding” sessions with the vendors on 11 June 2024 and 24 June 2024, it was clear the two (2) vendors that responded to the RFI could not execute the LCMP requirement due to the reasons listed