JA_JWCC_Advana_852573423_Redacted.pdf

CUI

Controlled by: OSD Controlled By: CDAO CUI Category: SSEL

JUSTIFICATION & APPROVAL FOR FEDERAL ACQUISITION

REGULATION SUBPART 16.5 ACQUISITIONS

EXCEPTION TO FAIR OPPORTUNITY

Multiple Award Contract

Orders under Fair Opportunity Federal Acquisition Regulation (FAR) 16.505(b), Defense FAR Supplement 216.505(b), Procedures, Guidance, and Information 216.505(b)

Military Interdepartmental Purchase Request Number: HQ06425139664 Joint Warfighting Cloud Capability (JWCC) Contract Number: HC105023D0005 Task Order (TO) Number: TBD Procurement Title: Advana Estimated Value:

Statutory and Regulatory Authority: 10 United States Code (U.S.C.) 3204(a) and FAR 16.505(b)(2)(i)(B)

EXCEPTION TO FAIR OPPORTUNITY

Number: JA25-133

Upon the basis of the following justification, I, as the Senior Procurement Executive (SPE), hereby approve this exception to fair opportunity pursuant to the Statutory Authority of 10 U.S.C. 3204(a) and Regulatory Authority of FAR 16.505(b)(2)(i)(B).

1. REQUESTING AGENCY AND CONTRACTING OFFICE:

Requesting Agency:

Office Secretary of Defense (OSD)/Chief Digital and Artificial Intelligence Office

(CDAO)

9010 Defense Pentagon, 3D1053 Washington, DC 20301

Contracting Activity:

Defense Information Systems Agency (DISA)/Defense Information Technology Contracting Organization (DITCO)/Cloud Capabilities Section (PS8511)

2300 East Drive Scott Air Force Base, IL 62225-5406

2. NATURE/DESCRIPTION OF ACTION(S):

This action is to issue a firm-fixed-price TO against the JWCC Indefinite Delivery/Indefinite Quantity Contract for Advana. This TO will be issued directly to Amazon Web Services (AWS), Inc. The anticipated period of performance (PoP) is for a 1-year base period, plus two 1-year option periods. The total estimated value is which will be funded by Operations & Maintenance and Research, Development, Test & Evaluation funds.

Advana

Page 2 of 8 Pages

CUI

3. DESCRIPTION OF SUPPLIES/SERVICES:

The Advana system is a Department of Defense (DoD) platform that seamlessly integrates data from any number of sources, cleanses it, and makes it discoverable and usable enterprise wide.

Advana is a large and complex information system, i.e., software, tools, services, and data, that contains hundreds of commercial and open-source capabilities that are deployed and operated across multiple environments and security enclaves. As of March 2025, Advana hosts data from over 475+ systems of record, provides 80+ commercial software capabilities on Non-classified Internet Protocol Router Network (NIPR) and 35+ commercial software capabilities on Secret Internet Protocol Router Network (SIPR) and Joint Worldwide Intelligence Communication System (JWICS), shares 6,000+ unique data tables externally with other systems, and runs 20,000+ Artificial Intelligence (AI) inferences to applications a month. The DoD Chief Information Office (DoD CIO) designated Advana as a Defense Business System in financial management and has been working toward certification under those standards. Historically, the Advana team also served as the central intake mechanism for Combatant Commands (CCMD), Principal Staff Assistants (PSA), Military Departments (MILDEP), and Defense Agencies and DoD Field Activities (DAFA) for both CDAO-funded and Component-funded data, analytic, and AI projects. Since 2024, CDAO has focused on decentralizing application development on the Advana platform and has worked with Component customers to execute their own acquisition actions for application development labor and paying CDAO for Advana software licensing and use of the infrastructure, platform, and services.

Advana is built on AWS infrastructure and consists of an environment that hosts products, platforms, and services on cloud hosted multi-classification domains of NIPR, SIPR, and JWICS at impact levels (IL) 2, 5, 6, and Top Secret, in addition to a hybrid environment. This requirement is to obtain a JWCC TO to support modernization of the Advana architecture and sustainment of Advana that will provide automated development, security, and operation pipelines; advanced AI/Machine Learning (ML) capabilities; an enriched development experience; scalable and interoperable resources; and security. The Advana system relies on secure services for executing programs that leverage virtualized computing, storage, networking, and security resources; running and managing software containers; ensuring high system availability and scalability; delivering high-performance graphical processing; providing data engineering and operations services; supporting AI development and modeling; and enabling cross-domain solutions. These capabilities must be provided on three separate security enclaves, Unclassified, Secret, and Top Secret.

4. SUPPORTING RATIONALE, INCLUDING A DEMONSTRATION THAT THE

PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR THE NATURE OF THE

ACQUISITION REQUIRES USE OF AN EXCEPTION TO FAIR OPPORTUNITY:

(a) Exception to Fair Opportunity.

FAR 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.

Page 3 of 8 Pages

CUI

(b) Description of the Justification.

The CDAO’s Directorate for Scaled Capabilities has a requirement to speed-up the application and adoption of frontier AI technologies, support the DoD audit, and work with PSAs, CCMDs, MILDEPs and DAFAs to ensure mission readiness. This JWCC TO will provide cloud compute and storage services for the Advana environment, a large scale, secure platform that provides data, analytic, and AI tools and services to the DoD.

The Advana system currently provides capabilities that services over 72,000 users, contains over 700 data sets, and over 100 product lines and organizations. The Advana system acquired its initial cloud capacity in 2017 via an integrator and has been operating within AWS since its inception. To align with the DoD CIO policy, CDAO is transitioning its cloud capacity services to JWCC.

AWS currently provides existing services to CDAO Advana. Due to the size, complexity, and maturity of the Advana system, any transition to another cloud service provider (CSP) would be technically infeasible to meet the Government needs. The transition to a new CSP would cause significant delays and risks for operating and maintaining the Advana system and would cause immediate and significant impacts to ongoing DoD operations and requirements. In addition, there are technical requirements and capabilities that only AWS can fulfill.

(c) Justification.

(1) Minimum Government requirements.

The minimum Government requirements are to modernize and sustain the Advana system without the re-architecture of the Advana solution. To accomplish this, the Government requires the AWS cloud offerings listed below. The cloud service offerings must continue at their current level to support ongoing DoD data, analytic, and AI activities being supported by the Advana system including the DoD audit and decision support operations across all MILDEPs, and multiple CCMDs, and DAFAs.

The specific technological capabilities required to meet the Government’s minimum needs that can only be provided by AWS include, but are not limited to:

• AWS Organizations

• Anthropic and Amazon Augmented AI

• AWS Bedrock and integration with other organization models

• AWS Systems Manager – a capability that allows the management and updating of software packages across a very large number of virtual machines at once. AWS is currently the only commercial CSP that provides this capability. Advana makes extensive use of this service to manage and deploy software updates across thousands of virtual machines simultaneously.

The above technological capabilities are vital to the Advana program. The capabilities are essential for effectively managing Advana’s large-scale infrastructure, which includes

Page 4 of 8 Pages

CUI

thousands of virtual machines. Without these capabilities, Advana’s program resources would be insufficient for maintaining operational stability.

(2) Proposed sole source contractor. AWS

(3) Discussion regarding the cause of the sole source situation.

The only source capable of performing the requirements for OSD CDAO’s Advana at the required level and quality is AWS. Transitioning to a new CSP would present major challenges in delivering the technical capabilities tasked to Advana from the Secretary of Defense (SECDEF). There are three SECDEF tasks of critical importance: audit, supply chain, and AI acceleration. Any major disruptions to the program timelines and operations will impact the SECDEF’s priorities. The Government’s minimum requirements are to sustain the existing system to support the PSAs achieving DoD’s priorities. Estimated delays of refactoring, re-architecting, re-engineering, and migration of data is estimated between 18 to 24 months. The platform’s ability to deliver scalable AI models at every security domain is heavily reliant on the native and proprietary AWS services that are currently procured and implemented. Any delays due to a change in the CSP would create an undue amount of risk and delay achievement of the Department’s priorities.

(4) Demonstration of unique source.

AWS possesses approximately eight years of historical knowledge in supporting the design and operation of the Advana system and has the skills, capabilities, certification, clearance, and experience required to continue the program without a break or degradation in critical mission services. Transitioning Advana to a new CSP would require a minimum of two years of engineering work to redesign and reimplement Advana in the new CSP environment, and completion of side-by-side operation and duplicative costs in both AWS and the new CSP to ensure a safe and orderly transition to the new CSP environment. This would not meet the Government’s minimum requirements. Given current Advana critical mission requirements to deliver scalable AI models as the Department’s enterprise data and AI platform, AWS is the only CSP that can provide the necessary AI/ML modeling services.

Although many of the cloud offerings used in Advana on AWS have comparable services offered within the other JWCC CSPs, a direct one-to-one match does not exist. For example, Azure Virtual Networks do not offer the same functionality as AWS Virtual Private Cloud, which would necessitate significant architectural changes to Advana.

Currently, Advana heavily relies on specific AWS services that would require a complete re-architecture of the solution if migrated to another CSP. Thus, only AWS’ cloud offerings can meet the Government’s minimum requirements.

While basic services such as virtual machines, virtual storage, and Kubernetes are available across multiple CSPs, even these have significant differences that would require rework of their implementation within Advana. Furthermore, there are greater disparities

Page 5 of 8 Pages

CUI

in the AI Large Language Models across the JWCC offerings. Certain AI services, such as Anthropic and Bedrock, are not available in other CSPs, and Advana customers are already invested in leveraging these unique AWS capabilities. AWS’ cloud offerings are required to meet the Government’s minimum needs.

Finally, discrepancies exist in the availability of CSP services at various FedRAMP levels (IL2, IL5, and IL6). Utilizing alternative CSP services would necessitate re-engineering Security Impact Analyses (SIA) for each service, which would not meet the Government’s minimum needs. If an SIA fails, Advana would be required to reproduce a similar service.

(5) Procurement discussion.

The Advana system is currently designed to meet DoD security requirements, including Zero Trust, using wide set cloud native AWS security services including AWS Security Hub, AWS Identity and Access Management Identification Center, AWS Key Management System, and AWS GuardDuty. Transitioning to a new CSP would require redesigning the Advana security architecture, as well as going through a full DoD Risk Management Framework compliance process to obtain a new Authority to Operate. Any re-architecting, re-engineering, and refactoring of any of the critical cloud offerings from AWS to any other CSP would not meet the Government’s minimum need to utilize and build upon the unique AI/ML models that have been developed to meet the DoD’s needs.

(6) Impact.

Transitioning to a new CSP environment would require the redesign, refactoring, and reimplementation of the Advana system in the new CSP environment, including making significant architectural changes to Advana. This would result in fewer resources to support DoD customer operations, impacting mission effectiveness. In addition, if Advana were to migrate to a new CSP environment, DoD customers would have to devote time and effort to migrating their operations from the AWS environment to the new CSP environment resulting in additional work, cost, risk, and potential mission failure. Based on the existing Department priorities by the SECDEF for an unmodified financial audit opinion, supply chain risk assessments, and mission readiness, any major overhaul of the Advana system prior to the FY27 multi-cloud re-architecture will introduce risk into each of the SECDEF priorities. This risk is unacceptable to the DoD’s mission and thus, the Government’s minimum needs are to sustain and modernize the existing Advana system.

5. COST/PRICE FAIR AND REASONABLE DETERMINATION:

A determination that the price is fair and reasonable will be based on a comparison of the contractor’s proposal to the independent government cost estimate and the JWCC Catalog pricing, including any discounts, which was previously found to be fair and reasonable and based on the contractor’s commercial pricing.

Page 6 of 8 Pages

CUI

6. MARKET RESEARCH:

Market research for the basic JWCC Contracts was conducted and resulted in a signed market research report on November 9, 2021, that was revalidated and recertified on July 29, 2024.

After a survey of the market, it was concluded that use of the JWCC Contract is in the Government’s best interest due to technical feasibility and cost to the Government.

OSD CDAO conducted market research from May 6, 2024, to December 12, 2024, examining the capabilities offered under the JWCC Contracts. This research determined that AWS is the only source capable of fulfilling the Government's minimum requirements within the required timeframe. An Additional Research to Support Exception to Fair Opportunity document was issued on December 12, 2024. While Google Public Sector and Microsoft Corporation did not respond to the request, Oracle America confirmed they would not provide a response. AWS was the only CSP to respond affirmatively, demonstrating the capability to meet the Government's needs. Subsequent market research, conducted from July 15, 2025, through August 28, 2025, confirmed the initial findings: only AWS can provide the necessary cloud offerings and level of support.

7. ANY OTHER SUPPORTING FACTS: None.

8. ACTIONS THE AGENCY MAY TAKE TO REMOVE OR OVERCOME BARRIERS

THAT LED TO THE EXCEPTION TO FAIR OPPORTUNITY:

(a) Procurement History:

Incumbent Contractor: Metrostar Systems LLC Contract Number: FA800325C0002 Task Order Number: Not Applicable Period of Performance: March 1, 2025 - February 28, 2027 Competitive Status: Small business (SB) set-aside Business Size: SB

(b) CDAO is exploring how future Advana programs can operate within a multi-cloud service provider environment, removing the current dependency on AWS. CDAO has been directed to partner with the Office of the Under Secretary of Defense (OUSD) for Acquisition and Sustainment (A&S) and the Advana program is currently being considered for designation as a Program of Record (POR). The CDAO roadmap submitted to OUSD A&S includes a re-architecture to integrate with multiple CSPs. This effort includes a Capabilities Needs Statement, Program Roadmap, and a Cost Analysis Requirements Description. CDAO is currently awaiting a determination from OUSD A&S regarding the program's organizational alignment and the feasibility of incorporating cloud competition. Several factors present challenges, including SECDEF priorities, potential risks associated with change, required contractual adjustments, and the transition of Advana with existing staff while sustaining the POR. The period of the J&A accounts for several factors. The A&S deliberative decision making process; planning and then designation as a POR (designation is expected to require a year, commencing in the

Page 7 of 8 Pages

CUI

second or third quarter of FY26); requirements development; award of a JWCC task order with a multi-cloud environment or a competitive task order and possible transition to a new CSP; and possible re-architecture, migration, and implementation over 18-24 months.

Pending the OUSD A&S decision on the future of Advana, the current environment must be sustained.

The previous procurement was not based upon an exception to fair opportunity.

Page of

TECHNICAL CERTIFICATION: I certify that the supporting data under my cognizance which are included in the J&A are accurate and complete to the best of my knowledge and belief.

NAME: SIGNATURE:

TITLE/AGENCY/ORGANIZATION:

PHONE:

REQUIREMENTS CERTIFICATION: I certify that the supporting data under my cognizance which are included in the J&A are accurate and complete to the best of my knowledge and belief.

NAME: SIGNATURE:

TITLE/AGENCY/ORGANIZATION:

PHONE:

CONTRACTING OFFICER CERTIFICATION: I certify that this justification is accurate and complete to the best of my knowledge and belief.

NAME: SIGNATURE:

TITLE/AGENCY/ORGANIZATION:

PHONE:

SENIOR PROCUREMENT EXECUTIVE APPROVAL: I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Since this justification exceeds $100M, this review serves as approval.

NAME: Mr. Christopher Barnhurst SIGNATURE:

TITLE/AGENCY/ORGANIZATION: SPE, DISA

PHONE:

ALL QUESTIONS REGARDING THIS JUSTIFICATION ARE TO BE REFERRED TO: