LSJ_20150066_Verizon_OCC adjudictaed_ss06252025.pdf

Attachment 4 U.S. Customs and Border Protection

Limited-Sources Justification (LSJ) - FAR 8.405-6 For orders or BPAs exceeding the Simplified Acquisition Threshold (SAT)

Version 2.0 November 2020

Date: _____06/25/2025________ PR Number: ______20150066_________

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C.

152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting Activity. Identification of the agency, contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

U.S. Customs and Border Protection (CBP) Office of Acquisition, Procurement Directorate, Mission Support Contracting Division-East, on behalf of Office of Trade (OT), proposes to award an order against CellCo Partnership GSA MAS Schedule # 47QTCA20D00B5 pursuant to FAR 8.405-6(a), Limiting Sources. Accordingly, MSCD-E in collaboration with OT have prepared this Limited- Sources Justification.

2. Nature and/or description of the action being approved. Describe the action being approved, and include the name and address of the proposed contractor(s).

CBP intends to limit the number of sources solicited pursuant to FAR Part 8.405-6(a) for wireless communication services to support its mission-critical operations. The requirement to maintain accounts was previously handled using an Intra Agency Work Agreement (IRWA) or Government purchase card. Due to a policy change, it was necessary to establish a contract using the General Services Administration (GSA) Multi-Award Schedule (MAS). for mobile voice and data plans, device connectivity, mobile hotspot services, government-prioritized emergency communications in support of national and economic security mission of the Office of Trade. These services must be domestic and international to support the many offices of CBP worldwide. These services are essential for CBP to perform its duties in relation to the Tariff Act of 1930, which outlines the procedures for importing and exporting goods into the United States.

The proposed contractor for this effort is:

CELLCO PARTNERSHIP dba VERIZON WIRELESS

1 VERIZON WAY

BASKING RIDGE, NJ

07920-1025

UEI: CK77N4SCAJD3, CAGE: 1HWU7

Size Status: Other than Small

Total value of proposed action: $480,668.53

3. Description of Supplies/Services. Describe the supplies or services to be acquired. Provide the estimated total value (including options, if any).

http://uscode.house.gov/

This procurement is for continued services that needs to be marked and provisioned as Government Law Enforcement with first responder priority. The plan gives the user preferred access to network resources. In times of need, CBP receives preemption service that terminates or relocates lower priority users to give priority access to primary users. The dedicated core shall provide end-to-end network encryption and be interoperable with other Federal, State and Local agencies. Verizon service is far superior in the Florida, Georgia, Texas and Washington outside of the primary metropolitan areas. The need for of Florida, Texas, Georgia and Washington. Verizon Wireless is the only responsible source that can meet the agency’s requirements due to the following reasons:

(a) Network Coverage and Infrastructure

The FirstNet Authority was established in 2012 by Congress. In March 2017, AT&T was the sole awardee to provide the FirstNet Network to build out a dedicated, secure, nationwide LTE network for first responders. This network is overseen by the First Responder Network Authority, an independent government authority mandated to provide a single interoperable platform for emergency and daily public safety communications. Since March 2017, Verizon Wireless is the second provider using its Frontline capabilities to meet the requirement for dedicated, secure, uninterrupted, prioritized service for first responders, law enforcement personnel and personnel supporting national security operations. Verizon Wireless network and technology platforms that provide critical communications for first responders and public safety agencies. Verizon Wireless is the only provider that can meet the Government’s requirements to provide reliable, 7x24x365 priority service for CBP’s area of operations and especially in the remote (outside of major metropolitan centers) areas in Florida, Georgia, Texas and Washington. CBP personnel are frequently moving between many miles as they perform their duties which means that they often cross over multiple coverage areas. To maintain uninterrupted oversight of daily trade operations, the Office of Trade (OT) must equip a clearly defined cadre of key Government personnel— supervisors and employees whose decisions initiate, authorize, or escalate enforcement actions with government-issued smartphones configured for secure voice, data, and Wireless Priority Service.

These personnel play a critical role in enforcing trade laws, protecting revenue, and responding to emerging issues in real time. Many serve in an on-call capacity during nights, weekends, and federal holidays, and must be reachable within minutes to address high-priority matters such as cargo holds, forced-labor, revenue discrepancies, and port related enforcement incidents. Their decisions often carry immediate operational, legal, and financial implications that cannot be delayed without jeopardizing CBP’s mission and statutory responsibilities. Secure, continuous, and reliable mobile connectivity throughout multiple types of terrain and coverage areas ensures that supervisors can issue directives, resolve operational challenges, and manage sensitive enforcement activities in real time, especially in high-pressure situations involving system outages, cross-port coordination, or urgent legal determinations. These capabilities are vital for maintaining continuity of operations, ensuring workforce safety, and supporting fast-moving enforcement decisions outside traditional office environments. This requirement is further reinforced by the Presidential Memorandum titled Return to In-Person Work (90 Fed. Reg. 8251, January 28, 2025), which directs all federal agencies to restore a consistent on-site presence and strengthen supervisory accountability. While OT supervisors have resumed in-office leadership in compliance with this mandate, they continue to oversee geographically dispersed operations that require real-time mobile responsiveness beyond core business hours. CBP’s user experience and tracking of coverage outages over the past five years has demonstrated that the safety and security of CBP personnel and ability to carry out its mission in these area of operation and throughout the USA.

This is a cost-effective solution that minimizes disruptions to essential national security functions performed by CBP.

Alternative carriers have been assessed and do not provide adequate coverage in remote areas outside of major metotroplitan areas of Georgia, Florida, Texas and Washington, leading to potential service disruptions and therefore are unable to meet CBP’s requirements.

(b) Existing Government Contracts and Compatibility

CBP currently utilizes CellCo Partnership Verizon Wireless services under contract 47QTCA20D00B5 – Order 70B06C25F00000165, and continuity is essential to avoid operational disruptions. Switching to another provider would require significant reconfiguration costs, new device provisioning, and risks to enforcing trade regulations. The ability to send and receive time-sensitive information, without delay, or service interruption is essential for maintaining operational integrity and supporting CBP’s trade-enforcement posture. For example, among these mission-critical personnel are employees assigned to Enforce and Protect Act (EAPA) Investigations, a specialized unit responsible for statutory enforcement actions under Title IV, Section 421 of the Trade Facilitation and Trade Enforcement Act of 2015. These investigators routinely receive calls from CBP Attachés, outside counsel, and interagency partners beyond duty hours. OT personnel are required to respond to regulatory inquiries, meet statutory deadlines, support verification efforts both domestically and abroad, and manage urgent requests from the Office of Chief Counsel, the field, and federal courts, including filings due by 11:59 p.m. as mandated by judicial order.

(c) Priority Communications for Government Use

Verizon Wireless offers Wireless Priority Service (WPS) and Government Emergency Telecommunications Service (GETS), which are critical for ensuring uninterrupted communications during emergencies. Competing carriers do not provide the same level of government-prioritized connectivity.

(d) Bundled Services and Cost Efficiency

Verizon Wireless provides an integrated solution with bundled services that align with the agency’s technical and operational needs. Switching providers would require additional costs for transitioning to new equipment, dispensing with existing operational equipment, software integration with existing applications, and personnel training.

These accounts can no longer be procured via an IRWA and thus the price remains the same and the accounts will remain current at the same rates offered under CellCo Partnership’s GSA MAS.

The total anticipated obligation amount will be $480,668.53 for a term of 12 months, which includes all charges incurred for the closeout of an expired IRWA and also keeping those accounts active through June 25, 2026. The price proposed by CellCo Partnership is based off their commercial GSA MAS rates. The contracting officer has determined that the pricing is fair and reasonable.

4. Authority and supporting rationale.

This justification is prepared under the authority of FAR 8.405-6(a)(1)(i)(B), which allows for limited sources procurement when only one source is capable of providing the required supplies or services due to unique capabilities, urgency, or brand name requirements. The award will be made against CellCo Partnership’s GSA MAS 47QTCA20D00B5, which is valid through June 10, 2030.

Through the duration of the previous IRWA with CellCo, CBP obtained accounts which are only compatible with the current Verizon Wireless Frontline system. CellCo is the only provider capable of seamlessly providing these services utilizing its Frontline network under the IRWA while maintaining compatibility with existing CBP equipment and continuing services on the accounts.

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 the proposed Delivery Order for CelloCo product represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs. The General Services Administration (GSA) has already negotiated fair and reasonable price. CBP will solicit competition from authorized FSS resellers to ensure a fair price. Discounts from the GSA schedule prices will be requested.

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.

Market research was conducted to identify potential competitors. Research included a review of other major wireless carriers and past experience of CBP users revealed that other provider’s network coverage in CBP’s remote areas, outside of major metropolitan areas, in Georgia, Florida, Texas and Washington can be insufficient. Consultation with agency technical personnel confirmed that Verizon Wireless is the only provider capable of meeting mission-critical communication needs for the entire area of operations domestically . CBP conducted market research by reviewing available FSS vendors but determined that only Verizon Wireless could provide the required nationwide coverage, security compliance, and priority communication capabilities to keep these accounts active. Other vendors either lacked sufficient coverage in CBP’s operational areas in remote areas, outside metropolitan areas, in Georgia, Florida, Texas and Washington or required extensive infrastructure modifications.

Techniques and sources used during market research investigation included the review of GSA and CBP procurement guidelines for the wireless access and cost estimates for this service were taken from the current vendor as well as General Service Administration (GSA) Federal Supply Schedules and market research estimates from DHS strategically sourced contracts, Office of Field Operations Blanket Purchase Agreement (BPA) for Front Royal, AT&T GSA Federal Supply Schedule 47QTCA19D00MV and GSA-Multiple Award Schedule #47QTCA20D00B5.

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.

No additional facts.

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.

To remove or overcome barriers to competition prior to any future acquisitions of the same or similar wireless communications solutions, the agency will take the following actions:

1. Market Research: Conduct comprehensive market research to identify alternative wireless carriers and emerging technology providers capable of meeting agency requirements, including coverage area, data security compliance (e.g., FedRAMP, FISMA), device compatibility, and emergency response interoperability.

2. Requirements Definition and Standardization: Review and refine agency wireless service requirements to eliminate specifications that unnecessarily restrict consideration to a single vendor. Where feasible, adopt performance-based and brand-neutral language to enable broader competition.

3. Technology Assessment: Evaluate the feasibility and cost of transitioning to or incorporating multiple wireless service providers through carrier-agnostic device platforms, multi-carrier SIMs, or managed mobility services.

4. Engagement with Category Management and Strategic Sourcing Vehicles: Coordinate with GSA, DHS Strategic Sourcing, and relevant Category Management teams to identify upcoming enterprise-wide contract vehicles or Best-in-Class (BIC) solutions that support competitive wireless services acquisitions, including multi-award BPAs or IDIQs.

5. Acquisition Planning: Develop an acquisition strategy that phases out reliance on proprietary Verizon-specific hardware or service bundles, thereby enabling increased vendor participation in subsequent procurements.

6. Industry Engagement: Issue Requests for Information (RFIs) or hold industry days to better understand marketplace capabilities and incentivize new entrants to propose solutions for future requirements.

7. Documentation and Lessons Learned: Maintain records of the limitations encountered in this procurement and disseminate best practices and lessons learned within the agency acquisition community to inform future planning and enhance competition.

9. CBP intends to post this requirement on SAM.gov pursuant to FAR 8.405-6(a)(2)(i).

10. Technical/Requirements Personnel Certification:

Pursuant to FAR 8.405-6(c)(2)(x), I certify that this requirement meets the Government’s minimum need and that the supporting data, which form a basis for the Limited-Sources Justification, are accurate and complete.

Technical Representative/COR Date

11. Contracting Officer Certification and/or Approval: *

Pursuant to FAR 8.405-6(c)(2)(ix), I certify that the Limited-Sources Justification is accurate and to the best of my knowledge and belief.

Contracting Officer Date

*Note: In accordance with FAR 8.405-6(d)(1) for proposed BPAs or orders with an estimated value exceeding the simplified acquisition threshold, but not exceeding $750,000, the ordering activity contracting officer’s certification that the justification is accurate and complete to the best of the ordering activity contracting officer’s knowledge and belief will serve as approval.

► LSJ Approvals:

13. COMPETITION ADVOCATE (Per FAR 8.405-6(d)(2) - Exceeding $750,000)

Approved Disapproved

Name (Print): ________________________ Competition Advocate

Signature: ___________________________ Date: _____________

14. HEAD OF CONTRACTING ACTIVITY (Per FAR 8.405-6(d)(3) – Exceeding $15M to $75M)

Name (Print): _______________________ Head of the Contracting Activity

Signature: __________________________ Date: _____________

15. DHS CHIEF PROCUREMENT OFFICER (Per FAR 8.405-6(d)(4) - Exceeding $75M)

Name (Print): _______________________ DHS Chief Procurement Officer

Signature: __________________________ Date: _____________

Note: Each Limited-Sources Justification must be reviewed and approved by lower level approval(s).

For example, actions over $75 million requiring CPO approval must be reviewed, approved, and signed by the contracting officer, Component Competition Advocate, and HCA.