LSJ_PR20150067 kh _approved ss26Jun2025.pdf

Attachment 3 U.S. Customs and Border Protection

Limited-Sources Justification (LSJ) - FAR 8.405-6 For orders or BPAs above the micro-purchase threshold but not exceeding the SAT

Version 2.0 October 2020

Date: ___06/25/2025______ PR Number: ___20150067______

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. Specify the agency, contracting activity, and identify 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 AT&T Mobility GSA MAS Schedule # 47QTCA19D00MV 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), if applicable.

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 includes keeping a closed IRWA account(s) active 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:

AT&T Mobility, LLC

1025 Lenox Park BLVD NE Atlanta, Georgia 30319-5309

UEI: P2S7GZFBCSJ1, CAGE: 1XGS4

Size Status: Other than Small

Total value of proposed action: $78,075.09

3. Description of supplies/services to be acquired, including the estimated total value (including options).

http://uscode.house.gov/

Limited-Sources Justification (LSJ) - FAR 8.405-6 For orders or BPAs above the micro-purchase threshold but not exceeding the SAT

Version 2.0 October 2020

This procurement is for continued services under an expired IRWA that need to be marked and provisioned as Government Law Enforcement with first responder priority. The plan should give the user preferred access to network resources. In times of need, there should be preemption service that terminates or relocates lower priority users in order 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. AT&T Mobility is the only responsible source that can meet the agency’s requirements due to the following reasons:

(a) Network Coverage and Infrastructure

AT&T and Verizon Wireless are the only providers that can provide priority service.

Together the 2 providers cover the world. Therefore, CBP and DHS use these two providers as the standard. This is a cost-effective solution that minimizes disruptions to essential national security functions performed by CBP. 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. Since that time Verizon is second provider using its Frontline capabilities. Both are a network and technology platforms that provide critical communications for first responders and public safety agencies. Both offer: Priority and preemption: Ensures reliable communication during emergencies; Interoperable network: Allows for seamless sharing of information between agencies and departments; Satellite connectivity: Provides portable satellite connectivity for voice, data, and WiFi; Custom safety plans: Includes priority and preemption, regardless of data usage; and Bandwidth and resource prioritization: Removes non-public safety traffic during congested periods. Both networks are 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.

Alternative carriers have been assessed and do not provide adequate coverage, leading to potential service disruptions.

(b) Existing Government Contracts and Compatibility

CBP currently utilizes AT&T Mobility Wireless services, and continuity is essential to avoid operational disruptions. Switching to another provider would require significant reconfiguration costs, new device provisioning, and potential security risks.

(c) Priority Communications for Government Use

AT&T Mobility 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.

Limited-Sources Justification (LSJ) - FAR 8.405-6 For orders or BPAs above the micro-purchase threshold but not exceeding the SAT

Version 2.0 October 2020

(d) Bundled Services and Cost Efficiency

AT&T Mobility 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.

Market research was conducted to identify potential competitors. Research included a review of other major wireless carriers (AT&T, T-Mobile, etc.), which revealed that their network coverage in the agency’s operational areas is insufficient. Consultation with agency technical personnel confirmed that AT&T Mobility Wireless is the only provider capable of meeting mission-critical communication needs. CBP conducted market research by reviewing available FSS vendors but determined that only AT&T Mobility 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 or required extensive infrastructure modifications.

These accounts can no longer be procured via an IRWA and thus the price is remaining the same and the accounts will remain current at the same rates offered under FSS Contract

47QTCA19D00MV AT&T MOBILITY LLC.

The total anticipated award amount will be $78,075.09 which includes all charges incurred for the closeout of an expired IRWA and also keeping those accounts active through May 24, 2025. The price proposed by AT&T 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. If limiting sources pursuant to FAR 8.405-6(a), demonstrate the proposed contractor’s unique qualifications to provide the required supply or service, if applicable. Select one of the circumstances justifying limiting sources pursuant to FAR 8.405-6(a)(1)(i) below and provide supporting rationale. [Delete the circumstances/rationale that are not applicable.]

This justification is prepared under the authority of FAR 8.405-6(b)(1), 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 FSS Contract 47QTCA19D00MV AT&T MOBILITY LLC, which is valid through September 2030.

Through the duration of the previous IRWA with AT&T Mobility, CBP obtained accounts which are only compatible with the current AT&T Mobility Wireless Frontline system.

Compatibility is the capacity for two systems to work together without costly alterations.

AT&T Mobility is the only provider capable of seamlessly providing these services utilizing its Frontline network under the expired IRWA while maintaining compatibility with existing CBP equipment and continuing services on the accounts.

Limited-Sources Justification (LSJ) - FAR 8.405-6 For orders or BPAs above the micro-purchase threshold but not exceeding the SAT

Version 2.0 October 2020

5. CBP intends to post this requirement on e-Buy pursuant to FAR 8.405-6(b)(3)(i)(A). [Only include this statement if preparing a Brand Name Specification]

6. Technical/Requirements Personnel Certification:

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the Limited-Sources Justification, is accurate and complete.

Technical Representative/COR Date

7. Contracting Officer Certification/Approval:

I hereby determine that the circumstances described herein exist and that the information is accurate and complete to the best of my knowledge:

Contracting Officer Date