852675107_JA_Final_AMD01_Redacted.pdf

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CUI

JUSTIFICATION FOR EXCEPTION TO

FAIR OPPORTUNITY OR BRAND NAME

Federal Acquisition Regulation (FAR) Part 16.5 Justification & Approval (J&A)

CSS Tracking Number: 852675107 Military Interdepartmental Purchase Request: HC1085606239 Procurement Title: Citadel Estimated Value:

Regulatory Authority: FAR 16.507-6(b)(2)

J&A Exception to Fair Opportunity Number: Not Applicable

1. REQUIRING AGENCY AND CONTRACTING ACTIVITY:

Requiring Agency: Defense Information Systems Agency (DISA) / ACQ – Services Program Executive Office (SD) Contracting Activity: DISA Defense Information Technology Contracting Organization (DITCO)/Cloud Capabilities Section

(PS8511)

2. NATURE/DESCRIPTION OF ACTION(S):

Type of Action: New Task Order (TO) Type of Contract: FFP

AMD01: This amendment increased this estimated value by . This increase is due to the miscalculation of anticipated growth within the Citadel environment on the IGCE and the pricing of specific EC2 services available for Option Period 2 of the period of performance.

This action is to issue a firm-fixed-price TO against the JWCC Indefinite Delivery/Indefinite Quantity Contract for Citadel. This TO will be issued directly to Amazon Web Services, Inc.

(AWS) The anticipated period of performance (PoP) is for a 1-year base period, plus one 1-year option period and one 5-month option period. The total estimated value is which will be funded by Operations & Maintenance (O&M) funds.

3. DESCRIPTION OF SUPPLIES/SERVICES:

Citadel is a cloud-based admin-tenant Development, Security, and Operations (DevSecOps) integration platform hosted in accredited Impact Level (IL) 5 & IL6 environments. Its core capability is a centrally hosted toolchain of software used for the execution and auditing/testing of contracted products for multiple mission partners

4. IDENTIFICATION OF EXCEPTION TO FAIR OPPORTUNITY:

FAR 16.507-6(b)(2) - 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.

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5. DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF THE

EXCEPTION CITED:

1. UNIQUE QUALIFICATIONS:

The sole source situation is driven by absolute dependency to AWS-specific microservices and Application Program Interfaces. Citadel’s foundational architecture relies on AWS-native capabilities that do not have a 1-to-1 operational equivalent in other JWCC Cloud Service Provider (CSP) environments. AWS is uniquely qualified as the only source capable of meeting the Government’s requirement because they are the sole owner and operator of the IL5/IL6 fabric upon which Citadel’s customized DevSecOps toolchain relies. No other JWCC CSP possesses a cloud environment that can directly ingest and operate Citadel’s AWS-formatted workloads. Any other CSP would require a ground-up engineering effort;

continued use of AWS ensures uninterrupted operations, maintains existing accreditations, and preserves prior Government investment all for the benefit of the mission.

2. IMPACT:

Pursuing competitive procedures would introduce significant schedule delays and real disruption to ongoing IL5 and IL6 mission operations, jeopardizing mission success for dozens of 4th Estate partners. A transition from the existing AWS environment would require a transition of workloads, revalidation of security controls, testing and reaccreditation activities, resulting in unnecessary cost and operational risk. Continued use of the current AWS environment ensures uninterrupted service, maintains existing accreditations, and supports mission continuity without impacting current customers or operations.

6. DETERMINATION OF FAIR AND REASONABLE COST:

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.

7. MARKET RESEARCH:

Market research for the basic JWCC Contracts was conducted and resulted in a signed market research report on November 9, 2021. This market research was subsequently revalidated and recertified on July 29, 2024, and most recently on February 6, 2026. 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.

Based on current market research, dated March 2026, through July 2026, it has been determined that only the aforementioned cloud services provided by AWS, can fully meet the Government’s needs. Additional research to support an exception to fair opportunity was issued on July 1, 2026, to all four JWCC CSPs. Responses were received from AWS and Microsoft. While Microsoft responded, technical analysis of Microsoft’s proposed architecture confirmed that transitioning Citadel to Microsoft would require discarding the current AWS-native codebase and completely re-engineering the continuous integration/continue deployment pipelines and Cross-Domain solutions to align with Azure-proprietary services. Microsoft’s response did not provide a transition timeline or migration schedule to demonstrate an ability to executive this re-

J&A: Citadel

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CUI

engineering effort prior to the current task order expiration, leaving the Government’s technical estimate of 18-24 months for re-architecture and IL7 re-accreditation as the only viable timeline.

A service lapse of this duration would disrupt secure software delivery, execution, and auditing capabilities for the 4th Estate mission partners.

8. ANY OTHER SUPPORTING FACTS: Not applicable

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

THAT LED TO THE EXCEPTION TO FAIR OPPORTUNITY:

Reviewing officials and the approval authority have reviewed the previous J&A, which was routed with this J&A, and determined any planned actions to remove barriers to competition listed on the previous justification were considered. While development of a containerized platform is underway, it is still not complete. After review of the actions taken, it is determined that a sole source environment still exists.

Procurement History:

Incumbent Contractor: Amazon Web Services (AWS) Contract Number: HC105023D0005 Task Order Number: HC105024F0025 Period of Performance: August 1, 2024-July 31, 2026 Competitive Status: Other than full and open competition/Exception to fair opportunity Business Size: Large business

To increase future competition, the government is continuing to work to modernize the platform through containerization, Kubernetes, a modular architecture that reduces dependency on provider specific services. These efforts will include portability and position future cloud hosting requirements for broader competition as equivalent technical and security capabilities, including comparable Cross Domain Solution to the AWS Diode becomes available across CSPs. Until then, AWS remains the only CSP capable of meeting the current operational, security and mission requirements without unacceptable cost schedule and mission risk.

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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: Noah Grinspoon SIGNATURE/DATE:

TITLE/ORGANIZATION: DISA, ACQ SD

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: Noah Grinspoon SIGNATURE/DATE:

TITLE/ORGANIZATION: DISA, ACQ SD

PHONE:

CONTRACTING OFFICER CERTIFICATION: I certify that this justification is accurate and complete to the best of my knowledge and belief. Since this effort exceeds the SAT but does not exceed $10M, this certification serves as APPROVAL.

NAME: Jacob R. Benhoff SIGNATURE/DATE:

TITLE/ORGANIZATION: Contracting Officer/DISA/DITCO/PS8511

PHONE:

ALL QUESTIONS REGARDING THIS JUSTIFICATION ARE TO BE REFERRED TO

Jacob Sopiars, , jacob.m.sopiars2.civ@mail.mil