JA26-080_JWCC_JA_852675181_Redacted.pdf

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System Delta 81 (SYD 81) Space Digital Ecosystem and iNtegration (DEN)
Solicitation number
852675181
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Justification for Exception to Fair Opportunity

This document is a Justification & Approval (J&A) for an exception to fair opportunity procurement under FAR 16.507-6(b)(2), authorizing a sole-source award to Amazon Web Services (AWS) for cloud services supporting the System Delta 81 (SYD81) SpaceDEN program.

The Space Systems Command (SSC), under the Department of War, is issuing a Firm-Fixed-Price task order directly to AWS against the Joint Warfighting Cloud Capability (JWCC) Indefinite Delivery/Indefinite Quantity contract. The anticipated period of performance is 12 months base plus one 12-month option. The requirement involves providing Impact Level 5, 6, Top Secret, and Special Access Program commercial cloud services and support enabling the United States Space Force and partner agencies to meet multi-security level digital ecosystem needs. SYD81 SpaceDEN will deliver capabilities in collaboration, model-based systems engineering, modeling and simulation analysis, development security and operations, agile requirements management, external data integration, data analytics, visualization, and digital twin functionality. AWS is deemed the sole capable provider because it is the only cloud service provider with Authority to Operate accreditation for architectures meeting unclassified, Top Secret, and Special Access Program classification requirements, and it maintains the only platform capable of providing cross-domain solution secure multilevel security enclaves compliant with Joint SAP Implementation Guide requirements. Discontinuing AWS services would create mission failure risk, impact approximately 3,000 users including USSF service members, civilians, sister service personnel, industry partners, academic institutions, and international partners. Market research conducted between December 1, 2025, and June 14, 2026, and revalidated in July 2026 by surveying all four JWCC cloud service providers confirmed that only AWS currently possesses the required architectural and Special Access Program cloud-based capabilities. Price fairness and reasonableness will be determined through comparison with the independent government cost estimate and JWCC Catalog pricing previously established as fair and reasonable. The procurement history references a prior task order (FA205724F8551) with performance period January 23, 2025, through December 31, 2028, awarded under exception to fair opportunity.

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Source Selection Information -See FAR 2.101 and 3.104

SYD81 SpaceDEN with mission partners and stakeholders. SYD81 SpaceDEN delivers high-fidelity services to identify capability gaps, define performance requirements, and inform acquisitions. The primary focus areas include; collaboration, model-based systems engineering (MBSE), modeling simulation and analysis (MS&A), development security and operations (DevSecOps) and capture the flag assist, agile requirements and project management, external data integration, data analytics and visualization, and digital twin capabilities.

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.

5. DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF

THE EXCEPTION CITED:

1. UNIQUE QUALIFICATIONS:

AWS is the only cloud service provider (CSP) that can provide cloud services and support at the level the USSF requires, including the capability to provide cross domain solution secure multilevel security enclaves to meet the Joint SAP Implementation Guide requirements. AWS is currently providing operationally based mission critical cloud-based services and support and is the only CSP that has an Authority to Operate (ATO) accreditation for the existing cloud-based architectures. The current AWS architecture meets the USSF requirements at the unclassified, TS, and SAP security levels and provides the critical support needed to meet joint military operations. At this time, there are no other CSPs that have a cloud platform at the required SAP classification level and the ATO needed to meet mission requirements.

2. IMPACT:

There are several impacts to discontinuing AWS’s current critical cloud services and support. There is high risk of mission failure, along with impact to the ongoing capability development, RDT&E, MBSE, MS&A, analysis, fielding, test, training, and exercising efforts for USSF guardians and classified programs. Without continued performance by AWS, the program will not meet the Government’s need for critical mission and weapon systems development. Only AWS’s cloud services will enable the program to deliver and execute a minimum viable product, and support a multitude of engineering and threat analysis use-cases. AWS cloud offerings are necessary to adhere to the Presidential Executive Order 14186 Golden Dome initiative and support other classified weapon and mission systems. Switching to a different CSP would greatly impact current users of approximately 3,000 USSF service members, supporting civilians, DoW sister services, industry partners, academic institutions, and international partners by causing a lapse in cloud services and support. If and when another CSP can meet SAP and ATO requirements, time and planning is required to transition to another architecture. A re-architecture and re-engineering without sufficient transition time would pose an unacceptably high risk to the mission.

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 were 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, conducted between December 1, 2025, and June 14, 2026, it has been determined that only the aforementioned cloud service and support offerings provided by AWS can fully meet the Government’s need.

Additional research was conducted in July 2026 by reaching out to all four JWCC CSPs.

submitted a response confirming the ability to provide the architecture and SAP cloud-based capabilities that fully met the SYD 81s requirements. responded but currently does not have the architectural and SAP cloud-based capabilities required. and did not respond.

8. ANY OTHER SUPPORTING FACTS: None.

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. The SYD81 SpaceDEN team continuously evaluated cloud-agnostic data aggregation solutions across various CSPs and conducted technical market research across all four JWCC CSPs. The current task order ceiling has been reached. After reviewing the actions taken, it is determined that a sole source environment still exists.

The previous procurement was based upon an exception to fair opportunity.

Procurement History:

● TO Number: FA205724F8551

● PoP: January 23, 2025–December 31, 2028

● Competitive Status: Other than full and open competition/Exception to fair opportunity

In order to try to remove barriers and avoid future exceptions SYD81 will actively continue to evaluate cloud-agnostic data aggregation solutions across various CSPs. And to overcome technical barriers, SYD81 will continue to monitor the marketplace to see if other CSPs have developed the architectural and SAP cloud-based capabilities required.

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