852675230 JA_FINAL_Redacted.pdf

CUI

J&A: System Delta 81 Secure Cloud

Page 2 of 4 Pages logging, and data-integrity requirements. Separate cloud environments at each classification level do not satisfy the requirement unless they are connected through an authorized cross-domain capability that supports the required data flows and operational timelines.

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: Currently, AWS is the only commercial cloud service provider (CSP) that currently possesses a pre-approved, fully integrated Cross Domain Solution (CDS) capable of automated data streaming between SECRET and TOP SECRET security classifications while remaining fully compliant with the National Security Agency’s (NSA) "Raise the Bar" (RTB) initiative. AWS's cross-domain streaming mechanisms exist within boundaries that have already undergone rigorous Department of War (DoW) and Intelligence Community (IC) assessment. After receiving responses from all CSPs (Oracle, Google, and Microsoft), the government verified no other CSP is currently capable of supporting the requirement of streaming SECRET data to a TOP SECRET environment in near-real time.

2. IMPACT: The USSF currently utilizes a private data center; however, due to the

'sunsetting' of the private data center, a commercial cloud alternative is required to support the US Space Force (USSF) Test and Training requirements and prevent loss of a capability before October 2026. Attempting to engineer a similar RTB-compliant streaming architecture in an alternate cloud environment would require an estimated 24 months of custom engineering, independent testing, and Authorization to Operate (ATO) adjudication, and would therefore not meet the Government’s current need of an operationally available, appropriately assessed and authorized CDS capable of automatically transferring approved SECRET data into a TOP SECRET/SCI environment in near real time. Failure to provide a capability before October 2026 will directly result in mission failure and compromised national security. If competitive procedures were pursued, the USSF will be unable to perform the required test and training activities to verify and validate system kill chain analysis and leave the United States national security at risk due to the urgency and time sensitivity associated with this requirement.

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.

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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.

Beginning on December 1, 2025, System Delta 81 began utilizing JWCC/DISA market research resources to establish a baseline understanding of the current CSP capabilities. After reviewing all DISA/JWCC market research repositories, an initial conclusion was reached that AWS is the only CSP currently capable of supporting the USSF Test and Training requirements.

Additionally, market research included listening to CSP customer representatives (Amazon, Google, Oracle, Microsoft) during reverse industry days, engaging with government cloud offices (DISA, AFLCMC, 16th AF), reviewing government contract offerings and their associated service catalogs (Commercial Cloud Enterprise (C2E), JWCC) and speaking with Federally Funded Research and Development Center (FFRDC) 3rd party technical experts (Aerospace Corp.)

On June 15th, 2026, all CSPs (Google, Oracle, and Microsoft) were contacted directly via JWCC inboxes and asked to provide current status of cross domain solution capability maturity. All responses reviewed and it was confirmed no other CSP is capable of supporting the USSF requirement to stream SECRET data to TOP SECRET environments in near real time without incurring significant cost and schedule delays. A critical Government need is an operationally available, appropriately assessed and authorized CDS capable of automatically transferring approved SECRET data into a TOP SECRET/SCI environment in near real time. The capability must support time-sensitive test, training, sensor, and mission-event data while enforcing Government-approved transfer rules, filtering, validation, classification markings, access controls, cybersecurity protections, audit logging, and data-integrity requirements. Separate cloud environments at each classification level do not satisfy the requirement unless they are connected through an authorized cross-domain capability that supports the required data flows and operational timelines.

8. ANY OTHER SUPPORTING FACTS: N/A

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

THAT LED TO THE EXCEPTION TO FAIR OPPORTUNITY:

(a) To overcome future barriers to competition, USSF is preparing a fair opportunity competitive follow-on requirement. The follow-on is expected to be completed, solicited, and awarded by Jan. 1, 2028.

(b) Procurement History:

Not Applicable

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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: Michael Hintzman SIGNATURE/DATE:

TITLE/ORGANIZATION: Section Chief, United States Space Force (USSF)

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: Michael Hintzman SIGNATURE/DATE:

TITLE/ORGANIZATION: Section Chief, United States Space Force (USSF)

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

NAME: Jacob R. Benhoff SIGNATURE/DATE:

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

PROCURING ACTIVITY COMPETITION ADVOCATE (PACA) 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 does not exceed $100M, this review serves as approval and my written determination that the aforementioned FAR circumstances apply.

NAME: Andrea Horstmann SIGNATURE/DATE:

TITLE/ORGANIZATION: PACA

PHONE:

ALL QUESTIONS REGARDING THIS JUSTIFICATION ARE TO BE REFERRED TO

Samantha A. Kathmann, .