852675242_JA_Final_Redacted.pdf

CUI

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JUSTIFICATION FOR EXCEPTION TO

FAIR OPPORTUNITY OR BRAND NAME

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

CSS Tracking Number: 852675242 Military Interdepartmental Purchase Request: W31XNJ62023418 Joint Warfighting Cloud Capability (JWCC) Contract: HC105023D0003 Procurement Title: Hybrid Cloud Landing Zone 04 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: U.S. Army (ARMY) /United States Army Corps of Engineers (USACE) Contracting Activity: Defense Information Systems Agency (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

This action is to issue a firm-fixed-price Task Order (TO) against the JWCC Indefinite Delivery/Indefinite Quantity Contract for USACE Hybrid Cloud Landing Zone 04. This TO will be issued directly to Microsoft Corporation (Microsoft). The anticipated period of performance (PoP) is for a 1-year base period. The total estimated value is of which will be funded by Operations & Maintenance (O&M) funds.

3. DESCRIPTION OF SUPPLIES/SERVICES:

The requirement will provide cloud services under the JWCC contract to perform an administrative “lift-and-shift” of the existing, fully operational Government Cloud enrollment at a total estimated cost of for a 12-month base period. This will allow the USACE to transfer the financial and contractual management of the established Hybrid Landing Zone Cloud Infrastructure to eh JWCC vehicle to continue active operations without service disruption or alteration to the authorized security boundary.

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.

J&A: Hybrid Landing Zone 04

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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:

Microsoft is the only JWCC Cloud Service Provider (CSP) capable of meeting the Government’s requirement because the USACE enterprise cloud environment is inherently and natively built upon Microsoft Azure proprietary architecture. This requirement is not a new-new cloud environment, but rather the sustainment, expansion, and continuous operations of the existing USACE Azure architecture which relies on millions of deployed components. Specific unique capabilities include:

a. Proprietary Platform-as-a-Service (PaaS) and Software-as-a-Service(SaaS) Integration: The USACE environment relies on hundreds of thousands of active instances of highly specialized, proprietary services native to the Azure fabric, including Azure NetApp Files, Microsoft Defender for Cloud, Azure Databricks, and Azure-native managed database services (Azure Structed Query Language (SQL) and PostgresSQL). Only Microsoft possesses the underlying source architecture to sustain and expand upon these offerings without forcing the Government to rebuild entire databases or refactor mission-oriented applications.

b. Native Enterprise Identity and Access Interoperability: The entire USACE cloud security posture and zero-trust framework are anchored in Microsoft’s proprietary identity management system, Microsoft Entra ID (Azure Active Directory), which manages authentication, conditional access, and zero-trust policies for the global USACE workforce. No other JWCC CSP can natively ingest, manage, or operate this identity architecture without and enterprise-wide overhaul of how USACE authenticates and secures its network

c. Infrastructure-as-Code (IaC) Continuity: Over its operational lifecycle, USACE has developed and deployed complex IaC templates written specifically in proprietary Azure Resource Manager formats. Transitioning to an alternative JWCC CSP would render thousands of lines of automation and telemetry scripts useless, requiring an immediate and complete rewrite.

2. IMPACT:

Pursuing competitive procedures for the sustainment of the existing USACE enterprise cloud environment would result in catastrophic operational, technical, and fiscal impacts, beginning with an immediate and severe degradation of mission-critical civil works and disaster response capabilities during an extended migration period. Transitioning to an alternative JWCC CSP would mandate severing the currently active, accredited DISA Boundary Cloud Access Point (BCAP) connection, introducing a 6-to-12-month network outage, and completely invalidating the existing Risk Management Framework Authority to Operate (ATO), which would require another 6-to-9 months to re-accredit.

Furthermore, to maintain baseline operations during this multi-year transition, the Government would be forced to fund parallel dual-hosting of both cloud environments for an estimated 24 months, alongside bearing the immense labor costs to re-train the workforce and rewrite thousands of lines of IaC, creating a massive, unrecoverable duplication of taxpayer funds that far outweighs any potential savings from competition.

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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.

The ARMY conducted market research in June 2026 by reviewing capabilities within the JWCC contracts. The Government initiated a formal inquiry on June 24, 2026, by transmitting Additional Research to Support an Exception to Fair Opportunity to all four JWCC CSPs with a closing date of July 1, 2026. The solicitation resulted in active engagement from three of the four vendors: Google formally responded that they would not participate; Oracle failed to respond prior to the deadline; Microsoft and Amazon Web Services (AWS) submitted technical responses.

While AWS submitted a technical white paper demonstrating general cloud-hosting capability, technical and operational evaluations concluded that only Microsoft Corporation can meet the Government's minimum requirements. Any solution other than Microsoft is incapable of sustaining the pre-existing proprietary Azure components, cannot support the existing identity access management (Microsoft Entra ID) without an enterprise-wide overhaul, and cannot ingest existing Azure-specific IaC. Furthermore, an alternative solution would require severing the active DISA BCAP connection and invalidating the active ATO, causing an unacceptable 6-to- 12-month service disruption and a substantial, unrecoverable duplication of cost over an estimated 24-month transition period. Therefore, it has been determined that only Microsoft can fully meet the Government’s needs.

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:

The previous procurement was not based upon an exception to fair opportunity under FAR Part

16.5. This is the initial J&A under the JWCC contract vehicle, as the previous procurement was executed as a Limited Sources action under a GSA Blanket Purchase Agreement (BPA) in accordance with FAR 8.405-6. Since the award of the current contract, circumstances have changed in that USACE has fully established, engineered, and accredited a highly complex, live, and mission-critical cloud environment natively within the Microsoft Azure ecosystem. After reviewing the current technical and operational architecture, it is determined that a sole-source environment now exists due to the extreme complexity of the pre-existing proprietary

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Procurement History:

• Contract Number: N6600121A0083

• Task Order Number: W9127825FA138

• Period of Performance: September 18, 2025 – September 17, 2026

• Other than full and open competition/Limited Sources (GSA BPA under FAR 8.405-6)

To overcome future barriers, the agency will monitor strategies for new, cost-effective tools that make moving between cloud platforms easier. Any future development will attempt to be as cloud-neutral as possible to avoid further vendor lock-in. The agency will re-evaluate competing this requirement when a secure, technically viable migration plan becomes available that does not disrupt ongoing operations or cause wasteful, duplicate hosting costs.

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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: Mrs. Teresa Cathleen Parks SIGNATURE/DATE:

TITLE/ORGANIZATION: GIS Program Manager, ARMY

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: Mrs. Teresa Cathleen Parks SIGNATURE/DATE:

TITLE/ORGANIZATION: GIS Program Manager, ARMY

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: DISA/DITCO/PS8511

ALL QUESTIONS REGARDING THIS JUSTIFICATION ARE TO BE REFERRED TO

Jacob Sopiars, , jacob.m.sopiars2.civ2mail.mil