A.3 DoW ESI -FAR Subpart 16.5 Justification for Use of Exception to Fair Opportunity - Cisco Firewalls - Redacted.docx

UNITED STATES MARINE CORPS

MARINE CORPS INSTALLATIONS NATIONAL CAPITAL REGION

MARINE CORPS BASE QUANTICO

3250 CATLIN AVENUE

QUANTICO, VIRGINIA 22134-5001

FAR Subpart 16.5 Justification for Exception to Fair Opportunity

FAR Subpart 16.5 Justification for Exception to Fair Opportunity

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY – NASA SEWP

(Acquisition under the Simplified Acquisition Threshold)

1. Identification of the agency and the contracting activity.

The Contracting Activity is the Marine Corps Installations National Capital Region – Regional Contracting Office (MCINCR-RCO), located at 2010 Henderson Road, MCB Quantico, VA. The requiring activity is Marine Corps Intelligence Surveillance Reconnaissance Enterprise (MCISRE) Insider Threat Program (InTP) M270 located at MCB Quantico, VA

2. Nature and/or description of the action being approved.

The action being approved is an exception to fair opportunity to fulfill a brand-name specific requirement for Cisco Next-Generation Firewall (NGFW) hardware, software subscriptions, and specialized professional engineering services. This acquisition supports the Marine Corps Intelligence Surveillance Reconnaissance Enterprise (MCISRE) Insider Threat Program (InTP) operating within the M270 environment for six (6) Cisco Next-Generation Firewall Appliances, two (2) Cisco Centralized Firewall Management Consoles, two-hundred and forty (240) Specialized Professional Service Support Credits, and one hundred and sixty (160) Training Credits (USMC Network Administrators).

This requirement encompasses the end-to-end modernization and replacement of legacy network security infrastructure within a strictly controlled Impact Level 5 (IL5) environment. To ensure zero degradation to active intelligence missions, the contractor shall provide specialized professional services to execute the following critical lifecycle phases:

· Pre-Deployment Engineering: Conducting comprehensive environmental discovery and engineering secure Low-Level Designs (LLD).

· Migration & Integration: Executing complex security policy migrations, cryptographic configurations, and endpoint integration to align with Department of War (DoW) Zero Trust Architecture (ZTA) mandates.

· Validation & Sustainment: Performing rigorous post-implementation system validation to preserve the network's Authority to Operate (ATO). Furthermore, the action includes dedicated ongoing engineering services for continuous infrastructure sustainment, quarterly proactive health checks, and secure vulnerability patch management.

Due to the highly sensitive and operational nature of the MCISRE InTP mission space, all contractor engineering personnel must possess the requisite national security clearances. Furthermore, personnel must maintain strict, continuous compliance with DoD 8140 / 8570.01-M Information Assurance (IA) and Cyber Workforce certification mandates prior to accessing the network.

This procurement will be executed in accordance with the Department of Defense (DoD) DoD ESI Ordering Guide for Cisco Systems, Inc. under the established DoD ESI Agreement through NASA SEWP V (Agreement Period of Performance: January 21, 2021 – End of NASA SEWP V). This acquisition directly supports the Marine Corps Intelligence Surveillance Reconnaissance Enterprise (MCISRE) Insider Threat Program (InTP) operating within the M270 environment.

3. Description of the supplies or services required to meet the agency’s needs (including the estimated value).

The Marine Corps Intelligence Surveillance Reconnaissance Enterprise (MCISRE) Insider Threat Program (InTP) requires the procurement of brand-name Cisco hardware, software subscriptions, and specialized professional engineering services to execute a comprehensive modernization to a Next-Generation Firewall (NGFW) architecture.

This mission-critical effort encompasses the end-to-end replacement of legacy network security infrastructure within a highly sensitive operational environment. To ensure zero degradation to active intelligence operations, the contractor shall provide specialized professional services to execute the following critical lifecycle phases:

· Pre-Deployment & Architecture: Conducting in-depth environmental discovery and engineering secure Low-Level Designs (LLD).

· Migration & Implementation: Executing complex security policy migrations and performing rigorous post-implementation system validation to preserve the network's security posture and accreditation.

· Continuous Sustainment: Providing ongoing professional services for continuous infrastructure support, quarterly proactive health checks, and secure vulnerability patch management.

Due to the classified and sensitive nature of the MCISRE InTP mission space, all contractor engineering personnel must possess the requisite national security clearances prior to deployment. Furthermore, personnel must maintain strict, continuous compliance with DoD 8140 / 8570.01-M Information Assurance (IA) and Cyber Workforce certification mandates to be granted privileged network access.

The Government intends to issue a single Firm Fixed Price (FFP) order with fixed-price CLINS against a NASA SEWP contract vehicle. This requirement is for one (1) twelve-month base period. The required base delivery/performance start date is 24 August 2026.

The total estimated value for this procurement is $ XXX,XXX.XX base period only. Marine Corps Procurement (PROC) appropriations will be used to fund this requirement as outline in the table below:

Base Period

4. Identification of the exception to fair opportunity and the supporting rationale.

This justification is prepared in accordance with FAR 16.507-6 and satisfies the applicable justification and approval requirements for exceptions to fair opportunity for orders placed under multiple-award contracts. In accordance with the ordering procedures at FAR 16.507, this action meets one of the statutory exceptions permitting an exception to fair opportunity for the Department of War and NASA under 10 U.S.C. 3406(c)(5).

Pursuant to FAR 16.507-2(a)(3), the ordering process is not subject to the competition requirements in FAR Part 6. An exception to fair opportunity is justified for this requirement due to the strict compatibility, interoperability, and enterprise-architecture constraints associated with the DoW Enterprise Software Initiative (ESI) program. Therefore, utilizing the mandated DoW ESI program, only the brand-name Cisco Next-Generation Firewall (NGFW) hardware and software suite possesses the unique capabilities required to satisfy the agency's critical IL5 cybersecurity requirements and ensure seamless, uncompromised integration into the DoW’s enterprise defense-in-depth architecture.

The Deputy Commandant for Information (DC I), Intelligence Division, MCISRE InTP (M270) necessitates the procurement of brand-name Cisco Next-Generation Firewall (NGFW) appliances and associated licensing to maintain its accredited network security posture. The existing M270 intelligence infrastructure is fundamentally engineered around a Cisco-centric architectural baseline. Cisco products constitute the accepted, mandated standard for firewalls on this network.

To maintain this technical baseline and execute the necessary network modernization, the Government requires specific Cisco NGFW components and specialized engineering services. This acquisition consists of three integrated pillars:

· Hardware & Appliance Infrastructure: The core of this requirement encompasses the procurement of high-throughput Cisco Secure Firewall 3105 Threat Defense Appliances and Cisco Secure Firewall Management Center 1700 Chassis. These specific hardware models are technically required to process encrypted intelligence traffic at scale without introducing network latency. The procurement includes all necessary physical infrastructure components, such as redundant AC power supplies, solid-state drives (SSDs), specialized network interface cards (NICs), and transceiver modules.

· Software Licensing & Threat Defense Subscriptions: The hardware must be activated and sustained via mandatory Cisco software subscriptions. This includes the Cisco Secure Firewall 3105 Threat Defense 5-Year Subscriptions, which provide continuous, automated updates for intrusion prevention, malware defense, and URL filtering. Additionally, the Firewall Management Center Software (v7.4) is required to provide a centralized, single-pane-of-glass administrative interface, enabling Marine Corps personnel to push security policies uniformly across the enterprise.

· Specialized Professional Services & Training: Due to the complexity of the IL5 environment, this requirement mandates 240 hours of Specialized Professional Services. These services provide certified Cisco network engineers to execute environmental discovery, complex policy migrations, cryptographic configurations, and rigorous post-implementation system validation. Furthermore, the procurement includes 160 Vendor Training Credits, which are essential to upskill current USMC network administrators, ensuring the government can independently operate and sustain the newly modernized architecture upon completion of the contractor's integration efforts.

The following technical market research comparison illustrates exactly why Cisco is the only viable technical solution, and why the evaluated alternatives introduce unacceptable mission failures:

Transitioning to another cybersecurity vendor is not feasible because it would require the physical removal and replacement of the core network boundary devices, the redevelopment of enterprise routing and security baselines, migration to an entirely new centralized management platform, and the full re-accreditation of the IL5 environment.

Such a transition would impose substantial cost and schedule impacts, including extensive network re-engineering, the manual reconfiguration of complex cryptographic tunnels and thousands of endpoints, and the rigorous revalidation of all inherited cybersecurity controls. Additionally, Marine Corps network defenders would require immediate, extensive retraining on unfamiliar administrative tools and firewall operating systems. Most critically, the organization would incur significant, unacceptable operational downtime during the physical cutover and transition period. These combined factors—duplicative engineering costs, schedule delays, unbudgeted training, ATO recertification, and operational disruption—render any transition to a non-Cisco solution impractical and fundamentally incompatible with mission-critical intelligence requirements.

In summary, Cisco is the only brand-name solution capable of meeting the Marine Corps’ minimum cybersecurity, interoperability, and IL5 operational requirements without causing severe mission degradation. No alternative vendor can provide native compatibility with the existing enterprise security architecture and the centralized Cisco Firewall Management Center (FMC), nor can they satisfy these technical needs without introducing extensive duplicative costs, unacceptable deployment delays, and high-risk re-accreditation efforts. Procuring this capability via the mandated DoD ESI Cisco Agreement ensures strict compliance, hardened security, and operational continuity for critical intelligence services within the Department of War.

In accordance with DFARS 208.7402, Department of War (DoW) components are required to fulfill requirements for commercial software and related services through the DoD Enterprise Software Initiative (ESI) when an agreement is in place for the required items. The required Cisco firewall products, licenses, and associated support are available through the established DoW ESI Agreement for Cisco Systems, Inc., executed via the NASA SEWP V Government-Wide Acquisition Contract (GWAC) (Agreement Period of Performance: January 21, 2021 – End of NASA SEWP V).

Market research into this mandated vehicle confirmed a robust industrial base capable of fulfilling the Government's requirement. Specifically, query analysis of the Cisco DoD ESI on NASA SEWP V identified fifteen (15) authorized Value-Added Resellers (VARs), consisting of seven (7) small businesses and eight (8) other-than-small businesses. To adhere to statutory socio-economic goals while utilizing the required ESI framework, the Marine Corps will solicit this requirement as a 100% Total Small Business Set-Aside restricted to the seven capable small business partners. Utilizing this mandated ESI vehicle and leveraging the competitive small business pool guarantees the Government receives pre-negotiated, heavily discounted pricing, standardized terms and conditions, and represents the absolute best value to the DoW.

5. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will determine the anticipated price to be fair and reasonable by confirming that the quoted pricing aligns with, or is lower than, the contractor’s established NASA SEWP contract rates and reflects current competitive market conditions. The Contracting Officer will also review available commercial pricing to ensure the Government is receiving the best value. If more advantageous pricing is identified through other commercial sources, the Contracting Officer will apply the procedures outlined in DFARS PGI 208.7403 to obtain the lowest available price consistent with DoW Enterprise Software Initiative (ESI) requirements.

6. Any other facts supporting the justification.

N/A

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

The Cisco network and security architecture is deeply integrated into the Marine Corps Intelligence Surveillance Reconnaissance Enterprise (MCISRE) Insider Threat Program (InTP) environment. Replacing the existing infrastructure would require substantial, non-recoverable investments in time and cost, and would introduce significant operational disruption to procure, configure, accredit, and train personnel on a completely new system. These deeply entrenched technical and financial factors currently limit the feasibility of full and open competition.

To reduce these barriers for future acquisitions, the Government will take the following actions:

· Continuous Market Research: The program office will conduct continuous market research to identify emerging network security solutions that may meet the Marine Corps’ unique technical, operational, and Impact Level 5 (IL5) requirements. As new vendors or technologies are added to the DoD ESI or become capable of meeting the Marine Corps’ interoperability and security needs, the Government will reassess the market.

· Future Requirements Planning: During future technology refresh cycles and requirements planning, the program office will evaluate the feasibility of architecting solutions that are less dependent on a single manufacturer, with the goal of fostering a more competitive environment for subsequent acquisitions.

These actions will ensure that while the current brand-name requirement is necessary, the agency remains proactive in seeking opportunities to overcome these barriers in the future.

In accordance with DFARS 208.7402, the agency will continue to leverage the DoW Enterprise Software Initiative (ESI) for commercial software and related services. ESI serves as the primary mechanism for identifying approved enterprise software solutions and ensuring standardized terms, pricing, and licensing across DoW. As new vendors or technologies are added to ESI or become capable of meeting the Marine Corps’ interoperability and security requirements, the contracting office will reassess the market and consider competition for future acquisitions.

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this Justification are accurate and complete to the best of my knowledge and belief.

Technical/Requirements Cognizance:

CONTRACTING OFFICER CERTIFICATION

I certify that this Justification is accurate and complete to the best of my knowledge and belief.

(Strat Branch, 02 April 2026)

(Strat Branch, 02 April 2026) image1.png