A12 - Class Sole Source Justification - AWS - 2026-06-30 - Redacted - Final.pdf

SOLE SOURCE JUSITIFICATION

REFERENCE: Class Sole Source Justification in accordance with Federal Acquisition Regulation (FAR) 8.401(b) and General Services Administration Acquisition Regulation

(GSAR) 538.7104-3

1. Identification of Agency and Contracting Activity The Defense Advanced Research Project Agency (DARPA), Contracts Management Office (CMO), proposes to issue task orders directly to Amazon Web Services (AWS) for Cloud Credit Services under AWS’s General Services Administration (GSA) Federal Supply Schedule (FSS) contract.

2. Nature and/or Description of the Actions Being Approved These actions are for the procurement of specialized cloud computing services and associated cloud professional support services through AWS’GSA FSS contract vehicle. This justification supports the issuance of task orders directly to AWS to maintain mission continuity of operations for critical research and development (R&D) programs and to obtain unique or highly specialized cloud capabilities necessary to satisfy DARPA mission requirements.

3. Description of Supplies or Services Required The requirement encompasses the provision of cloud computing credits and associated professional support services, including high-performance computing environments, cloud-native application hosting, proprietary serverless architectures, accredited machine learning (ML) and artificial intelligence (AI) platforms, advanced analytics capabilities, cybersecurity-compliant cloud environments, specialized database architectures, and hybrid cloud solutions.

These services support DARPA programs conducting advanced research in AI/ML, cyber operations, microelectronics, autonomy, space technologies, biotechnology, national security applications, modeling and simulation, and large-scale data analytics. Continued access to these cloud environments is necessary to maintain operational continuity, cybersecurity compliance, and mission execution.

4. Estimated Value The estimated value of all task orders awarded pursuant to this class justification is

DARPA may issue one or more task orders to AWS under its GSA FSS contract, provided the total value of all task orders issued under this class justification does not exceed this estimated value.

Cloud Credit Services

5. Identification of the Exception to Fair Opportunity and Supporting Rationale

a. Exception Cited: GSAR 538.7104-3(b)((ii) – Only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized.

b. Supporting Rationale: DARPA conducted market research and technical assessments regarding commercially available cloud computing environments and determined that certain mission requirements necessitate continued use of the AWS cloud environment. DARPA's research portfolio includes advanced AI/ML, cyber, microelectronics, autonomy, space, biotechnology, and national security programs that rely upon cloud-native architectures, large-scale data analytics, high-performance computing resources, and accredited computing environments. Many of these workloads have been developed, tested, accredited, and deployed within the AWS ecosystems over multiple years and are tightly integrated with provider-specific services, security controls, application programming interfaces (APIs), data architectures, and development toolchains.

AWS commercial cloud environments currently support multiple operational DARPA workloads utilizing established serverless architectures, accredited security configurations, and existing Authority to Operate (ATO) approvals. AWS provides mature cloud-native services frequently used throughout existing DARPA technical office cloud environments, including and other integrated services that support advanced analytics and AI/ML development at the IL2 level. Transitioning the DARPA workloads to an alternative CSP would require significant redesign of cloud-native applications, redevelopment of automation scripts and infrastructure-as-code deployments, extensive testing and validation activities, cybersecurity reassessment, and reaccreditation efforts. Such activities would result in substantial duplication of costs and unacceptable mission delays while providing little or no corresponding benefit to the Government.

c. Migration and Operational Impact: DARPA determined that migration of existing operational workloads from AWS cloud environments to alternative CSP environments would result in substantial duplication of cost to the Government that is not expected to be recovered through competition. Existing DARPA cloud environments represent significant prior investments in application development, cloud engineering, cybersecurity implementation, data migration, workforce training, and operational support. Recompeting these requirements and transitioning to alternative providers would require the Government to incur many of these costs again without realizing corresponding savings sufficient to offset the transition expense. In many cases, the costs associated with migration, redevelopment, testing, and operational disruption would exceed any potential pricing advantages obtained through competition.

Migration would also require extensive engineering and redevelopment efforts. Modern cloud environments frequently rely upon provider-specific services, APIs, orchestration tools, security architectures, data storage mechanisms, and AI/ML platforms. Applications developed using AWS serverless services cannot typically be transferred to another provider without significant modification. Redevelopment activities would likely include application refactoring, infrastructure redesign, data conversion, software testing, performance validation, and reconfiguration of automated deployment pipelines. These engineering efforts would consume scarce technical resources and divert those technical resources from mission-focused research activities.

Significant cybersecurity reaccreditation activities would also be required. Existing DARPA cloud environments operate under approved cybersecurity frameworks, security architectures, and authorization packages that support ongoing mission execution. Migration to a different CSP would require reassessment of security controls, updates to system security documentation, vulnerability testing, risk assessments, security engineering reviews, and coordination with Authorizing Officials to obtain revised or new ATO approvals. Depending upon the complexity of the affected systems, these activities could require substantial time and resources and could delay deployment or continued operation of mission-critical capabilities.

Operational disruption to ongoing DARPA R&D programs would be unavoidable during large-scale cloud migrations. DARPA programs frequently involve time-sensitive experimentation, prototype development, data analysis, modeling and simulation, and collaboration among Government personnel, performers, and research institutions. Interruptions to cloud-hosted development environments, data repositories, AI/ML training platforms, or operational research systems could adversely affect program schedules, delay technical milestones, and reduce the effectiveness of ongoing research efforts. Maintaining continuity within existing cloud environments minimizes these risks and supports uninterrupted mission execution.

Finally, migration to alternative CSP environments would create unacceptable delays in mission execution. Cloud transitions of complex enterprise and research workloads typically require extensive planning, engineering, testing, validation, cybersecurity review, and user transition activities before operational use can resume. For DARPA programs operating under aggressive schedules and pursuing rapidly evolving national security objectives, delays associated with cloud migration could postpone critical research outcomes, technology demonstrations, experimentation activities, and transition opportunities. The resulting schedule impacts would not be in DARPA's best interest and would materially impair DARPA's ability to execute its mission effectively.

Based on the foregoing market research, technical assessments, and operational considerations, DARPA determined that continued use of the AWS cloud environments is necessary to satisfy DARPA’s minimum mission requirements. Limiting sources for applicable task orders is justified because the required services are unique or highly specialized, and transitioning to alternative providers would result in substantial duplication of cost and unacceptable delays that are not expected to be recovered through competition.

6. Determination of Fair and Reasonable Cost The Contracting Officer has determined that the anticipated costs to the Government will be fair and reasonable. All task orders will be issued as Firm-Fixed-Price (FFP). All task orders issued pursuant to this class sole source justification will utilize pricing established under AWS’s competitively awarded GSA FSS contract vehicle. The Contracting Officer will conduct and document appropriate price analysis at the task order level to support a determination the costs to the Government are fair and reasonable.

7. Other Supporting Facts This class sole source justification applies to all DARPA task orders issued under the AWS GSA FSS contract vehicle up to the estimated value of across all issued task orders.

Prior to pursuing this sole source procurement through AWS’s GSA FSS contract, DARPA evaluated the use of the Joint Warfighter Cloud Capability (JWCC) Indefinite-Delivery, Indefinite-Quantity (IDIQ) contract vehicle, which is the Department of War’s (DoW) preferred enterprise cloud credit acquisition vehicle pursuant to the July 31, 2023, memorandum issued by the DoW Chief Information Officer. However, after issuing the AWS JWCC task order request for proposal,

8. Actions to Overcome Barriers to Competition DARPA will continue to promote future competition by requiring data portability, maximizing the use of open standards where practicable, and encouraging the use of open-source standards where feasible to prevent long-term vendor lock-in. The Government will maintain ownership of all mission data, periodically reassess commercially available cloud capabilities through market research, evaluate the availability of future JWCC capabilities, and consider opportunities to compete future requirements whenever technical, operational, and cybersecurity considerations permit migration to alternative cloud environments without substantial duplication of cost or unacceptable delays.

Technical/Requirements Personnel Certification

I certify that the supporting data, including the identification of the Government’s minimum needs and the rationale supporting this exception to fair opportunity, are complete and accurate.

Approval

Deputy Director and Advocate for Competition

In accordance with GSAR 538.7104-3(b)(ii) and DARPA CMO Procedure 26-02A, I have reviewed this class sole source justification and determined that the cited exception, and the justification supports issuance of task orders pursuant to the authority cited herein.