A38_JEFO_-_Mobile_Phone_Service_-_PBGC_ITIOD_-_REDACTED_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

BRAND NAME LIMITED-SOURCES JUSTIFICATION

AUTHORITY: FAR 8.405-6 and 40 U.S.C 501

Requirement: Smartphones Wireless Services / PBGC, ITIOD

This acquisition is conducted under the authority of the Multiple Award Schedule Program.

1. Identification of the agency and contracting activity, and specific identification of the document as a “Limited-Sources Justification.”

This document is a limited source (Brand Name) justification for the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division I, Branch IV, on behalf of the Pension Benefit Guaranty Corporation (PBGC), Information Technology Infrastructure Operations Department (ITIOD).

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

This is a follow-on requirement to Contract GS-35F-0297K, Task Order 16PBGC19F0031. The Contracting Officer intends to award a limited source (Brand Name) Task Order against the General Services Administration’s (GSA) Wireless Mobility Solutions Program, Multiple Awards Schedule (MAS) – Information Technology vehicle under Special Item Number (SIN) 517312. Brand name Apple products/peripherals are sought as portion of this requirement.

This requirement will be competed amongst the five (5) vendors who can provide wireless carrier services. See below table.

Vendor

AT&T MOBILITY LLC

CELLCO PARTNERSHIP

MANHATTAN TELECOMMUNICATIONS CORPORATION

VODAFONE GLOBAL ENTERPRISE LTD

WIDEPOINT INTEGRATED SOLUTIONS CORP

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

The Pension Benefit Guaranty Corporation (PBGC) is seeking a fast and effective way to manage and operate the services and service-enabling devices (SEDs). PBGC seeks to replace the current wireless devices and services which are critical to the agency’s Continuity of Operations Program (COOP) readiness with new services and devices.

PBGC is primarily concerned with maintaining consistent service coverage in all work

Requirement: Smartphone Wireless Services / PBGC, ITIOD areas and providing voice and data for a predictable cost regardless of where our employees are conducting business. See below table for products/services sought.

Description Quantity Apple iPhone 15s 128GB/Stock 100

1200 Smart Phone Device monthly plans: unlimited data AND 100 minutes/400 minutes pooled voice plans

Unlimited International data and voice service with tethering 1

Estimated overages/additional international services 1

Training and Support 1 Part-Time Project Manager 1 Mobile Device Website 1 Estimated trade in credit for 1200 iPhone 12s 64GB 1200 Apple iPhone 15s 128GB/w Activation 1200 USB-C Charge Cable 2600 USB-C Power Adapter 700 Phone Cases 1500 Phone Screen Protectors 1500 Ear Buds 200

Note that the brand name Apple products within this requirement include the Apple iPhone 15s as well as Apple brand name compatible peripherals USB-C Charge Cable, USB-C Power Adapter, Phone Cases, Phone Screen Protectors, and Ear Buds. Bold added in above table, for emphasis.

Estimated Value The estimated total contract value is $ . Of this amount, $ across the requirement is for Apple products/peripherals.

The total value per period of performance is broken out below.

Base Year: $ Option Year 1: $ Option Year 2: $ Option Year 3: $

Period of Performance

Base: 06/09/2024 – 06/08/2025 Option Period 1: 06/09/2025 – 06/08/2026 Option Period 2: 06/09/2026 – 06/08/2027 Option Period 3: 06/09/2027 – 06/08/2028

4. The authority and supporting rationale (see 8.405-6(a)(1)(i) and (b)(1)) and, if applicable, a demonstration of the proposed contractor’s unique qualifications to provide the required supply or service.

FAR 8.405-6(b)(1) – Items peculiar to one manufacturer (brand name).

ITIOD has explored, researched, and tested multiple mobile phone Operating Systems and management platforms to determine which products produce the best combination for managing and delivering mobile phone service to PBGC. Apple iPhone models have been vetted and accepted by PBGC to successfully meet PBGC's security and operational requirements. Android phones are the closest acceptable competitor to the Apple iPhones in features and usability, but have significant security issues not present in similar Apple devices.

Android phones require a digital security container, e.g.“Knox” for Samsung Android devices, creating a dual persona on the Android phones. These digital security containers require additional management and oversight by PBGC staff, additional licensing costs annually, and additional training to end-users, Service Desk personnel, and ITIOD operations staff to understand the features and functionality of an alternate container system. Furthermore, Android phone users will need to understand the difference between working within the security container in a safe environment and operating outside of the security container, where sensitive data can be easily compromised. And even if the Android user does perfectly understand how to operate the Android phone within the digital security container, the possibility remains for the accidental, unsecure exposure of sensitive data should the user forget to operate within the digital security container, instead of outside of it, when executing official work duties.

Additionally, Android phones would require additional anti-virus software while Apple iPhones do not. Apple iPhones also meet the DoDI 8500.2 virus protection requirements through a combination of security policies, application sandboxing, and code signing. Security on the Apple iPhone is transparent to the end-user and built into the operating system. Sensitive data is protected seamlessly within the iPhone device itself and does not require the end-user to be cognizant of which environment is in use.

Maintaining the brand name of Apple iPhone also comes with benefits due to PBGC's end-users already being familiar with the Apple operating system. This helps to ensure the security of PBGC's mobile phone service. PBGC also has established security controls, operation and maintenance procedures, end-user and Service Desk personnel knowledge-based articles tailored to the Apple iPhone, as well as trained PBGC's end-users on using this device, and trained Service Desk personnel to troubleshoot this device. Any other brand of mobile phone would require extensive rework of the current infrastructure of support and management of the mobile phone service. A new device management system would need to be tested, enabled, and configured which would require significant manhours to transition PBGC to a new mobile phone device, resulting in a significant cost increase to provide mobile service to PBGC. Furthermore, the time required to configure, secure, and organize a deployment of mobile phone models to something other than an iPhone would require substantial transition time (more than 6 months).

Lastly, should a non-Apple device be acquired, PBGC would be forced to operate a dual system for its current iPhone users and the new users who would have a non-Apple device for an extended period of time. This would require a longer transition period to accommodate the mandates of a new mobile phone device, operating system, and infrastructure and could lead to a significant increase in the risk of outdated security on the current Apple mobile devices. This would leave PBGC data open for potential compromise, which is unacceptable. Also, transitioning to a new mobile phone operating system would constitute a change in the work environment and would require reaching an agreement with PBGC's union on the impact and implementation of this change, which could take far more than 6 months. All transition tasks will increase manhours associated with the management, oversight, and support of the mobile phone service and risk the loss of mobile service to PBGC with little, if any, appreciable gain in functionality, efficiency, or productivity across the agency.

As it stands currently, PBGC has invested significant time, effort, and cost into creating an infrastructure around the Apple iPhone devices and maintenance to the current configured mobile phone service. Maintaining this infrastructure and support is an efficient use of government funds and a reasonable investment in PBGC’s support of a more mobile workforce.

5. A determination by the ordering activity contracting officer that the order represents the best value consistent with FAR 8.404(d).

The price of the products and services are based on existing line items that have been negotiated by GSA and determined to be fair and reasonable by the GSA Contracting Officer in accordance with FAR 8.404(d)) prior to award of the Offeror’s GSA contract.

GSA’s Wireless Mobility Solutions Program is a Best-in-Class (BIC) contract vehicle for commercial mobility solutions.

GSA schedule contracts are negotiated to achieve the contractors' "most favored customer" pricing/discounts under similar conditions. To ensure that they receive the best value at the lowest overall cost when using Schedule contracts, agencies are always encouraged and empowered to seek price reductions at any time before placing an order. By seeking discounts on all orders, the government can take advantage of flexible and dynamic pricing in the commercial marketplace. As such, additional discounts will be requested from the Offeror at time of solicitation.

In addition, this acquisition is for commercially available products with several years of historical data based on previous contracts that will help ensure the Government receives a fair and reasonable price. To better ensure fair and reasonable pricing, the