ANNEX 1 - JUSTIFICATION AND APPROVAL_5G PIN_Final_CCO 8.27.pdf

ANNEX 1 – JUSTIFICATION AND APPROVAL

J&A No. 15012

SOLE SOURCE JUSTIFICATION AND APPROVAL (J&A)

FOR USE OF OTHER THAN FULL AND OPEN COMPETITION

1. Contracting Activity.

Marine Corps Logistics Command (MARCORLOGCOM)

Contracts Department

814 Radford Blvd

Albany, GA 31704

2. Description of the Action Being Approved.

Award of a sole source contract to Federated Wireless for support services in the areas of Project

Management (PM), Model-Based System Engineering (MBSE), Risk Management Framework

(RMF), Network Security Operations Monitoring Services, and Technical Support for Marine

Logistics Command (MARCORLOGCOM). This contract will include the operationalizing and sustainment of The Marine Corps Logistics Base Albany (MCLBA) 5G Private Infrastructure

Network (PIN), which was developed for the Office of the Under Secretary of Defense for

Research and Engineering (OUSD R&E) through the 5G to NextG Program.

3. Description of Supplies/Services.

Subject to the provisions of the contract, Federated Wireless will provide 4G and 5G Private

Wireless systems, equipment, and services. The Private Wireless systems will provide advanced wireless communications capabilities in support of Logistics Modernization and other Marine Corps missions. Tenants include Marine Force Storage Command (MFSC), Marine Depot Maintenance

Command (MDMC), and Defense Logistics Agency (DLA). Private Wireless Support Services include day-to-day operations, maintenance, user support, technical support, and continuous monitoring for cybersecurity compliance.

Period of Performance: The period of performance for this sole-source action is 01 November 2024

– 31 April 2028, which includes a 12-month base period, two 12-month option periods, and a six-month option period. If all options are exercised, the total period of performance will be three years and six months. The estimated dollar value of the contract is and FY24 Navy Working Capital

Funds (NWCF) funding will be used for this requirement.

4. Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. 3204(a)(1), as implemented by the Federal Acquisition Regulation (FAR) 6.302-1. Only one responsible source and no other supplies or services will satisfy agency requirements.

5. Rationale Justifying Use of Cited Statutory Authority.

Competitive procedures were used for the selection of parties for participation in the original contract award for Federated Wireless' project agreement NSC-20-2010. The duplicative costs to the Government to have a new vendor provide these services would be estimated based on past actual costs to be approximately. A new vendor would be required to start at Risk Management

Framework (RMF) Step 1, leading to significant duplicative investment in the implementation and evaluation of the system cybersecurity posture. In addition to a new implementation and evaluation effort, Authorization to Operate(ATO) certification would require at least twelve (12) to eighteen (18) months of work from both the contractor and government teams, significantly delaying any operational capability.

5.1 System Capabilities. The 5G PIN has been developed over a period of three (3) years under the

Federated Wireless Project Agreement NSC-20-2010 specifically designed and deployed to meet

Marine Corps operational and security requirements. The system provides multiple capabilities above and beyond a typical wireless solution, including a Zero Trust Architecture (ZTA), Enterprise-Grade Identity, System Management, Multi-Tenant Configuration, and access to CBRS

Shared Spectrum for worldwide operation on the same equipment and frequencies.

5.2 System Maturity. The 5G PIN and associated technologies are the only 5G Private Wireless system deployed at scale, with over sixty (60) radios deployed providing approximately 1 million square feet of indoor and outdoor high-bandwidth coverage. Federated Wireless is currently at a

Technology Readiness Level TRL 7. Upon receiving the Interim Authorization to Test( IATT), the technical maturity of the Federated Wireless system will be at a TRL 8. Three (3) months following

IATT, an ATO will be attained certifying full system operations meeting all design criteria and operating within a production environment.

5.3 Risk Management Framework Cybersecurity Hardening. With the expectation that Marine

Corps would sanction an IATT within three (3) months of contract award, alternate solutions to the current 5G PIN would result in a significant negative impact to ATO certification process. The 5G

PIN at MCLBA has undergone extensive cyber analysis and hardening under the NIST Risk

Management Framework (RMF), NIST 800-53 Controls, ACAS scans, and DISA STIGs. The

Marine Corps and OUSD R&E have made significant investments in the security evaluation of the overall system architecture & implementation, and in the cyber artifacts created as part of the RMF process. This is already a time-intensive process, and any delays have the potential to interfere with system operation, as a system cannot be connected to the 5G PIN before that system has an ATO.

Due to the unique capabilities developed by Federated Wireless, the selection of an alternative contractor would extend the timeline and add significant program costs towards achieving an

(ATO).

Any deviations from the existing baseline infrastructure/architecture will incur a significant impact on the ability to carry out mission objectives by requiring cost intensive hardware replacement, software procurement and licensing, and system integration, optimization, and testing.

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable.

No other efforts were made to solicit offers. This requirement is transitioning from the completion of the 5G Network Prototype Program to the sustainment phase. The Government has verified that Federated Wireless successfully met the requirements of the Prototype Program based on the Agreements Officer Representative (AOR) Determination of Successful

Completion under the Spectrum Other Transaction Agreement (OTA), W15QKN-15-9-1004.

Due to the unique capabilities developed by Federated Wireless, the selection of an alternative contractor would extend the timeline and add significant program costs towards achieving an authority to operate (ATO).

7. Determination of Fair and Reasonable Cost.

The Contracting Officer has determined the anticipated cost to the Government of the supplies/services covered by this J&A will be fair and reasonable based off the current contract for all labor categories, 2021-332/NSC-20-2010, a Competitive Sole Source to Federadted

Wireless; PoP 12/4/2020 to 10/31/2024.

8. Actions to Remove Barriers to Future Competition.

NIWC Atlantic, the requirements owner of the Prototype Program is continuously reviewing data on the industry and commercial services that provide similar functionality/capability. However, Federated Wireless is the only solution available in deploying the 5G PIN and associated technologies. Federated Wireless has 12 to 18 months ahead of the other contractors implementing this technology on DoD installations using similar infrastructure and components, and therefore the only source capable of providing the system required to perform the necessary tasks for this effort. Introducing a different vendor would cause an inability to support the customer’s requirement for operation and security. Should other acceptable sources become known that meet the Government’s unique needs, appropriate action to ensure competition will be taken.

J&A No. 15012

CERTIFICATIONS AND APPROVAL

TECHNICAL/REQUIREMENTS CERTIFICATION

I certify that the facts and representations under my cognizance which are included in this

Justification and its supporting acquisition planning documents, except as noted herein are complete and accurate to the best of my knowledge and belief.