ASN Justification Approval ATT_Redacted.pdf

Source Selection Information – See FAR 2.101 and 3.104 be recovered through competition, and/or unacceptable delays. The only alternative would be for vendors to resell off the existing infrastructure, which was found to be technically unacceptable and lead to degraded service that does not meet the governments requirements. Any other technological solution (such as wireless networks) was discovered to be infeasible. As will be discussed below, the above challenges were all established through the agency’s attempts to compete this requirement.

When the agency solicited this requirement expecting competition, AT&T’s proposal demonstrated full understanding of the scale/scope of the requirement to transition TDM services to VOIP, they provided clear cellular first alternatives, and being an incumbent, can leverage use of existing vendor owned Outside Cable (OSP) to deliver VOIP to the user bases. AT&T also has reasonable transition timelines that will allow for full deployment of the solutions on/before 31 January 2027 when current CENTREX contracts end and meeting this timeline will ensure no breaks in critical commercial telephony services to all users/mission partners.

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

On 23 Apr 2026, with the intent of competing this requirement, the Navy issued solicitation N0018926RL014 to provide the VOIP services and replace the existing technology. Recognizing the potential for “vendor lock” and the concerns some industries have in that regard, the Navy made an earnest effort to maximize competition and ascertain if industry could produce an alternative solution to awarding a contract to holders of legacy infrastructure.

If an innovative solution was presented that could meet the requirement and work within the constraints the Navy had, the Navy was fully prepared to move on to a new vendor. However, as a result of the competition, it was quickly determined that no other offerors adequately demonstrated a viable plan for multiple reasons, as will be discussed below.

A. Timeline of Delivery

One significant issue was that a vendor would have to ensure service delivery to the large number of users, especially absent use of OSP delivery infrastructures, to meet the critical January 2027 full-service deadline. After a review of the offers, the source selection evaluation board established that no other offerors possessed and demonstrated the capability to transition telephony services, especially when considering the aggressive timeline.

Though hybrid transport solutions (Cellular or OSP transport) were expressly permitted and are expected, predicated on location/cellular coverage of base users, it became apparent that use of existing OSP infrastructure was required for the transition and will provide a significant cost benefit to the government.

B. Outside Cable plant

Another significant operational and technical constraint at Naval Air Station (NAS) Key West and Naval Station (NAVSTA) Great Lakes involves the physical distribution and Outside Cable Plant (OSP) infrastructure. In military telecommunications, the physical layer consists of underground conduit systems, concrete-encased duct banks, maintenance vaults, manholes, and the physical copper and fiber cables connecting base distribution hubs to individual building Minimum Points of Entry (MPOE). While the Government did not restrict access to existing base conduit where available space exists, the solicitation explicitly restricted the use of existing Government-owned physical cabling (OSP). If OSP is required, AT&T is the incumbent for the vendor owned OSP. Verifying the availability and continuous integrity of empty conduit across every building pathway would require extensive post-award physical site surveys.

To overcome these physical pathway constraints through terrestrial means, a new vendor would be required to install entirely new base-wide fiber rings and construct dedicated tail-end conduit connections to hundreds of individual facilities across both installations. Establishing a new, comprehensive OSP infrastructure would require a major Military Construction (MILCON) project classified under DoD Real Property Facility Category Code 135-10 (Communications Lines, Underground / Duct Banks) and CATCODE 892-70 (Utility Vaults and Manholes).

Additionally, NCTAMS LANT does not have the authority to grant or fund new MILCON projects. Navy Outside Plant technical experts estimate that purely replacing the physical infrastructure would cost approximately $20M per base ($40M+ total) for basic materials, equipment, and labor.

However, this per base figure represents a conservative baseline. At NAS Key West specifically, actual project costs would be significantly higher due to unique geographical and civil engineering factors. NAS Key West consists of six geographically separated annexes distributed across the City of Key West. Connecting these dispersed annexes requires physical pathways to traverse municipal city property and public rights-of-way, triggering extensive municipal permitting, city traffic impact management, right-of-way negotiations, and strict coastal environmental reviews. These civil hurdles are further compounded by the local geology, which requires specialized heavy rock-sawing machinery to trench through solid coral limestone bedrock. Furthermore, the island geography features an extremely low elevation and a high water table subject to frequent tidal inundation, storm surges, and chronic coastal flooding. Constructing underground duct banks in this environment requires specialized submersible-grade enclosures, watertight sealed vault systems, and continuous dewatering operations during excavation, which substantially increases civil engineering costs and introduces severe weather-related construction delays. Additionally, even if conduit space were identified, executing physical cable pulling across hundreds of secure facilities requires extensive NAVFAC excavation and utility permits, base access badging (DBIDS), and physical security escorts for controlled industrial and airfield zones. These administrative, environmental, and security lead times alone would not meet the 01 February 2027 timeline.

Civil construction of this magnitude across both installations would require 3 to 5 years to design, permit, and construct under Tri-Service standards (UFC 3-580-01 and UFGS 33 82 00). This timeline directly amplifies the impossibility of meeting the mandatory 01 February 2027 operational cutover deadline. Furthermore, at NAS Key West, this infrastructure directly supports the Primary and Secondary Crash Alarm Systems (Crash Nets) connecting Air Traffic Control, Fire/Rescue, and Medical response teams. Any transition to a non-incumbent vendor lacking verified, operational physical pathways introduces an unacceptable risk of service degradation or failure for mission-critical life-safety operations.

Constructing redundant physical infrastructure when usable, operational pathways already exist represents a substantial duplication of cost to the Government that cannot be recovered through competition under FAR 6.302-1.

Because AT&T owns and operates the existing physical cabling and distribution plant connected to all required endpoints, they are the only source capable of providing uninterrupted commercial voice services at NAS Key West and NAVSTA Great Lakes without catastrophic schedule failure and massive, non-recoverable capital expenditure.

C. Alternative Solutions within Existing Buildings

In conducting this competition, the Navy sought to determine whether industry could present viable alternative solutions to overcome Outside Cable Plant (OSP) constraints, specifically through non-terrestrial means such as Radio Frequency (RF) or commercial cellular wireless networks. The Government restricted use of existing OSP (i.e. cabling) but did not restrict access to base conduit infrastructures, consequently running new fiber is an option but only if available conduit exists, that would have to be assessed at each location. Any new construction of conduit would clearly extend delivery beyond 01 February 2027. Moreover, the government was researching an alternative approach to bypass the OSP, those solutions based on market research are Radio Frequency (RF) and cellular; each would bypass the OSP but would require base station installation in user buildings.

One issue that arose through this process is that industry would require significantly more detail about the physical installations and buildings than NCTAMS LANT is able to provide, such as building blueprints, engineering schematics, diagrams of infrastructure, physical inspections of site locations, and so on. The installations have hundreds (and in some cases, thousands) of buildings, all with their own unique challenges. NCTAMS LANT is able to provide requirements in a general sense, such as the number of endpoints, however NCTAMS LANT only provides the telecommunications service on the installation; it does not oversee the physical installation itself. It does not have ownership of the buildings, nor does it physically control them and is not responsible for either their maintenance or upkeep.

While the Navy acknowledges why this type of information was sought by industry (and through preliminary evaluations of offers received, it appears would be required for a feasible solution), a large-scale engineering survey of the type required to address this problem is not possible. NCTAMS LANT does not have the authority to direct such a survey, but even if it did, such an undertaking would involve multiple Navy commands (if not DoW-wide) and could potentially take years. Given an indefinite timeline with no deadlines and an unlimited amount of manpower, such a survey might be theoretically possible, however, legacy telecommunications providers have already decided that service of the existing obsolete technology will discontinue, which precipitated the need for an interim bridge contract that is currently ongoing. At the end of that contract, the service will end.

The US Government did not make the decision to discontinue this service, but it is also not within its authority or power to force a telecommunications company to provide an obsolete technology that it declines to provide anymore. The maximum amount of delay had already been achieved by implementing the bridge contract (which permitted the Navy’s attempt to compete this requirement), however legacy providers are unwilling to extend that service any longer, which is a constraint put upon this requirement that the Navy does not have the ability to change.

D. Reselling off of existing infrastructure

As new physical conduit construction and non-terrestrial alternatives did not prove feasible within the required cutover timeframe, several offerors proposed reselling services by leasing circuits from primary facility-based carriers, such as AT&T. While reselling is standard in static commodity supply procurements, commercial voice service across operational military installations is an ongoing, dynamic utility that requires active, real-time maintenance, physical Outside Plant access, and rapid emergency restoral capabilities. Through past operational experience, NCTAMS LANT has determined that inserting a third-party reseller between the Navy and the underlying physical infrastructure provider introduces unacceptable operational latency, fractured communications, and substantial mission risk.

In the daily execution of base communications, when an outage occurs, Base Communications Office (BCO) personnel submit trouble tickets for immediate resolution. Under a direct facility-based carrier model, troubleshooting and dispatch occur within a single, unified chain of accountability. Under a reseller model, a multi-tiered middleman structure is created where the BCO reports an outage to the reseller, who must then translate and submit a secondary trouble ticket to the primary carrier (AT&T) who owns the physical lines. This multi-layered structure creates a protracted, time-consuming troubleshooting loop. The underlying back-end carriers do not have direct contractual visibility into the Navy requirement and often fail to understand the severe operational impact when commercial telephony is lost across an entire Naval installation.

This communication barrier becomes critical during base-wide outages or emergencies. When mission-critical communications or airfield operations fail, Installation Commanding Officers immediately demand direct restoral timelines and real-time operational status updates from the BCO. In a reseller arrangement, the BCO cannot communicate directly with the technicians performing physical repairs in the field. Instead, the Navy must rely on the reseller for updates, who in turn must wait on the primary carrier for information. This fractured reporting chain generates confusion, introduces critical delays in service restoration, and prevents military leadership from obtaining accurate situational awareness during crises.

Furthermore, because the Government lacks privity of contract with the underlying infrastructure owner under a reseller model, the Navy has no direct legal or contractual mechanism to compel the primary carrier to prioritize emergency repairs, enforce mandatory Service Level Agreements (SLAs), or demand dispatch transparency. During regional disasters, severe weather events, or national security crises, the DoW relies on Telecommunications Service Priority (TSP) authorizations for prioritized line restoral. Managing TSP escalations through a third-party reseller adds bureaucratic friction and delays carrier dispatch to critical command facilities and emergency operations centers.

Extended communication outages on military installations present severe hazards to the safety of personnel, emergency response coordination, and the security of government property. While NCTAMS LANT has historically managed reseller arrangements when no alternative existed for legacy Time-Division Multiplexing (TDM) contracts, operational experience proves that direct engagement with the facility-based infrastructure owner results in significantly faster coordination, reduced mean-time-to-repair (MTTR), and minimal operational impact on deployed warfighters and tenant commands. Because modernizing to an IP-based architecture involves complex cutover activities, circuit grooming, and potential physical adjustments to the Outside Cable Plant, relying on a reseller introduces unacceptable schedule and operational risks that the Government cannot absorb.

Therefore, NCTAMS LANT has determined that only direct engagement with the physical infrastructure owner (AT&T) provides the necessary single-source accountability, direct technical coordination, and rapid emergency restoral capabilities required to ensure mission continuity across NAS Key West and NAVSTA Great Lakes.

E. Long-Term Vision and Potential for Competition

As discussed above in para. 5, the Navy is currently transforming how commercial telephony service is provided, which has four pillars. Current contract actions would be considered pillar four (extended coverage) and the contract is being prepared to provide service to all users at each location. However, moving forward Pillars 1-3 (Teams Telephony Softphones, Teams Shared-Device Phones for Safety (e911), Guaranteed Life-Safety Systems via Navy Enterprise Voice and Video System (NEVVS)) will provide commercial telephony support to most of all current telephony uses and the Pillar 4 contracted services will be greatly reduced in scope. The expected eventual scope reduction for Pillar 4 contract requirements will afford smaller, non-incumbent vendors the opportunity to enter full and open competitive bidding for future contracts at these locations. Unfortunately, primarily due to limited funding, the Navy is behind schedule on Pillar 1-3 deployments so it is difficult to estimate when the Navy will be ready for the first competitive acquisition for the reduced contract requirements.

A Sources Sought Notice (SSN)/Request for Information (RFI) was posted to SAM.GOV on December 9, 2025, until January 27, 2026, prior to the solicitation. As discussed above, subsequently, a full and open competitive combined synopsis/solicitation was issued on SAM.GOV. This solicitation was posted for 49 days. As the Navy actually issued a solicitation with the intent of awarding this requirement competitively and reviewed the offers received, the Navy has determined it has gotten sufficient market research into what industry is currently proposing and capable of doing, given the constraints the Navy currently has (and which cannot be changed in time for the end of the current bridge contract). Therefore, for the reasons discussed in paragraph 5-6 above, the Navy has determined that only AT&T can provide the required services.

7. Determination of Fair and Reasonable Cost.

The Contracting Officer has determined that the anticipated cost to the Government of the supplies/services covered by this J&A will be fair and reasonable.

8. Actions to Remove Barriers to Future Competition.

For the reasons set forth in Paragraph 5, NAVSUP FLC Norfolk has no plans at this time to compete future contacts for the types of services covered by this document. However, as discussed in paragraph 5(E) above, NCTAMS LANT eventually anticipates replacement of the VOIP telephony services entirely (via NEVVS or some other method), and there is potential for future competition. If another potential source emerges, NAVSUP FLC Norfolk will assess whether competition for future requirements is feasible.

In accordance with DFARS PGI 206.103-170(d), a sources sought notice was posted to the Government-wide Point of Entry (GPE) on December 9, 2025, 16 responses were received in response to the SSN notice and 10 proposals were received in response to the solicitation which was posted to SAM.GOV between April 23, 2026, until June 22, 2026, for a total of 60 days. As discussed above, a competition solicitation was also issued, in which offers were received and a preliminary evaluation of those offers had been initiated.

The Requiring Activity reviewed the information provided by each firm in response to the SSN to ascertain whether any of the responders were capable of meeting the Government’s minimum need for this requirement. Based on that review, the original determination was made that companies do exist that at least have the technical knowledge regarding this requirement and the potential capability, and it was decided to issue a competitive solicitation and ascertain what industry would propose given the Navy’s constraints. After further review of the responses, the Navy determined that none of the responders possess the technical capability to perform the required tasks and meet the government’s need. Furthermore, market research has determined that there are no other sources that provide the requirements other than AT&T. As such, no further actions to remove the barriers to competition other than which the Navy has already attempted are possible at this time. The circumstances requiring the acquisition be conducted pursuant to FAR 6.103-1 remain unchanged. Any subsequent follow-on requirements will be handled on a case-by-case basis. Market Research will be conducted for any future requirements to determine if there are any potential sources for competition.

J&A No. 26-276

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.

Technical Cognizance:

Signature Name (Printed) Phone No. Date

Requirements Cognizance:

Signature Name (Printed) Phone No. Date

LEGAL SUFFICIENCY REVIEW

I have determined this Justification is legally sufficient.

CONTRACTING OFFICER CERTIFICATION

I certify that this Justification is accurate and complete to the best of my knowledge and belief. To the extent that the Justification value is > SAT and < $10M, the Contracting Officer’s signature below also represents approval of the Justification.