B05 JA Sole Source_Redacted.pdf

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Raven Rock Mountain Complex ATT&T Wireless Cellular Services
Solicitation number
JB020320260751
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JUSTIFICATION FOR EXCEPTION TO FAIR OPPORTUNITY (JEFO)

This is a Justification for Exception to Fair Opportunity document submitted by the Department of War, Washington Headquarters Services, Acquisition Directorate, Enterprise Security Services Directorate (WHS/AD/ESID) on behalf of the Raven Rock Mountain Complex (RRMC). The Government seeks approval for a sole source award to AT&T for unclassified wireless cellular services under FAR 16.505(b)(2)(i)(B). The proposed contract is a Firm Fixed Price (FFP) agreement utilizing Operation and Maintenance (O&M) funds with an estimated value of $17,357.00 and a 12-month base period from September 27, 2026, through September 26, 2027. The requirement covers wireless services for 46 end-users, including unlimited voice, text, and data with network-approved smartphones one generation behind current market offerings. NAICS code 517112 (Wireless Telecommunications Carriers except Satellite) and PCS code DG11 (IT & Telecom – Network Access Services) apply to this acquisition.

The justification cites AT&T's unique compatibility with existing Government-owned hardware and the significant costs and operational disruptions associated with switching carriers, including estimated equipment replacement costs of $30,500 to $35,000. Market research was limited to the Navy Supply Systems Command (NAVSUP) Spiral 4 contract (N00244-24-D-0005) as a mandatory source per DoD Chief Management Officer Memorandum dated September 28, 2018, and OMB Memorandum M-16-20. The Contracting Officer determined fair and reasonable pricing using FAR 15.404-1(b)(2)(v) comparison techniques, noting that Navy's Spiral IV pre-negotiated prices are subject to potential additional discounts. The original order was placed under the fair opportunity process with all awardees considered. The document was certified by a Contracting Officer Representative on August 1, 2026, and approved by Contracting Officer Peter Polizzi on October 21, 2026.

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DEPARTMENT OF WAR

WASHINGTON HEADQUARTERS SERVICES

1155 DEFENSE PENTAGON

WASHINGTON, DC 20301-1155

ACQUISITION

DIRECTORATE

Control No.

JUSTIFICATION FOR EXCEPTION TO FAIR OPPORTUNITY (JEFO)

UNDER FEDRAL ACQUISITION REGULATION (FAR) SUBPART 16.5

1. AGENCY AND CONTRACTING ACTIVITY: The Department of War (DoW), Washington Headquarters Services, Acquisition Directorate, Enterprise Security Services Directorate (WHS/AD/ESID) is the contracting activity for the requiring agency Raven Rock Mountain Complex (RRMC).

2. DESCRIPTION OF ACTION: This follow-on requirement seeks approval for a sole source justification to AT&T for wireless services. WHS/AD proposes a Firm Fixed Price (FFP) contract using Operation and Maintenance (O&M) funds. The estimated value is $17,357.00, with a 12-month base period for the anticipated period of performance.

Period of Performance Dates Amount Base Period September 27, 2026 - September 26, 2027 $17,357.00 Total $17,357.00

3. DESCRIPTION OF SUPPLIES/SERVICES: Raven Rock Mountain Complex (RRMC) requires a follow-on contract for unclassified AT&T Wireless Cellular Services to support 46 end-users. The services include Unlimited Voice, Text, and Data, with network-approved smartphones (1 generation behind current market offerings). This requirement ensures continued wireless cellular support for RRMC members as they operate within offices, meeting locations, and international settings.

NAICS: 517112 - Wireless Telecommunications Carriers (except Satellite) PCS: DG11 - IT & Telecom – Network Access Services

Item and Description Quantity Unlimited Voice/Unlimited Text/Unlimited Data (w/Network approved Smartphone 1-GEN behind current market offering)

4. EXCEPTION TO THE FAIR OPPORTUNITY: This action is justified under FAR 16.505(b)(2)(i)(B), as only AT&T is capable of providing the required services at the level of quality necessary due to the unique compatibility of its services with existing Government-owned hardware. Raven Rock requires continuity of services to avoid additional costs and operational disruptions that would result from switching to another carrier (e.g., T-Mobile, Verizon, or Authorized Resellers).

Switching carriers would render existing AT&T-specific hardware and accessories unusable, requiring the Government to purchase new equipment at an estimated cost of $30,500 to $35,000. Additionally, transitioning to a new carrier would incur service fees and require retraining and troubleshooting for end-users, further increasing costs and reducing operational efficiency.

By remaining with AT&T, the Government can leverage existing hardware, avoid unnecessary expenditures, and maintain uninterrupted service, ensuring cost savings and operational continuity. This approach aligns with the Government's responsibility to minimize costs and maximize efficiency in its operations.

5. FAIR AND REASONABLE COST DETERMINATION: The Contracting Officer determines that this action represents the best value to the Government, as AT&T provides the services required by Raven Rock. Under contract N00244-24-D-0005 / HQ003425FE447 and previously under contract N00244-24-D-0005 / HQ003424F0769, N00244-18-D-0001 and Order W91RUS23F0340, AT&T has demonstrated outstanding performance in meeting all requirements.

AT&T holds an active DoD Wireless Service contract (N00244-24-D-0005) for wireless communication services, which is suitable for this requirement. The Navy’s Spiral IV has already determined that the prices for supplies, fixed-price services, and hourly rates under this contract are fair and reasonable. While these prices have been pre-negotiated, the Government may seek additional discounts before placing an order.

The anticipated price for this order is determined to be fair and reasonable. The Government will use the techniques outlined in FAR 15.404-1, specifically FAR 15.404- 1(b)(2)(v) “Comparison of prices proposed with independent government estimate, to ensure fair and reasonable pricing.

6. OTHER SUPPORTING FACTS: Market research was limited to the Navy Supply Systems Command (NAVSUP) Spiral 4 contract, as it is a mandatory source per (a) DoD Chief Management Officer Memorandum, 'Wireless Device Management Reform,' dated September 28, 2018, and (b) OMB Memorandum M-16-20, 'Category Management Policy 16-3,' dated August 4, 2016.

RRMC requires continuity of services, as awarding to another source would result in inefficiency costs that cannot be recovered through competition. Switching providers would disrupt the mission, degrade operational efficiency, and render previously procured hardware and accessories unusable.

Based on this, the Government recommends issuing this acquisition as a sole source direct award to AT&T under their Spiral 4 contract (N00244-24-D-0005) in accordance with FAR 16.505(b)(2)(i)(B), as only AT&T can provide the required services at the necessary level of quality due to their unique and highly specialized capabilities

7. ACTIONS TO REMOVE OR OVERCOME ANY BARRIERS THAT

OVERCOME ANY BARRIERS THAT LEAD TO THE EXCEPTION TO FAIR

OPPORTUNITY BEFORE ANY SUBSEQUENT ACQUISITION FOR THE

SUPPLIES OR SERVICES IS MADE: For future requirements of this nature, Raven Rock will review and consider other wireless carriers in this sector for future requirements. The Government will consider alternative products if market research supports the fact that alternative wireless carriers and their equipment provide additional benefits to the Government.

8. If this acquisition is for new work as a logical follow-on to an order already issued under the contract, was the original order placed under the fair opportunity process?

Yes, all awardees were given a fair opportunity to be considered for the original order.

No, a copy of the previous justification is attached. The actions to remove any barriers to competition cited on the previous justification were were not completed.

Not Applicable. This is a new requirement.

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