B10_PFP_-_JEFO_STB_UCaaS_140D0423Q1035_Redacted_1.pdf

United States Department of the Interior

INTERIOR BUSINESS CENTER

Washington, DC 20240

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

AUTHORITY: FAR 16.505(b)(2)

SOLICITATION # 140D0423Q1035

1. Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for an Exception to Fair Opportunity.”

This document is a Justification for an Exception to Fair Opportunity for the Department of the Interior (DOI), Interior Business Center (IBC), Acquisition Services Directorate (AQD), Division I/Branch II on behalf of the Surface Transportation Board (STB).

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

This is a logical follow-on requirement for STB Unified Communications as a Service (UcaaS) cloud services in accordance with FAR Part 16, to maintain the continuity of services previously competed and procured under the DOI Foundation Cloud Hosting Services (FCHS) Indefinite Delivery Indefinite Quantity (IDIQ) contract D13PC00025, task order D15PD01324. All awardees were afforded fair opportunity. This requirement will be sole sourced to Science Applications International Corporation (SAIC), 11720 Plaza America Drive, Reston, VA 20190-4757.

Currently, these services are provided to STB by SAIC through a task order off the DOI FCHS IDIQ. The current FCHS IDIQ is due to expire October 30, 2023, however a justification has been approved to modify the IDIQ to allow performance under orders to continue until October 30, 2025. The new FCHS2 contract is not expected to be awarded until March 2024, therefore making it unavailable before the end of the current contract with SAIC. STB needs to continue services with the existing contractor until FCHS2 is available and a transition can occur without interruption to essential services.

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

STB requires a hybrid cloud solution for UCaaS, that includes an Infrastructure as a Service (IaaS) via the Amazon Cloud (AWS) task order that supports mission critical STB applications, including internal and customer-facing systems. This includes meeting all cyber requirements, system backup/restore, disaster recovery, application development and Operation & Maintenance. Microsoft support is provided for O365, Exchange, Intune, Azure, Teams, SharePoint, Teams Calling, Defender, Viva, Windows Hello along with integrations into additional non-Microsoft systems. STB requires cloud migration services from the legacy data center into AWS and the creation of application development environments. Additional authentication services are provided via Okta. Fax services are provided via Esker.

The period of performance is 09/24/2023 – 09/23/2024 and FAR 52.217-8 Option to Extend Services will be included to allow for an additional six months of performance, if needed.

The total estimated dollar value for this action is (including 6-month extension).

4. Identification of the exception to fair opportunity (see 16.505(b)(2)) and the supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited. If the contracting officer uses the logical follow-on exception, the rationale shall describe why the relationship between the initial order and the follow-on is logical (e.g., in terms of scope, period of performance, or value).

FAR 16.505(b)(2)(i)(C) – The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

STB requires the cloud services under the existing task order to maintain critical network infrastructure and communication tools. In addition to maintaining STB’s operations, STB also has several key projects that are dependent that operate in and depend upon the cloud services and support utilized under this task order. These key projects include the data migration project which is in progress with the goal of migrating all STB file share data stored in the STB Data Center to Amazon Web Services (AWS) (expected completion fourth quarter of 2024); and security projects for Zero Trust, FISMA compliance, and disaster recovery planning.

The contractor for the STB cloud services through the DOI FCHS IDIQ is SAIC, with a period of performance ending on September 23, 2023. The follow-on work would move to the new FCHS2 IDIQ, but that contracting action has been delayed and will not be available until March 2024, which is after the end of this task orders period of performance.

Continuing services with the existing contractor, which was issued under the original FCHS IDIQ, is necessary for continued functionality of STB digital systems until FCHS2 is available and a transition of services can occur without interruption of essential services. The 12-month period of performance is required to allow for the award of FCHS2, which is not due to occur until March 2024 and the transition out of the cloud services from the current contractor to a new contractor. Since this task order provides overarching cloud support services to all of STB, there are various mission critical digital systems that would need at minimum three to six months transition time.

5. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

This requirement is being procured under the DOI FCHS IDIQ. A price analysis was done for the base awards in accordance with the FAR 15.305(a)(1) to ensure that a fair and reasonable price is paid by the Government. Reasonableness of proposed prices was established in accordance with FAR 15.403-1(c)(1)(i)(B). The AQD Contracting Officer will seek further discounts and use historical pricing, along with making a separate determination as to the reasonableness of the price quote prior to awarding the follow-on task order.

6. Any other facts supporting the justification.

Unfortunately, the STB’s current FCHS cloud services task order is due to expire and DOI’s FCHS2 is not yet available. Putting out a competitive task order for these services and managing a transition to another contractor simply to bridge the gap between FCHS and FCHS2 would result in an unnecessary expenditure of resources. To avoid this loss of resources and the risk to the systems that depend on the AWS cloud environment, it is prudent to continue the existing services with the current contractor for 12 months in order to have FCHS2 available and prepare systems for the transition.

7. A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

The DOI FCHS2 IDIQ, like the original FCHS, will provide contractors fair opportunity to prepare quotes that will be competed among the other FCHS2 contractors. STB, as a customer, not the owner, of the IDIQ, was unable to avoid the delays in FCHS2. This has resulted in a gap during which the STB contract for AWS services expires before FCHS2 is available. STB will continue to work with DOI to best leverage the benefits of and make the transition to FCHS2. The recompete of this STB requirement will be competed among the FCHS2 contract holders.