CC2.0_Bridge JA_Redacted.pdf

Justification and Approval (J&A) for Other Than Full and Open Competition

CONTROLLED UNCLASSIFIED INFORMATION

August 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 3 of 11 of a February 2025 award date. Considering that the original requirement was intended to be a direct follow-on to CC 2.0 using FAR Part 8 or 16, the team thought this lead time would be realistic to develop and award a new task order. However, due to the factors listed below, the requirement began to change into the ASCEND requirement that we see today. These changes, while necessary and important to the mission, drive a longer acquisition timeline than previously contemplated.

Background. Initially, the recompete was pursued as CC 3.0 - essentially an exact copy of CC 2.0. The initial requirement revolved around hiring labor categories on a Time & Material basis, like an A&AS requirement. This would have driven a commercial requirement that takes a modular approach to awarding a series of small requirements and task orders.

Therefore, the team did Request for Information (RFI) #1 (released 19 October 2023 on Contractor Opportunities, GSA Alliant, and PlatformOne) to work towards this CC 3.0 strategy. Meanwhile, as the CC 2.0 contract continued, the Program Management Team began to recognize and leverage lessons learned towards the follow-on requirement. One major issue was that CC 2.0's requirement did not accurately capture the mission need. The users believed that we would be paying a contractor to develop a platform. However, they had structured the requirement in a way that only required the contractor to provide qualified personnel and work a certain number of hours towards Government objectives. Specifically, the organization and platform it supports has matured to a level wherein a purely labor-based acquisition approach is not well-suited to achieving the Government's enterprise-level requirements. The Government's complex requirements call for a performance-based acquisition approach where the contractor is provided objectives to be achieved and they determine the labor mix and level of effort to achieve the desired outcomes. This approach mitigates risk and provides for more accountability towards the contractor, which is a significant change in the methodology employed by KR in past contracts.

Agency Re-Organization. As early talks for the recompete of CC 2.0 began, Kessel Run (KR) was made aware that due to an agency reorganization, they would be moved out of the HBB portfolio to reside under the umbrella of the C3BM organization. This presented a large unknown for KR's leadership as they began to navigate a new chain of command's priorities and needs. As KR integrated into its new organization, they found that C3BM had a much larger focus on the delivery of results rather than the level-of-effort approach used in many of KR's current requirements. As a result, KR took a tactical pause to better understand the needs of their new leadership and ensure that their vision for CC 3.0 aligned with their new mission. As it became clear that the current CC 2.0 contract was no longer meeting the most current needs as well as the priorities of C3BM, the program was expanded and renamed ASCEND on 02 January 2024 to reflect that it is a new and separate program from its predecessor.

Security. After RFI #1 was finished, the team became aware that there was a need to update and expand upon the security requirements. The changes to the security requirement were driven by a need to do coding in a more secure environment (for example, IL6). At the outset of CC 2.0, the amount of Development work in secure environments was very low (~10%).

The current need for Development work in a secure environment is now close to 50%. While the Government SCIFs were able to accommodate the level of Development work being performed on CC 2.0, there simply was not enough room/ workstations to be able to house the number of contractor personnel that would be necessary for the follow-on. As a result, the Government released RFI #2 in February of 2024 to examine whether and to what extent contractors would have access to a SCIF.

Potential Conflict of Interest. After RFI #2 was finished, the organization's chief information officer realized that a potential conflict of interest could exist based upon the RFI responses. It was pointed out that the requirement as written had the same contractor building security framework and completing security testing. This situation could create a conflict of interest which would threaten the program's Authority to Operate (ATO). Therefore, large portions of the security requirement contemplated by RFI #2 were removed to ensure that the ATO would not be affected.

Data Rights. The team then realized that a non-commercial requirement was necessary to get the desired data rights to any platform designed by a contractor team. The need exists for the Government to be able to manipulate and utilize the code from the platform in whatever way they see fit. A commercial contract would not provide the Government with the level of flexibility to edit that code without asserting appropriate data rights.

Finding a Contract Vehicle. Up until this point, the plan was to pursue a task order via a GSA ordering vehicle. To ensure that this was still a viable plan, the team released RFI #3 to GSA on 04 June 2024. However, after the requirement was updated and expanded to reflect the above factors, the team was unable to find a GSA vehicle that would find these requirements within scope to meet the need. The team needed a non-commercial contract, which is not typical for GSA (which tends to utilize commercial contract vehicles). For the few non-commercial contract vehicles available, most were not suited to the requirement's NAICS code. Lastly, the team needed a contract that was able to accept mixed funding. Despite exploring

August 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 5 of 11 months, if all options are exercised. However, it is within the sole discretion of the Government to exercise options associated with this bridge.

The IGCE will be utilized when analyzing pricing provided by the incumbent for this bridge contract to determine pricing is fair and reasonable. As stated in Section II of this justification, the contemplated bridge contract will be T&M with CLINs funded by O&M (3400) and RDT&E (3600) funding.

Intellectual Property (IP):

No intellectual property is currently being produced by the CloudCITI 2.0 contractor, and no intellectual property is anticipated to be developed by the contractor in support of this bridge effort. Further, all work products and deliverables, developed during the course of this bridge contract, will be done utilizing Government Furnished Equipment (GFE) and residing within Government owned and operated systems and infrastructure. Therefore, any intellectual property developed in support of this bridge effort, done so on GFE or within Government owned and operated infrastructure will automatically become the property of the Government without restrictions.

Additionally, applicable Defense Federal Acquisition Regulation Supplement (DFARS) clauses will be incorporated in the bridge contract which will strengthen the Government's rights to technical data. Specifically, the following DFARS clauses will be incorporated by reference:

-252.227-7013 Rights in Technical Data - Non-commercial items -252.227-7014 Rights in Non-commercial Computer Software and Non-commercial Computer Software Documentation -252.227-7015 Technical Data - Commercial Items -252.227-7019 Validation of Asserted Restrictions - Computer Software Limitations on the Use or Disclosure of Government Furnished Information Marked with Restrictive Legends -252.227-7030 Technical Data - Withholding of Payment

IV. Demonstration that the contractor's unique qualifications or the nature of the acquisition requires use of the authority cited above.

Pursuant to FAR 6.302-1(a)(2)(iii)(B), DFARS 206.302-1, and DFARS PGI 206.302-1 "when supplies or services required by the agency are available from only one responsible source, or, for DoD, NASA, and the Coast Guard, from only one or a limited number of responsible sources, and no other type of supplies or services will satisfy agency requirements, full and open competition need not be provided for."

Specifically, sub-paragraph (iii) of FAR 6.302-1 states "for DoD, NASA, and the Coast Guard, services may be deemed available only from the original source in the case of follow-on contracts for the continued provisioning of highly specialized services when it is likely that award to any other source would result in" (B) "unacceptable delays in fulfilling the agency's requirements" pursuant to 10 U.S.C. § 3204(b)(B).

The services provided by the incumbent under contract number FA8730-21-F-0166 are considered, by their nature, to be highly specialized services in support of a major weapon system and therefore comply with the intent of the cited clauses.

Further, this justification is for a follow-on bridge contract for identical specialized services as those provided by the incumbent under contract FA8730-21-F-0166.

Specifically, Kessel Run has the responsibility of developing, fielding, and operating mission critical warfighting applications in support of the U.S. Air Force. These applications need to be operationally available and mission capable 24/7/365 in highly contested environments. The incumbent provides a full spectrum of critical and highly specialized services to the Government that include, but are not limited to, supporting the maintenance and stabilization of the current cloud infrastructure on which applications are deployed and assisting the Government in the areas of DevSecOps software engineering, Kubernetes infrastructure, and multi-region platform services that facilitate Kessel Run in the modernization of legacy software systems and support external DoD software initiatives associated with Kessel Run.

Because of the criticality of the services provided and the need to avoid a potential gap in these capabilities, an award to any other contractor at this juncture would cause irreparable harm to the Government in the following areas:

-Current migration activities underway to transition the existing cloud infrastructure from a hybrid cloud to a cloud native

August 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 6 of 11 posture would stop. This would negatively impact the Government's necessity to stabilize its current infrastructure and delay the ability for the competitive sourcing of cloud services in the future.

-Development and deployment of mission critical applications would be directly impacted causing unacceptable delays in the fielding of Warfighter specific capabilities. These delays would cause fielded applications to degrade to unacceptable levels rendering them unusable.

-Security scans and associated protocols would immediately stop, causing vulnerabilities to the Government's current operations to attacks and outages.

-The health of the existing infrastructure would degrade to levels wherein it would no longer allow for the necessary host, store, and compute requirements to be met.

The incumbent has specialized knowledge of the current Kessel Run ecosystem and its ongoing operations in support of mission critical applications. The impacts identified above, should a gap in service occur, would cause the delay in the maintenance and deployment of currently supported capabilities by months or longer causing developmental progress to atrophy and degrade to unacceptable levels.

Market research conducted for this bridge effort demonstrates that only the incumbent has the capability to meet requirement staffing levels on day one of contract execution. Given the nature of external threats, the staffing levels required at contract award are necessary to maintain continuity of services across the enterprise ensuring no gap in performance or capabilities. Specifics surrounding this assertion are provided in Section V and VII of this justification.

The incumbent contractor, Raft, LLC, has been performing on the CC 2.0 contract, FA8730-21-F-0166, since July 2021. which was competitively awarded, in support of Kessel Run's enduring requirements. This justification is seeking approval to initiate a follow-on bridge contract with the incumbent, Raft, LLC, for the continued supply of highly specialized services in support of those requirements until a competitive acquisition can be successfully completed.

As stated in Section III of this justification, the contemplated bridge contract will have a base period of six (6) months with two (2) option periods consisting of six (6) months each. Given the uncertainty associated with the identification, refinement, and validation of requirements for the successor contract and the timeline defined for a competitive acquisition of those services, it is in the Government's best interest to approve this justification which provides the greatest flexibility and minimizes the operational risk to fielded applications associated with a gap in service. However, the Government has the unilateral right not to exercise the contemplated options should it become clear that a successful competitive acquisition of a successor contract can be accomplished earlier than the time requested by this justification.

Therefore, as demonstrated herein, this justification is for a follow-on bridge contract for the continued provisioning of highly specialized services in support of Kessel Run's requirements augmenting the Air and Space Operations Centers (AOC) enterprise level capabilities which directly contribute to the Department of the Air Force (DAF) Battle Network and Re-optimization for the Great Power Competition. Specifically, and pursuant to FAR 6.303-2(b)(5), the incumbent possesses unique qualifications to provide these specialized services in that they have successfully accomplished the requirements since July 2021 by identifying highly qualified Subject Matter Experts (SME) necessary to fulfill the mission requirements and are the only contractor currently able to provide staffing levels of these SMEs on day one of contract execution. Therefore, Kessel Run has determined that an award to another contractor for this bridge effort would result in unacceptable delays as described in FAR 6.302-1(a)(2)(iii)(B).

Moreover, changing contractors for this contemplated bridge effort would involve multiple administrative actions to include the negotiation and issuance, by the Government , of a new contract to an alternate contractor which would facilitate a completely new DD Form 254, followed by recruitment, background investigations, on-boarding of incumbent staff, if possible, identification of labor gaps by the successor contractor, and transfer of GFE from the incumbent to the successor contractor. This approach would require, at a minimum, a sixty (60) day transition period which makes it extremely unlikely another contractor could achieve required staffing levels on day one, further delaying support and progress with ongoing efforts and causing irreparable harm to the infrastructure and those applications residing on it. During this transition period, minimal work in support of the Government's requirements would be accomplished. This loss in productivity and continuity is unacceptable to the Government and places significant operational risk to fielded capabilities by adversely impacting schedule metrics associated with the development and deployment of mission critical applications.

Further, the incumbent has been successfully performing these requirements since July 2021 and during that period of time has developed a unique knowledge and understanding of Kessel Run's requirements which would require another

August 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 7 of 11 contractor numerous months to achieve parity with the incumbent in the various technical areas supported by this effort.

This certain delay in performance parity would impact the development and deployment of critical applications and maintenance on the existing infrastructure delaying for months any updates while the successor contractor transitioned and familiarized themselves with Kessel Run's ecosystem.

Moreover, given scope and scale of the follow-on effort and the critical need to clearly define new requirements while also refining existing requirements necessitates the Government's need to maintain stability associated with current operations until such time as a competitively awarded follow-on contract can be established.

Deviating from the current level of performance during this period of requirements definition would, as described herein, cause unacceptable delays to ongoing development efforts and irreparable harm to the maintenance and stability of the existing infrastructure.

Accordingly, Raft, LLC is the only contractor capable of providing the services described in Section III without the Government experiencing unacceptable delays in fulfilling its requirements.

V. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by subpart 5.2 and, if not, which exception under

FAR 5.202 applies.

On 1 August 2024, the Government released a Request for Information (RFI) through the Platform One (P1) Basic Ordering Agreement (BOA). In 2020 SAF/AQ approved a five (5) year class J&A consistent with FAR 6.302-1 finding that the P1 BOA holders were determined to have the capability of providing unique and highly specialized DevSecOps services, and therefore authorized limiting competition for such services to the BOA holders. The current CC 2.0 contract was competitively awarded through the P1 BOA and the Government determined this would be the appropriate venue for conducting market research for this bridge effort.

Of the current 45 total BOA holders, 28 (62%) responded to the Government's RFI with two (2) of these responses being no-bids. The Government cataloged and analyzed the responses received and used that information to develop a Market Research Report (MRR) outlining the findings of the Government and a recommendation for the acquisition of services in support of this bridge.

Specifically, it was determined from the market research that only the incumbent is capable of meeting the staffing requirements of the Government on day one of contract execution, therefore eliminating any performance risk to the program. Of the 26 actual responses received, the Government identified seven (7) respondents who stated they could meet the staffing requirements in ten (10) days or less; fifteen (15) stated they could meet the staffing requirements within thirty

(30) days and; four (4) that required more than 30 days to meet the requirement.

Further, an analysis was conducted wherein the staffing and transition plan of each respondent was compared to the performance schedule to determine each respondent's number of days fully staffed. From this analysis it was determined that only the incumbent was capable of achieving 100% capabilities across the PoP. Specifically, when considering the PoP in days (540) the average number of fully capable days across respondents was 477. This equates to an average of 88% capabilities across the PoP which is significantly below the incumbent's capabilities and would cause the Government to accept a lower contract performance over the PoP. These staffing levels are insufficient to meet the Government's requirements and causes excessive programmatic risk which the Government considers unacceptable.

As outlined in Section IV of this justification, any lapse in services will have immediate and long lasting negative impact on the organization's infrastructure and the applications supported. Only the incumbent has the ability to ensure the required staffing of SMEs on day one of contract execution and for the full duration of the contract.

Further, the Government is currently conducting thorough market research for the follow-on requirement, ADCP Security Cloud Engineering Network Development (ASCEND), to maximize competition. A third RFI was published for the ASCEND requirement on 11 June 2024 to maximize competition.

Information received from industry in response to this third RFI has assisted the Government in refining its requirements and

August 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 8 of 11 acquisition strategy, but has facilitated the need for a fourth RFI to gauge industries interest and ability to meet the Government's short and long-term requirements.

The fourth RFI was released through SAM.gov on 12 August 2024. The Government received adequate interest from potential sources to foster competition for the ASCEND effort. This RFI finalized the Government's market research and provides a solid foundation for finalizing an acquisition strategy and developing the documents for the competitive source selection.

VI. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer (CO) will conduct a cost and price analysis utilizing techniques listed in FAR 15.404-1, specifically FAR 15.404-1(b)(2)(ii) wherein the Government may use "comparison of the proposed prices to historical prices paid, whether by the Government or other than the Government, for the same or similar items" to determine proposed pricing submitted by the offeror is deemed fair and reasonable. Further, the CO will compare the proposed labor categories, hours, and rates to historical prices from the current contractor for similar/same work under the existing CC 2.0 contract. The CO will also compare the proposed labor rates against an existing IGCE developed for this specific action. Moreover, the CO will commit to obtain a certificate of current cost or pricing data when required by FAR 15.403-4 and will also utilize additional information from the technical analysis to determine the proposed costs are fair and reasonable to complete the requirement with minimal risk to the Government.

VII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

The Government has concluded market research regarding the CC 2.0 follow-on effort (ASCEND) beginning with the first RFI released on 19 October 2023. This market research has included four (4) RFIs to industry. The responses to the RFIs demonstrated to the Government that adequate interest exists in this requirement to foster competition.

Specifically, RFIs were released through SAM.gov, GSA Alliant 2 Government Wide Acquisition Contract (GWAC), P1 BOA, GSA VETS 2 GWAC, and the GSA Multiple Award Schedule (MAS). In response to these RFIs the Government received numerous responses from both large and small business indicating that adequate responsible offerors are interested in and will ultimately respond to the Government's Request for Proposal (RFP) to provide for robust competition.

After four (4) rounds of market research have been conducted and the responses from industry analyzed , the Government currently intends to competitively award a single ID/IQ contract for these requirements which provides the greatest flexibility to the Government.

Further, the Government has developed an acquisition schedule with critical milestones for the follow-on contract. Those milestones demonstrate the timeline to competitively down select for the ASCEND effort and reinforces the need for this justification to be approved to avoid a gap in current service. Therefore, the Government requires a bridge to the current CC

2.0 contract to avoid a gap in services while the ASCEND follow-on requirements are solidified and a competitive source selection can occur.

As demonstrated by the information provided within this J&A, the Government will not be in a position to award the ASCEND contract prior to the current ending of the existing CC 2.0 contract. And, without this bridge, the Government will experience a gap in service which as annotated in Section IV of this document, will have multiple negative impacts on the overall capabilities of Kessel Run to fulfill its mission requirements.

Therefore, it is an imperative that this justification be approved to avoid such a lapse in service and to maintain the current capabilities for a sufficient period of time to facilitate the competitive award of the follow-on contract.

VIII. Any other facts supporting the use of Other Than Full and Open Competition.

Since the inception of the CC 2.0 contract, mission requirements and theater specific threats have evolved significantly. In order to keep pace with these changes, Kessel Run must clearly understand the challenges and develop requirements that

August 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 10 of 11

-Accenture Federal Solutions, LLC -Advanced Technology Applications, LLC -Booz Allen Hamilton -BridgePhase, LLC -Clarity Innovations, LLC -Constellation Software Engineering, LLC -Dark Wolf Solutions -Fearless Solutions, LLC -Global InfoTek, Inc.

-IntelliBridge -Isobar Public Sector -Metronome, LLC -MetroStar Systems, LLC -Octo Consulting Group, LLC -Omni Federal, LLC -OneGlobe, LLC -Oteemo, Inc.

-Parsons Government Services -Rackner, Inc.

-Raft, LLC -Rancher Federal, Inc.

-Raytheon Company -Seed Innovation, LLC -Sev1Tech, LLC -SHR Consulting Group, LLC -VivSoft Technologies, LLC

X. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before any subsequent acquisitions for the supplies or services required.

Pursuant to FAR 6.101(a) and 10 U.S.C. § 3201 which "requires, with certain limited exceptions, that the Contracting Officer shall promote and provide for full and open competition in soliciting offers and awarding Government contracts," it is the intent of the Government to provide for competition for the follow-on effort with the possible exception of restricting competition to small business IAW FAR 19.502-2 based on the analysis of market research conducted IAW FAR Part 10 for the successor contract.

Planning to overcome any competition barriers by pursuing our own contract via competitive acquisition. The steps that the ASCEND program has taken to overcome this barrier are: 1) extensive market research (four RFIs) and 2) using this market research to formulate the ASP that will be briefed to General Cropsey on 7 October 2024.

ASCEND's Major Projected Milestones are as follows:

ASP Approval: 7 OCT 2024 Release Draft Solicitation: 14 JAN 2025 Solicitation Release: 17 JUN 2025 Proposals Due: 07 JUL 2025 Receive FPRs: 23 JAN 2026 Contract Clearance: 06 APR 2026 Award Date: 14 MAY 2026

XI. Certification by the Contracting Officer.

As evidenced by my signature above, I certify that this justification is accurate and complete to the best of my knowledge

August 2023 CONTROLLED UNCLASSIFIED INFORMATION Page 11 of 11 and belief.

XII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.