Limited Source Justification_RecoveryPoint_Redacted.doc.docx

U.S. COMMODITY FUTURES TRADING COMMISSION

Three Lafayette Centre 1155 21st Street, NW, Washington, DC 20581 Telephone: (202) 418-5419 Facsimile: (202) 418-5414

LIMITED SOURCE JUSTIFICATION

1. Agency, Contracting Activity and Document

The Commodity Futures Trading Commission (CFTC or Commission), Financial Management Branch, proposes a Limited Source Justification (LSJ) to expand the footprint at the Commission’s Alternate Computing Facility (ACF) to support additional government-provided equipment, rack space and power.

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

It is recommended that a modification be issued to increase GSA Contract No. GS-35F-0210R/ Task Order CFIT-10-DO-0152, with Recovery Point of Germantown, MD, to enable Recovery Point to provide additional floor space, power, cooling, security, fire suppression, and back-up power for the hosting of servers, and storage required to serve as CFTC’s ACF.

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

The Commission is required to provide offsite data protection and system recovery capability of its production data sets. Currently, the Commission supports 121TB of storage for production data sets at its headquarters in Washington, D.C. However, at the Commission’s ACF the storage capability is only 77TB. As a result, the Commission is only able to replicate 60% of the Commission’s production data sets at the ACF. This drastic gap is due to the Commission’s significant data growth.

If the Commission were to suffer significant data corruption or loss due to a logical, hardware, or human error, IT services would be drastically impacted. Data loss directly impacts the Commission’s ability to perform mission critical functions required to oversee the financial markets. Currently, 40% of our production data sets are not being replicated offsite due to the limitation of the ACF storage array. The Commission is procuring an additional storage array to support the 100% replication of production data sets as anticipated under Order CFIT-10-DO-0152. The additional ACF footprint is required to support the new equipment being procured.

It is anticipated that the Commission will not incur charges associated with the increased support until on or about 30 days after issuance of the modification. From date of modification award through all options, if exercised, it is estimated that the increased support will cost $775,000.00.

4. Authority and supporting rationale

The authority permitting other than full and open competition is Federal Acquisition Regulation (FAR) 8.405-6(a) (1)(i)(B) unique source.

Recovery Point was competitively awarded Task Order CFIT-10-DO-0152 to serve as the Commission’s ACF where the information technology systems will be used as a ‘Hot-Standby’. The contractor has successfully completed the Base Year and is currently performing under the first of four one-year option periods. To ensure that the Alternate Computing Facility could accommodate any growth experienced by CFTC the following language was included in the Statement of Work (SOW) “The contractor must be able to accommodate expansion as CFTC requirements increase. Any expansion to the requirements currently outlined in this order will be vetted with the contractor. If the expansion requires additional facility space or service from the contractor, a modification will be issued to affect the change.” Since Recovery Point is the contractor responsible for serving as the Commission’s ACF and the ACF functions cannot be separated, the contractor is considered to be uniquely qualified.

5. Determination by the ordering activity contracting officer that the order represents the best value

The contracting officer has determined that the anticipated cost to the Government will represent the best value consistent with FAR 8.404(d) based on an analysis of the price proposal for this increased support and a comparison of the proposed pricing with those outlined in Recovery Point’s GSA Schedule. Further, the contracting officer negotiated a 29% discount off the contractor’s GSA Schedule.

6. Description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted

Market Research was not conducted. Although there are other contractors that can perform these services, a new contractor could not perform the services without a disruption of existing services and duplication of costs. A disruption of the services would place the Commission at risk of not being able to fulfill their mission in the event the Continuity of Operations Plan (COOP) was activated. Further, Recovery Point has already been contracted to perform these services; but the current contract ceiling is not sufficient to allow for an increase in the ACF footprint required to fully replicate CFTC’s production environment as a result of a 189% increase in the Commission’s production data sets.

7. Any other facts supporting the justification

There are no other facts supporting this justification to be listed under this item. All supporting facts are stated in the preceding paragraphs.

8. Statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made A competition of this requirement is expected to be pursued in FY 2015.

Program Office Certification:

This is to certify that the data supporting this justification is the responsibility of the program office personnel, including verifying the Government's minimum needs or other rationale for exception to fair opportunity (pursuant to 16.605(b)(2)) which form a basis for this justification, and that such data and rationale are accurate and complete.

Contracting Officer’s Representative

Concurrence:

I certify that this submission is accurate and contains complete data, to the best of my knowledge and belief, necessary to support the recommendations for approval. I further certify that an award of this contract action reflects pricing that is fair and reasonable.

Contracting Officer

Approved:

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