Cloud One Class Exception to Fair Opportunity Justification for JWCC Cloud Services 16JAN26 (Redacted).pdf

This is a Justification for an Exception to Fair Opportunity under FAR 16.505(b)(2)(i)(B), filed by the United States Air Force to support non-competitive task order awards on the Joint Warfighting Cloud Capability (JWCC) Indefinite Delivery, Indefinite Quantity (IDIQ) contract. The document is a Class determination expiring December 7, 2028.

The Air Force Cloud One (C1) Office seeks authority to award four non-competitive Firm-Fixed-Price task orders against the JWCC IDIQ contract to Google (HC1050-23-D-0002), Microsoft (HC1050-23-D-0003), Oracle (HC1050-23-D-0004), and Amazon Web Services (HC1050-23-D-0005). These are the only four Cloud Service Providers (CSPs) available on the JWCC contract. The justification cites a Department of War memorandum dated July 31, 2023, and a Secretary of War memorandum dated April 10, 2025, mandating use of the JWCC contract vehicle for all Impact Level 6 requirements to consolidate cloud spending and reduce contracting burden. Task orders will have a one-year base period with two one-year option periods, utilizing multiple funding types with Operations and Maintenance as the primary funding source.

The Air Force argues the exception is warranted under 10 USC 3406(c)(2) because each CSP provides unique, highly specialized cloud-native and proprietary technologies and services necessary to sustain existing mission-critical applications currently hosted on their respective platforms. The document emphasizes that migrating existing applications (supporting worldwide warfighter missions, financial operations, and development capabilities across 320 separate Mission System Owners) to alternative CSPs would require extensive re-engineering over five years at prohibitive costs and would create unacceptable service disruption risks. The pricing is anticipated to be fair and reasonable based on JWCC base IDIQ rates, previously determined fair and competitive, supplemented by expected volume discounts. The Air Force acknowledges barriers to competition exist due to substantial MSO investments in each CSP's proprietary technologies but commits to future efforts to research cloud-agnostic capabilities, unified services, and identifying mandate push-backs to increase competition to the maximum practicable extent.