Comply365 Sole_Source_Justification _ Redacted.pdf

CONTROLLED UNCLASSIFIED INFORMATION

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

CONTROLLED UNCLASSIFIED INFORMATION March 2023 Page 1 of 4

Is this a new or amended J&A Document? New Amended ( Prior to Award Only! )

Is this a Bridge Action as defined in the AF Bridge Action Reduction Plan? Yes No

Funding level for this acquisition: x >SAT and < $750K x > $750K and < $15M

Contracting Activity: AFRC/PK

Purchase Request / Local ID Number: F5BFLG4122AW01

Program / Project (and PE, if applicable): Comply365 Publication Delivery System Licensing

Program Type (PEO or Other Contracting):

Authority: AFFARS 5313.501 - 10 U.S.C. 3572, Implementation of Simplified Acquisition Procedures (41 U.S.C. 1901)

AFFARS 5313.501 - 10 U.S.C. 3403, Special Emergency Procurement Authority (41 U.S.C. 1903)

Estimated Contract Cost (including options): $500,000 Justification Type: Class Individual

COORDINATION ( AFFARS 5306 . 304 ( a)) ** The text in the signature blocks below is editable, including the title.

** To remove a row, click the "X" next to the signature block. CAUTION: Once removed, it can only be restored by downloading the BLANK FORM again.

X

APPROVAL (AFFARS 5306 . 304 ( a))

Date

25 Nov 2024

Contracting Officer Maripet B. Beach

HQ AFRC/PKA/DSN 472-5868

Signature BEACH.MARIPET.BALLE Digitally signed by

BEACH.MARIPET.BALLESTEROS.1187567196

STEROS.1187567196 Date: 2024.11.25 11:56:03 -05'00'

NOTE: If a Justification was approved for the preceding acquisition, a copy of the approved Justification for the predecessor action must be included in the staff package for approval of the instant Justification. This applies to Justification staff packages that are submitted for review and approval at a level above the contracting officer. The predecessor Justification will be used as a reference document by the approving official.

Sign and Save Procedure

Date Project Lead / Program Mgr / Requiring Activity Danton V. Gipson

HQ AFRC/A3RM/DSN:497-2464

Signature GIPSON.DANTON.V.112 Digitally signed by

3315517

GIPSON.DANTON.V.1123315517

Date: 2024.11.25 11:18:40 -05'00'

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

CONTROLLED UNCLASSIFIED INFORMATION March 2023 Page 2 of 4

I. Contracting Activity.

AFRC/PK

II. Nature and/or description of the action being processed.

Comply365 is a Fit For Purpose publication delivery system designed for the aviation industry. This system uses tagging along with role and group based permissions to deliver a standardized user experience (UX) while customizing the data delivered to each user. These same permissions are then leveraged when utilizing the peer-to-peer file sharing functionality to ensure information protection measures remain intact even in a disconnected operations environment.

This system is specifically designed for the purpose of delivering publications to large groups of end users. These users gain the ability to directly mark up these documents and have these annotations remain with their documents regardless of updates or even when the user logs into another device. Additionally, Comply365 possesses the ability to handle aviation specific file types such as S1000D files.

III. Description of supplies/services required to meet agency needs.

Digital Publication Delivery system for the Electronic Flight Bag Program

IV. Statutory authority permitting other than full and open competition.

FAR 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements.

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

This is a new contract request for a digital publication delivery system to replace current system. VMWare software and WS1 platform delivers content for operational requirement. Software must be 100% compatible with our current total “cloud” solution we use across the Command at all our AFRC bases on low sides of the network. There is "no other" approved manufacture capable of providing AFRC & or the DoD the total and uniqueness for publications to of a total solution platform that VMWare offers within there VM/VDI/AW/Mobile & DA software platforms, and are 100% required to meet AFRC's current mobile & wartime mission. Comply365, is the only vendor capable of providing the annual subscription supplies required at the level of quality required. The license increase of an additional client access list (CAL) is required to keep AFRC legal within the software world of over provisioning/over using current licenses to handle today's growing wartime & mobile missions. All requested CALs will help AFRC in staying compliant & legal within all the Defense Information Systems Agency (DISA) & Security Technical Implementation Guides (STIG) in maintaining a clear security level of software CAT1-5 Security Vulnerabilities. It would be too cost prohibitive to change out all our virtual software solutions into multiple manufactures software platforms. Substantial duplication of cost to the government that is not expected to be recovered through competition. Quantifiable savings include reduced times, enhanced performance, increased efficiency and shorten acquisition cycle time. More information on this requirement can be found in the Market Research Report.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

A sources sought/request for information was posted on SAM.gov on 31 Oct 24 and closed 14 Nov 24. Two responses were received. After review of submissions, Adobe would still create extra work to convert our SD1000 files, thus reducing efficiencies and increase man hours to complete requirement and HEBCO did not show that they could convert the SD1000 file requirement. At this time, Comply 365 is the only company that can perform all of the requirements.

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

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

CONTROLLED UNCLASSIFIED INFORMATION March 2023 Page 3 of 4 reasonable.

The item is commercial and all the elements have been previously offered with sufficient resources to compare with historically paid prices and comparison of industry prices. The Contracting Officer anticipates cost to the Government is expected to be fair and reasonable.

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

A sources sought/request for information was posted on SAM.gov on 31 Oct 24 and closed 14 Nov 24. Two responses were received. After review of the submissions, Adobe would create extra work to convert the SD1000 files requirement, thus reducing efficiencies and increase man hours to complete and HEBCO could not show they could convert the SD1000 file requirement. Initial market research was conducted through Internet searches, aviation conference attendance, commercial airline research, and other known sources. Our research to meet our operational capabilities were to proficiency in and knowledge to deploy and maintain digital aircrew publication, safety and security, capacity to securely store and deliver publications on schedule. Ability to to collaborate and train with multiple stakeholders. Ability to customize publications for varying aircraft and mission. Ability to adapt to changing technology and deliver new methods such as apps or e-readers. SAF/CN directive memo dated 21 Jun 21, AFRC is required to hosting a private instance on a Cloud One brokered Azure environment, with the possibility of other MAJCOMs joining the effort. AFRC, AMC, ACC, AFMC, AFGSC and AETC have utilized several different products to try to address the capacity space in the past. Current solutions plagued by user interface complications, high costs, slow download capabilities and connection difficulties, unable to handle aviation specific file types such as S1000D files, which are structured data formatting and provide interoperability. At this time Comply365 is the only company that we have found that can meet all of our requirements.

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

Other publication delivery systems are unable to provide the conversion of S1000D files or provide files to the cloud.

X. List of any sources that expressed, in writing, an interest in the acquisition.

Comply365, Box, Adobe and HEBCO

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

HQ AFRC A3 will continue to research other delivery systems and work with Contracting on all possible future solutions.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. 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.

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

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