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JUSTIFICATION AND APPROVAL

TO PROCURE USING OTHER THAN FULL AND OPEN COMPETITION

Upon the basis of the following justification, I, as Procuring Activity Competition Advocate, hereby approve the use of other than full and open competition for the proposed contractual action pursuant to the authority of 10 U.S.C. 2304(c)(1).

JUSTIFICATION

1. Agency and Contracting Activity.

Contracting Activity:

Defense Information Systems Agency (DISA)/Defense Information Technology Contracting Organization (DITCO) , 2300 East Drive, Bldg. 3600

Scott AFB, IL 62225-5406 Requiring Agency:

Defense Information Systems Agency (DISA)/GE222-Narrowband Project Office 5275 Leesburg Pike

Falls Church, VA 22041-2714

2. Nature/Description of Action(s). The Ultra High Frequency (UHF) satellite communications (SATCOM) system provides the US Department of Defense (DoD) and other US Government departments and agencies critical beyond line-of-sight communications for tactical and special forces operations. However, the present UHF SATCOM is aging and the replacement system will not be fully operational until 2014 at the earliest. To allow for an increase of capacity over the aging system, DISA has developed improvements to the UHF SATCOM standards (MIL-STD-188-181C, -182B and -183B). These improvements are known as the Integrated Waveform (IW). These IW standards are structured to accommodate a variety of DoD unique requirements and systems, such as the Integrated Broadcast Service (IBS). The IW, with the addition of an IBS control layer, is known as the Common Interactive Broadcast (CIB) waveform.

IW implementation into fielded programmable terminals and upgrades which are the IW control system will more than double the UHF SATCOM capacity that can be immediately available to the warfighter. The interoperability and military standards which define IW have been specifically structured to be implemented in two Phases. The two Phase implementation provides a greater benefit to the warfighter since it allows for the introduction of the IW core capabilities to the warfighters sooner. These capabilities can then be followed or augmented by implementation of additional capabilities or enhancements defined in Phase II.

Able is currently on contract to provide services to Phase I and a contract is required with Able Communications Technology Corporation (Able), a veteran-owned small business, for the continued development, validation, integration, and testing of Ultra High Frequency (UHF) satellite communications (SATCOM) standards, software development and scientific and technical support to DISA/GE222 for Phase II. Development delays by other Integrated Waveform (IW) network terminal contractors has lengthened the government’s requirement for continued support for validation, integration, and testing of IW software as this interim waveform technology completes integration into DoD’s operational hand-held radios. This unplanned delay has increased the IW program’s risk and heightened the importance of Able’s role to complete these tasks without a break in IT service. IW is a critical interim fix to fill a communication gap until another Major Automated Information System (MAIS) program is fielded. Delays in IW’s schedule reduce the efficacy of the IW system’s role as a gap filler between Demand Assigned Multiple Access (DAMA) legacy and Mobile User Objective System (MUOS) capability. Further delays and risk must be minimized to provide this critical capability to the warfighter.

The government can not risk a break in service at this time for the deployment of the Integrated Waveform upgrade to DoD fielded UHF SATCOM radios. Therefore, a new contract is required to complete the ongoing fielding of radios and support the critical interim events that support the upcoming Major Automated Information System (MAIS) Program. Fielding of the IW solution into DoD network terminals and the IW control system must be accomplished before the IW system can interface with the MUOS MAIS; this is a dependency for the next generation MUOS development Period of performance is a one-year with two three-month options in case needed for sustainment to match with anticipated MAIS program schedule. This requirement will be a firm-fixed price (FFP) type contract, and the estimated lifecycle value of this requested contract is $2.7M.

3. Description of Supplies/Services. Able Communications’ support began in their Prime contract awarded under the full and open competition process on 23 Aug 2007 (HC1047-07-C-0017) that expired 22 May 2009. That work continues today in their sole source bridge contract HC1047-09-C-4015. Since 2007, additional requirements details have been added to the original requirements for completion of PDA-184 terminal software test and evaluation and for the DAMA-C terminal test and evaluation. Schedule slips drive a continued requirement for T&E engineering services for:

a. The Integrated Waveform (IW): Able’s tasks are approximately two-thirds complete. Due to the IW terminal contractor delays, this “last mile” work is required to complete that material solution. Able’s tasks include: analyzing and performing any IW waveform testing with respect to the UHF SATCOM standards; performing and validating test plans and procedures for the remaining IW certification at the Joint Interoperability Test Command (JITC); supporting the remaining design and fabrication of an IW channel controller test tool for use by the radio/terminal vendors, during the IW software development, unique user requirements for PDA-184 application, and JITC certification; evaluating and assessing proposed software designs by the radio vendors to implement IW; loading and testing the developed IW software in the radios/terminals; assessing software installation and radio operating procedures for the IW software; and the integration and test of the IW Planning Tool Satellite Access Controller (SAC) Component (PTSC) and the Planning tool Joint Integrated Satellite communications (SATCOM) Technology (JIST) Component (PTJC) software as part of the satellite controller system in initial deployment. The software is Government-owned.

b. The Integrated Broadcast Service (IBS): The United States Air Force, as the Executive Agent for IBS (IBS-EA), has requested that DISA develop and demonstrate UHF SATCOM standards which are DAMA compatible and meet the IBS requirements. Those IBS standards are known as the Common Interactive Broadcast (CIB). Able provides IT technical support to the government for the execution of the broader development, testing and fielding of the CIB capability into software programmable IW radios. An option has been added for the DAMA-C radio terminal. The IW, with the addition of an IBS control layer, is known as the Common Interactive Broadcast (CIB) waveform. The IBS, a classified USAF-led program, provides one-way broadcast of intelligence and threat information. This capability, which is built on IW, is a critical component for the US Intelligence Community.

c. MIL-STD-188-184 Software: The proposed service contract completes the assistance to the DISA program manager in the execution of the coding, testing, and fielding of the software implementation of the data exchange MIL-STD-188-184 and its revisions, known as the PDA-184. Tasks in progress include: software coding to upgrade the PDA-184 to new revisions; software modifications/changes include additional features and functionalities such as remote GUI modifications, Internet Protocol capability modifications, etc; option to perform any other software modifications to implement software changes and enhancements requirements from other users; software fielding support; testing, verification, and demonstration.

4. Identification of Statutory Authority. 10 U.S.C. 2304(c) (1), only one responsible source and no other supplies or services will satisfy agency requirements.

5. Demonstration of Contractors' Unique Qualifications

a. Over the past five years, Able Communications has established themselves as the only IW and PDA-184 integrator in the world with a highly specialized skill set. They have unparalleled experience and capital investment with the IW terminals, Channel Controller, integration, testing and verification. The government has also provided and installed a significant amount of GFE in this contractor facility that is in continuous use. They are/have been critical to the development and testing of the CIB waveform, which will be implemented by the Joint Tactical Radio System (JTRS) and other legacy terminals in support of IBS. Able Communications has developed software for the IBS simulation system, which is used to verify the CIB waveform and will satisfy the IBS capacity and time requirements. The IBS simulation system is being used to demonstrate the IBS functionality over the UHF SATCOM.

b. Able Communications maintains a UHF SATCOM waveform laboratory where many requirements of the MIL STDs are simulated and verified. They have climbed the learning curve and routinely provide a key role in integrating vendor software packages into the lab environment which is the only lab space DISA manages to ensure project success. Able Communications has also been instrumental in the systems engineering effort required to develop those MIL STDs 188-181C, -182B, -183B and -186. Additionally, Able participated in the definition of the future implementation and support requirements for the interim communication concepts defined by the MIL STDs. They developed a comprehensive set of technical documentation that is deemed critical for the completion and verification of the defined waveforms. Based on this demonstrated past performance, they thoroughly understand the military SATCOM requirements and lower the program’s risk. Able participates in the SATCOM Standards Technical Working Groups and supports efforts advanced by DISA, the Services, and industry members. Able Communications assists DISA in formulating positions and avocations of the MIL-STDs as a tool for operational requirements document developers, acquisition agents, and program managers.

c. Able's services are non-severable, which refers to the fact that the government will not receive a benefit from the vendor’s work unless the efforts are completed. The desired services from the vendor are the integration and test of the IW Planning Tool and software (PTSC) that is to be used as part of the satellite controller system being deployed. These products are also provided as GFE to IW terminal development contracts (Harris, Raytheon, Thales and Viasat) to complete software development for their respective radios’. These vendor’s network terminals were identified by the Joint Staff as the priority radios for IW conversion because of their proliferation across DoD. Able is developing critical aspects of the Government’s own ability, such as test plans and procedures, to verify MIL-STD compliance rather than relying on non-Government entities with respect to both the network terminals and the IW control system. Any interruption in the development, integration or testing of this product will severely impact the overall IW schedule. Services also include delivery of the certified IW/CIB software and waveforms to these IW terminal developers. Able assists DISA with validation, integration and testing of IW software developed under other IW contracts with Harris, Raytheon, and Viasat prior to the software being certification tested by JITC, a significant risk reduction effort. Able has continuously supported the development of the MIL-STD, and has an extensive testing and evaluation understanding of the Government’s intent with the IW system and compliance requirements of the MIL-STD capabilities. A new contractor would have a different interpretation of the IW MIL-STD which would result in an ineffective test tool and would take an unacceptable amount of time to complete this non-severable service at an equal level of understanding.

d. Award to any other source would result in a 3-6 month delay to move, qualify and certify a new test environment in a new facility which is currently established and calibrated at Able’s DD254 approved facility. Also, on average it takes 2 - 3 weeks for a vendor to hire the desired skill sets and ensure the security clearances are accurate with our requirement.

e. Since 2007, the specialization gap has further widened with Able’s additional expertise. As the operator of the Government-sponsored IW development and test lab, Able has continued to develope unique understanding of the IW waveform the further into development we proceed. This understanding can not be replicated by any other vendor in an amount of time that would not have a significant impact on the IW development.

6. FedBizOpps Announcement/Potential Sources. A FedBizOpps synopsis was published 29 March 2007 supporting the original awarded Aug 2007 contract (HC1047-07-C-0017). A bridge contract was awarded May 2009; at that time the DISA experts stated no other qualified source was available for this immediate need and a J&A was signed. A FedBizOpps RFI was released Oct 2009 that resulted in no additional qualified sources desiring this concluding IW work, other than the incumbent, Able. A notice of intent will be published on FedBizOpps; the government will consider all interested parties.

7. Determination of Fair and Reasonable Cost. The contractor will be required to provide the direct and indirect rates used to develop the fixed priced rates for the proposed labor categories. Actual current and historical data is being used to determine a fair and reasonable cost. Additionally, costs can be obtained from DCAA. A cost realism determination will be done during the proposal evaluation. The contracting officer will make the determination that prices are fair and reasonable.

8. Description of Market Research. Sources sought RFI was released on FedBizOpps 29 Oct 09 to gather new potential sources interested in completion of this ongoing IW effort. This RFI had one unqualified response that was evaluated; it lacked experience in two critical areas. One area was minimum experience modifying a fielded UHF SATCOM Network Terminal. The other area that did not meet minimum expertise requirements was with the design and development of the unique applications that enable communications using the CIB waveform. To date, Able Communications is determined to be the only fully qualified company capable and interested in proposing work to fulfill these remaining IW T&E requirements. Able won the original IW T&E task that was released full and open with a FedBizOpps and RFI back in 2007. When a bridge contract was required May 2009, a market survey via telephone was conducted and supported the current sole source bridge contract (HC1047-09-C-4015).

9. Any Other Supporting Facts. Over $1.2 M of GFE has been installed, calibrated and checked-out in the current Able facility and an IW/CIB test environment is established. This equipment is used continuously for development testing and evaluation and is required to meet remaining requirements that will complete the fielding and initial sustainment of this interim capability to the warfighter. Differently configured GFE will add technical risk to the solution. Final configuration of equipment is expected to take one month. Also, schedule risk could be critical given time taken away to remove, inventory, ship, and re-install the equipment in a different contractor location which would take three months minimum. Additionally, the learning curve for a new contractor will significantly impact the schedule. The government estimates this schedule impact based on vendor data which has been agreed to by the Government which shows a $1M impact for every six months of ongoing effort. The Government estimates that a move from the Able lab to any other laboratory environment, including learning curve would take at least 4 months based on our experience with adding new Government staff to the IW project.

Additional schedule risk could be critical to global operations and the lack of this interim IW/CIB solution to the field. This ripple effect will also impact the other IW terminal Prime’s cost and schedules because they are dependent on the IW and CIB solutions to accomplish their projects.

The current bridge contract (HC1047-09-C-4015) is a sole source contract to this small veteran owned business over the past 6 months. The DISA experts stated no other qualified source was available for this immediate need in a Feb 09 J&A. The original contract for this same engineering service waveform work was awarded 23 Aug 2007 in full and open competition (HC1047-07-C-0017) that expired 22 May 2009.

10. Listing of Interested Sources. Able Communications Technology, Corp., Sterling, VA.

11. Actions Taken to Remove Barriers to Competition. The Period of Performance for this effort is twelve months with two three-month options. The most valuable action to remove barriers to competition is the planned release of the translation functions and MIL-STDs to industry at the conclusion of this effort. MIL-STD normally are specific requirements that may restrict competition. These published MIL-STDs provide any interested vendor with the desire to compete on these SATCOM capabilities, basic technical requirements to develop IW capabilities. These MIL-STDs also enable an unlimited number of licensees the ability to purchase translation software and compete for any upcoming next generation waveform. Any of these alternatives could be integrated with all applicable DoD radios. Furthermore, DISA does not plan to update the present UHF SATCOM MIL-STDs because MUOS will replace the present UHF SATCOM system under a separate contract action. MUOS is a program of record which is a Major Acquisition Information System being developed under the Navy Program Executive Office for Space Systems (PEO Space). PEO Space planned for three sequential contracting phases, each will be full and open competitions that will need both waveform T&E services and waveform/radio/ground station development and integration. The first phase, consisting of concept exploration, has been completed and the second phase, comprising risk reduction and design development, is currently underway. The final phase which will be openly competed will conclude with an on-orbit operational capability in 2012.

Additionally, after initial fielding of the IW capability, the installed GFE at Able can be moved to allow full and open competition for the laboratory environment/test facility to support the next MAIS program. Management of this event will be highlighted to ensure a new contractor maximum use. It is the intent of the Government to compete future acquisitions for this requirement.

12. Statement of Period of Performance and/or Delivery Schedule. The period of performance is a twelve-month base period with two three-month options for unplanned delays.

13. Reference to the Approved Acquisition Plan (AP)/Program Plan (PP). This effort does not meet the threshold for an AP.

14. Reference to Information Technology (IT)/National Security System (NSS) IT and Information Management (IM): This effort was coordinated with the Information Management Officer for compliance with IT and IM standards/requirements and the Information System Security Manager relative to information assurance and traditional security requirements.