E20 - Limited Sources Justification_FAR8_13_16_Under SAT_signed ver2_Redacted.pdf

CUI

Page 1 of 5 Pages Controlled By: DMA Controlled By: War Media Activity CUI Category: SSEL Distribution/Dissemination Control: FEDCON POC: Robin Kelsick

(Source Selection Information - See FAR 2.101 and 3.104)

LIMITED SOURCES/ SOLE SOURCE JUSTIFICATION

Justification and Approval (J&A), Supporting Procurements under Federal Acquisition

Regulation (FAR) Subparts 8.405-6, 13.106-1 and 16.505 (Under the Simplified Acquisition Threshold (SAT)($350K) ONLY)

Purchase Request Number:

Contract Number: TBD Task/Delivery Order Number: N/A Procurement Title: Wheatstone Commissioning Support and Training Estimated Value:

Statutory and Regulatory Authority: See Paragraph 4

Justification Number:

Upon the basis of the following justification, I, as the Contracting Officer, hereby approve the use of other than full and open competition of the proposed contractual action pursuant to the authority of FAR Subpart 13.5.

1. REQUIRING ACTIVITY AND CONTRACTING ACTIVITY:

Requiring Activity:

War Media Activity (WMA)

Contracting Activity:

WMA HQ, Acquisition and Procurement Directorate

2. NATURE/DESCRIPTION OF ACTION: This is an acquisition for a follow-on sole-source Firm-Fixed-Price (FFP) Purchase Order utilizing Fiscal Year 2026 (FY26) Operations and Maintenance (O&M) funds. The WMA TSOEE requires an expanded support, and operator and maintenance technician training for systems supporting the American Forces Network (AFN) Radio mission. This proprietary services support brand-name Wheatstone Corporation products originally procured under contract and established under contract to ensure the continuous operational

Page 2 of 5 Pages readiness of the AFN Radio mission. This Purchase Order consists of one (1) 12-month base period of performance (PoP) with three (3) optional task line items (CLINs) to be exercised at discretion of the Government on an as-needed basis within the 12-month timeframe.

3. DESCRIPTION OF SUPPLIES/SERVICES: This requirement consists of on-site technical configuration, troubleshooting, and hands-on maintainer/operator training for brand- Automation System (ERAS) and Audio over Internet Protocol Routing System (AOIPRS). Specifically, the Contractor will perform system check-outs and hands-on training for maintenance and operator personnel at WMA HQ facility at Fort Meade, Maryland.

4. Regulatory Authority: Federal Acquisition Regulation (FAR) 13.106-1(b)(1). (Open Market Purchase Order) Soliciting from a single source (including brand name). The order may be solicited from one source if the contracting officer determines that only one source is reasonably available (e.g., urgency, exclusive licensing agreements, brand name).

5. Proposed Sole Source Contractor:

Wheatstone Corporation

Wheatstone Corporation, as the original equipment manufacturer (OEM) has the requirement. Due to the proprietary nature of the equipment and the existing support contracts, utilizing an unauthorized vendor for this additional volume of configuration and training would negate existing warranties on the hardware and software in use from the manufacturer confirms that Wheatstone Corporation does not authorize, license, or certify any third-party dealers or service providers to perform factory-direct configuration or training on these systems.

Furthermore, attempting to bring in a non-incumbent, unauthorized third-party contractor would result in unacceptable delays in fulfilling the agency's requirements and a substantial duplication of cost to the Government that is not expected to be recovered through competition. Specifically:

Duplication of Cost (System Discovery & Baselining): A new contractor would lack the proprietary system knowledge and existing baseline data that Wheatstone currently possesses. It is estimated that a new vendor would require approximately 11,500 to 22,000 hours of initial engineering time just to perform system discovery, reverse-engineer the current configuration, and map the

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ERAS/AoIP architecture before they could begin the actual required work. This duplicated effort would cost the Government an estimated which represents a premium over the purchase order for the base period.

Warranty Risk Exposure: The broadcast infrastructure represents an enterprise capital investment exceeding across AFN production facilities.

Utilizing an unauthorized third-party to alter system configurations or manipulate proprietary firmware would explicitly void existing OEM hardware and software warranties, exposing the Government to catastrophic financial risk and substantial hardware replacement costs in the event of system corruption or failure. The WMA ERAS and AOIPRS broadcast infrastructure represents an enterprise capital investment exceeding across global AFN production facilities.

Unacceptable Delays: Transitioning this requirement to an alternate vendor would require a minimum delay of 60 to 90 days to issue a competitive solicitation, evaluate technical capabilities, and onboard external personnel. critical expansion to a new vendor would require a new solicitation, award, and onboarding process, causing an estimated delay of 1 to 2 years. Any such delay directly jeopardizes the congressionally mandated timeline for relocating the AFN Radio mission from Riverside, California to Fort Meade, MD resulting in unacceptable operational downtime.

7. CONTRACT OPPORTUNITIES ANNOUNCEMENT/POTENTIAL SOURCES:

In accordance with FAR 5.201, a combined Notice of Intent to Sole Source and Sources Sought Synopsis was published on the System for Award Management (SAM.gov) on 07 August 2026 and updated on 01 September 2026 to notify the public of the Government's intent to solicit this requirement on a non-competitive, sole-source basis.

Following the close of the public response windows, the Government received zero

(0) capability statements, inquiries, or expressions of interest from industry. The lack of commercial response further validates the Government's finding that Wheatstone Corporation is the only available commercial source capable of satisfying this requirement.

8. DETERMINATION OF FAIR AND REASONABLE COST: The contracting officer will determine that the anticipated cost to the Government for this order is fair and reasonable pursuant to FAR 13.106-3(a)(2)(ii), comparison of the proposed price with prices found reasonable on previous purchases. Because this modification procures an expanded volume of the identical technical tasks established in the original contract, the contracting officer will compare the proposed engineering labor and training rates for this new work directly against the established, fair and reasonable rates approved on the base contract award

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9. Market Research: Market research conducted from October 2025 through August 2026 confirmed that Wheatstone Corporation remains the sole proprietary owner and manufacturer of the ERAS and AOIPRS architecture.

A review of mandatory and strategic Government-Wide Acquisition Contracts (GWACs), including GSA eLibrary, GSA Advantage! NASA SEWP, and the Interagency Contract Directory (ICD), yielded zero authorized commercial sources for these proprietary technical services. Furthermore, Wheatstone Corporation certified that they do not authorize, license, or certify any third-party dealers or IT resellers to provide factory-direct commissioning, system configuration, or certified operator training on their proprietary radio automation systems.

The Government will continue to monitor the marketplace for changes that would enable future competitive actions (e.g., if the OEM releases ownership rights, licenses of third-party providers, or if it becomes economically feasible to replace the entire proprietary system). Based on the technical justification provided by the program office, a determination has been made to issue a follow-on sole-source follow-on Purchase Order directly to Wheatstone Corporation.

10. ACTIONS THE AGENCY MAY TAKE TO REMOVE OR OVERCOME

BARRIERS THAT LED TO THE EXCEPTION TO FULL AND OPEN

COMPETITION:

(a) Procurement History:

(1)

(2) Sole Source

(3) Small

(b) Actions to Remove Barriers: Market research will be conducted on a continual basis to see if new radio automation products and services are available in the market that can meet the technical requirements of War Media Activity. As new products come on the market, we will review to determine if they can replace the current equipment, thus removing the barriers.

Based on the justification provided by WMA TS0/EE, a determination has been made to issue a sole source solicitation to Wheatstone Corporation for the above-described requirement.

PREPARED BY:

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APPROVED BY: