EPOS Redacted JA.pdf

Source Selection Information – See FAR 2.101 and 3.104

DEFENSE LOGISTICS AGENCY

DLA CONTRACTING SERVICES OFFICE

700 ROBBINS AVENUE

PHILADELPHIA, PA 19111-5092

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

1. IDENTIFICATION OF THE AGENCY AND CONTRACTING ACTIVITY

Requiring Activity:

Defense Logistics Agency (DLA) Information Operations at Fort Belvoir (J62BG) 8725 John J. Kingman Road Fort Belvoir, VA 22020-6220 POC: Ms. Lori Bovee Telephone: (571) 335-2675

Contracting Activity:

DLA Contract Services Office Columbus 3990 East Broad Street Columbus, OH 43213-1152 POC: William Melendez

2. DESCRIPTION OF THE ACTION BEING APPROVED

Pursuant to Federal Acquisition Regulation (FAR) 6.302-1, the purpose of this justification is to enable a sole source award to Coggins International (Coggins) for an AT&T data communications capability requirement described in previously submitted Electronic Point of Sale (EPOS) proposals submitted by Coggins and Varec Incorporated (Varec), the current EPOS contract awardees.

EPOS is a Defense Logistics Agency Energy (DLA-Energy) funded, DLA Information Operations (J62B) turnkey solution for capturing military fleet management fuel retail transactions at unattended military service stations, mobile ground fuel transactions, aviation fuel transactions for mobile airfield/flight line operations, and Custody Transfer Transactions.

The EPOS acquisition is divided into three groups, for which DLA Contract Services Office Columbus (DCSO-C) issued the following separate awards for contracts with a base period of five years with 10 one-year options:

Group One Active Directory Services, Indefinite Delivery/Indefinite Quantity (IDIQ) Contract

SP4702-19-D-0001, awarded on 19 Feb 2019 and Task Order SP4702-19-F-0045, issued on 22 Feb 2019 to Coggins; Group Two Fixed Pedestal Device Interface and Application Software

Development, Sustainment, and Hardware Installation and Sustainment, IDIQ Contract SP4702- 19-D-0002, awarded on 10 May 2019 and Task Order SP4702-19-F-0088, issued on 16 May 2019 to Varec; and

Group Three Mobile Device Integration, IDIQ Contract SP4702-19-D-0006, awarded on 14 Jun 2019 and Task Order SP4702-19-F-0098, issued on 14 June 2019 to Coggins.

3. DESCRIPTION OF THE SERVICES REQUIRED TO MEET THE AGENCY’s NEEDS

/ESTIMATED DOLLAR AMOUNT

As part of the Solicitation SP4703-17-R-CB01 and the subsequently awarded IDIQ contracts, the Government required services including data transfer communications capability and Subscriber Identity Module (SIM) Card management. Specifically, the requirement included the following:

The contractor shall provide internet connectivity, through cellular or satellite communication, for wirelessly obtaining lists of authorized source media and for the transmittal of transactional data to the enterprise solution

Connectivity that supports communication of fuel transactions and security monitoring/updates between the devices and the EPOS Enterprise.

Communication with the EPOS Enterprise via IPSEC (Tunnel Mode) over a Virtual Private Network employing dedicated SIM cards.

Communication through available secure cellular or satellite wireless connections.

Data communication in units that provide the most efficient and effective solution for the government.

Both EPOS awardees had proposed AT&T as their data communications capability requirement and AT&T’s satellite and cellular capability has been functional since February 2019. In order to meet the agency needs, AT&T’s communication capability must continue to be utilized for this requirement.

The period of performance for the communication capability will be five years, inclusive of a one-year base period and four one-year option periods. The estimated dollar award amount is for five years. It is necessary to establish a period of performance of five years during the EPOS initial rollout period that lasts approximately five years. This rollout is set to begin in the first quarter of FY21 and, until EPOS establishes full production capability and achieves a level of stability for both mobile and fixed pedestals (baseline in October of 2023), time will be needed to evaluate the next generation of communication service. It is not feasible to have a shorter period, due to stabilization of the system that is required. As described in the EPOS program requirements, periodic technical refreshes will occur for the EPOS mobile tablet at the four- to five-year point and for the pedestal circa the 10-year point. The communication capability will be addressed along those built-in points of reassessment.

cellular or satellite, that authorizes login. Each device with a SIM Card on the EPoS network is connected and authorized via the AD. The AD also manages the life cycle of the fixed and mobile devices. It is responsible for pushing security updates, patches, and configuration changes to the fixed and mobile devices that are connected.

Because all direct access to the EPoS network is via the Group One AD and SIM, it is imperative that these capabilities are managed by the Group One vendor. The criticality of keeping AD and SIM Data together falls in two areas, a) functionality troubleshooting and b) security. For functional troubleshooting, if the ability to connect to the Enterprise and/or send a transaction is lost, the government must be able to isolate and resolve the issue as soon as possible to restore the capability to transmit/receive transactions. For security purposes, it ensures the government can rapidly respond to security incidents. This is facilitated by having one focal point to ascertain the system(s) ability to connect to both AD and the SIM communication capability.

Due to the requirements and scope for visibility, management, maintenance, and real time actions, including both Mobile and Fixed devices, the data and SIM solution is seamlessly implemented across the entire EPOS enterprise network under the Group One AD.

As the vendor awarded Group One, Coggins is responsible for oversight of all EPoS Enterprise and End-Point systems through the AD. In contrast, Varec, the Group Two Fixed Device awardee is unable to access the Group One AD and therefore cannot manage the items within the AD, to include pedestals, mobile tablets, VPN/SIM cards and IP addresses. From a program perspective, without this AD ability/access, it is impossible for Varec to affect security in a real time capacity, to add / remove network assets, or terminate sites/SIMS. Similarly, the scope of the Coggins Group Three award, Mobile Device Integrator does not permit for management of the Group One AD or for management of the Group Two fixed devices. The Group One awardee, Coggins, is the only one that has the primary role for this SIM/data management which is inherent to the EPOS capability. If the requirement is not awarded to the Group One AD awardee, the help desk support provided as part of the IDIQ Contracts for Varec Group Two fixed devices and Coggins Group Three mobile devices would become strained and result in backlog scenarios due to their inability to manage the items within the AD.

For the same reasons set forth above, a third-party vendor would be unable to access the Group One AD and thus unable to manage the fixed and mobile devices within the AD. As a result, a third-party vendor would similarly be unable to affect security in a real time capacity, add/remove network assets, and terminate sites/SIMS from a program perspective.

(B) AT&T data must be provided as part of this requirement because AT&T satellite and cellular capability was already awarded as part of the EPOS IDIQ.

Awarding to a vendor to provide other than AT&T data is not viable because AT&T satellite and cellular capability was previously awarded as part of the EPOS solution. The EPOS solution has already progressed to final design and approval of production models, and deployment is scheduled for November 2020. Therefore, if other than AT&T data was provided, hardware modems, cybersecurity requirements, Virtual Private Network configurations, port and protocol configuration changes, and web service security configurations would need to be reconfigured and/or replaced and revised in the requirements, capability solution, specifications, Risk Management Framework artifacts and physical components. Rework would be required for all aspects of the program, representing thousands of labor hours and effort and this rework is not possible if the government wants to stay on schedule and within cost. Deployment of EPOS would be delayed by at least a year and millions of dollars in recovery would be incurred.

In summary, the only source capable of satisfying the Agency’s requirement for internet connectivity support is the Group One AD awardee, Coggins, and only AT&T cellular and satellite service will satisfy the Agency’s requirement. If DLA made an award to Varec or any other vendor, and if any service other than AT&T was provided, EPOS would be non-compliant with the established availability standards of DLA J6 and DLA Energy. This would jeopardize the EPOS solution, which will support over 6.5 million electronic transaction sales and credits amount to over 4.1 billion gallons of DLA Energy products to customers annually.

6. EFFORTS MADE TO ENSURE THAT OFFERS ARE SOLICITED FROM AS MANY

POTENTIAL SOURCES AS IS PRACTICABLE

FAR 5.202(a)(11) provides for an exception to synopsis requirements of proposed contract actions where, “the proposed contract action is made under the terms of an existing contract that was previously synopsized in sufficient detail to comply with the requirements of 5.207 with respect to the current proposed contract action.” The Contracting Officer finds that the existing EPOS contract, which was previously synopsized on October 11, 2017, was synopsized in sufficient detail to comply with the requirements of FAR 5.207 with respect to the current proposed contract action. Therefore, the current proposed contract action was not synopsized separately.

7. DETERMINATION OF FAIR AND REASONABLE COST

The Contracting Officer hereby determines that the anticipated price will be fair and reasonable IAW FAR 15.404-1(b)(2). An independent government cost estimate (IGCE) was developed by the DLA J62BG EPOS PMO for this capability using the US Navy Nationwide Wireless Service Contract for ATT Services (N00244-18-D- 0001) which contains negotiated AT&T data package rates. The Navy Wireless Service contract was used because it is the single contract vehicle for worldwide cellular / satellite services for the Department of the Navy and other DOD customers and was selected for comparison due to its scope and relevance to the EPOS requirement. The Contracting Officer will utilize the IGCE and historic cost/price information currently available to ensure that the current price to the government for this acquisition will be fair and reasonable.

8. DESCRIPTION OF THE MARKET RESEARCH CONDUCTED

On 2 December 2019, A Request for Information (RFI) was solicited by DLA DCSO-C from the two EPOS vendors, Coggins and Varec, and responses from both vendors were returned on 9 December

2019. The RFI sought market research regarding internet connectivity, through cellular or satellite communication and pricing from EPoS Group Two Fixed Facility Devices and Group Three Mobile Devices. The request asked for literature, provider coverage information, type of connectivity such as cellular or satellite, and pricing for one base year and four option years. Both vendors provided estimated pricing that appeared competitive when compared to the pricing of the US Navy Nationwide Wireless Service Contract for ATT Services (N00244-18-D- 0001), which was solicited with full and open competition previously stated.

As indicated in its proposal in response to Solicitation SP4703-17-R-CB01 and further supported through information provided by Coggins in response to the RFI, Coggins entered into an Exclusive Teaming Agreement (TA) on 27 October 2017 with AT&T for Electronic Point of Sale and Supporting Services. The Contracting Officer requested and received a copy of this exclusive TA via email on 20 February 2020.

Pursuant to the TA, Coggins is an AT&T Internet of Things (IoT) Partner and Certified Reseller, provider, developer, and integrator, and Coggins is an exclusive partner to AT&T on EPOS. Per the TA, All EPOS vendors that require AT&T communications must use Coggins as the integrator and reseller.

9. LISTING OF INTERESTED SOURCES

Coggins International 44 Canal Center Plaza 4th Floor | Suite 401 Alexandria, VA 22314 Phone: +1 703 496-5555

Varec, Incorporated 6909 Metro Park Dr., Suite 200 Alexandria, VA 22310 Phone: +1 703.861.2954

10. ACTIONS TAKEN TO REMOVE BARRIERS TO COMPETITION

The communication requirements for the EPOS solution was originally solicited as full and open competition under SP4703-17-R-CB01. All offerors had the opportunity as part of their proposal submissions to recommend a communication service provider. All of the awardees proposed AT&T as their communications service vendor.

Presently, it is not possible to compete the AT&T communications data requirement with full and open competition, as it is critical that EPOS communication capability continue to be supported by the AD manager, Coggins, along with the AT&T satellite and cellular capability which is part of the EPOS Group One IDIQ. Should there be a change in requirements, the Government will not exercise its option periods.

The Government intends to continue to conduct ongoing reviews for changes in technology in order to support future competition. A change to either vendor at some future date would potentially allow for competition of the communication data requirement. Before any future or subsequent acquisition for these services is required, changes to the vendors or the EPOS solution technology will be analyzed to determine if the current