Redacted_ESD_FOE_3_Nov_16_-_2_May_17_Redacted.pdf

Justification for an Exception to Fair Opportunity

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Is this a brand name product justification? Yes No If yes, please provide the following information.

Brand Name Product Title:

Brand Name Product Description:

1. Contracting Activity: 38 CONS/LGCC, Tinker AFB OK 73145-2713

2. Purchase Request: Estimated Price:

3. Program Name (and Program Element, if applicable): Enterprise Service Desk (ESD)

4. Estimated Cost/Price of the Order (including options):

5. Type Program (see AFFARS 5302.101 for definitions): PEO Program Other Contracting

6. Fair Opportunity Exception: FAR 16.505(b)(2)(i), subparagraph (A) (B) (C) (E)(D)

7. Type Determination: Class Individual

Date Program Manager Signature

Date Contracting Officer

Signature

Date Local Legal Reviewer

Date Chief of the Contracting Office (COCO)

Date Competition Advocate

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(1) Contracting Activity:

38 CONS/LGCC, Tinker AFB OK 73145-2713

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(2) Nature and/or description of the action being approved:

A. Acquisition History. The current task order was solicited and competed by 25 AF (formerly AF ISR Agency/ A7KA). It was solicited in accordance with (IAW) fair opportunity procedures amongst all of the Service-Disabled Veteran Owned Small Business (SDVOSB) contract holders under the General Services Administration's Veterans Technology Services (VETS) Government-wide Acquisition Contract (GWAC). The task order was issued to Information Innovators, Inc. (Triple-I) under GSA contract number GS-06F-0519Z on 15 Apr 2011 to provide Network Control Center/help desk-type services for all AF bases and Air Force Reserve locations. The task order was issued for a base period of one year with a one-year option period with a value of $70M. A six month extension of services modification was issued 9 May 2013 to provide service through 15 Nov 2013. The value of the six month extension was $14M which increased the total value of the order to $84M. The requested extension was awarded to Triple I as a modification to the current task order, FA7037-11-F-0033, which ended 15 Nov 2013. An additional extension for one 5-month option period and four 1-month options with a total period of performance (PoP) of 16 Nov 2013 - 13 Aug 2015. Additional extensions were also approved for PoPs of 14 Aug 2015 - 2 Aug 2016 and 3 Aug 16 - 2 Nov 16.

B. Instant Acquisition. The purpose of this extension is to extend services through the IAFNOS contract award and transition period. The requested task order extension will be awarded to Triple I as a modification to the current task order which ends 2 Nov 2016. This requested extension is for six 1-month options for the period of 3 Nov 2016 - 2 May 2017, with an estimated value of This action will increase the total value of this task order to

C. Background. This task order provides support and sustainment of the automated virtual enterprise support environment and orchestrates support to deliver mission assurance across the enterprise to fulfill the 690 NSS enterprise mission. This mission will be fully integrated into a follow-on competitive enterprise-level acquisition, entitled Integrated Air Force Network Operations and Services (IAFNOS). The IAFNOS effort was originally started as an Enterprise Network Services Acquisition (ENSA) re-compete action called ENSA II with an expected award date of 14 Oct 2013 using the NetOps and Infrastructure contract under the NETCENTS-2 contracting vehicle. Two major events, however, prevented the award of the ENSA II contract: the delay of the NETCENTS-2 award and the approval of an associated Weapon System Operating Concept. The NETCENTS-2 contract was originally intended to be available by Sep 2012, but was then pushed back to Mar 2013. On 28 Sep 2012, as the ENSA II team was adjusting its strategy to accommodate the shifting availability of contracting vehicles, the Cyberspace Security and Control System (CSCS) Weapons System Operating Concept was approved by AFSPC/A3. Up to this point, ENSA II was based on an Air Force Network Operations (AFNetOps) enabling concept and current methods of operation. The approval of the CSCS Operating Concept struck an official focus on enabling the centralized management of the enterprise, and it was determined that the ENSA II strategy should therefore be replaced with a new requirement to provide services in a manner which leverages efficiencies across the enterprise vice a one-for-one replacement of those services currently provided. The ENSA II requirements were updated to incorporate the new enterprise approach and the acquisition effort was renamed IAFNOS.

The IAFNOS acquisition has encountered several hurdles necessitating the continuation of the current ESD task order beyond 2 Nov 2016. First, given IAFNOS was now a new requirement after the CSCS Operating Concept was approved in Sep 2012, and with no definite award date for the mandatory use NETCENTS-2 contract, an alternate strategy was required. Additional market research was accomplished to determine industry capabilities and if other appropriate Government Wide Acquisition Contracts (GWACS) were feasible. The results of the additional market research were used to develop an IAFNOS Early Strategy and Issues Session briefing held on 11 Oct 2013 with the AFSPC/CC;

approved a Firm Fixed Priced Contract. Second, a CSCS Manpower Assessment (MA) was conducted to validate the work identified in the approved operating concept and was approved by AFSPC/A3 on 28 Mar 2013.

Due to current fiscal constraints and future anticipated budgets, less than can be allocated to the

Air Force Network Operations mission provisioned by IAFNOS. Thus, the 690th Cyberspace Operations Group (COG)

[ Enter security markings here -- or delete this text. ] re-prioritized the functions under IAFNOS to balance AF mission requirements against approved AFSPC/CC program funding levels. Mission analysis was conducted to determine this re-prioritization. Third, this procurement went through a third acquisition strategy. After the re-prioritization of the work to be performed under the IAFNOS, market research was done in Feb 2013, it was validated with the NETCENTS-2 Program Office that IAFNOS was within the scope of the NetOps and Infrastructure portion of the NETCENTS-2 contract. At that time, the NETCENTS-2 contract had not been awarded but was expected to be available in late summer 2013, which would have allowed the associated request for proposal to be issued in Sep 2013. However, by the time of the formulation and completion of the Acquisition Strategy Plan (ASP), NetOps and Infrastructure portion of the NETCENTS-2 contract was still not available for ordering. Therefore, given the NetOps and Infrastructure portion of the NETCENTS-2 contract was not available, AFSPC approved the Acquisition Strategy Panel (ASP) to proceed with an open market, small woman-owned business set-aside contract for the IAFNOS effort on 21 Jul 2014. Since this time, the changing nature of the 67 CW's and 690 COG's mission, the transformation of the Enterprise Service Desk (ESD), the assumption of responsibility for the entire Air Force network integrity and assurance by the 690 COG, and fiscal constraints have made the identification and solidification of network requirements for the IAFNOS difficult. However, a final performance work statement was completed in Jan 2015 and a RFP was issued on 13 Mar 2015. Proposals from vendors were received on 27 Apr 2015, with technical evaluations beginning 29 Apr 2015.

Thereafter, the IAFNOS acquisition encountered additional hurdles.

The competitive range briefing was held on 7 Aug 2015 with the

Source Selection Authority. Competitive Range letters were issued on 10 Aug 2015. A protest was received after the competitive range release, forcing the source selection team to devote time to the resolution of the protest, resulting in further delays to the technical evaluations.

C. Given the duration of these activities described above, the IAFNOS estimated award date slipped from 2 Sep 2016 to 16 Sep 2016, with full performance starting on 25 Nov 2016.

13 Oct 2016, and work would begin on 27 Dec 16.

D. Contract Type. The current ESD task order is Firm-Fixed-Price (FFP), with a not-to-exceed cost reimbursement contract line item for travel. The requested extension will remain FFP, with a not-to-exceed cost reimbursement contract line item for travel.

(3) Description of the supplies/services required to meet the agency's needs:

A. The 690 NSS has the following mission: Operate an AFIN Mission Assurance Center (AMAC) and accomplish

[ Enter security markings here -- or delete this text. ] enterprise governance and support. The AMAC directs AFIN Operations to ensure standardized execution of I-NOSC and ESU tasks. To conduct AFIN Operations, the AMAC utilizes its 24th Air Force (24 AF) authority to issue global maintenance-related cyber orders to Air Force units. The 690 NSS leverages the AMAC to enforce and direct policies established by its enterprise governance mission areas.

B. The contractor, Triple I, currently provides 24/7/365 support and sustainment of the automated virtual enterprise support environment and orchestrates support to deliver mission assurance across the enterprise to fulfill the 690 NSS enterprise mission. The physical location hosting contractor support is Lackland AFB, TX.

C. The task order to be modified was issued utilizing GSA VETS GWAC. In accordance with the VETS ordering guide, this functional area is for operations, maintenance and security of existing information technology. The work being performed under this task order was determined within this functional area. The extension modification is for the same type of work and is within the VETS Ordering Period of 2 Feb 2007 through 1 Feb 2017 and within the VETS ceiling of $5B. According to the VETS contract specifications, orders may be awarded through February 1, 2017. All orders should be completed by February 1, 2020. The task order is performance based.

D. The extension total is comprised of the following estimates based on current labor rates for the expected PoP:

(4) Identification of the exception to fair opportunity and the supporting rationale:

A. The applicable authority is FAR 16.505(b)(2)(i)(B), Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized. The order (or modification) must be issued on a sole-source basis because the 67 CW would experience an unacceptable delay to award to another vendor at this time.

B. Supporting Rationale: Triple-I was originally awarded the ESD contract as the prime contractor on GSA order FA8773-08-F-0218, in Aug 2008 in a competitive environment. The 25 AF (formerly AF ISR Agency/A7K) re-competed the requirement and the award was made again to Triple-I on 16 May 11. This current task order will expire on 2 Nov 2016. Given Triple-I has been awarded two previous task orders, they have performed ESD network support services for the past seven years. They have qualified and fully trained technicians with the specialized knowledge related to the network services requirements and experience to resolve customer que regarding network and systems issues. These technicians and managers are trained and certified to be DoD 8570 compliant, to include Security + and Information Technology Infrastructure Library (ITIL). Given it takes 6 months to one year to study and test for these certifications, another vendor brought in at this time would not be able to provide the same number and quality of qualified technicians to maintain the support Triple-I provides. The Triple-I Technicians hold Secret security clearances. Secret clearances are required for contractor employees to access the ESD Operations floor, and to operate and maintain the Cyberspace Security and Communication System (CSCS) weapon system. Security background checks for newly hired employees take three to five months to obtain a secret-level clearance. This adds to the certification delay mentioned in paragraph 4B above.

The contractor has undergone extensive training and possesses seven years of experience with the application of automated tools, updating the ESD portal and performing metrics analysis on ESD system performance.

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The contractor currently provides the 690 COG with 24 hours a day, 7 days a week, 365 days a year (24/7/365) support Air Force-wide, enterprise-level support for infrastructure operation, vulnerability analysis and management, firewall boundary op directory systems operations and maintenance, messaging and collaboration services, systems monitoring and management, storage area network, change and incident resolution and management, and system metrics and trend analysis. The contractor is also monitoring, identifying, analyzing, documenting, and reporting events and incidents, degradations and outages occurring on 24 AF operated systems and the Air Force Information Network (AFIN) in support of the Air Force Information Network (AFIN) Mission Assurance Center (AMAC) monitoring cell. Another critical AMAC task is to perform vulnerability management, by conducting AFIN vulnerability trend analysis, and ensuring and reporting compliance to required regulations. This is accomplished by relaying, executing, complying, and tracking cyber orders (i.e. Information Assurance Vulnerability Alerts/Bulletins (IAVA/B), Acknowledges USCYBERCOM released Information Assurance Vulnerability Alerts/Bulletins (IAVA/B) and reporting AF IAVA/B compliance to USCYBERCOM. The contractor also tracks Plan of Action and Milestones (POA&M) developed by units to mitigate risks when compliance dates for cyber orders cannot be met. They are also involved in the drafting, coordinating, reviewing, releasing and tracking the AFIN Time Compliance Network Orders (TCNO), Maintenance Tasking Orders (MTO), and 24 AF Notice to Airman Notifications (NOTAM) in their AMAC support role.

OSI). Thus, the Triple-I technicians and managers are thoroughly familiar with the ESD's, AMAC and the enterprise processes and automated tools.

Using another contractor for this 24/7/365 ESD support would slow or halt the ESD mission tempo impacting network enterprise (AFIN) connectivity, vulnerability management, compliance management, service interruptions, and incidents affecting 850,000 AFIN users. The ESD contract augments ESD government personnel contributing to complying with the 24 Air Force (24 AF) 24/7/365 requirement. Not continuing the current ESD contract would degrade the 690 COG's capability to perform routine hardware/software checks for 24 AF operated equipment including: routers, switches, firewalls, web proxies, and Domain Controllers, Exchange, and Certificate Authorities servers making them more vulnerable to unauthorized entry. This would also slow or stop the planning of Authorized Scheduled Interruptions (ASIs), in which this interruption is used to install security and system improvement patches. The lack of these patches would also increase the vulnerability risk and could result in the AFIN users' inability to carry out their daily operations.

The AFIN hardware and software outages would deny senior leadership the ability to communicate with subordinate units during operational missions, and deny access to information vital to command and control communication functions and decision making processes. This would disrupt on-going operational missions, scheduled payload launches, major weapon system operational tests and defensive cyber actions. This would also mean necessary software and hardware upgrades would not be carried out, which would further hamper communications and render the AFIN vulnerable to adversary and other malicious intruders. Without these upgrades, data that is vital to operational missions and national defense would be vulnerable to theft, corruption, disruption or malicious manipulation. Inexperienced contractor personnel would have to defer functions performed at the 690 NSS to other squadrons in the 690 COG that are already operating at full capacity levels, with no additional government manpower forecasted to be brought in to assist. Using another contractor would also decrease the effectiveness of safeguards against classified messages leaking into unclassified networks. This would increase the risk of data loss or theft, thereby putting mission performance and crew safety in peril, and have a negative impact on national security. Further, there would be no support to document valid instructions to ensure proper release of mandated AFIN system updates. An improper update release renders the AFIN vulnerable to security threats and leads to system discrepancies, which would force the engagement of Air Force network operators to resolve these discrepancies and threats. Pulling these network operators, which would be better

[ Enter security markings here -- or delete this text. ] used in carrying out daily operations, would further compound the lack of support to the operations of the AFIN and increase threat vulnerabilities. Using another contractor would also slow or stop the issuance of the TCNO, TCTO, and NOTAM notices identifying system updates or events to systems operators and users in the AFIN. Lack of these notices would mean a breakdown in communication causing confusion and lack of awareness of system events across the AFIN enterprise. The 690 COG would be unable to provide data to the Office of Special Investigations in their conduct of criminal investigations as is currently being accomplished. The lack of data would hinder or stop OSI investigations, resulting in the inability of the OSI to halt criminal activity against the US Air Force, further endangering Air Force assets and personnel.

Creating and soliciting a new single ESD procurement would result in degraded support as described above in fulfilling the Air Force's requirements, and cannot be accomplished prior to the 2 Nov 2016 expiration date of the current ESD task order. Given it takes 6 months to one year to study and test for these certifications, another vendor brought in at this time would not be able to provide the same number and quality of qualified technicians to maintain the support Triple-I provides. The Triple-I Technicians hold Secret security clearances. Secret clearances are required for contractor employees to access the ESD Operations floor, and to operate and maintain the Cyberspace Security and Communication System (CSCS) weapon system. Security background checks for newly hired employees take three to five months to obtain a secret-level clearance. The ESD replacement contract, IAFNOS, was awarded on 13 Oct 2016 with a full performance start on 27 Dec 2016. While other contractors may potentially perform this ESD requirement, they will not be able to successfully staff critical ESD requirements before the IAFNOS contract starts on 17 Oct 2016 or before the current task order expires on 2 Nov 2016.

Triple-I is the only firm capable of providing the supplies and services described above without the U.S. Air Force experiencing a break in service in fulfilling its requirement. This bridge extension request for six one-month options for the PoP of 3 Nov 2016 - 2 May 2017, which will be utilized as required, to continue this highly specialized service performance to mitigate any delays leading up to the IAFNOS contract award and full performance start dates, and allow for continued support should the IAFNOS contract be protested after award.

(5) Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable:

The price will be negotiated utilizing the pre-established GSA VETS contract hourly rates as a baseline. It is anticipated that prices will be determined fair and reasonable based on predetermined out-year pricing referenced from the GSA hourly rates taken from the current task order, comparison of existing GWAC holders' price schedules, and other than certified cost and pricing data (since this is a commercial contract certified cost and pricing data will not be obtained).

Costs of this follow-on, sole source action are expected to be comparable to the current Information Innovators Inc. task order. No known changes in labor categories or staffing are expected during this extended period of performance.

(6) Other facts supporting the justification:

Type of Funding: FY17 O&M

The Contracting Officer has determined using a non-DoD contract for this acquisition is in the best interest of DoD. The factors considered consist of providing the services required to satisfy the customer's requirements and offering a cost advantage by further reducing their GSA rates.

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(7) Actions the agency may take to remove or overcome any barriers to increasing fair opportunity before any subsequent acquisition for the supplies or services:

This contract requirement will be absorbed by IAFNOS that is currently in source selection. The replacement contract will be conducted utilizing competition in accordance with FAR 15.

(8) Contracting Officer's certification that the justification is accurate and complete:

The Contracting Officer's signature on the signature page provides evidence that he/she certifies that the justification is accurate and complete to the best of his/her knowledge and belief.

(9) Certification of technical/requirements personnel that supporting data is accurate and complete:

As evidenced by his/her signature on the signature page, the Program Manager certifies that any supporting data contained herein, which is his/her responsibility, is both accurate and complete.

(10) Determination by the approving official that one of the circumstances in FAR 16.505(b)(2)(i) applies to the order

As evidenced by my signature on the signature page, I hereby determine that the fair opportunity exception checked in block 6 (Page 1) applies.