GSAM 538.71_SS JUST.pdf

SUBJ: MEMORANDUM TO THE FILE – SOLE SOURCE JUSTIFICATION

This justification is prepared in accordance with GSAM 538.71, which permits placement of an order without providing for full and open competition when only one source is reasonably capable of meeting the Government’s requirement.

1. Identification of the agency and the contracting activity.

The Contracting Activity is the First Responder Network Authority (FirstNet Authority) Contracting Office located in Reston, Virginia. The requiring activity is the Network Management Office (NMO), located in Boulder, Colorado.

2. Description of the supplies or services

This requirement provides AT&T commercial subscriptions to support coverage evaluation, service quality monitoring, and roaming/interoperability testing between FirstNet and commercial networks. It enables comparison of network performance, evaluation of cellular technologies, and support for mission critical application testing. The effort also includes dual SIM operation testing within FirstNet devices and router devices, as well as technical support for multiple cellular subscriptions. These activities are necessary to assess performance across both FirstNet and commercial environments.

The FirstNet Authority previously evaluated network performance using outsourced drive testing and external engineering support. Establishing equivalent internal capability would require significant investment and resources. Leveraging AT&T commercial subscriptions provides a cost-effective method to obtain comparable data and insights. This approach allows continued oversight of competitive network performance without incurring higher costs associated with external analysis.

3. Rationale for Sole Source

In accordance with GSAM 538.7104-3(b)(ii), only one source is capable of providing the supplies or services required at the level of quality required because the supplies or services are unique or highly specialized.

This requirement supports the FirstNet Authority’s need to evaluate network coverage, service quality, interoperability, roaming, and mission critical application performance between the FirstNet network and commercial carrier networks. The effort requires access to AT&T commercial wireless subscriptions that can be used alongside FirstNet services to conduct side-by-side performance assessments, dual-SIM testing, and validation of operational capabilities across both environments. These activities are essential to independently assess network performance and compare FirstNet capabilities against commercial offerings. AT&T is uniquely positioned to provide these services because it operates the Nationwide Public Safety Broadband Network (NPSBN) on behalf of the FirstNet Authority and is the only source capable of providing the required combination of FirstNet and AT&T commercial network access necessary to support the testing environment. Without these subscriptions, the FirstNet Authority’s ability to perform independent validation, interoperability testing, and comparative network analysis would be significantly limited, reducing visibility into network performance and hindering informed decision-making.

4. Market Research

Market research was conducted in accordance with RFO FAR Part 10 and Federal Supply Schedule ordering procedures. Research included a review of General Services Administration Multiple Award

Schedule holders under SIN 517312 (Wireless Mobility Solutions). While multiple vendors provide commercial wireless mobility services, AT&T is the only source capable of fulfilling this requirement.

The FirstNet network (NPSBN) is statutorily established and exclusively operated by AT&T under a public-private partnership, and access to FirstNet-specific capabilities cannot be obtained through any other provider. This requirement is not based on a brand preference, but rather on the need to access a unique and non-replicable network and ecosystem, including FirstNet subscriptions, priority and preemption features, and FirstNet Push-to-Talk Land Mobile Radio (FN PTT LMR) interworking capabilities. No other vendor can provide these services at the required level of need to support the FirstNet Authority’s mission.

5. A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The Contracting Officer will determine that the price is fair and reasonable based on applicable price analysis techniques and established schedule prices prior to award.

6. Efforts to Promote Competition

This requirement is not suitable for competition because only one source is capable of providing the required services. The NPSBN is exclusively operated by AT&T under a congressionally authorized public-private partnership, and the required services, including FirstNet subscriptions, priority and preemption capabilities, and FN PTT LMR interworking, are proprietary to that network.

7. Actions to Remove Barriers to Competition

The Government will continue to assess opportunities in future acquisitions to promote competition where feasible. This includes monitoring advancements in public safety communications technologies and evaluating whether alternative solutions emerge that can provide comparable capabilities. However, due to the unique and non-replicable nature of the NPSBN and its mission-critical services, the Government does not anticipate viable competitive alternatives in the near term.

8. Any other facts supporting the justification.

This justification will be made publicly available in accordance with GSAM 538.71.

Brandon Payne Contracting Officer