A12 - Class Exception to Fair Opportunity - Redacted - Final.pdf

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

REFERENCE: Class Justification for an Exception to Fair Opportunity in accordance with Federal Acquisition Regulation (FAR) 16.507-6

1. Identification of Agency and Contracting Activity The Defense Advanced Research Project Agency (DARPA), Contracts Management Office (CMO), proposes to issue task orders directly to Cloud Service Providers (CSPs) for Cloud Credit Services under the Joint Warfighting Clous Capability (JWCC) multi-award indefinite-delivery, indefinite-quantity (IDIQ) contracts.

2. Nature and/or Description of the Actions Being Approved These actions are for the procurement of specialized cloud computing services and associated cloud professional support services through the JWCC IDIQ contract vehicle. This justification supports the issuance of task orders directly to specific CSPs to maintain mission continuity of operations for critical research and development (R&D) programs and to obtain unique or highly specialized cloud capabilities necessary to satisfy DARPA mission requirements.

3. Description of Supplies or Services Required The requirement encompasses the provision of cloud computing credits and associated professional support services, including high-performance computing environments, cloud-native application hosting, proprietary serverless architectures, accredited machine learning (ML) and artificial intelligence (AI) platforms, advanced analytics capabilities, cybersecurity-compliant cloud environments, specialized database architectures, and hybrid cloud solutions.

These services support DARPA programs conducting advanced research in AI/ML, cyber operations, microelectronics, autonomy, space technologies, biotechnology, national security applications, modeling and simulation, and large-scale data analytics. Continued access to these cloud environments is necessary to maintain operational continuity, cybersecurity compliance, and mission execution.

4. Estimated Value The estimated value across all task orders awarded pursuant to this class justification is

The Government may issue one or more task orders to each CSP under their respective JWCC contract, provided the total value of all task orders issued under this class justification does not exceed this estimated value.

CLASS JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

Cloud Credit Services

5. Identification of the Exception to Fair Opportunity and Supporting Rationale

a. Exception Cited: FAR 16.507-6(b)(2) – 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.

b. Supporting Rationale: DARPA conducted market research and technical assessments regarding commercially available cloud computing environments and determined that certain mission requirements necessitate continued use of specific CSPs environments. DARPA's research portfolio includes advanced AI/ML, cyber, microelectronics, autonomy, space, biotechnology, and national security programs that rely upon cloud-native architectures, large-scale data analytics, high-performance computing resources, and accredited computing environments. Many of these workloads have been developed, tested, accredited, and deployed within specific CSP ecosystems over multiple years and are tightly integrated with provider-specific services, security controls, application programming interfaces (APIs), data architectures, and development toolchains.

The following provider-specific capabilities support DARPA’s minimum needs:

Amazon Web Services (AWS) AWS GovCloud environments currently support multiple operational DARPA workloads utilizing established serverless architectures, accredited security configurations, and existing Authority to Operate (ATO) approvals. AWS provides mature cloud-native services frequently used throughout the Federal Government, including Lambda, DynamoDB, Elastic Kubernetes Service (EKS), SageMaker, and other integrated services that support advanced analytics and AI/ML development. Transitioning the DARPA workloads to an alternative CSP would require significant redesign of cloud-native applications, redevelopment of automation scripts and infrastructure-as-code deployments, extensive testing and validation activities, cybersecurity reassessment, and reaccreditation efforts. Such activities would result in substantial duplication of costs and unacceptable mission delays while providing little or no corresponding benefit to the Government.

Microsoft Azure Microsoft Azure provides required integration with Department of War (DoW) enterprise identity management services, including Microsoft Entra ID and DoD365 capabilities, as well as Azure Stack hybrid cloud solutions supporting distributed and edge computing requirements.

DARPA’s Azure environments are frequently integrated with existing Microsoft enterprise technologies used throughout DoW, including identity management, collaboration platforms, endpoint management, and security monitoring capabilities. Migration from DARPA’s Azure-based environments would require reengineering of authentication and authorization architectures, modification of application integrations, redevelopment of automation workflows, and extensive validation of interoperability with existing DoW enterprise services. These efforts would increase costs, disrupt ongoing operations, and delay mission execution.

Oracle Cloud Infrastructure (OCI) OCI provides unique support for Oracle Real Application Clusters (RAC) and Exadata-based environments, which are anticipated requirements for future DARPA programs involving high-

7. Other Supporting Facts This class justification applies to all DARPA task orders issued under the JWCC IDIQ contract vehicle up to the estimated value of across all issued task orders.

8. Actions to Overcome Barriers to Competition DARPA will continue to promote future competition by requiring data portability, maximizing the use of open standards where practicable, and the use of open-source standards where feasible to prevent long-term vendor lock-in. The Government maintains full data ownership, ensuring that future efforts may be competed when it is technically feasible to do so.

Advocate for Competition Review I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief.

Approval

Head of the Contracting Activity

In accordance with FAR 16.507-6(e)(3)(i), I have reviewed this class justification and determined that the cited exception to fair opportunity applies, and the justification supports issuance of task orders pursuant to the authority cited herein.