Redacted_-_LSJ_FY16-0215_-_Amazon_Web_Services_7.6.16.pdf

Limited-Sources Justification (LSJ) For orders or BPAs exceeding the Simplified Acquisition Threshold

- 1 - LSJ No: FY16-0215

LSJ No.: FY16-0215

This acquisition is conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies.

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), United States Citizenship and Immigration Services (USCIS), Office of Contracting, proposes to award an order pursuant to FAR 8.405-6(a), Limiting Sources.

2. Nature and/or description of the action being approved.

USCIS intends to limit the number of sources solicited pursuant to FAR Part 8.405-6(a) for the procurement of Amazon Web Services (AWS) to proposed contractor: Aquilent, 1100 West Street, Laurel, MD 20707. The requirement is to provide continued Information System Infrastructure Hosting through AWS. AWS will continue to provide the capability to virtually create systems in the Amazon Commerical Cloud. The USCIS systems currently hosted in the Amazon Commerical Cloud are: Electronic Immigration System (ELIS); MyUSCIS; Verification Information System (VIS); and National Appointment Scheduling System (NASS). USCIS Chief Information Officer (CIO) has utilized this unique plaform for the successful operation of numerous software hosting services for the agency. These hosting services include Amazon accounts and Infrastructures as a Service (IaaS).

3. Description of Services.

USCIS previously acquired AWS cloud hosting (which is a product of AWS) from Aquilent through an InterAgency Agreement (IAA) with General Services Administration (GSA’s) 18F program. The 18F cloud.gov program is GSA’s program that supports and offers agencies the capability to obtain cloud hosting services. It provides support for the deployment of all USCIS systems and engineering services by providing space on the cloud.

On May 1, 2016, USCIS entered into a new IAA (HSSCCG-16-X-00016) with GSA’s 18F program to continue the services. However, shortly thereafter, USCIS was abruptly notified by GSA that we would no longer be able to utlize the 18F services. Almost immediately thereafter, USCIS executed a 30 day task order, which expires on July 11, 2016, with Aquilent utilizing their GSA Schedule contract (GS-35F-360CA) to continue to acquire the AWS services.

At this time, we have an Request for Information out to First Source II contractors to determine if they can provide the AWS services and whether First Source II is the proper vehicle from which to acquire the services. The short notice given by GSA created a situation under which USCIS, under FAR 8.405-6(a)(1)(i)(A), has an urgent and http://uscode.house.gov/

- 2 -compelling need to procure AWS directly from Aquilent, the contractor that currently holds USCIS AWS accounts. Attempting to procure AWS from any other contractor would necessitate a large account transfer taking several weeks and causing a break in service which would severely impact the USCIS mission and public appearance.

Period Unit Price Total 3 mo

4. Authority and supporting rationale.

This acquisition is being conducted under the authority of the Multiple-Award Schedule Program, 41 U.S.C. 152(3), Competitive Procedures, and 40 U.S.C. 501, Services for Executive Agencies, in accordance with FAR 8.405-6(a), Limiting Sources. An award will be made as an urgent and compelling need exists pursuant to FAR 8.405- 6(a)(1)(i)(A) utilizing the vendor’s Federal Supply Schedule contract # GS-35F-360CA, and following the ordering procedures would result in unacceptable delays. Transfering of data for the systems would take up to several weeks and a loss of service would occur, causing mission failure for the agency and would disable critical USCIS enterprise architecture. The agency would be unable to deliver the I539 Applicant to Extend/Change Nonimmigration Status, I90 Permanent Resident Card Replacements, N400 Application for Naturalization, and the National Appointment Scheduling Service.

This would mean that the agency will not be able to perform mission-critical functions such as issuing Green Cards, performing naturalizations, scheduling any appointments to meet with applicants for adjudication, or allowing applicants to update their nonimmigrant status.

The resulting loss of hosting these essential systems on the AWS cloud will cause damage to USCIS’ public image and would directly affect the ability to perform mission-critical functions.

5. Determination by the ordering activity contracting officer that the anticipated order represents the best value consistent with FAR 8.404(d).

The Contracting Officer has determined that issuing the proposed Task Order to Aquilent for Amazon Web Services (AWS) represents the best value and will result in the lowest overall cost, considering price and administrative costs, to meet the Government’s needs for a period of 90 days. This order will be placed in accordance with FAR 8.404, “Use of Federal Supply Schedules.” The General Services Administration (GSA) has already negotiated fair and reasonable pricing rates. Discounts to these GSA schedule rates will be requested.

6. A description of the market research conducted among schedule holders and the results, or a statement of the reason market research was not conducted.

- 3 -

Market Research was conducted as it pertained to the determination of best procurement approach when USCIS received these services via IAA with GSA’s 18F program who awarded a competitive procurement under which our funds were being applied. For this sole source requirement, further market research was not conducted. However, for the follow on procurement to this sole source requirement, USCIS issued a Request for Information (RFI) to determine whether vendors under FirstSource II, DHS’ mandatory contract vehicle, can provide AWS. The results of the market research will determine the contract vehicle that will be utilized for the competitive recompete.

7. Any other facts supporting the limited-sources justification.

No additional facts.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted consideration (i.e., limited-sources) before any subsequent acquisition for the supplies or services is made.

The intent is to award this action to the current contractor (Aquilent) supporting USCIS under the GSA Schedule 70, GS-35F-360CA. USCIS will be recompeting and awarding this requirement as a competitive acquisition within 90 days of the sole source award.

9. DHS intends to post this requirement on Fedbizopps pursuant to FAR 8.405-6(a)(2)(i).