ID08170052_LSJ_20170711_Redacted.pdf

LIMITED-SOURCES JUSTIFICATION FOR FEDERAL SUPPLY SCHEDULE PROGRAM

Upon the basis of the following justification, prepared in accordance with Federal Acquisition Regulations (FAR) 8.405-6(c), I, as Competition Advocate (Region 8 FAS) hereby approve the use of sources limited to fewer than those required in FAR 8.405-1, FAR 8.405-2, and FAR 8.405- 3 pursuant to the authority of 41 U.S.C 3302 as implemented by FAR 8.405-6(a)(1)(i)(B). This acquisition is conducted under the authority of the Multiple-Award Schedule Program (41 U.S.C.

3302, et seq. and 40 U.S.C. 501).

1. Identification of the agency and the contracting activity.

Requiring Activity: Army National Guard (ARNG)

Contracting Activity: General Services Administration, Federal Acquisition Service, R8, Denver, Colorado

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

This is a limited source justification for ARNG for the approval of the procurement of VCOT C4 Software License Packages which includes related cybersecurity efforts for 110 Government owned Virtual Convoy Operator Trainers (VCOTs). The VCOT C4 Software License Packages are necessary for the VCOTs to comply with the requirements of Risk Management Framework (RMF) and to receive Authorization to Operate (ATO). ATO is the validation that VCOT is in compliance with all cyber security requirements in accordance with Department of Defense Instruction (DoDI) 8510.01 Risk Management Framework (RMF).

GSA intends to issue a firm fixed price task order to Raydon, Inc. (Raydon), using the Federal Supply Schedule (FSS) contract # GS-02F-0154R, under schedule 00CORP, SIN 874 9, for procurement of the VCOT C4 Software License Packages.

3. A complete description of the supplies and/or services required to meet the agency’s needs.

ARNG has an immediate need for the procurement of 110 VCOT C4 Software License Packages with related cybersecurity efforts to assist with the issuance of an RMF ATO.

VCOTs provide training for American combat convoys under realistic conditions so that they can operate in war zones such as in Iraq and Afghanistan. They ensure that soldiers are trained to anticipate ambushes and other insurgent actions from all possible directions by allowing the crew to observe, maneuver, and fire their weapons through a full 360-degree circumference. Just as in real-world scenarios, in which soldiers have a complete and continuous view of the battlefield, crew members must have the entire virtual world around them to simulate real combat conditions.

To enable the Government to operate the VCOTs and conduct training with the VCOT, an ATO is required per DODI 8510.01 and to maintain security. Raydon will upgrade the 110 existing VCOT software to VCOT C4 Software. The VCOT C4 Software License Package includes the effort to provide the documentation package for the ATO under RMF for the VCOTs. The documentation package will be in compliance with DoDI 8510.01 and be to a level acceptable to the government Authorizing Official (AO), who grants the ATO.

The estimate for Raydon to build the ATO documents package and stand up an ATO support lab is noted below as per the Raydon FSS Schedule contract prices.

Part # Description Qty Unit Price Schedule

Total Schedule Price

VCOT C4 SW 13-

VCOT C4

Software License Package

110 $29,491.00 $3,244,017.00

Estimated Total Price $3,244,017.00

4. Authority and supporting rationale and, if applicable, a demonstration of the contractor’s unique qualification to provide the required supply or service.

The authority for this limited source justification is FAR 8.405-6(a)(1)(i)(B) – Only one source is capable of responding due to the unique or specialized nature of the work. Raydon has unique qualifications to provide the VCOT C4 Software License Package to the 110 existing VCOTs within ARNG’s mission requirement timeframes, so it is the only one capable of meeting the Government’s requirements. The supporting rationale is discussed in detail below.

The ARNG has a specific requirement for VCOTs that must be met in order to provide soldiers with quality and effective training simulations. The entire inventory of VCOTs are used by approximately 12,000 ARNG personnel for training purposes to meet the soldier training requirements of ARNG Training Circulars (TC) 3-20.31 and 4-11.46. Specifically, in alignment with the Army’s “Home Station Training Initiative,” each Brigade and Regimental-level organization must provide its subordinate elements the means to train and sustain platform gunnery proficiencies at the crew, section and, when applicable, the platoon level. Due to fiscal constraints, the ARNG is only able to meet these training requirements through the state of the art VCOTs and VCOT software upgrades provided by Raydon. The necessary training can be provided with these VCOTs and VCOT software upgrades without the costs associated with using live-ammunition and the actual equipment.

Raydon is the only contractor with the software rights for the 110 VCOTs. Raydon developed the software used for the existing and new VCOTs on its own without any funding from the Government or from any Government contract. Therefore, the Government does not have the right to share the software for the Raydon VCOT with contractors to support competition to procure software upgrades and cybersecurity efforts to achieve the ATO under RMF for the existing VCOT inventory.

This means that a contractor seeking to meet ARNG’s mission needs for the software upgrades and cybersecurity efforts to attain the ATO under RMF must have permission from Raydon to use Raydon’s software for software upgrades. Even if another contractor obtained rights to the software, any other contractor would need to take extra time and money to make itself familiar with Raydon’s software in order to test and validate it to provide ATO documentation. Any delays by the closing date of November 15, 2016 but only Raydon was determined capable of meeting ARNG’s mission needs for new VCOTs and software upgrades, including the VCOT C4 Software License Package, for existing VCOT systems. Based on this recent information and as discussed in more detail below, GSA determined that only Raydon is capable of providing the VCOT C4 Software License Package for this procurement.

Raydon was determined to be the only vendor that could provide the software upgrades that can meet the needs of this requirement. The specific software deemed to only be available from Raydon is the same software involved in obtaining the ATO under RMF for this requirement. No other contractor can test and validate through the cybersecurity efforts to attain the ATO compliance for the existing VCOTs.

It is clear from the facts above that Raydon is the only contractor capable of meeting ARNG’s mission needs for this requirement, and it has been determined that any additional efforts to engage in market research or encourage other contractors to submit quotes would ultimately fruitless and inefficient for both Government and Industry.

7. Any other facts supporting the limited source justification.

There are no other facts supporting this justification.

8. A statement of actions, if any, the agency may take to remove or overcome any barriers that led to restricted considerations before any subsequent acquisition for supplies or services is made.

If GSA is requested to procure VCOT software upgrades for ARNG in the future, GSA intends to comply with applicable competition requirements after consulting with ARNG about its mission requirements and conducting the appropriate market research.

9. The ordering activity Contracting Officer’s certification that the justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief and evidence that the supporting data that form a basis of justification have been certified as complete and accurate by technical/program personnel.

Certification

Technical/Requirements Certification:

I certify that the supporting data which form the basis for this justification are completed and accurate to the best of my knowledge and belief.

20170705__ Jack Colburn Date

SFC, ARNGUS

NGB Master Gunner/NGB TADSS MGR