ID40160051-Comcast_JA_commercial-A_Redacted.pdf

Comcast Business Communications, LLC is migrating internet services to a MetroEther (high speed) connection. This migration will require all SOUTHCOM commercial internet (SPIAN) to change IP addresses. Comcast Business Communications, LLC will allow SOUTHCOM to run both connections (legacy and new) simultaneously until the re-IPing of the entire SOUTHCOM internet network is complete.

Comcast Business Communications, LLC is the only cable and internet provider capable of supporting the existing infrastructure as well as providing the least disruptive option while SOUTHCOM assesses the impact of changing IP addresses with its users. A significant number of SOUTHCOM sites on SPIAN support the Commander’s objectives to foster security, ensure stability, and promote prosperity throughout Central and South America, the Caribbean and the global community. If another vendor is selected the SPIAN connection will be shut down by Comcast Business Communications, LLC on 11 May 2016 until a new vendor can provide the service which could take months.

6. Other Supporting Facts:

Currently there is a SOUTHCOM J6 tasking to estimate the level of effort (cost, time, personnel, number of devices, travel, etc.) required by SPIAN users (NCE, Canadian CSNI, AMNET, CENTRIX, TCSC, SIMNET, CROSS etc.) to change IP addresses. This information is required to estimate the Re-IP project timelines, prepare a decision brief on the way ahead, and coordinate a transition with Comcast. J6 CIO states one of their internet (SPIAN connections) supports systems with “counterparts” in other countries. They estimate approximately in travel and 2-3 months with a vendor change.

7. Efforts to Obtain Competition:

Prior to the initial service selection of Comcast Business Communication, LLC, consideration was given to available vendors that could provide the needed service. , the only major competitor, declined and indicated they could not provide the requested service.

8. Determination the Cost will be Fair and Reasonable to the Government:

The Contracting Officer will determine that the anticipated cost to the Government for this acquisition will be fair and reasonable. Actions anticipated to ensure the reasonableness of the price will be accomplished with the procedures and criteria contained in FAR Subpart 13.106-3, as appropriate. The Contracting Officer will use various cost analysis techniques and procedures to ensure a fair and reasonable price including the comparison of proposed prices from Comcast Business Corporation, LLC found reasonable on previous purchases, comparison of the proposed prices with the independent Government cost estimate, comparison with actual costs previously incurred, and have a technical expert perform technical analysis of the proposal.

9. Market Research:

Market Research was conducted in accordance with FAR Part 10 during the initial service requirement in which Requests for Information were posted. USSOUTHCOM received one response from a vendor other than Comcast, was unable to meet the capabilities necessary for the requirement by only being able to provide service, but not dual platform for the transition from the legacy equipment to fiber. In regard to the Cable portion, advised that they could not provide the cable service, however they are working on a business product for their UVerse cable package but it is not currently available to the public at this time.

In accordance with FAR Subpart 8.002(a)(1) Priorities for Use of Government Supply Sources and GSA Memorandum; “Preferred Use of Existing GSA Contract Vehicles” dated October 11, 2012, exceptions to using existing GSA acquisition vehicles are allowed for an assisted acquisition where a customer agency has a mandatory restriction to use an established internal source. In accordance with AFARS 5139.101-90 (a) Commercial Information Technology hardware and software is to be procured first thru the Army’s Computer Hardware, Enterprise Software and Solutions (CHESS) program under the Program Executive Office Enterprise Information Systems. Given this effort falls under what is considered IT Services, the mandated requirement to procure thru CHESS is considered inapplicable per CHESS Ordering Guidelines.

As such “Preferred Use of Existing GSA Contract Vehicles” was then considered. Two separate RFIs (RFI1066783 and RFI1064820) were issued against GSA MAS Schedules. GSA received one response which was provided by Comcast Business Communications, LLC advising that the items required were not available via GSA Schedule. Additional Government-Wide Acquisition Contracts (GWACS) such as OASIS, Alliant, and NASASEWP were reviewed; however Comcast Business Communications, LLC does not have a contract or any resellers with any of the researched GWACS. Thru this research it was determined that this requirement can only be satisfied by open market procedures utilizing FAR subpart 13.5-Simplified Procedures for Certain Commercial Items and the authority of FAR 13.501(a)(2)(i). A combined Synopsis/Solicitation will be issued thru FEDBIZOPS to Comcast Business Communications, LLC.

10. Listing of Sources:

Comcast Business Communications, LLC One Comcast Center, 1701 JFK Blvd.

Philadelphia, PA, 19103-0000

DUNS: 968185491

Cage Code: 6ER97

11. Statement of Actions to Overcome Barriers to Competition

In an effort to remove or overcome barriers to competition in the future, USSOUTHCOM has continued and will continue its due-diligence in researching the current market for new internet service providers that can satisfy the Government’s requirements. USSOUTHCOM has been informed that they must continuously conduct market surveys to keep current on technology and to identify new, open technologies that can satisfy future infrastructure requirements. However, given the current situation, Comcast Business Communications, LLC is the only source that can fulfill the current requirement without causing a catastrophic impact to the networks and therefore impacting mission.

12. Requiring Activity Certification:

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

Date

13. Contracting Officer Certification:

The undersigned has determined that the anticipated cost to the Government for this acquisition will be fair and reasonable. Further, I certify that this justification is accurate and complete to the best of my knowledge and belief.

Elizabeth Kennedy Date Senior Contracting Officer