J_A_FO Exception_OSC_PoP_EXT_PK edits_7.10.2026 co signed.pdf

Justification for an Exception to Fair Opportunity or to Use Brand-Name Restriction

[ RFO 16.507-6(b)(1) ]

May 2026 [ RFO 16.507-6(b)(1) ] Page 1 of 6May 2026 [ RFO 16.507-6(b)(1) ] Page 1 of 6

Is this a brand-name justification? Yes No

Is this a Bridge Action as defined in the AF Bridge Action Reduction Plan? Yes No

Contracting Activity: AFLCMC/HNCKJ

Purchase Request / Local ID Number: FA8307-23-F-B173

Program Name (and Program Element, if applicable): Command and Control the Information Environment (C2IE)

Estimated Cost/Price of the Order (including options): $1.982M

Type of D etermination: Individual Class Expires: [ click and select ]

Fair Opportunity Exception: RFO 16.507-6(b) (Check the applicable subparagraph below.)

(A) (B) (C) (D) (E) (F) (G) Check this box to display the RFO 6.103 exceptions.

Click here for instructions to complete the boxes below.

(1) Contracting Activity:

The Air Force Life Cycle Management Center, Cryptologic and Cyber Systems Division, Command & Control Information Environment Section, Joint Cyber Command Contracting Branch (AFLCMC/HNCKJ)

(2) Nature and/or description of the action being approved:

This action is a sole-source, six (6) month bilateral extension of services under Task Order FA8307-23-F- B173 with Open San Consulting, LLC (OSC Edge). This modification is required to prevent an immediate and critical gap in service for the Command and Control the Information Environment (C2IE) program.

The extension will provide essential continuity of operations while the Government finalizes the transition and award of the follow-on 8(a) sole-source contract (FA8307-26-R-B045) to an Alaska Native Corporation (ANC) entity, which has already been formally offered to and accepted by the Small Business Administration (SBA). This extension will be executed as a Firm-Fixed-Price (FFP) bilateral modification, utilizing negotiated fair and reasonable rates based on the current Year 3 pricing structure.

(3) Description of the supplies/services required to meet the agency's needs:

Under the terms of this Task Order, the contractor is required to deploy and maintain qualified CIL personnel at the eleven (11) Combatant Commands and the Joint Staff for the entire duration of the performance period, beginning on a mutually agreed-upon date. To maintain operational flexibility, the contractor may also be tasked to provide additional qualified CILs under separately funded initiatives governed by this Task Order.

Any auxiliary costs associated with specialized host-nation or site-specific requirements—such as mandated cost of living adjustments, localized travel, specialized housing, or requisite overseas insurance—will be mutually agreed upon by both parties. To ensure seamless integration, the contractor is responsible for providing CIL personnel who possess and maintain the appropriate security clearances necessary for access to their designated Government facilities. The Government PMO will deliver these specific clearance requirements to the contractor prior to executing any formal performance agreements under the Task Order.

The administration and physical security integration of CIL personnel require close coordination between the Government and the contractor. The Government PMO, working in tandem with the contractor, is responsible for executing all necessary administrative actions required to facilitate base and network access. This includes

May 2026 [ RFO 16.507-6(b)(1) ] Page 2 of 6May 2026 [ RFO 16.507-6(b)(1) ] Page 2 of 6 processing Common Access Cards (CACs), generating Synchronized Pre-deployment and Operational Tracker (SPOT) orders, and navigating complex overseas contractor approval workflows, such as the European Contractor Online Processing System (ECOPS). Locally, the designated Government site sponsor, in coordination with the PMO and the contractor, will ensure CILs are granted the physical site access, workstations, and local network permissions required to execute their duties in support of the host Command.

Once deployed, CILs assume full responsibility for integrating C2IE capabilities into the day-to-day battle rhythm of their assigned Commands. This operational integration includes actively supporting Battle Rhythm events, maintaining comprehensive program documentation, and facilitating direct technical engagements with the Government PMO.

Furthermore, CILs are responsible for developing and delivering both on-site and virtual training programs tailored to local requirements, with any training activities requiring off-site travel coordinated through the PMO. Acting as the primary "first responders" for their respective Commands, CILs provide immediate troubleshooting and technical support for user access or system functionality issues in strict accordance with the contract's Service Level Agreement (SLA).

Finally, CILs actively support command-level implementation of C2IE for joint mission planning, execution, and campaign plan objective assessments, while continuously monitoring the system's performance within the Command’s enterprise architecture and documenting any technical deficiencies or anomalies for resolution.

(4) Identification of the exception to fair opportunity and the supporting rationale, including a demonstration that the proposed contractor's unique qualifications or the nature of the acquisition requires use of the exception cited. If the contracting officer uses the logical follow-on exception, the rationale must describe why the relationship between the initial order and the follow-on is logical (e.g., in terms of scope, period of performance, or value):

The C2IE program supports the Joint Staff and eleven (11) Combatant Commands, serving over 18,000 military and civilian personnel worldwide. The current Task Order expires on 28 September 2026. A six-month bridge extension is urgently required because a follow-on contract cannot be executed prior to expiration due to unavoidable, compounding administrative delays:

1. Pending Programmatic Approvals: The program's Acquisition Plan is currently undergoing senior executive review and has not yet been finalized. Additionally, because this is a non-commercial service, the program is undergoing mandatory reviews to obtain the required Request for Approval (RFA) under Executive Order 14271. These legal prerequisites cannot be bypassed.

2. International Treaty & Germany Personnel Status (ECOPS/DOCPER): A significant portion of the critical work is performed OCONUS in Germany. Under the NATO Status of Forces Agreement (SOFA), contractor personnel must maintain active accreditation via the European Contractor Online Processing System (ECOPS). If the current contract expires or lapses, these personnel will instantly lose their SOFA status, logistical support, and access to military installations.

A new competitive solicitation for a 6-month period is physically and administratively impossible. A new competition would take a minimum of 90 -120 days, guaranteeing a catastrophic 3-to-4 month gap in critical global military operations. Only the incumbent, OSC Edge, is positioned to provide uninterrupted service without requiring a lengthy, legally complex ECOPS onboarding and transition period.

May 2026 [ RFO 16.507-6(b)(1) ] Page 3 of 6May 2026 [ RFO 16.507-6(b)(1) ] Page 3 of 6

(5) Contracting Officer's determination that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer is responsible for evaluating, determining, and documenting the anticipated contract cost/ price is fair and reasonable in accordance with RFO Subpart 15.4, Contract Pricing.

(6) Other facts supporting the justification:

The continuity of services provided by the incumbent, OSC Edge, is uniquely critical due to the highly specialized technical environment and the challenging OCONUS labor market.

Historically, this program has faced severe recruitment and retention hurdles due to the niche cyber and intelligence skillsets required, coupled with the complex international DOCPER vetting process.

Furthermore, previous administrative delays in Government funding and invoicing --which have since been fully resolved --created temporary operational challenges for subcontractors.

Despite these severe, market-driven and Government-caused hurdles, OSC Edge demonstrated exceptional organizational resilience. The contractor successfully stabilized the workforce, successfully recruited and retained the necessary highly cleared technical personnel, and currently maintains a fully staffed and operationally ready team in Germany and CONUS.

Introducing a new contractor for a short-term, 6-month period would re-introduce catastrophic recruiting, onboarding, and ECOPS processing risks. OSC Edge is the only source that can guarantee zero disruption to warfighter capabilities during this transition period. The long-term acquisition strategy is actively being executed via a sole-source 8(a) transition to an active ANC subsidiary (OSC EdgeTech, LLC, SBA Case No.

307331), which has already been accepted by the SBA.

(7) Actions the agency may take to remove or overcome any barriers to increasing fair opportunity before any subsequent acquisition for the supplies or services:

n/a

(8) Program Manager's certification that supporting data is accurate and complete:

As evidenced by my signature below, I certify that any supporting data contained herein, which is my responsibility, is both accurate and complete.

(9) Contracting Officer's certification that the justification is accurate and complete:

As evidenced by my signature below, I certify that the justification is accurate and complete to the best of my knowledge and belief.

(10) Approving Official's determination that one of the circumstances in RFO 16.507-6(b) applies to the order.

As evidenced by my signature below, I hereby determine that the fair opportunity exception checked on page 1 applies.

May 2026 [ RFO 16.507-6(b)(1) ] Page 4 of 6May 2026 [ RFO 16.507-6(b)(1) ] Page 4 of 6

REMOVING ROWS: CAUTION (click here first) NOTE: The text in the signature blocks below is editable, including the title.

Date Program Manager Sean T. McCanna, Maj, USAF

AFLCMC/HNCD / 210-395-1280

Signature

X

Date

10 Jul 2026

Contracting Officer LeMarc K. Holcombe

AFLCMC/HNKJ / 210-925-0994

Signature

X

May 2026 [ RFO 16.507-6(b)(1) ] Page 5 of 6May 2026 [ RFO 16.507-6(b)(1) ] Page 5 of 6

Instructions for Completing the Template

(2) State whether the action is a new order or a modification to an existing order. Identify the basic multiple award contract number and the order number for the current action. Also identify the type of the order/line items on the order (e.g., Firm Fixed price, Cost Plus Fixed Fee, etc.).

(3) Specifically describe the supplies/services to be acquired including the price/cost and quantity of each item in the order and the total estimated value of the order. For services, state whether services are performance-based, and if not, provide rationale for not being performance based. State the delivery/performance schedule/period for the items under the order. Explain how the requirement/order fits under the scope of the basic multiple award contracts.

(Note: The Contracting Officer must ensure that the order is issued within the period of performance and within the maximum value of the contract).

(4) Include the appropriate exception from RFO 16.507-6(b) and the supporting rationale. RFO 16.507-2(a) requires the Contracting Officer to provide each awardee under a multiple award contract, a fair opportunity to be considered for each order exceeding the micro-purchase threshold unless a statutory exception applies. If a brand name product description is being justified, use this section to explain why the particular brand name, product, or feature is essential to the Government's requirements and why other companies' similar products/services do not meet, or cannot be modified to meet, the agency's needs.

RFO 16.507-6(b)(1): “The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays”. When using this exception provide a detailed justification with supporting documentation that explains the exact urgency of the requirement and the mission impact if awarded to any other contractor. The user/customer typically provides this supporting information. Recommend attaching supporting documentation to the back of the document. General statements of urgency are not acceptable.

RFO 16.507-6(b)(2): “Only one awardee is capable of providing the supplies or services required at the level at the level of quality required because the supplies or services ordered are unique or highly specialized”. When using this exception provide a detailed justification, with supporting documentation, as evidence of the “unique or highly specialized” nature of the procurement. The user/customer typically provides this supporting information.

Supporting documentation may be attached to the back of the document. General statements are not acceptable.

RFO 16.507-6(b)(3): “The order must be issued on a sole-source basis in the interest of economy and efficiency as a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order”. When using this exception provide information on the previously competed order under this contract and detail the economies and efficiencies that will be obtained by going sole source for the follow-on order. The user/customer typically provides this supporting information.

General statements are not acceptable.

RFO 16.507-6(b)(4): “It is necessary to place an order to satisfy a minimum guarantee.”

RFO 16.507-6(b)(5): “For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.”

RFO 16.507-6(b)(6): “For DoD, the order satisfies one of the exceptions permitting the use of other than full and open competition listed in part 6.103 (10 U.S.C. 3406(c)(5)). The public interest exception must not be used unless Congress is notified in accordance with 10 U.S.C. 3204(a)(7).”

Discuss the market research that was conducted by the user/technical team/contracting officer among the supplies/services of all awardees that resulted in the conclusion that a fair opportunity exception applied. The narrative in this section should provide a high level of confidence that the requirements of fair opportunity could

May 2026 [ RFO 16.507-6(b)(1) ] Page 6 of 6 not be met. If no market research was conducted, state so and provide the rationale. If any other awardee expressed interest in fulfilling the requirement, but was not considered a potential source, explain why that awardee cannot provide the required supplies/perform the service.

If the use of a brand name purchase description is being justified, the market research should include an analysis of any industry proposed alternative products or approaches to meeting the requirements. Additionally, the Government's efforts to identify as many potential sources as practicable offering the required brand name item(s) should be addressed.

(5) Provide any other facts supporting the use of exceptions to the fair opportunity process.

(6) Include a statement of the actions, if any, to be to be taken to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made. If no actions are planned, so state and provide reasons.

New RFO 6.103 Exceptions for drop down 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements 6.103-2 Unusual and compelling urgency 6.103-3 Industrial mobilization; engineering, developmental, or research capability; or expert services 6.103-5 Authorized or required by statute 6.103-6 National security 6.103-7 Public interest https://usaf.dps.mil/sites/AFCC/KnowledgeCenter/templates_admin/aqc-front.jpg https://usaf.dps.mil/sites/AFCC/KnowledgeCenter/templates_admin/aqc-back.jpg Justification for an Exception to Fair Opportunity or to Use Brand-Name Restriction May 2026 Page of Is this a brand-name justification?

Please provide the product title and description. [ FAR16.505(a)(4)(i) ] Is this a Bridge Action as defined in the AF Bridge Action Reduction Plan?

Type of D etermination:

Fair Opportunity Exception: RFO 16.507-6(b) (Check the applicable subparagraph below.)

(1) Contracting Activity:

(2) Nature and/or description of the action being approved:

(3) Description of the supplies/services required to meet the agency's needs:

(4) Justification for restricting consideration to a brand-name item:

(4) Identification of the exception to fair opportunity and the supporting rationale, including a demonstration that the proposed contractor's unique qualifications or the nature of the acquisition requires use of the exception cited. If the contracting officer uses the logical follow-on exception, the rationale must describe why the relationship between the initial order and the follow-on is logical (e.g., in terms of scope, period of performance, or value):

(5) Contracting Officer's determination that the anticipated cost to the Government will be fair and reasonable:

(6) Other facts supporting the justification:

(7) Actions the agency may take to remove or overcome any barriers to decreasing the use of brand-name items before any subsequent acquisition of the supplies or services:

(7) Actions the agency may take to remove or overcome any barriers to increasing fair opportunity before any subsequent acquisition for the supplies or services:

(8) Program Manager's certification that supporting data is accurate and complete:

As evidenced by my signature below, I certify that any supporting data contained herein, which is my responsibility, is both accurate and complete.

(9) Contracting Officer's certification that the justification is accurate and complete:

As evidenced by my signature below, I certify that the justification is accurate and complete to the best of my knowledge and belief.

(10) Approving Official's determination that FAR16.505(a)(4)(i) applies to the order:

As evidenced by my signature below, I hereby determine that the use of brand-name restriction applies.

(10) Approving Official's determination that one of the circumstances in RFO 16.507-6(b) applies to the order.

As evidenced by my signature below, I hereby determine that the fair opportunity exception checked on page 1 applies.

NOTE: The text in the signature blocks below is editable, including the title.

Instructions for Completing the Template

(2) State whether the action is a new order or a modification to an existing order. Identify the basic multiple award contract number and the order number for the current action. Also identify the type of the order/line items on the order (e.g., Firm Fixed price, Cost Plus Fixed Fee, etc.).

(3) Specifically describe the supplies/services to be acquired including the price/cost and quantity of each item in the order and the total estimated value of the order. For services, state whether services are performance-based, and if not, provide rationale for not being performance based. State the delivery/performance schedule/period for the items under the order. Explain how the requirement/order fits under the scope of the basic multiple award contracts. (Note: The Contracting Officer must ensure that the order is issued within the period of performance and within the maximum value of the contract).

(4) Include the appropriate exception from RFO 16.507-6(b) and the supporting rationale. RFO 16.507-2(a) requires the Contracting Officer to provide each awardee under a multiple award contract, a fair opportunity to be considered for each order exceeding the micro-purchase threshold unless a statutory exception applies. If a brand name product description is being justified, use this section to explain why the particular brand name, product, or feature is essential to the Government's requirements and why other companies' similar products/services do not meet, or cannot be modified to meet, the agency's needs.

RFO 16.507-6(b)(1): “The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays”. When using this exception provide a detailed justification with supporting documentation that explains the exact urgency of the requirement and the mission impact if awarded to any other contractor. The user/customer typically provides this supporting information. Recommend attaching supporting documentation to the back of the document. General statements of urgency are not acceptable.

RFO 16.507-6(b)(2): “Only one awardee is capable of providing the supplies or services required at the level at the level of quality required because the supplies or services ordered are unique or highly specialized”. When using this exception provide a detailed justification, with supporting documentation, as evidence of the “unique or highly specialized” nature of the procurement. The user/customer typically provides this supporting information. Supporting documentation may be attached to the back of the document. General statements are not acceptable.

RFO 16.507-6(b)(3): “The order must be issued on a sole-source basis in the interest of economy and efficiency as a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order”. When using this exception provide information on the previously competed order under this contract and detail the economies and efficiencies that will be obtained by going sole source for the follow-on order. The user/customer typically provides this supporting information. General statements are not acceptable.

RFO 16.507-6(b)(4): “It is necessary to place an order to satisfy a minimum guarantee.”

RFO 16.507-6(b)(5): “For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.”

RFO 16.507-6(b)(6): “For DoD, the order satisfies one of the exceptions permitting the use of other than full and open competition listed in part 6.103 (10 U.S.C. 3406(c)(5)). The public interest exception must not be used unless Congress is notified in accordance with 10 U.S.C. 3204(a)(7).”

Discuss the market research that was conducted by the user/technical team/contracting officer among the supplies/services of all awardees that resulted in the conclusion that a fair opportunity exception applied. The narrative in this section should provide a high level of confidence that the requirements of fair opportunity could not be met. If no market research was conducted, state so and provide the rationale. If any other awardee expressed interest in fulfilling the requirement, but was not considered a potential source, explain why that awardee cannot provide the required supplies/perform the service.

If the use of a brand name purchase description is being justified, the market research should include an analysis of any industry proposed alternative products or approaches to meeting the requirements. Additionally, the Government's efforts to identify as many potential sources as practicable offering the required brand name item(s) should be addressed.

(5) Provide any other facts supporting the use of exceptions to the fair opportunity process.

(6) Include a statement of the actions, if any, to be to be taken to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made. If no actions are planned, so state and provide reasons.

New RFO 6.103 Exceptions for drop down 6.103-1 Only one responsible source and no other supplies or services will satisfy agency requirements 6.103-2 Unusual and compelling urgency 6.103-3 Industrial mobilization; engineering, developmental, or research capability; or expert services 6.103-5 Authorized or required by statute 6.103-6 National security 6.103-7 Public interest 9.0.0.2.20120627.2.874785