J and A Redacted Broadband.pdf

CUI

Department of the Air Force: Justification for Other Than Full and Open Competition

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I. Agency and Contracting Activity (RFO 6.104-1(a)(1)):

Agency: Department of the Air Force Contracting Activity: AFTC/PZIOCD, Eglin AFB, FL

II. Nature and/or description of the action being approved (RFO 6.104-1(a)(2)):

The Department of the Air Force intends to award a firm-fixed-price (FFP), sole-source contract to Cox Communications (or its authorized local affiliate) for the acquisition, delivery, installation, and management of a comprehensive Managed WiFi system at Eglin Air Force Base, Florida. This action will be executed without providing for full and open competition, as justified by the statutory authority cited below.

Charter Communications has completed its acquisition of Cox Communications, creating the nation's largest broadband and cable provider. Under the terms of the transaction, former Cox service territories are transitioning to the Spectrum brand for all consumer- and business-facing operations. Over the next year, the parent entity will formally adopt Cox Communications as its overarching corporate name.

Cox Florida Telcom, L.P. operates as a direct telecommunications subsidiary of Cox Communications, Inc., which serves as the ultimate parent company. In this corporate structure, Cox Communications maintains full ownership and strategic oversight, while Cox Florida Telcom, L.P. functions as the primary competitive local exchange carrier and authorized operating entity responsible for delivering broadband, voice, and commercial telecommunications services throughout the state of Florida.

III. Description of supplies/services required to meet agency needs (RFO 6.104-1(a)(3)):

- In accordance with Section 651 of the National Defense Authorization Act (NDAA) for Fiscal Year 2025, (amending Title 10 U.S.

Code § 2265), the Air Force is mandated to rapidly provide compliant high-speed broadband internet access to unaccompanied service members living in dormitories.

- The 96 CEG has a requirement to establish a fully managed, turn-key Wi-Fi system across 10 Unaccompanied Housing (UH) dormitory buildings at Eglin AFB (Buildings 820, 822, 831, 833, 835, 854, 855, 875, 877, and 879).

- The contractor shall deliver a managed network supporting 766 individual dormitory rooms and 10 common areas (including dayrooms, administrative offices, laundry facilities, and specific outdoor locations). The required system must:

- Provide broadband internet access meeting or exceeding the Federal Communications Commission (FCC) benchmark under Section 706 of the Telecommunications Act (currently established at 100 Mbps download and 20 Mbps upload speeds per FCC- 24-27A1).

- Include all necessary materials, equipment, and labor, including coaxial cabling and Category 5e (or greater) network cabling.

- Establish a user login/landing page displaying Terms and Conditions prior to granting system access.

- Include a minimum 2-year standard commercial warranty against product defects or poor workmanship.

IV. Statutory Authority Permitting Other Than Full and Open Competition (RFO 6.104-1(a)(4)):

10 U.S.C. 3204(a)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.

V. Rationale for Use of Authority (RFO 6.104-1(a)(5)):

Cox Communications is the only responsible source capable of providing the required Managed WiFi services within the mandated timeline without the Government experiencing unacceptable mission delays and substantial duplication of cost.

Under Section 651 of the National Defense Authorization Act (NDAA) for Fiscal Year 2025 (amending Title 10 U.S. Code § 2265), the Air Force is mandated to rapidly provide compliant high-speed broadband internet access to unaccompanied

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Existing Infrastructure:Due to the infrastructure already being established by Cox on Eglin AFB, it is uniquely postured to provide immediate, turnkey managed WiFi services. Cox possesses an established, currently active physical infrastructure in each of the ten (10) targeted dormitory buildings (820, 822, 831, 833, 835, 854, 855, 875, 877, and 879) and maintains exclusive operational control over this proprietary cable plant. Because Cox's distribution system and cabling are already fully built-out inside these facilities, no external digging, trenching, or penetration of interior or exterior walls will be required to execute this contract.

Substantial Duplication of Cost:Awarding to any other telecommunications provider would require a complete rebuild of the physical transport medium. This would incur substantial, unrecoverable costs for extensive exterior trenching, building entry penetrations, internal coaxial/fiber distribution installation, and localized headend construction across ten (10) separate facilities.

Unacceptable Delays:Under 10 U.S.C. § 2265, the 96th Test Wing (96 TW) is mandated to rapidly address broadband access deficits in Unaccompanied Housing (UH). Any attempt to award to an alternative provider would require extensive site surveys, civil engineering permits for trenching, and prolonged construction schedules. This footprint expansion would make it physically and administratively impossible to meet the required 60-duty-day installation window starting on or around 30 September 2026, resulting in an unacceptable delay in providing mandated quality-of-life services to armed forces members.

VI. Integrated Market Analysis and Efforts to Solicit Competition (RFO 6.104-1(a)(6), (8), and (10)):

A Notice of Intent to Sole Source will be published on SAM.gov for a minimum of 30 days in accordance with RFO 5.303. Any responses received will be evaluated by the Contracting Officer and the 96 CEG technical team prior to award. However, because alternative providers lack existing physical utility easements and direct cable infrastructure to these specific facilities, they cannot realistically meet the performance parameters within the requisite timeframe.

VII. Determination of Fair and Reasonable Cost (RFO 6.104-1(a)(7)):

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. The total estimated dollar amount for this requirement is This estimated value is considered fair and reasonable across the 5-year period of performance, covering both the initial system setup and subsequent operational managed service years.

VIII. Any Other Facts Supporting the Justification (RFO 6.104-1(a)(9)):

Market research was conducted by the 96th Civil Engineering Group and contracting personnel. While other telecommunications carriers operate in the broader regional area of Okaloosa County, Florida, none possess the physical distribution network, right-of-way permissions, or terminating equipment within the specified dormitory buildings on Eglin

AFB.

A comprehensive physical Site Visit was conducted across all 10 target dormitory buildings with commercial industry providers.

During this Site Visit, multiple participating telecommunications companies explicitly stated that delivering the required managed Wi-Fi services would require them to perform extensive exterior trenching to run physical cabling from off-base locations onto Eglin AFB, followed by invasive drilling to penetrate the exterior and interior walls of the dormitories. This joint physical assessment confirmed that any source other than Cox Communications would necessitate destructive civil works and invasive structural modifications.

Cox Communications currently maintains an active, base-wide license that permits immediate submission of work order requests and commencement of excavation for fiber installation. Awarding this contract to an alternative provider would necessitate the acquisition of a formal easement. This administrative coordination process traditionally requires several months to secure, during which all physical trenching and fiber deployment operations would be entirely stalled.

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IX. Actions to Overcome Barriers to Competition (RFO 6.104-1(a)(11):

The 96 CEG and the 96 TW Contracting Activity will continue to track telecom development in the Okaloosa County/Eglin AFB region. For future telecommunications and IT infrastructure updates, the government will engage in early planning to identify opportunities for open-access ducting and shared-conduit agreements, which would allow multi-carrier competition inside federal facilities.