JA AMD01 - 852573041_Redacted.pdf

CUI

Controlled by: ARMY

Controlled By: CEIT-PMO

CUI Category: SSEL

Distribution/Dissemination Control: FEDCON

POC: REGINALD KING, +1 2288066157, REGINALD.L.KING@USACE.ARMY.MIL

JUSTIFICATION & APPROVAL FOR FEDERAL ACQUISITION REGULATION

SUBPART 16.5 ACQUISITIONS

EXCEPTION TO FAIR OPPORTUNITY

Multiple Award Contract

Orders under Fair Opportunity

Federal Acquisition Regulation (FAR) 16.505(b), Defense FAR Supplement 216.505(b), Procedures, Guidance, and Information 216.505(b)

Purchase Request Number:

Joint Warfighting Cloud Capability (JWCC) Contract Number: HC105023D0004

Task Order (TO) Number: To be determined

Procurement Title: Hybrid Cloud Landing Zone 02

Estimated Value: + (AMD 01) =

Statutory and Regulatory Authority: 10 United States Code (U.S.C.) 3204(a) and FAR

16.505(b)(2)(i)(B)

EXCEPTION TO FAIR OPPORTUNITY

Number: JA25-129 AMD01

Upon the basis of the following justification, I, as the Procuring Activity Competition Advocate

(PACA), hereby approve this exception to fair opportunity pursuant to the Statutory Authority of

10 U.S.C. 3204(a) and Regulatory Authority of FAR 16.505(b)(2)(i)(B).

1. REQUESTING AGENCY AND CONTRACTING OFFICE:

Requesting Agency:

United States U.S. Army (ARMY) / U.S. Army Corps of Engineers (USACE)

4155 Clay St

Vicksburg, MS 39183

Contracting Activity:

Defense Information Systems Agency (DISA)/Defense Information Technology

Contracting Organization (DITCO)/ Cloud Capabilities Section (PS8511)

2300 East Drive

Scott Air Force Base, IL 62225-5406

2. NATURE/DESCRIPTION OF ACTION(S):

AMD 01: This amendment is to increase the value by for a total of .

The purpose of this increased amount of is due to estimated growth which is required to accommodate expansion throughout the life of the order. The Government required estimated growth in the Description of Work, Task 4.2.2, in the amounts of 25% during the Base Period, 50% during Option Period 1, and 75% during Option Period 2.

Hybrid Cloud Landing Zone 02

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However, the Independent Government Cost Estimate did not include the requested growth and therefore underestimated the estimated value.

This action is to issue a firm-fixed-price TO against the JWCC Indefinite Delivery/Indefinite

Quantity Contract for Hybrid Cloud Landing Zone 02. This TO will be issued directly to Oracle

America, Inc. (Oracle). The anticipated period of performance is for a 1-year base period, plus two 1-year option periods. The total estimated value is which will be funded by

Working Capital funds.

3. DESCRIPTION OF SUPPLIES/SERVICES:

USACE has a requirement to establish a Landing Zone for Oracle Cloud Infrastructure (OCI) which will allow the onboarding of other already established USACE workload accounts. To begin this process, a Fast Connect from the USACE Boundary Cloud Access Point (BCAP) to the OCI will be established. This will allow USACE to expand the environment to establish a

Transit Network (Hub-Spoke Model). In addition, USACE needs to maintain a tenancy to be able to view billing and establish child tenants in the future and ensure all security guardrails are being implemented by USACE.

4. SUPPORTING RATIONALE, INCLUDING A DEMONSTRATION THAT THE

PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR THE NATURE OF THE

ACQUISITION REQUIRES USE OF AN EXCEPTION TO FAIR OPPORTUNITY:

(a) Exception to Fair Opportunity.

FAR 16.505(b)(2)(i)(B) - Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

(b) Description of the Justification.

USACE is required to operate the Corps of Engineers Financial Management System

(CEFMS) to manage its complex financial operations, comply with federal mandates like the Federal Financial Management Improvement Act, and provide real-time financial data for mission accomplishment. CEFMS integrates all USACE business processes, ensures that financial transactions are processed and summarized in accordance with the U.S.

Government Standard General Ledger, and enables USACE to achieve an unqualified opinion on its financial statements. CEFMS has over 72 areas of functionality and consists of approximately 62 Field Operating Activity production databases and supporting development/testing environments.

CEFMS software operates on Oracle software. This proprietary software can only be used with Oracle due to the IP constraints and includes Oracle Database, Oracle WebLogic

Server, Oracle Forms and Reports, Oracle Business Intelligence (BI) Tools, and Oracle

Identity Management. Oracle software will only operate in an OCI environment.

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This effort supports USACE’s requirement to establish a Hybrid Cloud Landing Zone based on the OCI product for CEFMS. To meet widely established and accepted

Information Technology (IT) governance cyber security requirements, these accounts are mandated to securely connect to the USACE BCAP. This connection is to be accomplished via a direct, private connection to a hybrid cloud environment through an

OCI Fast Connect path. This will ensure USACE can monitor and control OCI traffic coming into the USACE network. The OCI Fast Connect from Oracle is the only service that enables a dedicated, private network connection directly into OCI Optical Carrier 3.

This direct connectivity is critical for ensuring low-latency, high-bandwidth, and secure data transfer between the on-premises infrastructure and OCI, supporting mission-critical applications and sensitive data subject to regulatory controls. The OCI Fast Connect from

Oracle is essential to the Government’s requirement and is the only JWCC offering that can meet the Government’s requirement.

OCI Fast Connect bypasses the public internet, significantly reducing exposure to common cyber threats and ensuring compliance and security mandates that require private, non-internet-facing connectivity. OCI Landing Zones provide a secure, automated, scalable multi-tenant OCI environment, forming the foundation for USACE’s hybrid cloud. The Landing Zone framework, automates Compartment/Tenant provisioning, establishes baseline security controls, and enforces governance policies across all OCI Compartments/Tenants. This enables rapid deployment of workloads while maintaining strong resource isolation, centralized security monitoring, and compliance with internal and external requirements. OCI Landing Zone integrations with

OCI Fast Connect ensure that all Compartments/Tenants and workloads benefit from consistent security, networking, and compliance configurations. The OCI Landing Zones from Oracle is essential to the Government’s requirement and is the only JWCC offering that can meet the Government’s requirement.

As discovered through market research, due to IP copyright constraints no other CSP can provide a native direct connection into OCI environment required by CEFMS.

(c) Justification.

(1) Minimum Government requirements.

USACE requires a fast and secure connection to a cloud environment via the USACE

BCAP. The solution must support direct connectivity that allows a low-latency, high-bandwidth, and secure data transfer between our on-premises infrastructure and the CSP solution, supporting mission-critical applications and sensitive data subject to regulatory controls. The CSP offering must be compatible with the USACE’s existing architecture.

As CEFMS is designed to operate on Oracle software, USACE requires a CSP to provide a cloud environment that can securely host the CEFMS application ensuring compatibility with the current software that comprises the CEFMS application.

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(2) Proposed sole source contractor. Oracle

(3) Discussion regarding the cause of the sole source situation.

The only CSP capable of providing an OCI Landing Zone and OCI Fast Connect compatible with the current USACE CEFMS at the required level of quality is Oracle.

Any re-architecting, re-engineering, and refactoring of any of the critical cloud offerings from Oracle to any other CSP would not meet the Government’s need for compatibility.

In addition, there would be a duplication of costs by having to keep the solution running on one platform while refactoring it on another platform, none of which would meet the

Government’s current need.

(4) Demonstration of unique source.

USACE OCI compliance obligations, including data residency, auditability, and private network requirements, can only be met with OCI Fast Connect and OCI Landing Zone.

These services uniquely enable USACE to maintain regulatory compliance while ensuring mission continuity and operational efficiency in an OCI environment. Only Oracle can provide the OCI Landing Zone integrations with OCI Fast Connect needed to support applications such as CEFMS. Market Research revealed that Oracle does not freely give or license their technology to other CSPs and other CSPs do not offer an equivalent connection which is required for Oracle applications. The only CSP capable of performing the Hybrid Cloud Landing Zone at the required level of quality is Oracle.

(5) Procurement discussion.

Based on outreach to the four JWCC CSPs in May 2025, the only CSP that is currently capable of meeting the minimum needs of the Government for an OCI Landing Zone and

Fast Connect is Oracle. No other CSP offering can meet the compatibility constraints of the OCI Landing Zone due to IP copyrights. Using another CSP to meet this requirement would require substantial re-architecture of USACE’s workloads and governance model, resulting in unacceptable risk, increased costs, and operational disruption to the USACE mission. Oracle is capable of meeting the full scope of technical, security, and operational requirements.

(6) Impact.

Transition to another CSP from Oracle is not feasible based on the inability of any other

CSP to seamlessly integrate within the existing architecture. The impact of not utilizing an OCI Landing Zone would result in USACE inability to operate the CEFMS financial system which would result in a worldwide failure of USACE civil works missions.

Additionally, USACE would be unable to complete a successful and timely transition to

JWCC from the Joint Regional Security Stack (JRSS) capabilities. USACE is transitioning from JRSS due to the Department of Defense sunsetting the JRSS capabilities which must be completed by 2027. USACE will not be able to close legacy

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Data Centers until the hybrid cloud is implemented. This will result in mission failure of the current USACE Oracle applications as other CSPs do not have the ability to operate according to the requirement for the Oracle enclave. OCI Landing Zone integrations with

OCI Fast Connect ensure that all Compartments/Tenants and workloads benefit from consistent security, networking, and compliance configurations. These services uniquely enable USACE to maintain regulatory compliance while ensuring mission continuity and operational efficiency.

5. COST/PRICE FAIR AND REASONABLE DETERMINATION:

A determination that the price is fair and reasonable will be based on a comparison of the contractor’s proposal to the Independent Government Cost Estimate and the JWCC Catalog pricing, including any discounts, which was previously found to be fair and reasonable and based on the contractor’s commercial pricing.

6. MARKET RESEARCH:

Market research for the basic JWCC Contracts was conducted and resulted in a signed market research report on November 9, 2021, that was revalidated and recertified on July 29, 2024.

After a survey of the market, it was concluded that the JWCC Contract is in the Government’s best interest due to technical feasibility and cost to the Government.

Additional research was conducted from February 2, 2025, through May 25, 2025. The USACE-

IT Cloud Engineering Team conducting market research consisted of cloud engineers, cyber engineers, and the project manager. The USACE-IT Cloud Engineering Team reviewed CSP provided technical white papers and participated in meetings with CSPs to disseminate technical details. USACE did not receive a response from Google; however, responses were received from AWS, Microsoft, and Oracle. All three CSPs indicated in their responses they only deliver connectivity to their own cloud platforms. USACE determined though market research discussions that this was due to IP copyright constraints. Thus, only Oracle is capable of meeting the Government’s requirement for Oracle proprietary software, such as CEFMS, to connect to

OCI. Market research determined that while other CSPs offer direct connection and environment automation services, none provide native, private connection to the proprietary OCI or a landing zone solution with the same maturity, security and automation that integrates with OCI.

Therefore, using alternative CSPs is not an option as it would require substantial re-architecture of the USACE cloud governance model, resulting in unacceptable risk, unnecessary duplicative costs, and operational disruption culminating in mission failure.

7. ANY OTHER SUPPORTING FACTS: None.

8. ACTIONS THE AGENCY MAY TAKE TO REMOVE OR OVERCOME BARRIERS

THAT LED TO THE EXCEPTION TO FAIR OPPORTUNITY:

(a) Procurement History: USACE’s CEFMS was developed in the early 1990s using Oracle software and migrated in 2023 to a cloud platform with the implementation of the Cloud

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Account Management Optimization (CAMO) contract. CAMO was initiated as an Other

Transaction Authority to experiment with industry partners to bring multi-cloud products and services with best possible pricing to the Army.

(b) To remove or overcome future barriers to competition, USACE is planning to explore multiple CSP offerings that allow for a diverse cloud platform. USACE is building a diverse cloud environment that encompasses three different CSPs. The anticipated USACE cloud strategy will allow applications to be deployed to three different cloud technologies to best make use of the strength of each CSP for a given need. Since the IP Copyright constraint is a prevalent issue, the USACE will continue to search for industry partners that have secured rights to the IP from Oracle to be able to provide connection alternatives to its proprietary cloud solution. Additionally, the USACE Cloud Program team will conduct Market Research expansion, requirement standardization, acquisition planning improvements, technical data ownership, modular design and lessons learned reviews to determine if there are changes in the marketplace that would enable future competitive actions.