JA - Final_Redacted.pdf

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United States Marine Corps Marine 26 TS Cloud Region
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852572373
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This document is a Justification & Approval (J&A) for a Federal Acquisition Regulation (FAR) Exception to Fair Opportunity for a sole-source contract with Microsoft Corporation. The U.S. Marine Corps (USMC) M26 Information Intelligence, Surveillance, and Reconnaissance Enterprise is procuring a Top Secret (TS) Cloud Region solution through the Joint Warfighting Cloud Capability (JWCC) contract, specifically seeking Microsoft's EntraID P2, Microsoft 365, and Azure Virtual Desktop services.

The contract aims to provide a secure, seamless cloud environment supporting advanced computing, analytics, and enterprise service operations for the USMC Sensitive Compartmented Information environment. After market research involving four Cloud Service Providers (CSPs), USMC determined Microsoft is the only vendor capable of meeting their specific requirements, including compatibility with existing infrastructure, Zero Trust standards, and the ability to scale from 100 to 6000 users. The proposed contract has a base period plus one 12-month option period, with the total estimated value to be funded by Research, Development, Test & Evaluation funds. The contract is expected to be awarded by August 1, 2025, with USMC planning a competitive follow-on requirement by October 1, 2026.

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USMC (M26) TS Cloud Region

Page 3 of 7 Pages hybrid cloud implementation and leverage existing application investments to maximize efficiency and cost savings.

Microsoft is uniquely positioned as the only Cloud Service Provider (CSP) capable of delivering this comprehensive solution. Their integrated suite – encompassing Entra ID P2, M365, and AVD directly addresses these needs. This aligns with existing USMC efforts at lower Impact Levels (MCEN/MCENS), enabling us to utilize their established DevSecOps environment and integrate our IL-7 TS Region, leveraging a CDS in the future. This represents a natural progression toward expanding similar services to the TS Region.

The Microsoft offering provides a complete, end-to-end service including work production capabilities, virtual desktop infrastructure, and robust, integrated security. A key component is a compliant, consumption-based cross-domain solution facilitating secure data flow between IL5, IL6, and Top Secret levels. The proposed infrastructure will align with existing systems across classification domains, supporting Department of Defense (DoD) and Intelligence Community (IC) Zero Trust and Digital Rights Management (DRM) standards within the USMC. Furthermore, Microsoft’s scalability readily accommodates growth from 100 to 6000 users without significant modifications, and a contract structure with both base and optional periods will support evolving consumption needs.

(2) Proposed sole source contractor.

Microsoft Corporation

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

The only CSP capable of performing the services for the USMC M26’s pilot program with JWCC at the required level of quality is Microsoft. Microsoft is the only CSP that can provide the services requested (EntraID P2, M365 and AVD), to align with USMC efforts already completed at lower Impact Levels (MCEN / MCENS). This will allow the USMC to utilize their already in place DevSecOps environment and attach their IL-7 TS Region, leveraging a CDS in the future and is in line with a natural progression to provide similar services to the TS Region. The following services are required to meet the characteristics of the pilot with expansion to support 6000 users and additional option years within the scope of the JWCC contract that supports Consumption and Services.

Failure to keep Impact Levels aligned will cause issues with leveraging tools at lower networks supporting DevSecOps CI / CD Pipeline and proposed Automated Transfer Services (ATS) planned within all ILs.

The Microsoft offering provides a complete, end-to-end service including work production capabilities, virtual desktop infrastructure, and robust, integrated security. The proposed infrastructure will align with existing systems across classification domains, supporting DoD and IC Zero Trust and Digital Rights Management (DRM) standards within the USMC. Furthermore, Microsoft’s scalability readily accommodates growth

Page 4 of 7 Pages from 100 to 6000 users without significant modifications, and a contract structure with both base and optional periods will support evolving consumption needs.

(4) Demonstration of unique source.

Microsoft possesses the knowledge, skills, capabilities, certification, clearance and experience required for the pilot program without a degradation in critical mission services. Given these critical mission requirements, Microsoft is the only contractor that is capable of performing the necessary services for the DoD.

Microsoft Government Top Secret offers EntraID P2, M365 and AVD that will couple with our existing environment to provide a seamless hybrid cloud solution preventing further costs and delays, while also keeping the mission requirements on track. No other CSP offering will seamlessly integrate into the existing solution, and thus would not meet the Government’s minimum requirements.

(5) Procurement discussion.

Based on outreach to the four CSPs in August 2024, the only CSP that is currently capable of meeting the minimum needs of the Government is Microsoft. Failure to keep Impact Levels aligned will cause critical issues with leveraging tools at lower networks supporting DevSecOps CI/CD Pipeline and proposed ATS’s planned within all IL's that are critical to the mission.

(6) Impact.

Microsoft is the only CSP feasible based on the inability of any other CSP seamlessly integrating all three services for the pilot program. The impact of not procuring through Microsoft would result in the Marine Corps not being able to provide a seamless solution utilizing existing products that are in daily use within Sensitive Compartmented Information Network (SCINet), as well as the degradation of critical mission requirements within the pilot program.

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.

Page 5 of 7 Pages

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 August 01, 2024 by reviewing the specific capabilities in the JWCC Contracts and it was determined that Microsoft Corporation is the only source capable of fulfilling the Government’s minimum needs in the manner and time frame required. USMC M26 requested Additional Research to Support Fair Opportunity from the four JWCC CSPs in April 2025. M26 received responses from Microsoft, Oracle, Amazon Web Service (AWS). Google Public Sector did not respond.

AWS stated in their response that they can meet the compute portion but Workspaces Direct has already been noted that it cannot work with existing hardware. AWS cannot provide the collaborative services that have been requested but can act as a passthrough failing the requirement for additional costs to access. In addition, they cannot provide the federated Active Directory (EntraID) requested, while they will be able to provide federation at a later date there is an extended cost to procure it through secondary CSP and would not meet the as a service requested in the requirements. Additionally, AWS cannot meet the requirements requested for ZeroTrust (ZT) as outlined in the requirements.

Oracle’s response was tied to compute only and they could not meet the collaboration or as a service requested in the requirements. While they did speak to ZT the requirement was for collaborative services that meet ZT in an as a service model, again they could act as a passthrough with additional cost which would not meet the requirement specified.

Microsoft is the only CSP that meets all the Government’s requirements and can be seamlessly integrated with the USMC M26 workload hosted in the Microsoft infrastructure.

Market research indicates other companies’ similar services, or services lacking specific features, do not meet, or cannot be modified to meet, the Agency’s needs. Other cloud services cannot be extended into the Microsoft environment and, thus, do not meet the Government’s minimum requirements.

After reviewing the information gathered from the Market Research, it was determined that while AWS and Oracle offer comparable services, 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 minimum need for compatibility. The ability to utilize same capabilities reduces time to deploy, costs associated with normalizing the data and licenses across environments and impacts to staff and data sharing.

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:

CUI

Page 6 of 7 Pages

CUI

Not Applicable

(b) To overcome future barriers to competition, U.S. Marine Corps (USMC) is preparing a fair opportunity competitive follow-on requirement utilizing PEO Digital existing and approved contracts for future procurements. The follow-on is expected to be completed, solicited, and awarded by October 1, 2026.

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