JA06-077_852675395_Redacted.pdf

Source Selection Information -See FAR 2.101 and 3.104

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JUSTIFICATION FOR EXCEPTION TO

FAIR OPPORTUNITY

Federal Acquisition Regulation (FAR) Part 16.5 Justification & Approval (J&A)

Contract Support System Tracking Number: 852675395 Military Interdepartmental Purchase Request: F3ST956203GC02 Joint Warfighting Cloud Capability (JWCC) Contract: HC105023D0005 Procurement Title: United States Transportation Command (USTRANSCOM) Government Cloud Estimated Value:

Regulatory Authority: FAR 16.507-6(b)(2)

J&A Exception to Fair Opportunity Number: JA26-077

1. REQUIRING AGENCY AND CONTRACTING ACTIVITY:

Requiring Agency: USTRANSCOM Contracting Activity: Defense Information Systems Agency (DISA) Defense Information Technology Contracting Organization (DITCO)/Cloud Capabilities Section

(PS8511)

2. NATURE/DESCRIPTION OF ACTION(S):

Type of Action: New Task Order (TO) Type of Contract: Firm-fixed Price (FFP)

This action is to issue a TO against the JWCC Indefinite Delivery/Indefinite Quantity Contract for USTRANSCOM Government Cloud. This TO will be issued directly to Amazon Web Services, Inc (AWS). The anticipated period of performance (PoP) is for one 12-month base period, plus one 12-month option period. The total estimated value is of which will be funded by transportation working capital funds.

3. DESCRIPTION OF SUPPLIES/SERVICES:

The requirement is for cloud computing services and support to process workloads supporting USTRANSCOM operations at both Department of Defense (DoD) Impact Level (IL) 5 and IL6.

The current USTRANSCOM cloud environment within AWS provides the core enabling technology for critical DoD missions, including global logistics, global bulk fuel, and inter/intra-

J&A: USTRANSCOM Government Cloud

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The USTRANSCOM environment has been specifically designed and tailored over the past nine plus years using AWS-native tools like cloud formation and organizations service to address the unique global mission sets required to be executed 24/7, 365 days a year. This TO will ensure the continued operation of this highly specialized environment on both non-classified internet protocol router network and secret internet protocol router network, maintaining current operational functionality with zero service disruptions. The requirement also includes cloud support for expert-level advisory support and a cross-domain solution for secure data transfer.

4. IDENTIFICATION OF EXCEPTION TO FAIR OPPORTUNITY:

FAR 16.507-6(b)(2) - 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.

5. DEMONSTRATION THAT THE PROPOSED CONTRACTOR’S UNIQUE

QUALIFICATIONS OR THE NATURE OF THE ACQUISITION REQUIRES USE OF THE

EXCEPTION CITED:

1. UNIQUE QUALIFICATIONS:

The USTRANSCOM enterprise environment is uniquely and deeply integrated with proprietary AWS tools, most critically "AWS AppStream 2.0". This service is not simply a virtual desktop interface; it is the core technology used to securely stream desktop applications from AWS to any user's web browser, which is the primary method of access for all 43 programs of record operating in the environment. While other cloud service providers (CSPs) offer virtual desktop solutions, none offer a service that is directly compatible with the existing AppStream configurations, fleet settings, and image builders that have been developed and customized for USTRANSCOM. The functional difference is not in the end-user experience, but in the underlying architecture and management.

Similar services, utilize entirely different systems for image management, fleet configuration, user session brokering, and network integration. A transition from AWS AppStream would require USTRANSCOM to abandon the entire library of custom-built AppStream images and fleets, re-architect the network access and security posture from the ground up for the new service and retrain all technical support staff. It is not a matter of a simple "lift and shift"; it is a complete re-engineering of the enterprise user access layer. Therefore, the required cloud services must be compatible with AWS's unique AppStream service. This is a material and binding technical requirement that cannot be met by any other CSP without introducing unacceptable cost, schedule and mission risk.

AWS’ cloud services are required for compatibility with the required AppStream service that is essential to meeting USTRANSCOM’s minimum need.

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2. IMPACT:

Pursuing a competitive strategy would force the replacement of AWS AppStream 2.0 with a non-compatible virtual desktop solution from another CSP. This replacement process, which requires complete re-architecture, re-testing, and re-accreditation of the access layer for all 43 programs of record, would result in an immediate and unacceptable, prolonged service disruption to USTRANSCOM's enterprise cloud services.

The direct operational impacts of losing this critical access capability include the immediate halt of strategic airlift, sealift, and air refueling command and control systems worldwide. Furthermore, the Joint Deployment and Distribution Enterprise would lose its end-to-end supply chain visibility and synchronization, depriving warfighters of critical equipment, sustainment, and ammunition. Consequently, a disruption to this unique service would mean the DoD loses the rapid force projection necessary to deter transregional threats and sustain active combat operations.

6. DETERMINATION OF FAIR AND REASONABLE COST:

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.

7. MARKET RESEARCH:

Market research for the basic JWCC Contracts was conducted and resulted in a signed market research report on November 9, 2021. This market research was subsequently revalidated and recertified on July 29, 2024, and most recently on February 6, 2026. After a survey of the market, it was concluded that use of the JWCC Contract is in the Government’s best interest due to technical feasibility and cost to the Government.

Based on current market research, conducted between July 24, 2026, and August 14, 2026, it has been determined that only the unique combination of the cloud service offerings provided by AWS can fully meet the Government’s need without significant duplication of cost, delays in readiness and risk to overall mission.

Additional research was conducted in August 2026 to all four JWCC CSPs. AWS submitted a response that fully addressed the technical questions and confirmed their ability to meet the requirements. provided a response that did not address the specific architectural compatibility and service-level requirements. did not respond.

8. ANY OTHER SUPPORTING FACTS: None

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

THAT LED TO THE EXCEPTION TO FAIR OPPORTUNITY:

Reviewing officials and the approval authority have reviewed the previous J&A, which was routed with this J&A, and determined any planned actions to remove barriers to competition listed on the previous justification were considered. The previous J&A identified the primary barrier to competition as the deep architectural and technical dependency on AWS’s proprietary services. Prior to this acquisition, USTRANSCOM conducted technical market research across all four JWCC CSPs to evaluate if alternative platforms could support the command's existing environment and proprietary dependencies without mission disruption. The assessment concluded that alternative CSP solutions cannot natively support the mature architecture or replace the deeply integrated AppStream services without incurring high costs and operational delays which would last a minimum of 36 months.

After reviewing the actions taken, it is determined that a sole source environment still exists for the current Fiscal Year 2027 requirement, as the barriers could be overcome due to unacceptable cost, risk to mission, and schedule delays associated with moving to another CSP.

The previous procurement was based upon an exception to fair opportunity.

Procurement History:

Incumbent Contractor: AWS Contract Number: HC105023D0005 TO Number: HC105023F0035 PoP: October 1, 2023–September 30, 2026 Competitive Status: Other than full and open competition/Exception to fair opportunity Business Size: Large

To enable open competition for future acquisitions, USTRANSCOM will execute a phased strategy that will include analyzing multi-cloud options using analysis of alternatives, reducing or eliminating proprietary dependencies, and building a data-driven transition strategy.