JA19-165 9575a Class MOD 01_Redacted Final.pdf

LIMITED SOURCE CLASS JUSTIFICATION & APPROVAL (J&A)

FEDERAL ACQUISITION REGULATION (FAR) PART 8 ACQUISITIONS

Multiple Award Schedule (MAS)/Multiple Award Contract Orders under MAS/General Services Administration Schedules (GSA)/Federal Supply Schedules

(FSS) FAR 8.405-6

Purchase Request Number: To be determined (TBD) Contract Number: Not applicable Task/Delivery Order Number: TBD Procurement Title: Enhanced Mobile Satellite Systems (EMSS) 9575A Blanket Purchase Agreement (BPA) Class Justification Estimated Value: Modification (MOD) 01: no increase to ceiling Statutory and Regulatory Authority: 41 U.S.C. 152(3) and FAR 8.405-6(a)(1)(i)(B)

LIMITED SOURCE JUSTIFICATION

J&A Number: JA19-165 MOD 01

Upon the basis of the following justification, I, as Procuring Activity Competition Advocate, hereby approve this limited source justification in accordance with FAR 8.405-6(a)(1)(i)(B).

The acquisition referenced herein is conducted under the authority of the MAS Program.

1. REQUIRING AGENCY AND CONTRACTING OFFICE:

Requesting Agency:

United States Air Force Space Command (AFSPC) Commercial Satellite Communications Office (CSCO) Enhanced Mobile Satellite Service (EMSS) Program Management Office (PMO) P.O. Box 549 Ft. Meade, MD 20755-9088

Contracting Activity:

Defense Information Systems Agency (DISA)/ Defense Information Technology Contracting Organization (DITCO) DISA Services Section (PL8221) 2300 East Drive Scott Air Force Base, IL 62225-5406

2. NATURE/DESCRIPTION OF ACTION(S):

MOD 01: This modification is to extend the end date of this class justification from September 1, 2020 to January 14, 2021. The single award blanket purchase agreement (BPA) put into place under the original justification is being extended in accordance with FAR 52.217-8 and will now expire on January 14, 2021. This modification will not change the lifecycle value, as there is sufficient ceiling remaining in the justification. This extension is necessary to facilitate a proper follow-on, competitive requirement, which is

EMSS 9575A Equipment Blanket Purchase Agreement-JA19-165 MOD 01

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Module 2 to provide NSA type 1 secure encryption communications. This equipment must be certified for use on the Iridium Satellite constellation, capable of utilizing the EMSS , and in compliance with/accredited by the NSA. The attached APL identifies items that meet these requirements. The approved equipment listed is manufactured by Iridium-certified and Iridium-designated Value Added Manufacturers (VAMs). As discussed below, only Iridium VAMs are authorized to produce equipment that communicates with the Iridium network. The equipment provided in the APL list has also been reviewed and approved by the EMSS PMO for use on the EMSS ;

ensuring that the equipment complies with applicable federal trade regulations, information assurance, and security policies. Only items identified on the EMSS APL have the necessary certifications, approvals, and accreditations to meet and fulfill the Government’s need. EMSS equipment offered under this class justification is understood to be produced by the original equipment manufacturer (OEM) and only the OEM/OEM’s supply chain network. Iridium communications equipment is only to be sold by authorized Iridium-certified and Iridium-designated Value Added Resellers (VARs).

These restrictions are a mandate of Iridium, as the owner and operator of the satellite constellation. The only authorized resellers, Trace Systems, Inc. and General Dynamics Mission Systems, Inc., have the ability to satisfy this requirement. Market research has indicated no other contractors or distributors are able to provide NSA approved 9575a satellite phones. No other product can meet, or be modified to meet, the agency’s need for NSA type 1 secure communications. Both Trace Systems and General Dynamics Mission Systems have previously demonstrated the ability to deliver a 9575A handset kit and are capable of meeting the requirement need currently.

The equipment on the APL is manufactured by an Iridium VAM and provided by an Iridium VAR. Due to an NSA mandated expiration for the current cryptographic keying material used in the EMSS secure unit, EMSS customers are facing a mandated near-term equipment refresh to upgrade from legacy 9505A to a supported model, the 9575A, which is capable of providing NSA Type 1 secure communications, when used with the Iridium secure voice module (ISM2). No other contractors are qualified to provide this equipment based off of market research and communications with the

NSA.

(c) Justification:

(1) Minimum Government requirements.

The contractor shall provide the items named in the APL and must meet the conditions stated under 4(b), above. These items have been reviewed and approved for use on the EMSS . The Government requires 9575A handset kit equipment approved for use on the EMSS , including appropriate security tamper seals, and government approved software/firmware loads. All communications equipment must be delivered with appropriate software/firmware and capable of communicating with the EMSS (eligible for activation). All communications equipment shall be authentic and certified by Iridium with software/firmware approved by the Government, loaded by the contractor, and be

Page 4 of 6 Pages approved for use on the EMSS , including approved security tamper measures as required.

(2) Proposed sole source contractor.

Only two approved sources of the 9575A handset kits exist – Trace Systems, Inc. and General Dynamics Mission Systems, Inc. at this time. There is an immediate need for this equipment due to the mandate from the NSA. Consequently, this requirement will be competed between those two approved sources.

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

For the reasons under 4(b), above, and elsewhere in this document, only two sources are qualified to supply the 9575A handset kits with a secure tamper seal, that will meet all requirements of this acquisition.

(4) Demonstration of limited source.

Over the past year, General Dynamics Mission Systems and Trace Systems have worked to receive the necessary certifications to provide the 9575A secure handset.

No other contractors are currently able to provide the required equipment. This equipment is limited in distribution and requires approved handling processes and procedures. No other contractors have put into place the required processes, procedures or verifications with the NSA; conducted as recently as August 8, 2019 to provide the equipment.

(5) Procurement discussion.

As stated under 4(b), above, Iridium solely certifies businesses as Iridium VAMs and/or Iridium VARs. This is an internal Iridium policy for which the Government has no influence or control over is a limiting factor for competition. Furthermore, only Iridium VAMs/VARs that have been cleared by the NSA may provide the necessary secure handset that are capable of providing secure encryption capabilities.

The 9575A was previously acquired under the prior EMSS Equipment Blanket Purchase Agreement held by Trace Systems. Prior to that effort, General Dynamics Mission Systems assisted with the development of the 9575A and then sold the handset. This requirement will be competed between Trace Systems and General Dynamics Mission Systems.

(6) Impact.

Failure to procure the properly certified equipment could result in unauthorized and/or incompatible devices being sold to EMSS customers. This type of occurrence would be unacceptable as it would undermine the security of end-user’s uncertified device communications, and compromise the integrity of the EMSS as a whole, which in turn could compromise mission-critical communications for all EMSS users worldwide.

5. BEST VALUE DETERMINATION:

A determination will be made by the contracting officer that the BPA represents the best value to the Government, as defined in FAR 2.101, and results in the lowest overall cost alternative to

Page 5 of 6 Pages meet the Government’s needs. The contracting officer will determine whether the price is fair and reasonable based on analysis techniques at FAR 15.404-1.

6. MARKET RESEARCH:

Based on market research completed on August 8, 2019, it has been determined that only the aforementioned products can be supplied by General Dynamics Mission Systems and Trace Systems to fully support the Government’s need. Only equipment produced by Iridium VAMs and Iridium VARs are able to communicate with the Iridium constellation and are authorized to sell Iridium equipment. While there are a number of VARs & VAMs established through Iridium’s relationship with its resellers for equipment, there remains only two resellers whom have taken the necessary steps to receive approvals through the NSA to provide 9575a handsets that are capable of supporting NSA Type 1 Secure communications through the EMSS and the Iridium Satellite constellation.

7. ANY OTHER SUPPORTING FACTS: N/A

8. ACTIONS THE AGENCY MAY TAKE TO REMOVE BARRIERS THAT LED TO THE

RESTRICTED CONSIDERATION:

(a) Procurement history.

On 23 Jan 2017, a single award BPA was awarded to Trace Systems. The contract was a two-year small business set aside contract, awarded on a competitive basis. The 9575A handset was incorporated into this BPA in January, 2019 for EMSS user fulfillment needs. This contract expired July 22, 2019.

On 30 Sep 2016 a task order was issued against HC1047-13-D-4006 for the development of the follow-on secure handset. This was awarded as part of a sole source effort to General Dynamics Mission Systems, Inc. This effort included the development of a new Iridium Secure Module (ISM2) and the 9575A handset. On 08 Jan 2017, the 9575A handset was added to General Dynamic’s ID/IQ contract to be orderable by EMSS customers. This contract expired on 25 Nov 2018.

(b) Actions to Increase Competition This BPA will be competed between the two capable Iridium VAMs/VARs that can provide the 9575A handsets. The EMSS PMO will actively work with Iridium resellers capable of meeting NSA requirements to ensure competition in future efforts are maximized amongst Iridium VAMs/VARs.

9. REFERENCE TO THE APPROVED ACQUISITION PLAN (AP): In accordance with the exceptions under DISA Acquisition Regulation Supplement 7.103(S-90)(1), an AP is not required.

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TECHNICAL CERTIFICATION: I certify that the supporting data under my cognizance which are included in the J&A are accurate and complete to the best of my knowledge and belief.

NAME: LEROY L. LONG SIGNATURE: SEE ATTACHED PDF

TITLE/ORGANIZATION: EMSS PROGRAM MANAGER

PHONE: DATE:

REQUIREMENTS CERTIFICATION: I certify that the supporting data under my cognizance which are included in the J&A are accurate and complete to the best of my knowledge and belief.

NAME: CLARE A. GRASON SIGNATURE: SEE ATTACHED PDF

TITLE/ORGANIZATION: CHIEF, COMMERCIAL SATELLITE COMMUNICATIONS

CONTRACTING OFFICER CERTIFICATION: I certify that this justification is accurate and complete to the best of my knowledge and belief.

NAME: JARID L. SCHULTE SIGNATURE: SEE ATTACHED PDF

TITLE/ORGANIZATION: CONTRACTING OFFICER/DITCO

PROCURING ACTIVITY COMPETITION ADVOCATE (PACA) APPROVAL: I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Since this justification does not exceed $13.5M, this review serves as approval and my written determination that the aforementioned FAR circumstances apply.

NAME: Gay D. Arnold SIGNATURE: SEE ATTACHED PDF

TITLE/ORGANIZATION: Procuring Activity Competition Advocate/DISA

PHONE: DATE:

ALL QUESTIONS REGARDING THIS JUSTIFICATION ARE TO BE REFERRED TO

Michael A. Clifton at