JA25-134 ASCEND_250916_Redacted.pdf

CUI

ASCEND for DCO

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CUI

3. DESCRIPTION OF SUPPLIES/SERVICES:

The scope of this requirement is for DISA / EM to acquire cloud computing resources to deploy and operate a Generative AI platform through ASCEND for DCO.

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.

The current ASCEND Cloud environment is architected entirely within AWS GovCloud regions and leverages proprietary AWS services (Amazon Elastic Compute Cloud (EC2), Amazon Elastic Kubernetes Service (EKS), Amazon CloudWatch, Amazon Simple Storage Service (S3), and Amazon Relational Database Service (RDS)) that cannot be replicated or operated natively within another Cloud Service Provider (CSP)’s environment due to fundamental differences in infrastructure, service integration, and compliance boundaries. With AWS’s existing Impact Level 6 (IL6) authorizations and the recent Authority to Operate (ATO) obtained by the ASCEND program using AWS services, the ability to host mission-critical workloads and the exclusive compatibility with ASCEND’s current cloud architecture make AWS uniquely capable of performing this requirement. Specifically, AWS and Microsoft have obtained DoD Provisional Authorizations (PAs) for IL6, but only AWS's cloud services are fully integrated and authorized within the ASCEND Cloud environment. Obtaining a new ATO with another CSP would not meet the Government’s immediate need for cloud services that can seamlessly integrate into the existing environment. In contrast, AWS's existing IL6 authorization and integration with the ASCEND program enable seamless continuation of mission-critical workloads.

The government requires a secure, accredited cloud environment capable of handling Secret classified data. While some other JWCC CSPs offer services at IL6, AWS is uniquely suited to meet DISA's needs. AWS's Secret Region is purpose-built for Department of Defense (DoD) classified workloads at IL6 and operates under full DoD Cloud Computing Security Requirements Guide IL6 accreditation. This dedicated environment offers the complete suite of AWS cloud capabilities, including EC2, EKS, S3, and RDS, within a classified security boundary. AWS is the only CSP capable of meeting DISA / EM’s operational requirements within the security and compliance boundaries of the DoD.

(c) Justification.

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(1) Minimum Government requirements.

The existing cloud service offerings must continue at their current level in order to support four active mission partners. These offerings include cloud infrastructure that is currently deployed and accredited in the ASCEND Cloud IL6 environment. The minimum requirements for these offerings include compatibility with the existing application configuration and architecture, seamless integration with current workflows and processes, high-performance computing and storage capabilities to support demanding workloads, robust security features to protect sensitive data and ensure compliance with government regulations, and reliable and efficient data migration and backup capabilities to prevent data loss.

(2) Proposed sole source contractor. AWS

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

The only CSP capable of performing the transition of ASCEND Cloud’s highly specialized IL6 cloud requirement at the required level of quality is AWS. Re-architecting, re-engineering, and refactoring any of the critical cloud offerings from AWS to another CSP would not meet the Government’s need for compatibility with the existing environment. This is because AWS provides unique services that are already fully integrated into ASCEND Cloud operations, including Amazon EC2, Amazon EKS, Amazon CloudWatch, Amazon S3, and Amazon RDS. Equivalent offerings from the other JWCC CSPs either do not exist in an identical form, lack DoD-accredited integration within AWS GovCloud, or would require extensive redevelopment to meet the same operational needs. 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 minimum need, nor be of benefit to the Government. Without continued integration within the AWS infrastructure, all four of these mission partners would be critically affected by any delays in refactoring, reengineering, and rearchitecting.

(4) Demonstration of unique source.

AWS possesses the knowledge, skills, capabilities, certification, clearance, and experience required to continue the program without a break or degradation in critical mission services. AWS is the only CSP capable of performing the required transition and sustainment of the ASCEND environment without introducing operational risk or mission degradation. The current environment is fully deployed within AWS GovCloud and leverages AWS-native services including Amazon EC2, Amazon S3, and Amazon RDS.

These capabilities are embedded in the architecture, tooling, and cybersecurity boundary authorized under the existing ATO. No other CSP can take over management of the environment without extensive re-engineering and re-accreditation.

(5) Procurement discussion.

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Based on outreach to the four JWCC CSPs in July 2025, the only CSP that is currently capable of meeting the minimum needs of the Government is AWS, using ASCEND IL6 cloud services to deliver Generative AI capabilities to the DCO in defense of the DoD information network (DoDIN) to the warfighter.

(6) Impact.

Transitioning to another CSP from AWS is not feasible based on the inability of any other CSP to seamlessly integrate within the existing architecture. Transitioning to another CSP would delay ASCEND’s ability to deliver Generative AI capabilities to the DCO in defense of the DoDIN to the warfighter. Without AWS, DISA / EM would be unsuccessful in transitioning ASCEND to JWCC and would result in mission failure.

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 on July 16, 2025, by reviewing the specific capabilities in the JWCC Contracts and it was determined that AWS is the only source capable of fulfilling the Government’s minimum needs in the manner required. DISA / EM also requested the Additional Research to Support Fair Opportunity from the four JWCC CSPs in July 2025. DISA / EM received responses from all four CSPs: AWS, Google, Microsoft, and Oracle. Microsoft and Oracle provided responses that they cannot meet the mission needs, while Google provided a “Not Interested” response. Only AWS confirmed service parity with the current environment and the ability to meet mission needs without introducing unacceptable operational risk.

Microsoft is unable to meet the Government’s requirements because they do not provide native interoperability within AWS GovCloud services, and their service offerings would require reengineering of workloads to achieve equivalent functionality and security compliance for IL6.

Oracle is unable to meet the Government’s requirements because they do not provide a full suite of services authorized at IL6 and they lack functional parity within critical AWS GovCloud capabilities required for DISA / EM mission systems.

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CUI

AWS is the only CSP that meets all the Government’s requirements and can seamlessly integrate within the ASCEND workload hosted in the AWS infrastructure.

While Google Cloud and Oracle Cloud do not possess the same level of authorization, and their services would require significant redevelopment to meet the same operational needs, AWS's IL6 authorization, combined with its existing infrastructure and services, makes it the only CSP capable of meeting DISA / EM's operational requirements within the security and compliance boundaries of the DoD.

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

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:

Not Applicable

(b) To overcome future barriers to competition, future development and enhancement of infrastructure-as-a-service components will include shifting to a containerized platform.

This will enable multiple CSPs to meet the requirements which will enable the flexibility to shift workload based on financial and mission requirements.

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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: SIGNATURE:

TITLE/AGENCY/ORGANIZATION: Electronics Engineer, DISA, EM

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: SIGNATURE:

TITLE/AGENCY/ORGANIZATION: Electronics Engineer, DISA, EM

PHONE: DATE:

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

NAME: SIGNATURE:

TITLE/AGENCY/ORGANIZATION: Contracting Officer/DISA/DITCO/PS8511

PHONE: DATE:

PROCURING ACTIVITY COMPETITION ADVOCATE 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 $15M, this review serves as approval and my written determination that the aforementioned FAR circumstances apply.

NAME: SIGNATURE:

TITLE/AGENCY/ORGANIZATION: PACA/DISA/DITCO

PHONE: DATE:

ALL QUESTIONS REGARDING THIS JUSTIFICATION ARE TO BE REFERRED TO