JA26-050 OTFAOC JA Ceiling Increase GCDSII Redacted.pdf

CUI

Controlled By: DISA

Controlled By: PSD/PS84

CUI Category: PROCURE

Distribution/Dissemination Control: FEDCON

POC: disa.scott.ditco.mbx.ps84-new-requirements@mail.mil

JUSTIFICATION FOR OTHER THAN FULL AND

OPEN COMPETITION (OTFAOC)

Federal Acquisition Regulation (FAR) Part 6 Justification & Approval (J&A), Supporting

Procurements under FAR Part 12, FAR Part 15, or FAR Part 13.5.

Purchase Request Number: To be determined (TBD)

Contract Number: HC108421D0002

Task/Delivery Order Number: N/A

Procurement Title: Global Content Delivery Service (GCDS) II

Estimated Value:

Regulatory Authority: FAR 6.103-1.

J&A Number: JA26-50

P00012 Ceiling Increase

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

(PACA), hereby approve the use of other than full and open competition of the proposed contractual action pursuant to the authority of FAR 6.103-1, only one responsible source and no other supplies or services will satisfy Agency requirements.

1. REQUIRING AGENCY AND CONTRACTING ACTIVITY:

Requiring Agency:

Defense Information Systems Agency (DISA) Hosting and Compute Center (HaCC)

Overcash Avenue, Building 3

Chambersburg, Pennsylvania 17201

Contracting Activity:

DISA/Defense Information Technology Contracting Organization

Scott/PS8411

2300 East Drive

Scott Air Force Base, Illinois 62225

2. NATURE/DESCRIPTION OF ACTION(S):

The proposed action is a modification of the existing GCDS II OS 2200 Capacity

Services contract (HC108421D0002) to increase the contract ceiling by in accordance with the latest Independent

Government Cost Estimate. The contract is a Firm-Fixed-Price usage award and will continue to provide GCDS II OS 2200 Capacity Services to DISA HaCC until the current expiration date of 8 February 2027. All additional funding will be sourced from Defense

Working Capital Funds (DWCF).

GCDS II Capacity Services JA26-050

Page 2 of 7 Pages

The original IDIQ contract was awarded using full and open competition, and prior modifications were determined to be within scope. This action does not change the contract’s technical scope, pricing structure, or period of performance; rather, it increases available contract capacity to accommodate higher-than-anticipated utilization of the existing GCDS II platform. The increased utilization is driven by valid mission growth among Department of Defense (DoD) mission partners, including expanded use of GCDS for secure global application delivery, edge security, and identity and access-related workloads. Most notably, the Department of the Air Force advised that Air Force Cloud

One needed to modify and adjust policy enforcement across current and new cloud service provider environments to meet DoD Zero Trust target activities, which materially increased demand for GCDS-supported identity, access, and policy-enforcement capabilities beyond what was anticipated when the original contract ceiling was established. Increased adoption of an existing DISA enterprise capability by strategic mission partners is a positive outcome for the Government, but it requires an increase to the contract ceiling to avoid constraining mission use during the remaining period of performance.

3. DESCRIPTION OF SUPPLIES/SERVICES:

This acquisition is to provide state-of-the-art global content delivery services to meet current and future DoD customer requirements. The objective is to obtain reliable, responsive, and cost-effective content delivery services that are dynamically scalable and utilize an on-demand service approach. DoD requires a reliable, secure, and fast way to deliver information such as websites, applications, and streaming video to its users across the globe. This requirement is for the contractor to provide and manage a complete, global Content Delivery Network (CDN). This involves setting up and maintaining all the necessary equipment (servers, storage, etc.) and software, providing technical support, and ensuring the system is highly available (99.95% uptime or better) anywhere in the world, from fixed bases to ships at sea. The required services include the procurement, installation, configuration, maintenance, and disposal of all necessary hardware and software to support the content delivery network. The contractor provides all technical personnel, data replication services, and hardware/software upgrades and replacements.

The scope is worldwide, covering the continental United States (CONUS), outside of the continental United States (OCONUS), and tactical locations, including Navy vessels. The contractor also provides full Network Operations Command Center capability and support for all service offerings. The performance period is February 9, 2021 through

February 8, 2027.

4. IDENTIFICATION OF STATUTORY AUTHORITY:

Only one responsible source and no other supplies or services will satisfy Agency requirements. This acquisition is conducted under the statutory authority of 10

U.S.C§3204(a)(1) and the regulatory authority of FAR 6.103-1.

5. DEMONSTRATION OF CONTRACTOR’S UNIQUE QUALIFICATIONS:

Page 3 of 7 Pages

Peraton, through its sub-contractor Akamai, provides the only immediately available, low-risk means to satisfy the Government’s increased requirement within the current

GCDS II period of performance because it is the only contractor that can expand capacity on the existing, globally deployed, accredited, and operational GCDS platform without redesigning, replacing, or re-accrediting the service. GCDS is not a stand-alone commercial subscription; it is an integrated DoD enterprise capability already deployed on NIPRNet and SIPRNet with established mission partner configurations, operational support, and worldwide edge infrastructure. The Government’s need is not to add licenses, rather it is to absorb materially higher operational demand on the currently deployed platform, particularly increased identity, access, security, and delivery workloads generated by mission partners, including the Air Force, while maintaining uninterrupted support to ongoing DoD missions. By leveraging the existing platform, the

Government avoids the substantial technical, schedule, operational, and cost risks that would result from attempting to replace or transition the service during the current contract period.

(a) Description of events:

Peraton was awarded GCDS II through full and open competition in 2021. Since award, actual utilization of GCDS II has exceeded the estimates used to establish the current contract ceiling. The increase is driven by growth in mission demand from DoD users and by expansion of security and access use cases on the existing platform, not by a new out-of-scope requirement. Most notably, the Air Force advised that Air Force Cloud One needed to modify and adjust policy enforcement across current and new cloud service provider environments to meet DoD Zero Trust target activities. That requirement materially increased use of GCDS-delivered identity, access management, and policy-enforcement capabilities beyond what was anticipated when the original ceiling was established. More broadly, GCDS demand has grown as DoD strategic partners have increased reliance on the service for secure global application delivery, OCONUS access, edge security, and enterprise identity-related functions. Increased utilization by strategic mission partners of an existing DISA enterprise capability is a positive outcome for the

Government because it reflects successful adoption of a shared enterprise service to meet operational needs; however, it also requires additional contract capacity to avoid constraining mission use before the current contract expires on 08 February 2027.

(b) Justification:

(1) Minimum Government requirements: The minimum Government requirement is to continue uninterrupted operation, maintenance, sustainment, and limited capacity expansion of the existing GCDS II platform through the end of the current period of performance, including software and hardware upgrades, ongoing managed services, and additional consumption capacity to support higher-than-projected traffic, identity, and policy-enforcement workloads. The Government is not seeking a new design or a replacement platform during this period. It requires continued use and limited expansion of the already deployed and accredited GCDS capability, including its existing global edge footprint, NIPRNet and SIPRNet integrations, mission partner configurations, and

Air Force Cloud One and other current identity-related workloads. Due to the proprietary nature of the incumbent platform and its existing operational integration into DoD

Page 4 of 7 Pages environments, no other source can satisfy this requirement within the available time frame without forcing migration to a different architecture, reengineering interfaces, repeating security authorization activities, and creating unacceptable risk of service interruption to ongoing missions. Competing this short-duration capacity increase would not provide schedule or cost benefit to the Government. Instead, it would introduce unnecessary transition risk and duplicative cost while the Government is already dependent upon the incumbent capability for current operations.

(2) Proposed sole source contractor: The current contractor, Peraton, through its sub-contractor Akamai, is the only responsible source capable of furnishing the required additional capacity on the existing GCDS II platform within the current period of performance. Peraton already operates the contract vehicle, and Akamai provides the proprietary technology, global edge infrastructure, and mission integrations that underlie the current service. Only this contractor team can scale the incumbent solution without replacing it. Any other source would either require access to the incumbent’s proprietary platform through the incumbent team or would have to propose an alternate solution, which would amount to a replacement effort rather than an in-scope ceiling increase.

(3) Impact: If the contract ceiling is not increased, the Government risks exhausting available contract capacity before contract expiration, forcing DISA to constrain or terminate mission partner use of GCDS. This would jeopardize continuity of critical DoD content delivery, edge security, and identity and policy-enforcement services that currently support CONUS, OCONUS, afloat, and tactical missions, including Air Force

Cloud One and other existing mission partner workloads. Transitioning to another provider during the current period of performance is impossible as it would require deployment, accreditation, and operationalization of a global infrastructure at substantial duplicative cost to the Government. Increasing the ceiling under the existing competitively awarded contract preserves continuity of operations, supports valid mission growth, and allows DISA to continue providing an enterprise capability that strategic partners are actively using to meet operational and Zero Trust objectives.

6. CONTRACT OPPORTUNITIES ANNOUNCEMENT/POTENTIAL SOURCES:

All required announcements were posted for award of the IDIQ contract to SAM.gov. In accordance with DARS 5806.302-1(d)(S-90), the Head of Contracting Activity has waived the requirement to issue a request for information or sources sought notice as a market research method for procurement actions to increase the ceiling amount of a contract/order. As such, no RFI/SSN has been posted for this modification, but a redacted copy of this J&A will be posted to SAM.gov within 14 days of award.

7. DETERMINATION OF FAIR AND REASONABLE COST:

A price analysis was conducted during the evaluation of the award of the base contract for the IDIQ. All offered prices have been determined to be fair and reasonable, in accordance with all applicable regulations. Any new orders issued against this contract shall be priced using the rates and pricing methodology stipulated in the base contract.

8. MARKET RESEARCH:

Page 5 of 7 Pages

As stated in Section 6, a Request for Information (RFI)/Sole Source Notification (SSN) was not required for this action. At the time of the original GCDS II award, DISA conducted market research and industry outreach over multiple acquisition cycles to identify qualified sources capable of meeting the Department's requirement for a globally distributed, secure, and highly available content delivery capability. That research included review of Peraton, through its sub-contractor Akamai, and other major commercial CDN providers. The results of that market research demonstrated that while other vendors may offer commercial content delivery services, the current GCDS II requirement is not for award of a new or replacement commercial CDN service. Rather, this action is to increase the ceiling of the existing competitively awarded contract in order to accommodate higher-than-anticipated utilization of the already deployed, accredited, and operational GCDS II platform during the current period of performance.

The incumbent solution is operationally integrated with DoD networks, mission partner configurations, and existing security and identity-related workloads across the enterprise.

For this modification, the relevant market consideration is not whether other firms generally provide CDN or similar services, but whether any other source could furnish the required additional capacity on the incumbent GCDS II platform within the available time frame and without requiring a replacement effort. The answer is no. Any alternative source would require migration to a different architecture, transition of existing mission partner configurations and workloads, reengineering of interfaces, operational testing, and additional security authorization activities. That would result in substantial duplication of cost to the Government and unacceptable delay in meeting current mission requirements. Accordingly, additional market research is not required for this action because the technical scope of the contract remains unchanged and the purpose of this modification is limited to increasing the ceiling amount necessary to continue and expand use of the incumbent proprietary platform through the current contract expiration date.

9. ANY OTHER SUPPORTING FACTS: None

10. LISTING OF INTERESTED SOURCES:

This action is a modification to raise the ceiling of an existing contract with the incumbent prime, Peraton, and is not a new competitive procurement. The unique services required by the Government under this contract are provided exclusively through

Peraton's subcontractor, Akamai.

11. ACTIONS THE AGENCY MAY TAKE TO REMOVE OR OVERCOME

BARRIERS THAT LED TO THE EXCEPTION TO FULL AND OPEN

COMPETITION:

(a) Procurement History.

(1) Contract Number: HC102815D0006 and HC108421D0002

(2) Competitive status of these actions: Full and Open

(3) Type of set aside: None. Large Business

Page 6 of 7 Pages

(a) This is the first time a sole-source ceiling increase modification has been required for the

GCDS II contract. Therefore, no prior actions have been undertaken to remove barriers to competition.

(b) The current Indefinite-Quantity contract, HC108421D0002, was awarded competitively on February 9, 2021 without the need for a justification for other than full and open competition. The competitive nature of the initial award allowed the Government to place orders as needed within the scope and ceiling of the contract.

The circumstances necessitating this J&A have changed significantly since the initial award. The primary reason for this change is an unforeseen and substantial increase in demand from critical Mission Partners. These new, high-priority orders were not anticipated when the original contract ceiling was established.

As a direct result of these emergent Mission Partner requirements, the cumulative value of orders has exceeded the contract's original competitively awarded ceiling of

To ensure continued, uninterrupted support for these vital missions, the Government must raise the contract ceiling.

This proposed action to increase the contract ceiling for the incumbent vendor, Peraton, on a sole-source basis is what constitutes the exception to full and open competition.

Awarding these new requirements to any other source would result in the substantial duplication of costs and unacceptable delays detailed in Section 5 of this document, which would directly impact Mission Partner operations.

Therefore, while the initial award was fully competed, the current need to raise the ceiling to accommodate this unanticipated surge in mission requirements represents a changed circumstance that requires this justification pursuant to FAR 6.103-1.

Page 7 of 7 Pages

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: James Garrett SIGNATURE/DATE:

TITLE/ORGANIZATION: J-9, HaC GCDS Program Manager

PHONE: 571.619.4081

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: John Hale SIGNATURE/DATE:

TITLE/ORGANIZATION: J-9, HaC Chief Product Management and Development

PHONE: 667.890.9000

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

NAME: Tricia L. Singler SIGNATURE/DATE:

TITLE/ORGANIZATION: Contracting Officer, DISA/DITCO/PS84

PHONE:

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 , this review serves as approval and my written determination that the aforementioned FAR circumstances apply.

NAME: Andrea L. Horstmann SIGNATURE/DATE:

TITLE/ORGANIZATION:PACA, DISA/DITCO/PS21

PHONE: 667.890.0841

ALL QUESTIONS REGARDING THIS JUSTIFICATION ARE TO BE REFERRED TO

Jennifer L. Kinser at 667.890.7534, jennifer.l.kinser3.civ@mail.mil