JandA_Redacted.pdf

Control No: JA-20-Adel-586 Contractor: ARTI

Supply/Service: Multilingual Computing and Analysis

JUSTIFICATION REVIEW DOCUMENT

FAR PART 6 JUSTIFICATION AND APPROVAL FOR OTHER THAN

FULL AND OPEN COMPETITION

Programs/Equipment: Multilingual Computing and Analysis Scientific Research, Development, Testing, Analysis and Data Generation Support Services

Authority: 10 U.S.C. 2304(c)(5) as implemented by FAR Part 6.302-5 – Authorized or Required by Statute, further implemented by FAR Part 6.302-5 (b)(6) -- Sole source awards under the Veterans Benefits Act of 2003 (15 U.S.C. 657f).

Amount: $3,972,625.00

Prepared by: DSN:

Computer Scientist/ Team Lead Date: 8/20/2020 Email:

Contracting Officer: DSN:

Contracting Officer Date: 9/1/2020 Email:

Technical: DSN:

Computer Scientist/ Team Lead Date: 8/20/2020 Email:

Requirements: DSN:

Branch Chief Date: 8/20/2020 Email:

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager:

Legal Counsel:

Supply/Service: Multilingual Computing and Analysis

FAR Part 6 Justification and Approval for Other than Full and Open Competition

1. Contracting Activity: Adelphi Contracting Division, Army Contracting Command- Aberdeen Proving Ground (Soldier, Chemical, Research & Test), ACC-APG (SCRT), 2800 Powder Mill Road, Adelphi, Maryland 20783-1138.

2. Description of Action: The U.S. ARL, Computational & Information Sciences Directorate (CISD), Information Sciences Division (ISD), Battlefield Information Systems Branch (BIS) requests a five (5) year Cost-Plus-Fixed- Fee (CPFF), Indefinite Delivery Indefinite Quantity (IDIQ), sole source award to Advanced Resource Technologies, Inc. (ARTI). Both Government Research, Development, Test and Evaluation (RDTE) funds and customer funds originating from the Office of the Under Secretary of Defense for Intelligence (OUSDI), from Congress and from the Program Executive Office for Intelligence, Electronic Warfare, and Sensors (PEO IEW-S) will be used.

_ _ An acquisition plan is not required because this procurement as it either does not meet the threshold at Defense Federal Acquisition Regulation Supplement 207.103(d)(i), or is an R&D acquisition and does not meet the definition of services in 10 U.S.C.

2330(c)(2).

3. Description of Supplies/Services: The purpose of this procurement is to provide linguistic expertise to conduct four (4) basic types of Research and Development (R&D) work in support of the (BIS).The four (4) basic categories are as follows:

(1) Linguistic data development, processing and refinement to enable Natural Language Processing (NLP) and NLP-based technology R&D

(2) Computational Linguistics and Computer Science research support

(3) Hardware and Software test and evaluation

(4) Computer system and application programming, computer system administration;

software design, development, integration, testing, and evaluation

The objective of this effort is to obtain: scientific research, development, experimentation, testing, analysis and linguistics-based data generation support in achieving cutting edge research; novel technological solutions for Army NLP, information processing and knowledge management challenges; and to fully support the wide variety of projects and programs that make up the ARL Multilingual Computing and Analysis mission. Native speakers of low density languages are required for ARL projects, such as Afghan Dari, Pashto, Iraqi Kurdish, and African-accented French, all from specific communities.

ARTI will be providing R&D services through individually issued task orders that support the above mentioned R&D initiatives.

Supply/Service: Multilingual Computing and Analysis

Ordering Period: 30 September 2020 through 29 September 2025 (Five (5) year; no options)

Total Ceiling Value: $3,972,625.00

4. Authority Cited: 10 U.S.C. 2304(c)(5) as implemented by FAR Part 6.302-5 – Authorized or Required by Statute. Refer to FAR Part 6.302-5 (b)(6) -- Sole source awards under the Veterans Benefits Act of 2003 (15 U.S.C. 657f).

5. Reason for Authority Cited: As described in FAR 6.302-5, full and open competition need not be provided for when a statute expressly authorizes or requires that the acquisition be made through another agency or from a specified source, or the agency’s need is for a brand name commercial item for authorized resale.

FAR Part 6.302-5 (b)(6) specifically states that the 6.302-5 “Authorized or required by statute” authority may be used: “(b) . . . when statutes, such as the following, expressly authorize or require that acquisition be made from a specified source or through another agency:” and then listed below that is “(6) Sole source awards under the Veterans Benefits Act of 2003.”

ARTI is a Service-Disabled Veteran-Owned Small Business (SDVOSB) that is eligible for sole source contract award under the cited authority. ARTI is currently the incumbent for the existing IDIQ contract (W911QX-16-D-0021) which provides Multilingual Translation Services for BIS. Per the discussion that follows, ARTI is the only SDVOSB source capable of providing both linguistic expertise and computer science services.

BIS of ARL’s CISD requires scientific research, development, testing, analysis and data generation support to continue and extend efforts for the development, integration and customization of language technologies, including Optical Character Recognition (OCR), Machine Translation (MT), Speech Synthesis and Automatic Speech Recognition (ASR) for the U.S. Army and various ARL customers. A unique aspect of the support required is that the Contractor must provide personnel who are highly proficient in low density languages of military interest and who are also capable of performing software and system development tasks associated with research and testing.

Over time, ARTI has developed a recruiting capacity which is highly successful in providing the type of technical Subject Matter Experts (SMEs) with the right foreign language backgrounds required to successfully support ARL requirements. Native speakers of low density languages required for BISprojects, such as Afghan Dari, Pashto, Iraqi Kurdish, and African-accented French from specific communities, are often persons who have immigrated and who need some support to understand US business requirements and work habits. While other businesses, both large and small, provide either technical research support or language expertise commensurate with those required, those businesses do not routinely provide personnel who possess both types of skill sets.

Language technology research and development work by the BISmakes extensive use of a unique human-in-the-loop method invented at ARL. Also described as a knowledge

Supply/Service: Multilingual Computing and Analysis management approach with machine learning, this methodology is particularly well suited to technical language of the type used for training, mentoring and exchanging operational information with coalition partners. The methodology requires the use of very short software development cycles using statistical methods to capture, or learn terms, phrase structure and other linguistic information at an accelerated cadence compared to commercial methods. The role of the human expert in this methodology is very different from that of a traditional translator; every word, phrase and sentence produced has as its primary purpose the development of new software benefiting from the capture and reuse of expert human knowledge. Learning this mindset is not trivial, but ARTI personnel have learned it very well and very fast through their own structure that has evolved over years of work with BIS, therefore requiring limited to no on-boarding training that would otherwise be required for an alternative vendor. ARTI uses local team leads to instruct their employees on the method. The same team leads perform editing and quality checks to ensure that the data generation and software development aspects of the languages receive the appropriate attention. ARTI is unique in its ability to perform within this framework without a significant ramp-up period which eliminates any schedule risks that would otherwise result in restricted and delayed research efforts in support of BISprojects.

In addition to language experts with technical skills needed for scientific research support, an important aspect of these non-commercial R&D services required is bilingual subject matter expertise in narrow domains of military interest including, for example, training medical doctors for coalition partners such as the Afghan Army. R & D efforts on behalf of the Combined Forces Theater Surgeon General for the Resolute Support mission in Afghanistan require access to bilingual SMEs for which the task at hand means an Afghan medical doctor with good knowledge of technical English and who writes medical Pashto with native proficiency. ARTI is highly successful in finding such persons, recruiting them, retaining them and thereby providing BISwith the required experts necessary to fulfill the requirements in support of the aforementioned effort.

There is a particular style of employer-employee relations needed to overcome cross-cultural barriers and misunderstandings that frequently surface in this work environment with ARTI personnel working with, but not for theGovernment personnel. ARTI management benefits from the successful completion of many urgent tasks requiring the technical skills of persons coming from very different cultures and language backgrounds. With this twin emphasis on computer science and bilingual technical expertise, ARTI is unique in being the only SDVOSB source ready to provide the required services.

If the Justification and Approval is not approved, delays will ensue that will impact the safety and threaten the lives of U.S. soldiers and coalition partners. Specific projects supported by this effort include the Algorithmic Warfare Cross-Functional Team’s Captured Enemy Materials effort, which uses artificial intelligence technologies to accelerate human processing of perishable information contained in captured devices.

Another key project supported by this effort that will be impacted by delays is a set of ongoing agreements to provide low-cost speech translation devices for use by small military teams operating on a short-term basis in Africa while conducting training missions. These teams need an expanded capacity to communicate with their African counterparts and with local nationals who speak accented versions of world languages, Supply/Service: Multilingual Computing and Analysis such as central African-accented French and north African Arabic. Delays in providing the services required by this contract impede the communication capabilities of U.S.

military teams, resulting in more misunderstandings, reduced safety and impaired operational efficiency.

Based on the above, it is the best interest of Government to award to ARTI pursuant to FAR Part 6.302-5 – Authorized or Required by Statute, further implemented by FAR Part 6.302-5 (b)(6) -- Sole source awards under then Veterans Benefits Act of 2003 (15 U.S.C. 657f).

6. Efforts to Obtain Competition:

A synopsis (W911QX20R0045) was posted to betasam.gov on 01 September 2020 for 15 days. The notice also functioned as a Request For Information (RFI). One (1) Vendor responded prior to the close of the Synopsis.

Vendor: Lilt, Inc

CAGE: 8C8T7

DUNS: 116927632

COR Evaluation: The requiring activity reviewed the response obtained from Lilt for this Synopsis. They concluded that the services and skills offered by Lilt are non-responsive to this particular requirement, due to being focused on the machine-learning aspect of software development, and not on the needed language experts with technical and military-domain expertise required by this effort.

However, in efforts to promote competition, ARL CISD continuously collects and analyzes industry information about Multilingual Computing and Analysis Scientific Research, Development, Testing, Analysis and Data Generation Support Services within the market to identify as many potential sources possible.

7. Actions to Increase Competition:

Market research is continuously being conducted on an ongoing basis as part of the regular work of the BIS to be experts in their field. The aim of this ongoing market research is: knowing what new potential contractors exist, how known contractors have evolved their capabilities, and the experience various possible vendors are gaining from other government or private industry projects. Specifically related to this effort:

consulted with SMEs, examinened GSA offerings, and regularly attends industry days, all of which are described in greater detail below in Section 8.

8. Market Research: Market research and evaluation was conducted beginning in February 2020 by a Subject Matter Expert (SME), with fourteen (14) years of experience in foreign language technology development and technical translations for security assistance.

Specific avenues of market research included searches of General Services’ Administration (GSA) Schedules; discussions with SMEs; attendance at a government

Supply/Service: Multilingual Computing and Analysis virtual Industry Day for voice-to-voice Human Language Translation services, involving Microsoft, Amazon, SRI International, Raytheon BBN, SYSTRAN, IBM and Apple;

reviews of market research efforts conducted for similar services; internet searches and review of historical data for W911QX-06-C-0127, W911QX-11-D-0012, and W911QX-16- D-0021 and the market research efforts conducted under those efforts. The SME searched GSA schedules for translation services (Special Item Number (SIN) post a sources sought or request for information as required by DFARS 206.302-1(d) and DFARS Procedures, Guidance and Information 206.302-1(d) was approved on 382-1), interpretation services (SIN 382-2), and Information Technology (IT)/Computer Sciences Schedule 70 for support services. In addition to the above market research efforts, consulted with , a Government civilian managing language technology efforts for the National Virtual Translation Center, and , an Electronics Engineer for BIS. The results of these consultations confirmed that there are no other SDVOSB concerns offering the on-site language and linguistic services of the type required by this contract.

Examination of similar related efforts yielded the following information beyond the Maven project noted above in section 6:

1) W911NF-16-D-0039/ W911NF-19-F-0018 was awarded to GXM Consulting (GXM).

This requirement was for the development of an Android compatible application (app) which would incorporate government provided components into a Libyan Arabic language pack. The focus of this requirement was the app development, using government provided language data. GXM’s expertise is in software and app development, not in language translation itself, nor the recruitment of individuals suited for such work. In addition, GXM is a Veteran Owned Small Business, and not eligible for a SDVOSB set-aside per FAR Part 6.302-5 (b)(6).

2) W911QX-17-P-0259 was awarded to Appen Butler Hill Inc (Appen) as the reseller for the required language database and lexicon sets from the Karlsruhe Institute of Technology, a German University. This was a purchase of already collected and standardized data, and not for the collection nor testing of said data. Appen, the reseller used in this contract, specializes in the development of Artificial Intelligence (AI) technologies, and the collection and provision of datasets for these technologies. They do not themselves have any specific expertise in the language collection methods required for the subject effort. In addition, Appen is an not a Small Business, and therefore not eligible for any potential SDVOSB set-aside per FAR Part 6.302-5 (b)(6).

After extensive market research, it was determined that ARTI is the only SDVOSB that can offer both the bilingual SMEs and computer sciences services needed to meet the Government’s minimum requirements in accordance with the requirements detailed in paragraph 5 above.

Based on the aforementioned and in accordance with 10 U.S.C. 2304(c)(5) as implemented by FAR Part 6.302-5 – Authorized or Required by Statute, ARTI is the only SDVOSB identified and only capable source of providing Multilingual Computing and Analysis Scientific Research, Development, Testing, Analysis and Data Generation Support Services.

Supply/Service: Multilingual Computing and Analysis

For the reasons stated above, in response to FAR 19.1406(a)(1),the contracting officer does not have a reasonable expectation that offers would be received from two or more service-disabled veteran-owned small business concerns.

9. Interested Sources: In accordance with FAR 5.201, an intent to sole source synopsis was posted to betaSAM.gov on 01 Sept 2020 for 15 days with a response/closing date of 15 September 2020. This notice also functions as a (RFI). As of the closing, only the one

(1) response from Lilt has been received, as noted and evaluated in Section 6. Based on the aforementioned, ARTI is the only SDVOSB capable of providing Multilingual Computing and Analysis Scientific Research, Development, Testing, Analysis and Data Generation Support Services as detailed in paragraph 5 above. As required by FAR 5.201, any other bids or proposals received shall be forwarded to the approving official for consideration.

10. Other Facts:

a. Per FAR 19.1406 (a) (3) and (4):

1) This requirement is not currently being performed by an 8(a) participant under the provisions of subpart 19.8 nor has it been accepted as a requirement by SBA under subpart 19.8

2) ARTI has been determined to be a responsible contractor with respect to past performance.

b. Procurement History

Contract: W911QX-11-D-0012 Contractor: ARTI Award Date: 29 September 2011

Competitive Status: Other than Full and Open Competitive Status under the authority of 10 U.S.C. 2304(c)(1) as implemented by 6.302-1(a)(2)(ii) – Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

On 29 September 2011, while the RDRL-CII-T was in the middle of a special effort to provide technical translation support to Combined Interagency Joint Task Force 435 under Joint Urgent Operational Need (JUON) CC-0429, ARTI was awarded a three (3) year IDIQ CPFF type contract for Linguistic data refinement & processing, software integration, test & evaluation, Computational Linguistics Research Assistance, and Application and Software Design, Development, Integration, Testing, and Evaluation services. Contract W911QX-11-D-0012 was awarded under Other than Full and Open Competitive Status under the authority of 10 U.S.C. 2304(c)(1) as implemented by 6.302-1(a)(2)(ii) – Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

The contract was modified several times via change order requirements that extended the POP to 28 September 2016. Under W911QX-11-D-0012, ARTI linguistic analysts provided engineering, integration, testing, linguistic data development and research

Supply/Service: Multilingual Computing and Analysis assistance for a number of low-resource languages including Pashto, Dari, Urdu, Tagalog, Korean, Iraqi Arabic and Kurdish. ARTI linguistics analysts made major contributions to JUON CC-0429, to a follow-on Overseas Contingency Operation Machine Translation project, and to large technical translation projects for the Combined Security Transition Command – Afghanistan in medical, criminal justice and military training domains. Most recently ARTI linguistic analysts are supporting an ongoing joint effort in the Counter Improvised Explosive Device (IED) domain for coalition partners whose native languages include Dari, Pashto, Iraqi Arabic, Kurdish and African-accented French.

Contract: W911QX-16-D-0021 Contractor: ARTI Award Date: 25 August 2016

Competitive Status: 10 U.S.C. 2304(c)(5) as implemented by FAR Part 6.302-5 – Authorized or Required by Statute. Refer to FAR Part 6.302-5 (b)(6) -- Sole source awards under the Veterans Benefits Act of 2003 (15 U.S.C. 657f).

Building on W911QX-11-D-0012, the objective of W911QX-16-D-0021 was to obtain scientific research, development, experimentation, testing, analysis and linguistics-based data generation support to assist ARL achieve cutting edge research, novel technological solutions for Army NLP, information processing and knowledge management challenges and to fully support the wide variety of projects and programs that make up ARL’s mission.

ARTI is a Service-disabled Veteran-owned Small Business (SDVOSB) that is eligible for sole source contract award under 10 U.S.C. 2304(c)(5) as implemented by FAR Part 6.302-5(b)(6) -- Sole Source Awards under the Veterans Benefits Act of 2003 (15 U.S.C.

657f).

The proposed requirements complied with FAR Part 19.1406 -- Sole Source Awards to Service-disabled Veteran-owned Small Business Concerns, which establishes the procedures for Sole Source Awards to SDVOSB concerns.

11. Technical Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Signer’s Title: Computer Scientist and Branch Chief (A)

Supply/Service: Multilingual Computing and Analysis

12. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

Signer’s Title: Branch Chief

Supply/Service: Multilingual Computing and Analysis

13. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable.

This determination will be made using the following:

_X_ Cost analysis __ Price analysis __ Should cost

_X_ IGE

__ Audit:

__ Other:

As a part of this basis, certified cost or pricing data:

_X_ Will be required.

__ Will not be required and the following exception applies (FAR 15.403):

__ Prices that will be agreed upon are based on adequate price competition.

__ Prices that will be agreed upon are based on prices set by law or regulation.

__ A commercial item is being acquired.

__ A waiver has been granted by the head of the contracting activity (HCA) in accordance with DFARS PGI 215.403-1.

__ The contract action is a modification to a contract or subcontract for commercial item(s).

__ The estimated cost of the contract action is less than the threshold for certified cost or pricing data.

14. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Supply/Service: Multilingual Computing and Analysis

Approval Based on the foregoing justification, I hereby approve the procurement of Multilingual Computing and Analysis Scientific Research, Development, Testing, Analysis and Data Generation Support Services for an estimate of $3,972,625.00 and for an ordering period of five (5) years, on an other than full and open competition basis pursuant to the authority of 10 U.S.C.2304(c)(5) subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition.

(End of J&A)