JEFO 24-043 - AWS IL 6 Cloud Compute and Storage Services - redacted.pdf

CUI/ISP-PROCURE

Control Number: 24-043 Contractor: Amazon Web Services

Supply/Service: AWS IL6 Cloud Compute and Storage Services for Enterprise ICAM Est Dollar Value:

JUSTIFICATION REVIEW DOCUMENT

FOR EXCEPTION TO FAIR OPPORTUNITY

Supply/Services: Amazon Web Services (AWS) Secret Impact Level (IL) 6 Cloud Compute and Storage Services for Army Enterprise Identity, Credential and Access Management (ICAM)

Authority: Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(B)

Prepared by: Kathleen Rudd Phone: (703) 307-8385 MITRE Corporation, Contractor to HQDA, CIO, ECMA Email: kathleen.rudd.ctr@army.mil

Contracting Officer: Angela G. Quinn Phone: (309) 782-2101 Contracting Officer Email: angela .g.quinn.civ@army.mil

Technical:

Requirements:

Reviews: I have reviewed this justification and find it adequate to support the justification for an exception to fair opportunity.

Legal Advisor:

CUI/ISP-PROCURE

Controlled by: HODA, ECMA CUI Category: PROCURE Limited Dissemination Control: FEDCON POC: M. Parish, matthew.s.parish .civ@army.mil

Contractor: Amazon Web Services

Supply/Service: AWS IL6 Cloud Compute and Storage Services for Enterprise ICAM Est Dollar Value

Department of the Army Justification for Exception to Fair Opportunity

Under Multiple Award Indefinite Delivery Contracts

1. Contracting Activity: U.S. Army Contracting Command - Rock Island (ACC-RI), Rock Island Arsenal, Rock Island, IL 61299-8000.

2. Description of Action: The Enterprise Cloud Management Agency (ECMA) requests a Firm Fixed Price task order (TO) with Amazon Web Services (AWS) to procure Secret Impact Level (IL) 6 cloud computing capabilities, where the unit prices are fixed, but consumption (service usage) may vary. ACC-RI will execute this action against Joint Warfighting Cloud Capability (JWCC) multiple-award Indefinite Delivery, Indefinite Quantity (IDIQ) contract HC105023D0005. ACC-RI projects award for

Operations and Maintenance, Army funds. An acquisition plan is not required because this procurement does not meet the threshold at Defense Federal Acquisition Regulation Supplement 207.103(d)(i)(B).

3. Description of Supplies/Services: This requirement is for compute and storage services for the Army Enterprise Identity, Credential, and Access Management (ICAM) application in the AWS IL6 Secret Region. The Army awarded a competitive TO for an Enterprise ICAM solution through the Air Force Strategic Transformation Support IDIQ contract on 20 April 2023 to deliver this critical cybersecurity capability across the Army.

The integrator proposed an AWS architecture for both the unclassified (i.e., IL 4 and 5) and classified (i.e., IL 6) ICAM requirements, leveraging AWS native services. The ICAM requirements include privileged access management (PAM); identity, governance and administration; and migration of all existing ICAM capabilities to the cloud. The integrator began deployment of the AWS architecture on the unclassified side at Department of Defense (DoD) IL 4 and 5 under the Cloud Account Management Optimization (CAMO) Other Transaction Agreement (OTA), awarded 03 March 2023, and now requires access to the AWS Secret Region, IL6, to deploy the same architecture there. Due to issuance of the DoD Chief Information Officer (CIO) memorandum on 31 July 2023, entitled "Department of Defense Joint Warfighting Cloud Capability [JWCC] and Next Steps to Rationalize Cloud Use Across the Department of Defense," mandating the use of the JWCC contract vehicle for IL6, the IL6 level, is required to be pursued on the JWCC contract.

DoD IL 6 security classification requires strict controls to protect classified information up to "Secret." DoD Manual 5200.01, Volume 2, DoD Information Security Program: Marking of Information, provides detailed guidance on how to classify, mark, handle, and safeguard such information. The manual specifies that "Secret" information must be

Contractor: Amazon Web Services

Supply/Service: AWS IL6 Cloud Compute and Storage Services for Enterprise ICAM Est Dollar Value:

protected in accordance with the security controls specified in Committee on National Security Systems Instruction 1253, which includes the National Institute of Standards and Technology (NIST) Special Publication 800-53 controls, as well as the application of an IL6 overlay. The ICAM services requires the acquisition and use of AWS, to include the use of AWS native and cloud-supported technologies, because the ICAM solution included an AWS architectural design in both classified and unclassified cloud environments.

ACC-RI intends to award one TO, with the Period of Performance (PoP) beginnin

4. Authority Cited: 1 O United States Code (USC) 3406(c)(2), as implemented in 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.

5. Reason for Authority Cited: The Army must deploy an Enterprise ICAM solution in AWS' IL6 environment to address the Financial Improvement Audit Remediation findings, and satisfy the DoD Zero Trust target level compliance necessary to achieve the outcomes in the Army Unified Network Plan. In addition, part of the Enterprise ICAM requirement includes PAM, which NIST identified as critical software for ICAM pursuant to Executive Order 14028, "Improving the Nation's Cybersecurity," which states:

Contractor: Amazon Web Services

Supply/Service: AWS IL6 Cloud Compute and Storage Services for Enterprise ICAM Est Dollar Value:

The AWS cloud native and proprietary services the integrator utilized in designing the current Enterprise ICAM architecture were developed initially by AWS for commercial customers, entirely at AWS' expense. AWS is the only source capable of providing the cloud capabilities required to support this architecture at the level and quality required because the architecture is based on AWS cloud native coding and infrastructure, which can only be acquired and integrated efficiently in AWS cloud environments.

6. Efforts to Obtain Competition: The JWCC IDIQs were established after substantial market research and awarded to the contractors deemed capable of meeting the requirements and schedule.

Contractor: Amazon Web Services

Supply/Service: AWS IL6 Cloud Compute and Storage Services for Enterprise ICAM Est Dollar Value

A synopsis of proposed contract action will not be posted pursuant to FAR 5.202(a)(6) because the proposed contract action is an order placed under subpart 16.5.

a. Effective competition. Given the fact that AWS is the only CSP 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, effective competition is not applicable.

b. Subcontracting competition. This acquisition does not provide any subcontracting possibilities. Therefore, subcontracting competition is not applicable. This effort is for the purchase of AWS cloud compute and storage services for IL6, which is billed on a consumption basis. There is no labor being funded under this effort.

8. Market Research: On 31 July 2023, the DoD Chief Information Officer (CIO) issued a memorandum, entitled "Department of Defense Joint Warfighting Cloud Capability [JWCC] and Next Steps to Rationalize Cloud Use Across the Department of Defense," mandating the use of the JWCC contract vehicle for IL6. As a result, the ICAM solution, at the IL6 level, is required to be pursued on the JWCC contract. ACC-RI and ECMA conducted market research in April 2024, by reviewing the capabilities of the JWCC contract holders. The JWCC contracts were established as a multiple-award IDIQ in 2022, with awards to

7. Actions to Increase Competition: For future acquisitions, the Government intends to continue to leverage and comply with DoD mandated contract sources, while

Contractor: Amazon Web Services

Supply/Service: AWS IL6 Cloud Compute and Storage Services for Enterprise ICAM Est Dollar Value:

conducting market research and assessments of CSPs' emerging technologies and IL6 capabilities to increase competition to the maximum practicable extent.

9. Other Facts:

Procurement history. None.

Contractor: Amazon Web Services

Supply/Service: AWS IL6 Cloud Compute and Storage Services for Enterprise ICAM Est Dollar Value:

10. 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.

11. 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.

12. Fair and Reasonable Cost Determination: In accordance with FAR 16.505(b)(2)(ii)(B)(5), I hereby determine that the anticipated cost to the Government for th is contract action will be fair and reasonable based on price analysis and a comparison of AWS' proposed prices to the historical prices paid under the CAMO OTA, AWS's JWCC prices, and the IGE in accordance with FAR 15.404-1(b). Certified cost or pricing data will not be required in accordance with FAR 15.403-1 (b)(3) because commercial services are being acquired.

Date: 6/17/24 QUINN.ANGELA Oigitallysignedby

QUINN.ANGELAG.1281320722

Signature: .G.1281320722 Date 2024.06.17 13:17:19-05'00"

Angela G. Quinn Contracting Officer

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

Date: 6/17/24 au INN .ANG ELA Digitally signed by

QUINN.ANGEI.A.G.1281320722

Signature: .G.1281320722 Date:2024.06.17 13:1740-05'00'

Angela G. Quinn Contracting Officer

Contractor: Amazon Web Services

Supply/Service: AWS IL6 Cloud Compute and Storage Services for Enterprise ICAM Est Dollar Value:

Approval

Based on the foregoing justification , I hereby approve the procurement of AWS IL6 cloud computing capabilities and storage services for the Enterprise ICAM appl ication under the JWCC contract using an exception to fair opportunity pursuant to the authority of FAR 16.505(b)(2)(i)(B), subject to availability of funds, and provided that the services or supplies herein described have otherwise been authorized for acquisition .

Date: 6/20/24 Signature:

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RACHEL M. PHELPS

Competition Advocate