JEFO (ECMA JWCC AWS IL456) 9 Sep 24 Final Signed_Redacted_v2.pdf

CUI//SP-PROCURE

Control Number: 24-046

(3) Previous justification’s intended action to increase competition and results: “For future acquisitions, the Government intends to continue to leverage and comply with DoD-mandated contract sources, while conducting market research and assessments of CSPs’ emerging technologies and IL 4, 5, and 6 capabilities to increase competition to the maximum practicable extent.”

(4) Explanation of the changed circumstances causing this action to now limit the sources: On 31 July 2023, the DoD CIO issued a memorandum, subject: Department of Defense Joint Warfighting Cloud Capability and Next Steps to Rationalize Cloud Use Across the Department of Defense, mandating the use of the JWCC contract vehicle for IL 6, and encouraging the use of the JWCC contract vehicle for other Military Department requirements for cloud capabilities and services. As a result, ECMA contractually moved all the classified (IL 6) customers/applications from the CAMO OTA to the JWCC contract vehicle. Since that time, ECMA has determined that it is in the Army’s best interest to move the 117 unclassified (IL 4 and 5) customers/applications from the CAMO OTA to the JWCC contract since the CAMO OTA is currently scheduled to end on 2 March 2025, and AWS is the only CSP that can provide the services required to support AWS-designed applications because AWS capabilities are unique (i.e., proprietary) and highly specialized. In addition, transitioning all AWS IL 4, 5 and 6 requirements into a single contract vehicle will provide the Government with the best discounts available and reduce the number of overall contracts in the Army's footprint, supporting category management efforts and reducing the volume of contract administration that is required for multiple contracts.

(5) Explanation of any unusual patterns that may be revealed by the history, e.g., several consecutive, urgent buys: None.

(6) Previous justification’s circumstances justifying the procurement and whether there have been any significant changes: Not applicable to the CAMO OTA. The three AWS IL 6 JWCC TOs were awarded on a sole source basis pursuant to approved JEFOs, and there have been no changes since those awards.

b. Other facts.

(1) This TO will operate in parallel with other sole-source TOs awarded to other CSPs because the existing IL 4, 5, and 6-certified CSPs are not equivalent, despite the common misconception that CSPs are interchangeable, and workloads can be moved seamlessly between clouds. Each CSP has spent hundreds of millions of dollars on the research and development of their proprietary solutions and technologies, which provide superior performance and security within their niches, but are not interchangeable.

Therefore, existing applications that were designed and tailored to use the capabilities of a particular CSP will generally be required to use that CSP’s cloud compute and storage services to enable the applications to function without the need to redesign, re-engineer, re-configure, reauthorize, and redeploy them in another CSP. Additionally, because each CSP provides different capabilities and benefits from a cost, technical, and security standpoint, MOs will have to assess their applications before those applications are modernized and migrated to the cloud to determine which CSP provides the optimal solution. In some cases, that CSP will be AWS, and the application will be included in this TO. In other cases, that CSP will be Azure, Google, or Oracle and the application will be added to the sole-source TO awarded to that CSP.

(2) The JWCC contracts include terms and conditions associated with Government data and intellectual property, to include applicable rights, titles, and interests. The contracts also include terms and conditions associated with License Agreements and Service Level Agreements.

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 or price to the Government for this contract action will be fair and reasonable based on the price analysis and a comparison of AWS’ proposed prices to the historical prices paid under the CAMO OTA, AWS’ 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: 7/11/24

Angela G. Quinn Contracting Officer

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

Date:

7/11/24

Angela G. Quinn Contracting Officer