JOFOC - TDM Gap Contract (redacted)_Redacted.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

10 U.S.C. § 3204

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by the Federal Acquisition Regulation (FAR) 6.103 (FAR Class Deviation 25-111) and in accordance with the requirements of RFO 6.104, the justification for the use of the statutory authority under RFO 6.103 is justified by the following facts and rationale required under RFO 6.104-1 as follows::

1. Agency and Contracting Activity.

The Department of Homeland Security (DHS), U.S. Coast Guard (USCG) Command, Control, Computers, Communications, Cyber, and Intelligence Service Center (C5I), proposes to enter a contract on a basis other than full and open competition.

2. Nature and/or Description of the Action being Approved.

(a) Nature of the action:

The USCG intends to award a sole source contract to the incumbent contractor, Verizon Business Network Services LLC (Verizon), to extend the support services for Time-Division Multiplexing (TDM) and Ethernet circuits that have not transitioned to the follow-on, competitively awarded task order.

(b) Name and address of the contractor:

Verizon Business Network Services, LLC 22001 Loudoun County Parkway Ashburn, Virginia 20147

(c) Type of action: contract type to be negotiated.

(d) Estimated total value (including options):

Period Total

Base Year

6 mo.

Total $

1 In this document, citations to RFO Parts 6, 10, 15, 25 are citations specifically to FAR Class Deviation 25-11 for FAR Part 6, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 26-08 Rev. 1 for FAR Part 15, and FAR Class Deviation 25-09 Rev.1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

(e) Type of funding: Operations and Support Funds

(f) Year of funding: Fiscal Year 2026

(g) Solicitation number: TBD

(h) Background information about the requirement:

The USCG Enterprise Voice and Data Telecommunication Services supporting Rescue 21 (R21), Vessel Traffic Service (VTS), Communication Services Network (CSN) are currently provided via existing task order under GSA’s Networx Universal (NU) contract. GSA has mandated all services to transition off of NU prior to 31 May 2026. A competitive follow-on was solicited and awarded, but the transition from the current contract to this follow-on has not been completed. Support is still required until the transition is completed.

3. Description of Supplies/Services.

This requirement is to procure support and sustainment of services for legacy enterprise-wide data transport connectivity and associated services to include R21, CSN, VTS, and Miscellaneous circuits. The incumbent contractor, Verizon, will continue to maintain the current state of legacy enterprise-wide data transport connectivity and associated services until the services are transitioned to the follow-on task order. This includes point-to-point TDM data and Broadband Internet circuits, enabling connectivity to the USCG’s wide area network, maintaining existing configurations, and disconnecting circuits upon notification.

4. Identification of Statutory Authority Permitting Other Than Full and Open Competition.

The statutory authority permitting other than full and open competition is 10 U.S.C. § 3204(a) implemented by the RFO 6.103-1 titled “Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements,” specifically RFO 6.103- 1(c)(2)(ii).

5. Demonstration that the Proposed Contractor’s Unique Qualifications or the Nature of the Acquisition Require Use of the Authority Cited.

The USCG requires continued support and sustainment of legacy enterprise-wide data transport connectivity and associated services to include R21, CSN, VTS, and Miscellaneous circuits. The current NU task order will end 31 May 2026. In 2020, a follow-on task order, awarded to AT&T, began the transition of services from Verizon to AT&T, however, the transition is behind schedule and will not be completed prior to 31 May 2026.

Verizon is the only vendor that can provide all support and sustainment for the legacy services because the specific architecture, configuration, and management of this network is unique to Verizon's infrastructure. An award to any other vendor would cause an unacceptable break in service, leading to operational failure of USCG sites. The networks for R21, VTS, and CSN rely on these circuits and services, without which, the USCG would be unable to rescue distressed mariners or monitor marine traffic. Furthermore, a competitive follow-on was already awarded to AT&T and as shown by the delayed transition, it takes longer than anticipated to transfer the circuits from one vendor to another.

Having a competitive follow-on in between the transition from Verizon to AT&T would result in the same delays, as well as delaying the overall transition from Verizon to AT&T.

Due to the USCG’s need for continued data circuit services and the proprietary requirements of these services, the contracting strategy that will provide the Government with the best value is a direct sole source contract to Verizon.

6. Description of Efforts Made to Ensure that Offers are Solicited from as Many

Potential Sources as is Practicable.

The follow-on task order was awarded competitively.

7. Determination by the Contracting Officer that the Anticipated Cost to the Government will be Fair and Reasonable.

The contracting officer determines that the anticipated prices will be fair and reasonable based on a comparison of proposed prices to historical pricing for the same services being procured. The contracting officer will conduct a price evaluation prior to award.

8. Description of Market Research.

Market research was not conducted for this action; however, market research was performed for the competitively awarded follow-on task order that is consuming these services upon transition.

9. Any Other Facts Supporting the Use of Other Than Full and Open Competition.

N/A

10. A Listing of the Sources, if Any, that Expressed, in Writing, an Interest in the Acquisition.

N/A

11. A Statement of the Actions, if Any, the Agency May Take to Remove or Overcome

Any Barriers to Competition Before Any Subsequent Acquisition for Supplies or Services Required.

There are no barriers to future competition. The follow-on requirement was competitively awarded. It is anticipated that future follow-on contracts for this requirement will also be competitively awarded.

12. Contracting Officer’s Certification.

I certify that the data supporting the recommended use of other than full and open competition is accurate and complete to the best of my knowledge and belief.

Date

Contracting Officer

13. Technical/Requirements Personnel Certification.

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the justification, is accurate and complete.

Date

Technical Representative/COR

APPROVAL:

Date

Procuring Activity Advocate for Competition (PAAC)

07May2026

ActingHCA