justification_and_approval_document RFO 1_Redacted.pdf

Department of the Air Force: Justification for Other Than Full and Open Competition

CUI

March 2026 CUI Page 2 of 3

I. Agency and Contracting Activity (RFO 6.104-1(a)(1)):

Air Force Materiel Command

AFTC/PZZG

5 South Wolfe Ave.

Edwards AFB, CA 93524.

II. Nature and/or description of the action being approved (RFO 6.104-1(a)(2)):

The has a Sole Source requirement for Classified IT Equipment Destruction. Classified destruction capability is only possible through vendors who have been approved per NSA regulations. System High Corporation INC is the only vendor currently known to have a "mobile" destruction capability and is approved per NSA regulations.

III. Description of supplies/services required to meet agency needs (RFO 6.104-1(a)(3)):

The contractor shall provide all management, personnel, equipment, supplies, facilities, transportation, tools, materials, supervision, and other items and non-personal services necessary to local on site classified IT destruction. The destruction must meet NSA 9-12 requirements and/or granted AF waiver/approval to perform classified destruction. The destruction must include on site inventory and disassembling of IT equipment to be destroyed except for those items specified as Government Furnished Property and services. The destruction must be conducted by cleared member as defined in this Statement of Work (SOW) except for those items specified as Government Furnished services.

IV. Statutory Authority Permitting Other Than Full and Open Competition (RFO 6.104-1(a)(4)):

10 U.S.C. 3204(a)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.

V. Rationale for Use of Authority (RFO 6.104-1(a)(5)):

The agency has a critical need for the secure destruction of classified information technology (IT) hardware and data-bearing media. This requirement is subject to stringent security protocols mandated by National Security Agency/Central Security Service (NSA/CSS) Policy Manual 9-12, "Storage Device Sanitization and Destruction."

This policy requires that all classified storage devices be destroyed using equipment that has been evaluated and approved by the NSA, as published on the NSA Evaluated Products List.

In addition to this regulatory constraint, the agency's minimum requirements include the need for mobile, on-site destruction services.

This on-site capability is essential to maintain a secure and unbroken chain of custody from the point of collection to the moment of final destruction. It allows for direct government oversight of the entire process, mitigating the significant security risks associated with transporting sensitive and classified materials to an off-site facility

VI. Integrated Market Analysis and Efforts to Solicit Competition (RFO 6.104-1(a)(6), (8), and (10)):

A notice of intent to sole source will be posted to the GFP IAW RFO 6.104-1(a)(6) to ensure that System High Corporation is the only capable vendor.

In accordance with FAR 6.302-1(a)(2), market research was conducted to identify all potential sources capable of meeting the

Department of the Air Force: Justification for Other Than Full and Open Competition

CUI

March 2026 CUI Page 3 of 3 agency's requirement for mobile, on-site classified IT destruction services compliant with NSA/CSS Policy Manual 9-12.

A Sources Sought notice was published to the System for Award Management (SAM.gov) website for a period of seven calendar days, from March 19, 2026, to March 26, 2026. This notice detailed the agency's minimum requirements, including the need for NSA-approved destruction methods and mobile, on-site service capabilities. No responses, statements of capability, or inquiries were received from any vendor in response to this notice.

In addition to the public posting, the contracting team performed direct outreach to identify other potential sources. On March 17, 2026, the contracting team contacted of HAF SAF/OCS, the identified Point of Contact for the memorandum regarding SAP IT Sanitization standards. When asked for a list of other approved sources, response indicated that the typical process involves transporting materials to a fixed, approved facility (e.g., for melting/ smelting) and that such plans require approval from the Program Security Officer (PSO). While this information confirms the stringent approval process, it did not yield any additional sources that possess the capability to provide mobile destruction services that meet the agency's essential security requirements.

The results of this integrated market analysis—combining both the public sources sought and direct SME inquiry—confirm that no other responsible sources are known to exist that can satisfy the agency's need for mobile, on-site destruction of classified IT using NSA-evaluated equipment.

VII. Determination of Fair and Reasonable Cost (RFO 6.104-1(a)(7)):

The Contracting Officer is responsible for evaluating, determining, and documenting the anticipated contract cost/price is fair and reasonable in accordance with RFO Subpart 15.4, Contract Pricing.

VIII. Any Other Facts Supporting the Justification (RFO 6.104-1(a)(9)):

System High Corporation INC current has a Waiver DAF-2021-05 dated 29 October 2024 for Special Access Programs (SAP) IT Santization Standards. This vendor is an alternative to offsite SAP IT destruction because their method of destruction meets the requirements set forth by DOW.

IX. Actions to Overcome Barriers to Competition (RFO 6.104-1(a)(11):

The Government will continue to evaluate opportunities to increase competition for future requirements. For future requirements, the agency will conduct ongoing market research to identify new vendors that become approved for mobile, on-site destruction under NSA/CSS Policy Manual 9-12.

While removing the on-site service requirement could increase competition, the alternative of transporting classified materials to an off-site facility introduces unacceptable security risks and requires a significant increase in government oversight personnel. Therefore, on-site destruction is a firm, mission-critical requirement that cannot be waived. The agency will continue to seek opportunities to foster competition in future acquisitions.