Justification for EFO - USACE Regulatory Project Management Digital Assistant - Award Notice.docx

JUSTIFICATION REVIEW DOCUMENT

FAR Part 16 Justification for an Exception to Fair Opportunity

Program/Equipment: A “Project Manager (PM) Digital Assistant” is required by the US Army Corps of Engineers (USACE) Regulatory Program (URP) that can unify various IT tools into a single platform. This requirement is currently pending award of Phase 2 to implement and provide maintenance services for the digital assistant.

Authority: 10 United States Code 3406(c)(2) as implemented in Revolutionary Federal Acquisition Regulation Overhaul (RFO FAR) 16.507-6(b)(2), only one such contractor is capable of providing the services or property required at the level of quality required because the services or property ordered are unique or highly specialized.

Amount: $5,212,287.00 (including all options)

Contract Specialist Phone: (703) 428-8487 Date: 2026.04.10

E-mail: David.A.Kaplan@usace.army.mil

Contracting Officer:

Douglas E. Pohlman Contracting Officer

Phone: (703) 428-6420

E-mail: Douglas.E.Pohlman@usace.army.mil

Technical:

Tunis W. McElwain Deputy Chief

Phone: (202) 761-4591

E-mail: Tunis.W.McElwain@usace.army.mil

Requirements:

Tunis W. McElwain Deputy Chief

Phone: (202) 761-4591

E-mail: Tunis.W.McElwain@usace.army.mil

Control Number: 26-0024

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

Program Manager:

Justin W. Hughes Regulatory Program Manager

Business Oversight:

Randy H. Force Business Oversight Branch Chief

Small Business:

Monique M. Holmes Small Business Program Analyst

Legal Counsel:

Assistant Center Counsel

FAR Part 16 Justification for an Exception to Fair Opportunity

1. Requiring Activity: USACE Regulatory Program

2. Contracting Activity: USACE Mission Support Battalion (UMSB)

3. Description of Action: Approval is requested to award a noncompetitive firm fixed price (FFP) Delivery Order (DO) to be issued by UMSB. It is anticipated that UMSB will issue the DO against an Enterprise License Agreement within the Commercial Hardware Enterprise Software and Solutions (CHESS) pool of contracts, awarded and administered by Army Contracting Command, Rock Island, Illinois (ACC-RII).

The estimated total cost of the DO is $5,212,287 with award to be made to Computable Insights, LLC, SAM UEI: L2TGB7MSSFU7, CAGE: 604M8, for software products and services titled “Project Manager (PM) Digital Assistant”. The Performance Work Statement for this DO incorporates products and services peculiar to the manufacture, namely their “Salesforce Software Licenses and Professional Services”. This DO will be funded using Fiscal Year (FY) 2026 Infrastructure Investment and Jobs Act (IIJA) funds (96 x 3126). These funds were provided to USACE Regulatory Program to transform and modernize the program. Fund are available on Purchase Request and Commitment W74RDV61063058.

4. Description of Supplies/Services: This procurement is for to continue Phase 2 tool development previously initiated under Phase 1, via Delivery Order W519TC26FA127, as detailed below in section 9(a). The URP is undergoing a comprehensive modernization of its systems and processes to reduce decision times and enhance public service.

This pending DO is for brand name specific software licenses titled “Core Salesforce” and “MuleSoft” along with associated professional and advisory support services to implement and maintain the tool. The required products and services were previously procured for URP via DO W519TC26FA127 issued by ACC-RII against Army CHESS contract number W519TC26DA009. The estimated total value of this pending DO is $5,212,287.00. The total period of performance will be 12 months. The anticipated DO will be broken down sequentially into Phase 2a and Phase 2b. The period of performance is detailed as follows in the table below:

** Due to the delay between the end of Delivery Order W519TC26FA127 where Phase 1 was completed and award of a follow-on Delivery Order for Phase 2, the Contracting

Officer will approve pre-contract costs to maintain software licenses in accordance with RFO FAR 31.205-32 and RFO FAR 31.110.

5. Authority Cited: 10 United States Code 3406(c)(2) as implemented in Revolutionary Federal Acquisition Regulation Overhaul (RFO FAR) 16.507-6(b)(2), only one such contractor is capable of providing the services or property required at the level of quality required because the services or property ordered are unique or highly specialized.

6. Reason for Authority Cited:

a. Background: The Regulatory Project Management Digital Assistant requirement is necessary to modernize the Automated Information Systems (AIS) used by the URP in accordance with a Presidential Memorandum titled “Updating Permitting Technology for the 21st Century” and dated 15 APR 2025, directing federal agencies to modernize environmental review and permitting processes using technology. Specifically, the memo calls for eliminating the use of paper-based application and review processes, and maintaining a readily available source of information that may be relevant to judicial review of any permits; with a goal to streamline the overall environmental review and permitting process at the Federal level, which allows speeding of data gathering and decision-making that can improve timeliness for State, local and tribal decision-making as well.

This modernization effort also aligns with the Permitting Technology Action Plan issued by the Council on Environmental Quality and twelve Executive Orders to speed permitting related to energy, precious metals, minerals and timber. Key requirements include developing workflows to digitize and automate permit processing and case management, integrating with the existing Regulatory Request System (RRS) and Operations and Maintenance Business Information Link (OMBIL) Regulatory Module (ORM), establishing a secure single sign-on (SSO) access point, and building analytics dashboards for real-time visibility into program performance. Currently, URP operates across five disparate legacy systems, hindering efficiency, data integration, and the adoption of advanced technologies such as AI and digital labor. Creating a fully integrated, AI-augmented, workflow-driven system will reduce or eliminate staff-time spent on routine data management, foster more focused and efficient review, and expedite inter- and intra-agency collaborations. URP’s Automation Improvement strategy is structured around three main goals:

1. A Single user interface with enhanced self-service portals, AI-driven assistance, and real-time reporting capabilities.

2. A workflow-based project management tool that automates routine tasks and incorporates AI-assisted data analysis.

3. Fully integrated data and document management capability that will allow enhanced search capabilities and seamless intra- and interagency data sharing and collaboration.

Project Managers (PMs) are required to pull information from disparate systems and trackers to manage their workload and respond to data calls. This manual process creates a significant administrative burden. It is estimated that URP PMs spend between 10-15 hours per week on administrative tasks, creating a significant data lag that hinders timely decision-making. This project seeks to address this inefficiency by developing a "Regulatory PM Digital Assistant" on the Salesforce platform. This solution will provide a centralized environment for data aggregation, workflow automation, and reporting. The objective is to automate low-value administrative tasks, enabling PMs to focus on their core mission duties. This directly aligns with Administration priorities by moving the program towards a more data-centric, efficient, and transparent operational model. The URP currently processes approximately 71,000 actions per year. Therefore, full implementation of this automation improvement strategy would conservatively result in savings of approximately 42,600 hours/year, the equivalent of approximately 21 full time equivalents per year. Additionally, it is necessary to create end-user training documentation and a "train-the-trainer" program.

b. Justification: Computable Insights, LLC is the Original Equipment Manufacturer (OEM) and sole provider of its proprietary software. The Department of the Army has an Enterprise Level Agreement within the CHESS pool of contracts, administered by the Army's Digital Market, Capability Program Executive Enterprise Software & Services (CPE ES2). This contract vehicle was awarded to Computable Insights, LLC. on 26 JAN 2026 under contract number W519TC26DA009.

Previously awarded DO W519TC26FA127 was issued to Computable Insights, LLC in the amount of $914,393.94 to initiate Phase 1 of the requirement. This action is to issue a new DO to execute Phase 2 of the requirement.

Phase 1 focused on team onboarding, program increment (PI) planning, minimum viable program (MVP) blueprinting, platform readiness (org setup/security), and the initiation of Build Sprints. Phase 2a encompasses the remaining build sprints, User Acceptance Testing (UAT), and production deployment for the MVP. Phase 2a requires the implementation team to conduct PI Planning with key stakeholders and the PM Digital Assistant Product Owner to prioritize features and remaining work that will be incrementally released into production. Phase 2b will result in scaling the "PM Digital Assistant" core functionality across the remainder of the USACE Regulatory mission. To award Phase 2 to another vendor would require substantial duplication of effort and unnecessary expense that cannot be recovered through competition. Alternatives cannot meet or be modified to meet the requirements.

c. Alternatives: While alternative products exist in the marketplace, it is impractical to consider replacing Salesforce for Phase 2 implementation. A comparison of the alternative tools and their capabilities is provided in the table below.

Analysis of Alternatives Compared to Salesforce/MuleSoft

Product (across) Requirement (down)

Data Integration & API Management Pro: A market leader in API-led integration.

Exceptionally powerful for complex, high-performance scenarios.

Con: Can be complex and requires specialized developer skills.

Pro: Extremely user-friendly with a low-code interface and a vast library of pre-built connectors.

Con: Performance will be insufficient compared to MuleSoft for very high-volume, real-time API use cases.

Pro: Strong integration capabilities, including native database connectors and web APIs.

Con: Integration is a feature supporting the main application platform, not a standalone best-of-breed product.

Pro: Strong integration with Oracle's ecosystem (SaaS, PaaS, on-premise apps).

Features pre-built adapters.

Con: Less extensive connector library for non-Oracle systems compared to competitors.

Con: Not its primary function. Lacks a native, sophisticated visual workflow or case management designer.

Pro: Good workflow automation features ("Boomi Flow") suitable for many use cases.

Con: Not as advanced as a dedicated BPM platform like Appian for complex, stateful, and long-running cases.

Pro: Core strength. A market leader in designing and automating complex business processes, case management, and rules-based logic.

Con: May be overly complex for very simple, linear automation tasks.

Pro: Offers visual process automation for orchestrating workflows across applications.

Con: Workflow capabilities are generally considered less mature than competitors for complex business processes.

Con: Provides no native, out-of-the-box UI builder. This requires a separate and significant development effort.

Pro: Boomi Flow allows for the creation of simple forms and basic portals.

Con: UI capabilities are not as sophisticated, customizable, or rich as those offered by Appian.

Pro: Core strength. Excels at rapidly building rich, dynamic user interfaces, dashboards, and self-service portals with low-code tools.

Con: UI is proprietary to the Appian platform and its framework.

Pro: Includes a visual application builder to create simple web and mobile front ends.

Con: The UI builder is not as powerful or flexible as competitors’ low-code platform for creating complex, enterprise-grade applications.

Con: AI features are developer-centric, not aimed at providing AI assistance to the end-user of the final application.

Pro: Strong, integrated AI capabilities for use in workflows, decisioning, and data processing (e.g., IDP).

Con: Integrating cutting-edge generative AI may require more configuration than other platforms.

Pro: AI and machine learning capabilities are available and can be integrated into processes.

Con: The AI ecosystem is less mature and extensive compared to what is available through Salesforce/MuleS oft.

FedRAMP Compliance

A narrative analysis of each alternative product is detailed beginning on the page below:

Boomi – This requirement includes creating a functional user interface and workflow manager will require a significant amount of customization and development due to the inherent complexity of the URP. Boomi is not as strong in building the kind of sophisticated, custom user interfaces and complex, long-running case management workflows that seem to be at the heart of the "Digital Assistant" requirement. Research indicates that Boomi’s ability to customize very complex integrations is limited and there is an increased risk of unsuccessful performance for extremely large-scale tasks. Accordingly, Boomi will not meet the URP requirement given its lack of sufficient ability to customize complex integrations.

Appian - Research also indicates that Appian is not as strong with data integration with legacy systems (such as the RRS and ORM), which is a key requirement of the PM Digital Assistant Tool. The core of the "Digital Assistant" requirement is not just to build a single application, but to fundamentally modernize how the URP legacy systems interact. Choosing MuleSoft is a strategic decision to build a robust, secure, and agile system that will serve the URP for years to come. Appian falls short because it is more suited to delivering a single point solution which is a significant limitation that will not meet URP’s requirement.

Oracle Integration Cloud (OIC) - Based on the requirements, Oracle Integration Cloud should not be considered because its core strengths are in back-end data integration, particularly within the Oracle ecosystem. This is compared to Oracle’s native tools for building a sophisticated user interface and complex workflows which are significantly less mature than its competitors. OIC would fail to deliver the complete, user-facing "Digital Assistant" application that is the central requirement of the project. Accordingly, OIC is not suitable to meet URP’s need.

Salesforce/Mulesoft - The “Digital Assistant” requires more than just connecting systems and adding a UI; it requires a complete agentic AI enterprise platform. Salesforce, is uniquely positioned to deliver this. While MuleSoft does not have a native UI builder, it is owned by Salesforce. This provides a clear, best-of-both-worlds path forward.

1. Use MuleSoft to securely unlock the five legacy systems and create a library of reusable System and Process APIs.

2. Use the Salesforce Platform (available via Government Cloud) to build the user interface and workflows.

3. Integrate Salesforce Agentforce to provide the AI-assistance layer, fed by the clean, orchestrated data coming from the MuleSoft APIs. This allows for the creation of a true "assistant" that can provide predictive insights, generate content, and automate decisions—capabilities that go far beyond the developer-focused AI of Boomi or the less mature offerings of others.

In conclusion, while the other platforms can address parts of the requirements, alternatives cannot meet or be modified to meet the requirements. Only Salesforce delivers a single, unified platform that combines a market-leading low-code application builder, deeply integrated AI, a best-in-class integration engine (MuleSoft), and a proven, trusted infrastructure. The ability to seamlessly integrate with systems such as RRS and ORM while providing a unified user interface with advanced analytics and superior AI capabilities is paramount, making the Salesforce/MuleSoft platforms the best overall solution for the URP "Digital Assistant" requirement.

d. Impact if not approved: If this Justification for an Exception to Fair Opportunity is not approved the USACE Regulatory Program will not be able to fully deliver on all the requirements for the PM Digital Assistant tool. The URP has already purchased licenses and made a significant investment in in-house resources devoted to tool development. As indicated above, Computable Insights LLC has begun development of the tool under a previous delivery order. Not approving this Justification would negate the anticipated savings of 42,600 labor hours per year identified above. Additionally, not approving would result in wasted resources that have already been expended initiating development and would result in unacceptable delays between 6-12 months.

7. Actions to Increase Competition: As stated above, Computable Insights LLC is the sole provider of its proprietary software and provides the software and support through its CHESS contract. AFARS 5139.101-90 states that CHESS is the mandatory source for commercial IT software purchases. Additionally, this action is to continue development that began under Delivery Order W519TC26FA127. The previously issued Delivery Order was issued concurrently with award of IDIQ contract W519TC26DA009 using the procedures of FAR 6.302-1(a)(2), only one responsible source. Accordingly, actions to increase competition are not practical. Market research will be conducted for future requirements to determine if competition is feasible. Notices required in accordance with RFO FAR Part 5 will be posted. An award notice with this Justification will be posted within 14 days after placing the order in accordance with RFO FAR 16.507-6(f)(1).

8. Market Research: The Contracting Officer conducted market research from 01 APR 2026 through 10 APR 2026 in conjunction with expert knowledge of the Program Manager from URP to determine if alternative products could meet the Government need. A search using Google and AI identified comparable products to Salesforce which were then analyzed by the Program Manager as detailed above in Section 6. None of the alternatives detailed above in Section 6 can meet Government needs. As stated above, Computable Insights LLC is the OEM and sole provider of its proprietary software. Analysis of alternatives was considered as detailed above and it was determined that there are no viable alternatives. The alternatives cannot meet or be modified to meet the requirements. This procurement is for Phase 2 to continue software development previously initiated under Phase 1 via Delivery Order W519TC26FA127, detailed below in section 9(a).

9. Other Facts:

a. Procurement history:

(1) Contracts: Delivery Order W519TC26FA127 was previously issued to Computable Insights, LLC as a FFP order in the amount of $914,393.94 by Army Contracting Command – Rock Island, Illinois (ACC-RII), the contracting activity with authority for providing the CHESS suite of IDIQ contracts. This order had a period of performance of 27 JAN 2026 through 26 MAR 2026. No options were included in this order. A no cost time extension was awarded to extend only the professional services under this order to 26 MAY 2026. This extension did not cover software licenses.

(2) Competitive Status of these Actions: Delivery Order W519TC26FA127 was awarded non-competitively concurrently with the issuance of Army CHESS IDIQ contract W519TC26DA009.

(3) Authority Previously Cited if Less than Full and Open Competition Was Used: Authority for Delivery Order W519TC26FA127 followed the same authority used to issue the IDIQ W519TC26DA009, FAR 6.302-1(a)(2), only one responsible source. The IDIQ and the order were issued concurrently.

(4) Changed Circumstances: The market has not changed significantly in the 3 months since Delivery Order W519TC26FA127 was issued in JAN 2026.

(5) Unusual patterns: None.

(6) Protests received: None.

b. Other facts: None.

Certifications, signatures and approvals are contained on the pages below.

1. 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.

Tunis W. McElwain Deputy Chief

2. 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.

Tunis W. McElwain Deputy Chief

3. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price/cost to the Government for this contract action will be fair and reasonable. This determination will be made using the various techniques found in RFO FAR 15.404-1 which include but are not limited to comparison to an independent Government estimates and comparison to historical prices paid by the government for the same or similar. As part of the basis, certified cost or pricing data will not be required due to the exception found at RFO FAR 15.403-2(b)(3). This requirement is for commercial products and services. Additionally, prices for licenses and labor rates for professional services were negotiated at the IDIQ level by ACC-RII.

Douglas E. Pohlman Contracting Officer

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

Approval

Based on the foregoing justification, I hereby approve the procurement of the “USACE Regulatory Program Digital Assistant” on an Exception to Fair Opportunity basis pursuant to the authority of 10 USC § 3406(c)(2) as implemented in RFO FAR 16.507-6(b)(2), only one such contractor is capable of providing the services or property required at the level of quality required because the services or property ordered are unique or highly specialized. The estimated value of the new Delivery Order is $5,212,286.96 with an end date for the period of performance being 25 MAR 2027 which coincides with the end of the software license. The approval is subject to availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for this acquisition.