Justification for Exception to Fair Opportunity_693JJ126F00015N_Logical Follow-on Palo Alto.pdf

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Logical Follow-on Justification for Palo Alto Unit 42 Cybersecurity
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693JJ126F00015N_P00001
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This is a Justification for an Exception to Fair Opportunity document submitted by the Department of Transportation for a logical follow-on order modification.

The Document outlines a modification to Task Order 693JJ126F00015N, originally awarded to Colossal Contracting LLC under the NASA Solution for Enterprise-Wide Procurement (SEWP) governmentwide acquisition contract (GWAC). The contracting activity is the Federal Highway Administration (FHWA) Information Technology Acquisition Center of Excellence (ACE), and the program office is the DOT Office of the Secretary of Transportation, Office of the Chief Digital and Information Officer (OCDIO). The modification adds Palo Alto Unit 42, an extended detection and response platform and automated attack surface management (ASM) platform that identifies and mitigates cybersecurity threats. The modification includes emergency defensive support in response to a White House threat detection warning and increases the total order value from $259,531.82 to $798,991.82, with an extension amount of $539,460.00. The pricing consists of two line items: PAN-U42-AIDEFENSE U42 Consulting Services at 2 units of $134,865.00 each ($269,730.00 total) for base support covering 3-4K assets, and PAN-U42-AIDEFENSE-ADDON U42 Consulting Services at 12 units of $22,477.50 each ($269,730.00 total) for additional add-on services. The justification for sole-source procurement under FAR 16.507-6(b)(3) cites the logical follow-on nature of the order and the technical infeasibility of switching vendors without major disruption. Fair and reasonable pricing was established through NASA SEWP's prior determination and a market research quote from Quadra Solutions, LLC. The Contracting Officer is Ajmal Khan, and the Contracting Officer Representative is Michael Shivik.

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Department of Transportation Federal Highway Administration

Information Technology Acquisition Center of Excellence

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

LOGICAL FOLLOW-ON

The Department of Transportation (DOT) makes this Justification for an Exception to Fair Opportunity for orders pursuant to Federal Acquisition Regulation (FAR) 16.507-6.

(a) Identification of Agency and Contracting Activity:

Program Office:

DOT

Office of the Secretary of Transportation (OST) Office of the Chief Digital and Information Officer (OCDIO) 1200 New Jersey Avenue, SE Washington, D.C. 20590

Contracting Activity:

Federal Highway Administration (FHWA) Information Technology (IT) Acquisition Center of Excellence (ACE) 1200 New Jersey Avenue, SE Washington, D.C. 20590

(b) Nature and/or Description of Action Being Approved:

The OCDIO has a need to update the requirements list under Task Order (TO) 693JJ126F00015N awarded to Colossal Contracting LLC. utilizing the National Aeronautics and Space Administration (NASA) Solution for Enterprise-Wide Procurement (SEWP) governmentwide acquisition contract (GWAC). This requirement supports DOT’s strategic goal of organizational excellence by combating cyber threats, delivering accessible government services, and managing data systems to support decision-making, transparency, and accountability.

(c) Description of Supplies/Services and Estimated Value:

Palo Alto Unit 42 is an extended detection and response platform that gathers and integrates all security data to stop sophisticated attacks. Palo Alto Unit 42 is an automated attack surface management (ASM) platform for identifying and mitigating cybersecurity threats against an organization’s infrastructure. The Palo Alto ASM platform combines the organization’s endpoint details collected by Cortex XDR with public asset information discovered by Xpanse, allowing organizations to effectively identify and alert on security issues on remote worker systems and network environments.

The purpose of this modification to order 693JJ126F00015N is to add emergency defensive support in response to the White House threat detection warning. The estimated amount of this extension is $539,460.00. This amount is based on service point enhancement credit hours. As a result, the total obligation amount for this order is increased by $539,460.00 from $124,773.00 to $664,233.00 and the total order value is increased by $539,460.00 from $259,531.82 to $798,991.82.

(d) Identification of the Exception to Fair Opportunity and Rationale:

The original acquisition was conducted as a competitive task order under National Aeronautics and Space Administration (NASA) Solution for Enterprise-Wide Procurement (SEWP) governmentwide acquisition contract (GWAC). This justification for an exception to fair opportunity is prepared in accordance with:

FAR 16.507-6(b)(3) – the order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

Competition is not possible because another vendor would not be able to test the product, perform launch activities and post go-live activities without causing major disruption and project risk to the OCIO environment. Palo Alto licenses and maintenance support meet the DOT’s requirements due to support and licenses being integral to brand name equipment that DOT owns and operates as part of its security infrastructure. The equipment is an item peculiar to the Original Equipment Manufacturer (OEM), Palo Alto. No other license or maintenance agreement, other than the licenses and maintenance provided by Palo Alto will satisfy the Government’s requirements.

(e) Determination That the Anticipated Cost is Fair and Reasonable:

A fair and reasonable pricing determination is conducted and posted by the NASA SEWP Program Management Office database before a product is added to the contract. Therefore, any product listed on NASA SEWP has already been determined to be fair and reasonable at the contract level. Additionally, the IT ACE Contracting Officer obtained a market research quote from Quadra Solutions, LLC in the amount of $539,460.00 that establishes that the proposed price for this modification is determined to reasonableness. Here is the price breakdown for the support:

Line # Part # QTY Unit Price Ext. Price

1 PAN-U42-AIDEFENSE, U42

Consulting Services 2 $134,865.00 $269,730.00

2 PAN-U42-AIDEFENSE-ADDON,

U42 Consulting Services

12 $22,477.50 $269,730.00

Note: Line 1 is the base support for 3-4K assets, while line 2 is additional add-on of two hours services for over 2k per the base cost.

(f) Other Facts Supporting the Justification:

Not applicable.

(g) Statement of Actions, if any, the Agency May Take to Remove or Overcome any Barriers that Led to the Restricted Consideration Before Any Subsequent Acquisition for the Supplies or Services is Made:

Not applicable as this is a follow-on order to competed SEWP Order # 693JJ126F00015N.

(h) Contracting Officer Certification:

The Contracting Officer (CO)’s signature constitutes a certification that the justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief.

Ajmal Khan Contracting Officer

(i) Certification by Technical or Requirements Personnel:

The signature of the Contracting Officer’s Representative (COR) on the Approvals Signature page constitutes a certification that all the supporting data that forms the basis for this justification is complete and accurate.

Michael Shivik Contracting Officer Representative (COR)

2026-09-30T15:42:50-0400
KYLE ROBERT GRIGGS
2026-09-30T15:10:26-0400
MICHAEL ANTHONY SHIVIK

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