Justification Narrative.pdf

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY IN

ACCORDANCE WITH FAR 16.505(b)(ii)(B)

(1) Identification of the agency and the contracting activity, and specific identification of the document as a "Justification for an Exception to Fair Opportunity."

Agency: U.S. Department of Housing and Urban Development (HUD)

451 7th Street SW, RM 5184

Washington, DC 20410

Contracting Activity: Office of Chief Procurement Officer, Headquarters

Program Office: Office of the Chief Information Officer (OCIO)

(2) Nature and/or description of the action being approved. Execute a modification to add

$10,000,000 to the Enterprise Infrastructure Solutions (EIS) multiple award contract, task order

1(TO1) 86615321F00007 for current option year ending 9/30/2024 bringing the total value to

$69,523,106.32. This funding is required to execute the replacement of End-of-Life Switches across the enterprise that are currently operating in a minimal/break fix mode with significant risks to the agency due to a lack of vendor support re spares, software, and security support. This effort must be executed to comply with Executive Order 14028 “on Improving the Nations

Cybersecurity.”

Method of Contracting: Modification to existing Task Order

Type of Contract: Firm Fixed Price

Type of Funds: IT

(3) A description of the supplies or services required to meet the agency’s needs (including the estimated value).

The estimated value of the requested supplies or services is $10,000,000. The supplies and services include network switches, WIFI equipment, associated engineering, support, licenses, and installation for replacement of end-of-life equipment and completion of HUD’s enterprise

WIFI deployment (spanning 9 HUD sites including the Headquarters building).

Period of Performance: July 25, 2024, through September 30, 2024

(4) Identification of the exception to fair opportunity (see 16.505(b)(2)) and the supporting rationale, including a demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the exception cited. If the contracting officer uses the logical follow-on exception, the rationale shall describe why the relationship between the initial order and the follow-on is logical (e.g., in terms of scope, period of performance, or value).

Contractor’s Unique Qualifications

In accordance with the exception to fair opportunity and the supporting rationale the requested follow-on is logical as the contractor has multiple unique qualifications. The contractor’s familiarity with HUD’s infrastructure is advantageous as the end-of-life IT equipment is located in the Headquarters Building and has a tremendous impact on multiple stakeholders meeting their mission priorities without the IT capabilities being upgraded. Furthermore, the contractor’s understanding and familiarity of the criticality and complexity of HUD’s networks reinforces the logical reasoning for the requested follow-on. As the current contractor is currently providing continuous service to the networks, issuing a new or separate contract to another contractor would cause delays in services and disrupt operational activities taking place in the Headquarters building, directly impacting HUD’s overall mission. Re-competing this effort verses a modification is not in the best interest of the Government due to delays with issuing a solicitation, making a contract award, onboarding contractors, as this process would further the impact of the need to replace the outdated equipment and further have impacts on HUD’s critical

IT Infrastructure and support its organic customers. HUD currently has to rely on stocks of used in inventory spare parts for this equipment and will be unable to obtain security updates for end of life equipment leading to loss of network services if a security vulnerability arises which will not be corrected in this end of life equipment. A modification to the existing task order will be most cost effective and avoid undue delays for the infrastructure requirements.

Logical Follow-on Exception

The replacement of the end life WIFI equipment at HUD Headquarters Weaver Building

[originally installed in 2018] serves to be the most advantageous and attainable approach to the

Government as the approach is logical, sound, and cost effective. This equipment is maintained, operated, and configured by the current vendor who has the ability to seamlessly replace end of life equipment with refresh equipment with minimal disruption to HUD operations

Scope

The contractor will perform the following activities and functions (these tasks are within the scope of work):

• Upgrade HUD enterprise WIFI controllers and associated equipment to allow the expansion of both Enterprise WIFI and Guest WIFI to all remaining HUD regional and field offices. This expansion includes the Atlanta Swing Space, Boston Regional Office, Chicago

Regional Office, Fort Worth Regional Office, Headquarters, Potomac Center, Richmond Field

Office, San Francisco Regional Office, and the Washington Office Center.

• Procure, configure, and prepare for deployment WIFI Equipment, software, engineering needed to install both guest and enterprise WIFI at all HUD sites which do not yet have

Enterprise and Guest WIFI.

• As backup reference for this request attached is document EIS SRE ROM HQ and

Enterprise which lays our Rough Order of Magnitude pricing for equipment, engineering, and configuration of equipment for the above efforts.

• Procure w Wireless and Switching equipment to integrate with the agencies existing wireless management system

Period of Performance

The current contractor can perform these upgrades during the period of performance of August

01, 2024, through September 30, 2024. This is an acceleration of previous efforts, to meet lifecycle requirements and mission requirements for WIFI across the HUD enterprise.

(5) A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable.

The anticipated cost to the Government proves to be reasonable as the site surveying, cabling, and other installation funding requirements beyond that in the ROM led to the request to add

$10,000,000 to the current contract. This is based on a quote from the vendor based on HUDS requirements and an IGCE. Upon review of the quote and pricing this pricing is below market pricing for the equipment required and below previous prices for similar efforts due to the large quantity of equipment being purchased for this effort. Specific review of pricing was conducted on vendors proposal (see tabs HQ through Region 10, columns D (manufacturers list price) against column E (vendors non-recurring price) of each equipment tab. Pricing for all equipment was evaluated as discounted from vendors list price and from previous EIS pricing.

(6) Any other facts supporting the justification.

The network equipment upgrades and installs referenced above are required to maintain HUDs cybersecurity posture as end-of-life equipment will not receive software and or hardware updates needed to address cybersecurity threats. In addition, the addition of WIFI to all HUD offices is critical to enabling HUD to operate effectively in a hybrid work environment as well enabling public interaction at HUD offices in person by providing guest WIFI.

(7) A statement of the actions, if any, the agency may take to remove or overcome any barriers that led to the exception to fair opportunity before any subsequent acquisition for the supplies or services is made.

The Contracting Officer has confirmed that market research was conducted to ensure capabilities that exist in the marketplace are not cost effective versus using the current contractor to perform these functions. This effort includes both purchase of equipment and support as well as integration and installation of equipment to match the current HUD network configuration. It would not be cost effective to utilize another vendor to install and integrate this equipment in the existing HUD network. In the future, fair opportunity will be afforded by issuing a competitive solicitation for future refreshes and equipment installs. The value of the contract will be sized appropriately to meet all refresh requirements and projected new installations of existing infrastructure. Refreshes will be conducted on a yearly basis as per industry standard replacement guidelines.

(8) The contracting officer’s certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

This justification is accurate and complete to the best of the Contracting Officer’s knowledge and belief. See HUD Form Limited Source Justification - Governmentwide Acquisition Contract

(GWAC) or Multi-Agency Contract (MAC) Orders Exceeding the Simplified Acquisition

Threshold for the Contracting Officer’s Certification, Part 2.

(9) Evidence that any supporting data that is the responsibility of technical or requirements personnel (e.g., verifying the Government’s minimum needs or requirements or other rationale for an exception to fair opportunity) and which form a basis for the justification have been certified as complete and accurate by the technical or requirements personnel.

The program office technical personnel have reviewed technical proposal in response to governments requirements and have found it to be complete and accurate. Technical personnel are the HUD OCIO, Infrastructure and Operations Office, Unified Communications Division.

See HUD Form Limited Source Justification - Governmentwide Acquisition Contract

(GWAC) or Multi-Agency Contract (MAC) Orders Exceeding the Simplified Acquisition

Threshold for the Program Office Official’s Certification, Part 1.

(10) A written determination by the approving official that one of the circumstances in paragraphs (b)(2)(i)(A) through (E) and (G) of this section applies to the order.

Based on the above, I hereby determine that in accordance with FAR 16.505(b)(ii)(B), that an exception to Fair Opportunity is necessary and justified.

Dwayne Gist

Contracting Officer