Lumen Logical follow-on v2_Redacted.pdf

Justification for an Exception to Fair Opportunity

1) Identification of the agency and the contracting activity

Federal Maritime Commission Office of Management Services Washington, DC

2) Nature and/or description of the action being approved.

The Office of Information Technology requests approval to issue a logical follow-on Task Order with Lumen Technologies to extend Enterprise Infrastructure Solutions (EIS) services currently provided under Task Order 65310221F00006 for one year effective 9/30/2026 – 9/29/2027.

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

Enterprise Infrastructure Solutions is the federal government’s recommended contract vehicle for Best-in-Class enterprise telecommunications and networking solutions. EIS includes service-related labor and equipment, wireless, cloud and managed cyber-security solutions.

The scope of FMC’s requirement involves telecom (voice and data) services consisting of:

IPVS – SIP trunking o 80 concurrent call paths o ~184 DID numbers

TFS – 2 toll free numbers MTIPS – 1000 Mbps Ethernet circuit (1000 Mbps port) MNS – Managed Network Services Secure Remote Access (Zscaler) DDoS (Distributed Denial of Service) protection o Monitoring o Attack stoppage o Remediation

Estimated Value: $592,754.31

(4) Identification of the Exception to Fair Opportunity and Supporting Rationale

Authority: FAR 16.505(b)(2)(i)(C) – Logical Follow-on

The existing critical services that will continue to be performed under this follow-on Task Order to maintain continuity of services are:

Network and Voice: IP Services (IPS). IP Voice (IPVS), Managed Network Service (MNS), Virtual Private Network Service (VPNS), and Toll-Free Services.

Security: Managed Trusted Internet Protocol Services (MTIPS) and Managed Security Service (MSS)

Infrastructure: Co-located Hosting (CHS). Ethernet Transport (ETS), and Cable Wiring (CWS).

Currently, Lumen is the only provider with the established infrastructure and technical expertise required to sustain FMC’s existing EIS services without interruption and prevent a lapse in service.

Award of the one-year logical follow-on to Lumen is in the interest of economy and efficiency while FMC completes the planned competitive acquisition for these services.

Transitioning the requirement to another EIS contractor for the limited interim period would require the replacement of data network router equipment, networking configuration changes to support firewall rules/remote access/Virtual Private Networks, VoIP equipment, and the installation of a new 1 GIG circuit.

Because the services include FMC's network connectivity, voice services, secure remote access, managed security services, and DDoS protection, interruption during transition could adversely affect FMC's ability to maintain network operations and secure access to agency systems. Maintaining the existing services with Lumen during the limited follow-on period avoids a 2 to 4 months new circuit installation, changes to public IP Address range, and several modifications on how FMC communicates with cloud services.

The original EIS task order was competed among eligible EIS contract holders, and all eligible awardees were provided a fair opportunity to be considered for the original order.

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

The contracting officer determines that the anticipated price(s) will be fair and reasonable based on EIS established contract rates.

(6) Any other facts supporting the justification.

In the interest of economy and efficiency, this action is a logical follow-on to an order previously issued under the EIS contract, under which all awardees were given a fair opportunity to be considered for the original order.

(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.

FMC will competitively acquire the requirement during the one-year logical follow-on period and provide eligible contract holders a fair opportunity to be considered for the subsequent order. The intent to issue a logical follow-on will be posted in Contract Opportunities in SAM.gov.

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

(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.

(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.

(C) 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.

APPROVALS:

Proposed actions not exceeding $250,000, the CO’s certification will serve as approval.

Head of the Contracting Activity Competition Advocate

Proposed actions over $250,000, but not exceeding $500,000, the written approvals of the HCA and the agency CA are required. (CO-112).

Proposed actions exceeding $500,000, the written approval of the SPE is required.