Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

FOR OFFICIAL USE ONLY

25 May 2018 FOR OFFICIAL USE ONLY Page 1 of 7

NOTE: If a Justification was approved for the preceding acquisition, a copy of the approved Justification for the predecessor action must be included in the staff package for approval of the instant Justification. This applies to Justification staff packages that are submitted for review and approval at a level above the contracting officer. The predecessor Justification will be used as a reference document by the approving official.

Is this a new or amended J&A Document? New Amended ( Prior to Award Only! )

Is this a Bridge Action as defined in the Yes No

Funding level for this acquisition:

Contracting Activity: 502 CONS/

Purchase Request / Local ID Number:

Program / Project (and PE, if applicable): 37TH TRW iPad mini and Otterbox Cases

Program Type (PEO or Other Contracting): Other Contracting

Authority: AFFARS 5313.501 - 10 U.S.C. 2302b, Implementation of Simplified Acquisition Procedures (41 U.S.C. 1901)

AFFARS 5313.501 - 10 U.S.C. 2304a, Special Emergency Procurement Authority (41 U.S.C. 1903)

Estimated Contract Cost (including options): Justification Type: Class Individual

COORDINATION (AFFARS 5306.304(a) )

APPROVAL (AFFARS 5306.304(a) )

Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

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I. Contracting Activity.

US Air Force, 502D Contracting Squadron/PKB

1655 Selfridge Ave, Building 5450

Joint Base San Antonio (JBSA) Lackland, TX 78236

II. Nature and/or description of the action being processed.

This brand name justification is in accordance with (IAW) FAR Part 13.501(a)(ii) under the authority of 41 U.S.C. 1903 - Special documentation requirements. This action will be awarded as a new firm fixed priced contract.

iPad mini. The 2nd AF and 37 TRW units will use the same iPad mini to support the BMT students and students under the 37 TRW for the 2nd AF Tier 3 transformation.

III. Description of supplies/services required to meet agency needs.

The purchase of 1,900 Apple iPad mini 7th Generation Tablet 128 GB with wi-fi only and Otterbox cases with a firmed fixed price contract vehicle. The total estimated value of the acquisition is and the estimated delivery date is 90 days after receiving order (ARO).

IV. Statutory authority permitting other than full and open competition.

IAW FAR Part 13.501(a)(ii) under the authority of 41 U.S.C. 1903 - Special documentation requirements and under the procedures of FAR part 6.302-1(c) - Brand Name Descriptions.

V. Demonstration that the contractor's unique qualifications or nature of the acquisition requires the use of the authority cited above (applicability of authority).

BMT support squadrons have implemented a multi-million-dollar infrastructure communications upgrade that provides backbone support for high-bandwidth, real-time learning experiences built around the iPad mini's for the DAF BMT mission to graduate our future warfighters on time/schedule. The iPad mini are a standardization across BMT and subsequent training squadrons. Being standardized, both programs currently have the approved device IAW CIPS# 502 ABW-2025-04039 for the necessary software. The infrastructure was tailored for iOS device connectivity and favors the iPad mini's compact form factor and efficient past performance. With over 8,000 iPad mini devices already in use, CSTs, MTI, and MTL who possess existing familiarity with LMS content being delivered on iPad mini will have an increased learning curve and reduction in productivity. The following justification factors should also be considered:

A. iPad mini Compatibility with Established Mission LMS Systems:

• The iPad mini's support Airman Learning Platform LMS software that enables Airmen and Guardians the ability to gain the basic knowledge, mindset, skills and abilities manifested in BMT training

• Apple iPad mini offer superior compatibility with existing LMS platforms through native support for secure browsers and legacy DAF LMS mobile applications.

• Digital Curriculum Delivery - All eight BMT line squadrons and nine formal courses are now fully digitized and optimized for adaptive learning platforms like Airman Learning Platform (ALP) which is integrated with the iPad mini's.

• iPad mini consistently ensure smooth operation of BMT and Technical Training SCORM-compliant and HTML5-based training content, which many of our current DAF LMS systems rely on

• The current iOS device inventory maintains broad compatibility with federal agency single sign-on (SSO) systems and identity providers (e.g., PIV/CAC, SAML 2.0, Okta, etc.) necessary for our BTM trainees and mission partners

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B. Seamless Integration with AETC Managed IBM MaaS360 and ABM

IBM MaaS360 offers full feature support for iOS devices, including:

• Remote provisioning via Apple Business Manager (ABM) and Device Enrollment program (DEP)

• Scalable Device Management - The use of MaaS360 enables efficient, centralized control over thousands of devices --including the 750 instructor iPad mini and 8,000 trainee tablets currently in use

• Enforced FIPS-compliant security policies, such as encryption at rest, VPN tunneling, and remote data wipe

• DAF agency-wide app deployment and version control

• iPad mini support zero-touch enrollment, significantly reducing IT burden and enabling compliance at scale

C. Security and Federal Compliance

Apple iPad mini meet or exceed numerous federal cybersecurity standards, including:

• Enforced FIPS-compliant security policies, such as encryption at rest, VPN tunneling, and remote data wipe

• FIPS 140-2 validated cryptographic modules

• NIST SP 800-53 and FedRAMP Moderate control alignments

• Full disk encryption, biometric security (Face ID/Touch ID), and integration with identity credentialing systems

• Devices will be deployed in accordance with agency policy, ensuring data protection, device accountability, and controlled access

D. Cost Efficiency and Lifecycle Value

• iPad mini demonstrate a high residual value and extended iOS update lifecycle (often >5 years), lowering the total cost of ownership

• Charging stations & storage lockers are already configured for iPad mini devices, reducing the need for retrofitting or new purchase

• Maintenance workflow already supports Apple device lifecycle --from provisioning to decommissioning

• Existing inventory includes iPad mini -compatible accessories (e.g., Lightning cables, stands, protective cases), which minimizes additional procurement cost

• Their reliability and battery performance reduce service desk incidents and operational interruptions

• Centralized iOS app management lowers software licensing waste and enables app rationalization across user group

• iPad mini integrates seamlessly into BMT's existing Apple-based mobile framework --requiring no adaptation or interoperability fixes

E. Enhanced User Experience and Accessibility

• iPad mini improve learning outcomes with intuitive interfaces and strong multimedia support (ideal for LMS video, quizzes, and interactive modules)

• Built-in accessibility tools ensure compliance with Section 508 of the Rehabilitation Act

• iPad mini's compact size and lightweight design is ideal for BMT students and mission partner training operations

• The iPad mini offers rapid response, intuitive interaction, and native app compatibility to support advanced learning platforms and dynamic content delivery

F. Risks of Changing the Current iPad mini Device Ecosystem Instructional Continuity:

• Training Managers would need to redesign device integration plans, retrain Military Training Instructors (MTIs), and reconfigure lesson plans across all squadrons

• With over 8,000 iPad mini devices already in use, CSTs, MTI, and MTL who possess existing familiarity with LMS content being delivered on iPad mini will have an increased learning curve and reduction in productivity

• Current curriculum and adaptive platforms are optimized for Apple iOS, meaning significant software redesign or replacement would be required

• Cognitive Load on Trainees - BMT trainees already face demanding schedules --introducing a new iOS (Windows or

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Android) would add unnecessary friction and slow down onboarding

• Learning curve differences impact early training momentum and cognitive readiness for mission-critical skills

• Support System Overhaul - IT teams would have to maintain dual knowledge bases, troubleshoot new hardware-software relationships, and expand support infrastructure

• Existing Apple device workflows under MaaS360 would either need duplication or full replacement --both costly and inefficient

• Cost vs. Benefit-The return on investment for switching platforms would be negative in the short to medium term due to retraining, app redevelopment, and loss of operational familiarity

• MaaS360's current deployment already demonstrates scalable Apple device control --with minimal additional training or investment required.

• Cross-platform setups require parallel workflows for app configuration, access management, and policy enforcement.

• A single iOS ecosystem streamlines all of this, reducing cognitive load on instructors and IT staff alike.

VI. Description of efforts made to ensure that offers are solicited from as many potential sources as practicable.

The following were efforts to ensure offers are solicited to as many potential sources as possible. Sources checked are

(1) Mandatory sources, (2) GSA and Mandatory Use Policy, (3) Government Contracts, and (4) Small Business. To include information in Section VII and Section VIII in regards to providing maximum competition.

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

There is a reasonable expectation that the Government will receive more than three responses. Market research has identified contractors on the NASA SEWP that have the opportunity to provide a quote, Apple's Authorized distributors list of 84 contractors, and 28 contractors that submitted a quote from the previous requirement. In total, market research has identified over 100 contractors being able to provide the requirement.

Therefore cost to the Government will be fair and reasonable IAW FAR 13.106-3 Award and documentation. Based upon comparison of previously proposed price and previous Government and commercial contract prices, proposed prices with independent Government cost estimates received, and prices obtained through market research for the same or similar items, the contracting specialist determines anticipated cost to the Government will be fair and reasonable. This will ensure that costs maximize the value of limited funds and comply with legal and ethical standards.

VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

(1) Mandatory Sources:

Federal Prison Industry (Unicor) https://www.unicor.gov/ScheduleOfProducts.aspx and Lighthouse for the Blind (AbilityOne) https://www.abilityone.gov/procurement_list/index.html were checked to see if the requirement was available. Unfortunately, both Unicor and AbilityOne are able to provide the requirement.

(2) GSA:

General Services Administration (GSA) programs were checked IAW AFMAN 17-1203 that states that IT hardware has to be checked to see if the requirement can be procured from CCS-3 or 2GIT. Since the requirement is not on either program, a waiver was signed stating the requirement can be procured elsewhere. GSA also states that iPad mini are not a TAA compliant product. Therefore, GSA is unable to provide the requirement.

TAA Compliance: IAW FAR part 25.103, exceptions, "Information Technology that is a commercial product. The restriction on purchasing foreign end products does not apply to the acquisition of Information technology that is a commercial product, when using fiscal year 2004 or subsequent fiscal year funds (section 535(a) of Division F, Title V, Sole Source (Including Brand Name) Justification - Simplified Procedures for Certain Commercial Items

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Consolidated Appropriations Act, 2004, and similar sections in subsequent appropriations act). IAW FAR part 2.101, Information Technology "means any equipment, or interconnected system(s) or subsystem(s) of equipment, that is used in the automatic acquisition, storage, analysis, evaluation, manipulation, management, movement, control, display, switching, interchange, transmission, or reception of data or information by the agency. Therefore, when procuring this requirement, iPad mini do not need to be TAA compliant.

(3) Government Contracts:

N00244-18-D-0003 FA3016-20-F-0245 (Awarded in 26 June 2020 for 750 iPad mini and Cases): This requirement was awarded using the Navy's Spiral 3 MAC. When asked why cellular services were not included in the award when cellular services are required when using the Spiral 3, the Contract Specialist who awarded the task order stated it was because the services for the 750 iPads were already purchased using the Spiral 3 GPC procedures. Since both (services and products) were purchased with the Spiral 3, it was allowed for the task order to be awarded without the services as it was simple enough to connect the iPad mini to the service accounts. The Spiral 3 would not be used as services were not required due to the iPad mini having Wi-Fi capability and utilizing the WiFi already provided by the surrounding training facilities.

(4) Small Business:

SBA Dynamic Search

Using SBA dynamic search the below are what is listed as set-asides for this NAICS code. Overall the NAICS code that was used is 334111 and the keyword used "Apple iPads" SBA certified as 8(a) or 8(a) JV, HUBZone, WOSB, EDWOSB, VOSB, or SDVOSB, and designated small in NAICS code(s) 334111. SBA dynamic search was able to refine the search to 26 vendors with dual certifications. They are as follows:

WOSB - 19

HUBZone - 12

EDWOSB - 5

VOSB - 5

SDVOSB - 5

8(a) or 8(a) Joint Venture - 1

Another search was done with the keyword used "tablet" as all iPad mini and tablets are categorized as tablets.

Small business containing "tablet" in their profile, SBA certified as 8(a) or 8(a) JV, HUBZone, WOSB, EDWOSB, VOSB, or SDVOSB, and designated small in NAICS code(s) 334111. SBA dynamic search was able to refine the search to 38 vendors with dual certifications. They are as follows:

8(a) or 8(a) Joint Venture - 4

HUBZone - 7

WOSB - 10

EDWOSB - 3

VOSB - 23

SDVOSB - 23

Additionally, based off a previous requirement FA3016-24-P-0129, there were 28 contractors that provided a quote to the solicitation. Out of the 28 contractors, the following is the break down for socioeconomic set-asides:

Small Business: 19

Hubzone: 1

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EDWOSB: 1

WOSB: 2

SDVOSB: 5

Authorized Distributor's list

According to Apple's website, https://ecommerce.apple.com/content/b2b/static-v2/en/us/default/federal.html, have a list of 84 contractor's that are able to provide the requirement. However, the list of distributors does not specify if any are small businesses. Additionally, although Apple states that the link above is their distributor list, the website does not specifically state that it's an authorized distributor list. Therefore, this list of vendor's does not qualify as an authorized distributor list.

IAW FAR 19.203(c) the Government has enough evidence to identify a particular small business set-aside. Therefore, the Government intends to solicit this requirement for Service Disabled Veteran Own Small Business (SDVOSB) set aside as a firm fixed price contract.

Non-manufacturing Rule:

Per the SBA and IAW FAR part 19.505, the government researched if manufacturing rule applied. A business may qualify as a non-manufacturer if it meets the all of following criteria:

- does not exceed 500 employees

- is primarily engaged in the retail or wholesale trade and normally sells the type of products being supplied

- will supply the end products of a small business manufacturer or processor made in the United States, or obtains a waiver of such requirement.

The SBA has a Non-manufacturing rule class waiver list that they provide to waive the manufacturing rule. NAICS code 334111 was listed as being waived for computers and tablets. Therefore, small businesses are able to provide this requirement to the Government.

Previous Requirements:

FA3016-24-P-0129 - 100% small business -

FA3016-21-P-0104 - 100% small business -

CONCLUSION:

With the above information, market research indicates that this requirement be solicited on www.sam.gov for SDVOSB set-aside. This requirement has a reasonable expectation of obtaining at least two quotes from responsible small business contractors. The Government will solicit this requirement IAW FAR part 12 and the streamlined acquisition procedures under FAR part 13.5. A firm fixed price purchase order will be awarded to the contractor found to have the lowest price and technically acceptable (LPTA) offer.

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IX. Any other facts supporting the use of Other Than Full and Open Competition.

The iPad mini are a standardization across BMT and subsequent training squadrons. Being standardized, both programs currently have the approved device IAW CIPS# 502 ABW-2025-04039 for the necessary software.

Alternatives Considered - Other platforms (Windows and Android tablets) were evaluated but deemed less suitable for the following reasons:

• Costly reconfiguration of iPad mini established support infrastructure• Support staff are experienced in the Apple iOS, streamlining troubleshooting and minimizing training overhead• Waste of thousands of man-hours already invested for in-house Client Support Technicians (CST) performing Apple device support administration like, iPad mini device configuration, patching, inventory management and rollout

• BMT CSTs are trained with MDM and ABM configurations integration and centralized

• control for BMT and DAF issued iPad mini

• Faster boot-up and app responsiveness compared to many Android and Windows tablets, specially in mission-critical scenarios

• Battery performance is optimized for long-use, with lower drain under typical workloads than Surface or Android equivalents

• Supporting multiple operating systems means redundant licensing, device procurement, tech support contracts, and platform-specific training has a significant financial impact

• Maintenance, updates, and security patches across varying systems drastically increase labor and downtime costs

X. List of any sources that expressed, in writing, an interest in the acquisition.

No contractor's have expressed interest.

XI. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition before making subsequent acquisitions for the supplies or services required.

The government aims to promote competition by exploring alternative solutions and identifying capable sources.

However, based on the fact that 37TRW has invested in and currently using this item, the government has concluded that is only one brand capable of meeting the government needs seamlessly and without risk resulting from degradation of platforms currently in use. The 37 TRW will continue to validate if other platforms can be included or meet the agency's requirements.

XII. Certification by the Contracting Officer.

As evidenced by Ms. Belinda Tindal signature, the Contracting Officer has determined this document to be both accurate and complete to the best of her knowledge and belief

XIII. Certification by the technical/requirements personnel.

As evidenced by signature, the Technical and/or Requirements Subject Matter Expert has certified that any supporting data contained herein, which is there responsibility, is both accurate and complete.