Part 8 Limited Sources JA_Over SAT signed.pdf

United States Department of Agriculture Limited Sources Justification

For an Order/BPA Exceeding the Simplified Acquisition Threshold

FAR 8.4 Federal Supply Schedules (FSS) Multiple Award Schedule Program

Control No. (if applicable) ______________________

1. Identification of the agency and the contracting activity.

1a. Requesting Activity Agency: USDA Office of the Chief Information Officer 1b. Contracting Activity: USDA Office of Contracting and Procurement, Procurement Operations Division

2. The nature and/or description of the action being approved.

This limited source justification supports the establishment of a firm fixed-price delivery order under the GSA Multiple Award Schedule (MAS), Information Technology (IT) for Palantir Platform solutions in support of USDA’s Return to Office Tool.

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

The delivery order will provide specialized software licenses, configuration services, integration support and operational capabilities necessary to continue the design and full deployment of the Return to Office Tool.

USDA OCIO requires advanced data integration capabilities to consolidate information from multiple sources, real-time analytics to optimize space utilization and employee seat assignments, and robust security compliance to protect sensitive organizational data. These features are critical because they enable efficient decision-making, ensure compliance with federal regulations, and enhance overall operational effectiveness.

This requirement is for mission-critical capabilities, including real-time data fusion, operational planning, logistics optimization, and intelligence analysis, all delivered within secure, accredited internal USDA and mission partner network environments spanning FedRAMP High and higher standards for Controlled Unclassified Information (CUI) and National Security Systems (NSS) information, such as DOD’s Impact Levels (IL)-4 and IL-5.

The diverse configurations of the Palantir Platform encompassing advanced AI/ML capabilities, data integration, operational planning tools, and secure cloud services consistently operate across classified and unclassified environments. This consistent security posture is enabled by leveraging the PFCS and Software as a Service (SaaS) offering, which are already accredited to meet stringent security requirements.

Palantir platform’s existing accreditations ensure compliance with these policies, eliminating the need for additional efforts and costly delays and expenses that would occur if other vendors had to obtain equivalent certifications.

The commercial product, which already meets the USDA's security and compliance criteria and holds a USDA ATO, allows for speedy implementation to meet USDA mission needs in a matter of days, not years.

Specific technical requirements include, but are not limited to, implementing real time and continuous compliance monitoring with automate risk or alert generation of regulatory compliance officers and other personnel upon detection of threats or anomalies, in addition to establishing complete transaction logging and compliance documentation capabilities across all integrated tools and workflows for regulatory reporting and oversight activities. This includes implementing standardized integration protocols and Application Programming Interfaces (APIs) that maintain existing security controls, audit trails, and data privacy protection across all system interfaces.

4. Identification of the authority for limiting sources.

This statutory authority permitting the use of limiting sources is RFO 8.401 (b), pursuant to the ordering procedures established by GSA and implemented under GSAM Subpart 538.71, specifically 537.7104-4, Items peculiar to one manufacturer.

5. Supporting rationale demonstrating the unique qualifications of the proposed contractor or the nature of the action requiring the use of the authority.

Palantir is the only vendor capable of providing the required capabilities in Section 3 above without unacceptable delays and significant duplication of effort to the Government.

Specifically, accreditation efforts for another vendor would introduce substantial delays, requiring accreditation and system rebuilds, leading to unacceptable operational duplicative effort, and impact on mission disruption.

This integration encompasses a uniquely tailored framework developed through significant collaborative efforts with USDA mission area personnel. Achieving the necessary accreditations for FedRAMP High, DoD Impact Levels (IL)-2, IL-4, IL-5, and IL-6, as well as mission partner environment, would require a new contractor to invest significant time and resources. Full accreditation at the DoD Impact Level 5 (IL5), as defined in the US Department of Defense (DoD) Cloud Computing Security Requirements Guide (CC SRG), which is also based on NIST 800-53.

By proceeding with this Palantir order, the Government can avoid fragmented contracting efforts, increase efficiencies, ensure transparency, cost efficiency, scalability, and rapid access to Palantir's capabilities.

Palantir satisfies the following compliance frameworks which are part of the overall Palantir platform solution:

Service Organization Control (SOC):

SOC 1

SOC 2

SOC 3

Alignment with FISMA High.

Certifications in the following:

ISO/IEC 27001:2022

ISO/IEC 27017:2015

ISO/IEC 27018:2019

ISO/IEC 9001:2015

Palantir Technologies can deliver the high volume and scope of the work required and with the necessary interoperability capabilities needed for both existing and future systems to strengthen and maintain key USDA agricultural systems that are designated as critical infrastructure.

Additionally, Palantir’s agile development approach enables rapid adaptation to evolving requirements, a capability that has not been demonstrated by other developers. This speed and flexibility are essential for meeting the dynamic needs of USDA OCIO, ensuring that the software evolves alongside organizational demands.

Salesforce and similar applications have not demonstrated a product that has advanced data integration capabilities or the agility required to address rapidly changing requirements. Palantir is the only software that offers all of the features that OCIO requires, making it the sole solution capable of meeting USDA OCIO’s facility and employee seat management needs effectively.

6. A determination by the ordering activity Contracting Officer (CO) that the order represents the best value consistent with FAR 8.404(d).

The Contracting Officer will determine that the anticipated delivery order will represent the best value to the Government in accordance with the established ordering procedures. A fair and reasonable price determination will rely on analysis of the contractor’s GSA Schedule pricing, comparison to historical pricing paid by the Government and pursue additional pricing discounts.

7. A description of the market research conducted among schedule holders and the results or a statement of the reason market research was not conducted.

Based upon market research, while there are several companies that provide data analytics and integration platforms, Databricks, Snowflake, IBM, SAS, SalesForce, and Alteryx, none offer the combination of capabilities, enterprise scale data fusion, real-time analytics, compliance monitoring and integration with existing USDA systems that Palantir provides. Palantir is the only vendor capable of integrating USDA’s diverse data sources into a unified platform, providing real-time monitoring of facility and employee seat management, maintaining existing security controls across all integrated tools and supporting the highly specialized workflows within the USDA’s systems. Because these unique qualifications are essential to meeting USDA’s mission critical requirements, the capabilities and solutions offered by Palantir represent the most viable option for achieving USDA objectives.

8. Any other facts supporting the justification.

While other MAS vendors offer analytic or integration services, none provide a platform or service suite capable of delivery the required mission-critical, real-time system integration capabilities or interoperability with existing USDA Palantir components.

9. A statement of actions the agency may take to remove or overcome any barriers to competition if subsequent acquisitions are anticipated.

USDA will maintain unlimited rights and ownership to all Government data, documents, and computed data properties, which will enable future competition when market research identifies competitors able to meet the necessary requirements.

Certifications & Approval

Supporting data which form the basis for and included in this justification are certified accurate and complete.

Christoper Alvares Chief Data & Artificial Intelligence Officer

The information contained in this Limited Sources Justification is certified accurate and complete to the best of my knowledge and belief.

Ben Alpers Contracting Officer

Additional Reviews & Approvals

Signatures are required at each threshold up to the total estimated dollar value of the acquisition

Advocate for competition for the procuring activity (if over $750,000, but not exceeding $15 million). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as advocate for competition for the procuring activity/MASCO, I hereby approve this justification. If required, my approval constitutes clearance for submission to the Head of the Procuring Activity.

Insert Name of the Procuring Activity Competition Advocate/MASCO Title:

Procuring Activity Advocate for Competition

Head of the Procuring Activity (if over $15 million, but not exceeding $75 million). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, unless additional approvals are required as prescribed below, as Mission Area- Senior Contracting Official, I hereby approve this justification. If required, my approval constitutes clearance for submission to the Senior Procurement Executive.

Hilary (Cole) Erickson Head of the Procuring Activity United States Department of Agriculture

Senior Procurement Executive of the Agency (if over $75 million). I have reviewed this justification and find it to be accurate and complete to the best of my knowledge and belief. Therefore, as the Senior Procurement Executive, I hereby approve this justification.

Donald W. Baker, Jr.

Senior Procurement Executive United States Department of Agriculture

Notes and Guidance. Delete these notes prior to finalizing document for signature.

Pursuant to FAR 8.405-6, orders/BPAs under Federal Supply Schedule Contracts are exempt from the competition requirements of FAR Part 6; however, ordering activities may restrict consideration of Schedule Contractors. Circumstances justifying limiting the sources include:

a) An urgent and compelling need exists and following the procedures would result in unacceptable delays;

b) Only one source is capable of providing the supplies or services required because they are unique or highly specialized; or

c) In the interest of economy and efficiency, the new work is a logical follow-on to an original Federal Supply Schedule order, provide the original order was place in accordance with applicable Federal Supply Schedule procedures (e.g. competed).

Brand Name. Items peculiar to one manufacturer can be a particular brand name, product, or feature of a product, peculiar to one manufacturer. A brand name item, whether available on one or more schedule contracts, is an item peculiar to one manufacturer. Brand name specifications shall not be used unless the particular brand name, product or feature is essential to the Government’s requirements and market research indicates other companies’ similar products, or products lacking the particular feature, do not meet, or cannot be modified to meet the Agency’s needs. See below for posting of brand name requirements.

Program personnel are advised to work with contracting personnel early on in order to promote and provide for full and open competition amongst schedule holders to the maximum extent practicable. In circumstances permitting limited sources, program personnel shall provide necessary information to contracting personnel to support and document the circumstances limiting competition, including use of brand name specifications.

Posting. Contracting Officers shall make justifications publicly available (excluding brand name) within 14 days after award, in accordance with FAR 8.405-6(a)(2) and FAR 5.301. The justification shall be posted at the GPE (https://sam.gov/) and must remain posted for a minimum of 30 days. In the case of unusual and compelling urgency, justifications shall be made publicly available within 30 days after contract award in accordance with FAR 8.405-6(a)(2)(ii). Brand name justifications shall be posted with the solicitation to GSA’s e-Buy in accordance with FAR 8.405-6(b)(3)(B).

Screening. Before posting this Justification, in accordance with FAR 8.406-6 and 24.2, the Contracting Officer is responsible to redact any information that is exempt from disclosure under Freedom of Information Act or information proprietary to the contractor.

Signatures. After review and completion by the Program Office and Contracting Officer, the Word document shall be converted to an Adobe PDF file, and then routed for electronic signatures.

Signature blocks shall include dates.

https://sam.gov/