Part 8 Limited Sources JA_Over SAT-Tech for Ag Security Plan - Redacted.pdf

United States Department of Agriculture Limited Sources Justification

For an Order/BPA Exceeding the Simplified Acquisition Threshold

FAR 8.4 Ordering under the Federal Supply Schedule (FSS)

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 single award Blanket Purchase Agreement (BPA) under the GSA Multiple Award Schedule (MAS), Information Technology (IT) for Palantir Platform current and future commercial solutions, including core software, data, compute infrastructure, and ancillary support services, such as software modifications, auxiliary modules, engineering services, and training in direct support of the National Farm Security Action Plan

(NFSAP).

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

The BPA will provide the specialized software licenses, configuration services, integration support and operational capabilities necessary to design and deploy fully interconnected digital environments supporting NFSAP implementation.

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 Palantir Federal Cloud Service (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 consolidation of complex data systems and environments into a unified platform which enables rapid deployment of AI functionality. This capability includes integration with key user data previously submitted by applicants for access of USDA services to reduce overall application and processing times and to automate data collection and extraction from forms to seamlessly integrate existing USDA data sources to conduct key security checks and expedite benefits processing for eligible applicants. Real-time data synchronization with existing producer and entity management systems will ensure accurate applicant information to inform and facilitate speedier and more accurate application processing and payment disbursement where applicable.

Other key technical requirements include implementing real time and continuous compliance monitoring with automate risk or alert generation or 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.

The BPA will include a one-year base period, with two (2) one-year option periods for a total potential ordering period of three (3) years. The estimated BPA ceiling is $300 million.

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 establishing this BPA with Palantir, the Government can avoid fragmented contracting efforts, increase efficiencies, ensure transparency, cost efficiency, scalability, and rapid access to Palantir's capabilities with maximal purchasing power. This consolidated approach is critical to maximizing the return on the USDA’s investment and is not achievable through individual contracts.

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 as part of the Administration’s mandates under National Security Memorandums (NSM)-16 and NSM 22.

Alternative vendors lack Palantir’s comprehensive integration with existing USDA’s systems, its tailored data ontology, and its validated operational performance.

6. A determination by the ordering activity Contracting Officer (CO) that the order represents the best value consistent with FAR 8.401(b), and the GSA established ordering procedures outlined in GSAM Subpart 538.71, particularly GSAM 538.7102-2(d)(2).

The Contracting Officer will determine that the anticipated BPA 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, 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 agricultural transactions, 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. Issuing this BPA is necessary to ensure continuity of critical NFSAP capabilities. Any delay or forced substitution would result in significant operational, security and compliance risks including disruption in the ability for USDA’s security monitory and eligibility processing operations.

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.