Plum Retrofit Effort Justification for an Exception to Fair Opportunity - Redacted.pdf

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

1. Contracting Activity: Department of Veterans Affairs (VA) Office of Procurement, Acquisition, and Logistics Technology Acquisition Center 23 Christopher Way Eatontown, NJ 07724

2. Description of Action: This proposed action is for a Firm-Fixed-Price Delivery Order to be issued under the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Government-Wide Acquisition Contract (GWAC), for brand name Plum Laboratories (Plum) services and components in order to perform upgrades To existing brand name Plum Communications Cases.

3. Description of the Supplies or Services: VA Office of Information & Technology (OIT), Connectivity and Collaboration Services, Office of Emergency Management (OEM) has a requirement to retrofit and upgrade existing brand name Plum Enterprise ENT Cases (quantity of 165- Part Number ENT0007) with brand name services and components.

Upon completion, the cases will meet the same brand name specification as Plum Enterprise SR Mini with PCX (Star-link ready) (Part Number ENTSR0002). The brand name Plum Cases are the deployed emergency wireless, “on demand”, portable, and field deployable communications tool that provides communications support to medical centers, Community Based Outpatient Clinics (CBOCs), and VA sites when the VA Wide-Area Network (WAN) connection is impaired or lost. The Plum Case provides disaster response communications capabilities to maintain continuity of operations during natural disasters, civil unrest, or actions of violent extremism against civilian infrastructure. The ENTSR configuration integrates the storage and power distribution components required to support Starlink Mini network connectivity by enabling satellite backhaul when terrestrial communications networks are degraded. The Plum Case form factor for the ENTSR is approximately 21.96 inches by 13.97 inches by 8.98 inches at approximately 45 pounds.

As part of this upgrade proposed under this action, the required brand name services include the installation of brand name components including an additional electrical distribution harness, signal booster system, storage for Starlink Mini Hardware (device not part of this procurement), a 50 foot weatherproof ethernet cable, one additional year of Plum Care, and shipping of the Plum Case to the OEM’s facility and returned to VA for acceptance. As part of the upgrade, VA requires brand name Plum Care for each upgraded Case to provide comprehensive warranty coverage for all parts and labor related to the Plum Case upgrade. Additionally, Plum Care includes periodic software updates, software upgrade releases (minor and major), bug fixes, enhancements, and corrections to the software to ensure seamless operation and interoperability with the proprietary brand name Plum software and components. Furthermore, VA requires the capability to remotely manage and maintain these Plum cases.

Brand name Plum Case Retrofit Effort Control Number: VA-26-00048810

Also included in this requirement is an Optional Task for an additional (1) year of brand name Enterprise Network Cloud Management (NCM) license for each Plum Case upgraded, which shall co-term with the overarching footprint of licenses.

The Contractor shall coordinate shipment of the initial cases to be upgraded for receipt of the cases at Plum no later than 30 days from receipt of order. The period of performance for the upgrade of the cases will occur over a period of 12 months. Based on anticipated cadence and shipping times, VA anticipates that the total time from award to completion of all upgrades shall not exceed

4. Statutory Authority: Pursuant to Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) 16.507-6, the following brand name requirement is being justified and approved as an exception to fair opportunity under the statutory authority of Section 41 U.S.C. 4106(c)(2) as implemented by FAR 16.507-6(b)(2), entitled “Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized”.

5. Rationale Supporting Use of Authority Cited Above: Based on market research, as described in section 8 of this justification, only brand name Plum components and services will meet the Governments requirement for this upgrade.

VA currently owns 165 brand name Plum Cases which are used as a deployable communications tool by VA as part of the VA Office of Emergency Management, which were initially procured in fiscal year (FY) 2016 as part of a competitive acquisition to upgrade VA’s deployable emergency communications architecture. The brand name Plum Enterprise ENT Cases serves as the current deployable, portable communications solution which enables voice and high-speed data connectivity through cellular communications for locations experiencing loss of broadband, landline, or cellular communications networks caused by natural disasters or actions of violent extremism against civilian infrastructure. During FY 2026, VA identified a requirement to upgrade the currently deployed Plum Enterprise Cases (ENT0007) to align with current requirements for technical and functional requirements such as increased battery function/power and low earth orbit requirements. Based on the market research conducted, VA determined that upgrade of these existing cases to the specification of the Plum Enterprise SR Mini with PCX with Starlink Ready satellite communications (ENTSR0002) was the only solution that would meet the Government’s requirements.

Specifically, this upgrade will provide brand name Plum components and configurations which include, but are not limited to, an additional electrical distribution harness, signal booster, Star Link Mini power port, weatherproof ethernet cables (1EA @ 50’), and the customization and configuration of the case to allow for the necessary additional storage capabilities for the Star Link Mini hardware within the existing Plum Case. All components and configurations are based on proprietary information and engineering specifications. The introduction of hardware and software from another source would introduce an intolerable risk that the Plum Case would not function properly and provide needed communicators when facility communications loss has occurred. Furthermore, use of components other than those created or customized by Plum would not meet the fit, form or function specifications to ensure that the Plum Case remained operational and self-contained.

Additionally, only through upgrade of the existing brand name cases can VA meet the required power capabilities for these critical tools. For instance, the proprietary power distribution and voltage regulation system that is to be upgraded and incorporated as part of this effort allows the Starlink mini dish to be powered from the same proprietary Plum Power Bank (PPB) as the rest of the Plum Case components and antenna array without the use of another power source for the Starlink mini or additional alternating current (AC) adapter. This power regulation upgrade satisfies VA’s requirement for voltage without the use of additional, separate voltage regulators. This capability ensures uninterrupted communications when native power is lost, and communications failover occurs through the Plum Case ENTSR.

Further, VA has identified a requirement to expand mission capabilities in order to meet evolving mission requirements to maintain secure communications when cellular and landline communications have been compromised. While the currently fielded Plum Cases provides 4X4 Multiple-Input, Multiple-Output (MI-MO) communications capabilities which ensures VA can connect to two different cellular networks at the same time to ensure continuity and redundancy of operations by means of failover, it would not be usable in the event of a disaster where terrestrial cellular networks have been compromised. As such, VA must also incorporate components that meet the addition of low earth orbit communications capability.

Furthermore, VA has a requirement to maintain and manage the Plum Cases for these newly upgraded Plum Cases. Only Plum, as the Original Equipment Manufacturer (OEM), can provide these required services as the Plum Cases operate via proprietary code and configuration. That proprietary information is limited to Plum as the OEM, and VA does not have access to that technical data package. A responsible source would require access to not only the proprietary source code, but also to proprietary configurations and components, in order to provide the 24X7X365 technical support, warranty support and repairs, remote device management support, remote device optimization, and remote virtual training. Additionally, through the required Plum Care Warranty, VA is able to satisfy its requirement for remote access and maintenance via brand name Plum Cloud management. This functionality will allow VA to remotely manage the system and automatically detects and incorporates an attached Starlink mini into the communications architecture so that when cellular communications are lost, satellite communications are engaged.

The failure to use the OEM or an authorized reseller would require replacement of the current Plum Cases with a new solution while incurring additional support costs. This would introduce duplicative costs associated with the replacement of the cases, building new infrastructure models to support a new communications appliance, and the costs associated with maintenance, warranty, and technical support. VA estimates this cost to replace rather than upgrade the Plum Cases would be at a minimum of .

These costs do not include the ongoing and duplicative costs for maintenance support services beyond the first year which VA estimates to be in excess of per year. These costs fail to capture the necessary time for procurement of a new solution, training on use and deployment of a new solution, VA security testing, and management efforts involved in fielding a new solution in an efficient manner to support VA facilities when communications are impacted.

As such, failure to procure the brand name Plum components and services to complete the upgrade would have a real-world impact on the ability of VA to restore lost communications during a natural disaster(s) or other events that would disrupt normal communications. Further, this introduces patient safety and health risk concerns that are wholly unacceptable and avoidable. As such, VA must procure the brand name Plum Case upgrade services and components to ensure communications tools are upgraded and maintained so they can be deployed efficiently, effectively, and in an expeditious manner.

6. Efforts to Obtain Competition: Market research was conducted, details of which are in section 8 of this justification. This effort did not yield any additional sources that could meet the Government’s requirements. However, the undersigned VA technical representative determined that limited competition is available among authorized resellers for brand name Plum components and services. In accordance with RFO FAR 16.507-7(c)(1)(ii), this justification will be provided with the solicitation to all appropriate NASA SEWP V GWAC holders. Furthermore, in accordance with RFO 16.507-6(f)(1), the award notice for this action will be synopsized on the Contract Opportunities website and this justification will be made publicly available within 14 days of award.

7. Actions to Increase Competition: The Government will continue to conduct market research to ascertain whether there are changes in the marketplace that would enable future actions to be completed.

8. Market Research: The Government’s technical experts conducted market research starting in December 2025 and is being conducted on a continuing basis by reviewing technical documentation and vendor websites. As a result of this research, other OEMs such as Ericsson Cradlepoint, Peplink Communications Siera Wireless by Semtech, and RCN Technologies were considered but it has been determined that these brands do not meet the Governments interoperability and compatibility requirements with the existing Plum Cases as previously discussed in Section 5 of this Justification. Further, none of these solutions meet the functional and technical requirements, nor have access to the proprietary components or configurations to complete this task. Based on these market research efforts, the Government’s technical experts have determined that only brand name Plum components and services can meet all of VA’s needs.

The Contract Specialist conducted Market Research by reviewing the General Services Administration (GSA) Advantage website, the National Aeronautics and Space Administration (NASA) Solutions for Enterprise-Wide Procurement (SEWP) V Government-Wide Acquisition Contract (GWAC) website, and through review of similar products through a detailed web search starting in April 2025 and through June 2026.

One GSA Advantage vendor was identified and only provides new case options and does not provide the Plum Case Upgrade. A review of the NASA SEWP V has shown there are five (5) Service-Disabled, Veteran-Owned Small Businesses capable of providing the Plum Case Upgrade. As such, this action will be set aside to SDVOSBs in Groups B1, B2, C, and D under NASA SEWP V GWAC.

9. Other Facts: None

10. Technical/Requirements Certification

I certify that the supporting data under my cognizance, which are included in this justification, are accurate and complete to the best of my knowledge and belief.

11. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price to the Government for this contract action will be fair and reasonable based on a comparison of the successful quote to others received in response to the Solicitation.

Further, the successful quote will be compared with the catalogue pricing for the products under the apparent awardees NASA SEWP V GWAC contract, as items added to contract have already been determined to be fair and reasonable. Finally, the successful quote may be compared to the Independent Government Cost Estimate.

12. Contracting Officer Certification/Approval: I certify that this justification is accurate and complete to the best of my knowledge and belief.