Redacted EFO - GCP-Final.pdf

DEFENSE LOGISTICS AGENCY

HEADQUARTERS

8725 JOHN J. KINGMAN ROAD

FORT BELVOIR, VIRGINIA 22060-6221

Controlled by: DLA DCSO – Philadelphia (DCSO-P) CUI Category: PROCURE / SSEL Distribution/Dissemination Controls: FED ONLY

Controlled Unclassified Information (CUI)

Source Selection Sensitive Information - See FAR 2.101 & 3.104

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

UNDER FEDERAL ACQUISITION REGULATION (FAR) SUBPART 16.5

Multiple Award Schedule/Multiple Award Contract (MAC) Orders under MAC/Fair Opportunity, FAR 16.507

Upon the basis of the following justification, I hereby approve the issuance of the contractual action described below using an exception to fair opportunity, pursuant to the authority cited herein.

1. IDENTIFICATION OF THE AGENCY AND CONTRACTING ACTIVITY:

Requiring Activity:

DLA Information Operations 700 Robbins Avenue Philadelphia, PA 19111-5092

Contracting Activity:

DLA Contracting Service Office-Philadelphia (DCSO-P) 700 Robbins Avenue Philadelphia, PA 19111-5092

2. NATURE AND/OR DESCRIPTION OF THE ACTION BEING APPROVED:

This action is to issue a firm-fixed price Task Order (TO) against the Joint Warfighting Cloud Capabilities (JWCC) Indefinite Delivery/Indefinite Quantity Contract for Google Cloud Platform (GCP) services and associated technical support. This justification

DLA Contracting Services Office – Philadelphia (DCSO-P) SUBJECT: EFO – DLA Information Operations Google Platform and Google Capabilities Support authorizes and approves the use of other than full and open competition to award a Task Order directly to Google.”

3. A DESCRIPTION OF THE SUPPLIES OR SERVICES REQUIRED TO MEET

THE AGENCY’S NEEDS, INCLUDING AN ESTIMATED DOLLAR AMOUNT:

DLA requires the procurement of the Google Cloud Platform (GCP) cloud computing services and associated technical support provided by Google. These services are required to sustain, operate, and expand the existing DLA enterprise cloud environment hosted on GCP.

The required services include cloud hosting, architecture, engineering, implementation support, and performance monitoring to support the continued growth of DLA’s Google Cloud Platform (GCP), unified data backbone and fabric, advanced analytics, artificial intelligence (AI), and cybersecurity capabilities. It enables the development of new automated solutions for improved interaction with data powered by advanced AI, modernization of existing systems, and improved performance measurement across the enterprise.

Additionally, knowledge transfer, documentation, and on-the-job technical collaboration will be required to ensure designated DLA personnel are enabled to effectively operate, analyze, maintain, and sustain delivered capabilities and maintain operational continuity.

The total estimated value of this requirement is . The period of performance will consist of a 6-month base period from July 1, 2026 – December 31, 2026, with one (1) twelve (12) month option period 1 from January 1, 2027 - December 31, 2027, and one (1) six (6) month option period 2 from January 1, 2028 – June 30, 2028. The period of performance and option period(s) determination takes into account market stability and comparison of the time since award with the usual duration of contracts for such supplies and services.

4. IDENTIFICATION OF THE EXCEPTION TO FAIR OPPORTUNITY AND

SUPPORTING RATIONALE, INCLUDING A DEMONSTRATION OF THE

PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR THAT THE

NATURE OF THE ACQUISITION REQUIRES USE OF THE EXCEPTION

CITED:

Pursuant to FAR 16.507-6 and FAR 16.507-7(a), the action being approved is an exception to fair opportunity. This justification authorizes the use of other than full and open competition to award to Google LLC. The Google Cloud Platform (GCP) is a proprietary cloud environment owned and operated by Google. The Defense Logistics Agency (DLA) relies on tightly integrated, Google-native services including Big Query, Cloud Dataflow, Publish/Subscribe (Pub/Sub), Vertex Artificial Intelligence (AI), Gemini models, Cloud Storage, and Cloud Identity and Access Management (IAM), as well Google Distributed Cloud (GDC) air-gapped infrastructure. These services depend on Google-specific Application Programming Interfaces (APIs), data architectures, and managed execution environments that are not portable to other cloud providers.

As a result, transitioning to another provider would require a complete redevelopment of data pipelines, Artificial Intelligence/Machine Learning (AI/ML) workflows, and security configurations rather than a direct migration, causing substantial duplication of cost, schedule delays, and unacceptable mission risk.

Therefore, only Google’s platform can meet the requirement without significant disruption.

As the original equipment manufacturer (OEM), only Google has the proprietary rights, system-level access, and technical authority necessary to provide, maintain, and sustain the existing environment. The required engineering, architecture needed to operate, maintain, and sustain the existing environment. The Defense Logistics Agency (DLA) requires direct access to Google for engineering support, architecture changes, troubleshooting, and performance optimization. Authorized resellers do not have access to Google’s underlying infrastructure, internal configurations, or engineering teams, and cannot independently resolve platform issues or implement system-level changes. They must escalate issues back to Google, which adds delay, reduces visibility, and increases risk to mission-critical operations. For these reasons, only Google can provide the direct, system-level support and authority required to meet the Government’s needs.

Market research was conducted to identify potential sources capable of meeting the Government’s requirement. This research included a review of prior procurement history, including Solicitation No. SP4709-25-Q-2012, Contract No. SP4709-24-D-0051, Task Order No. SP4709-25-F-0062, awarded to Unity Technologies Corp.; Solicitation No.

SP4709-24-Q-1008, Contract No. SP4709-17-D-0023, Task Order No. SP4709-24-F-0069), awarded to Accenture Federal Services, LLC; Solicitation No. SP4709-24-Q-1008, Contract No. SP4709-17-D-0106, Task Order No. SP4709-24-F-0070), awarded to Coggins International; Solicitation No. SP4709-24-Q-1008, Contract No. SP4709-17-D-0109, Task Order No, SP4709-24-F-0071), awarded to EDO Consulting; Solicitation No. SP4709-25- Q-2013, Contract No. SP4709-24-D-0075, Task Order No. SP4709-25-F-0071), awarded to Credence Management Solutions Limited; Solicitation No. SP4709-25-Q-2009, Contract No. SP4709-24-D-0075, Task Order No. SP4709-25-F-0067), awarded to Credence Management Solutions Limited; Solicitation No. SP4709-21-Q-1023, Contract No. SP4709- 17-D-0023, Task Order No. SP4709-21-F-0088), awarded to Accenture Federal Services, LLC; Solicitation No. SP4701-22-Q-0031, Contract No. 47QTCA22D004D, Task Order No.

SP4701-22-F-0180), awarded to Advantaged Solutions Inc.; review of SAM.gov registrations and available industry capability information; evaluation of commercially available cloud service providers; and consultation with Defense Logistics Agency (DLA) technical personnel and IT architects with relevant experience.

The research focused on identifying providers capable of delivering cloud hosting, architecture, engineering, advanced analytics, artificial intelligence (AI), and cybersecurity support within the existing Google Cloud Platform (GCP) environment.

While previous procurement efforts successfully utilized third-party integrators to provide initial onboarding to the Google Cloud Platform (GCP), including environment setup and configuration, workload migration, infrastructure provisioning (compute, storage, and networking resources), identity and access management configuration, DevOps enablement, and ongoing managed services support for existing GCP workloads (including monitoring, maintenance, and operational sustainment), the requirement has since evolved. The current mission now requires GCP’s proprietary infrastructure, native services, and system-level access, which are only available through Google, the original equipment manufacturer (OEM). Third-party vendors and resellers do not have the ability to independently provide the services required.

The results of the market research determined that Google LLC is the only responsible source capable of meeting the Government’s requirement, due to its proprietary ownership of the Google Cloud Platform (GCP) and exclusive system-level access to the underlying infrastructure, native services, and integrated architecture. No other vendor or reseller possesses the technical authority, access, or capability to provide, replicate, or sustain these services within the existing environment.

Any transition to another cloud provider would require extensive reengineering, data migration, and system redesign, as the current environment would need to be rebuilt rather than migrated. This includes re-creating data pipelines, analytics workflows, machine learning models, and security controls across the platform. Given the scope and interdependencies of the existing environment, such an effort would likely require many months to multiple years to fully design, implement, test, and re-accredit. It would involve the redevelopment of numerous production workloads and the revalidation of mission-critical systems under a new cloud architecture. This level of effort would result in substantial duplication of cost and unacceptable delays in mission capability delivery, as well as increased risk to continuity of operations, system integrity, performance, and security compliance.

Based on the foregoing, the use of other than full and open competition is justified for the Google Cloud Platform (GCP) cloud subscription, which is essential to the Government’s requirements. As described above, the Government relies on GCP within its enterprise cloud infrastructure, and only Google, as the original equipment manufacturer (OEM), can provide the required platform and support services with the necessary system-level integration, continuity, and technical authority required by the Defense Logistics Agency

(DLA).

5. DETERMINATION BY THE ORDERING ACTIVITY CONTRACTING

OFFICER THAT THE ANTICIPATED COST TO THE GOVERNMENT WILL BE

FAIR AND REASONABLE:

As the Contracting Officer, I hereby determine that anticipated cost to the Government will be fair and reasonable based on price analysis in accordance with FAR 15.404-1. It is anticipated that the Government will use various price analysis techniques including, but not limited to: 1) comparison with competitive published price lists (FAR 15.404-1(b)(4);

and 2) comparison of proposed prices within prices obtained through market research of the same or similar items (FAR 15.404- 1(b)(6) in order to obtain a fair and reasonable price.

6. ANY OTHER FACTS SUPPORTING THE JUSTIFICATION:

N/A

7. A STATEMENT OF THE ACTIONS, IF ANY, THE AGENCY MAY TAKE TO

REMOVE OR OVERCOME ANY BARRIERS TO COMPETITION BEFORE

ANY SUBSEQUENT ACQUISITION FOR THE SUPPLIES OR SERVICES IS

MADE:

Google Cloud Platform (GCP) services must currently be obtained directly from Google due to the proprietary nature of the platform and its integration within the existing environment. Removing this barrier in the near term would require significant redesign and migration that is not practicable without unacceptable disruption to operations.