Redacted_Exception-to-Fair-Opportunity_1.pdf

140R8123Q0168 Page 1 of 4

WBR 1416.505 - Template 1 eFile - B02

(07/2021)

JUSTIFICATION FOR AN EXCEPTION TO FAIR OPPORTUNITY

In accordance with FAR 16.505(b)(2), the proposed contractual action is pursuant to the statutory authority of 41 U.S.C. 253(c). This template is required for all Task and Delivery Orders over the micro-purchase threshold issued under multiple-award Indefinite-Delivery Indefinite-Quantity or Definite-Quantity contracts where each awardee will not be provided a fair opportunity in accordance with FAR 16.505(b)(1)(i). Task and Delivery orders containing requirements for use of items peculiar to one manufacturer shall also use this template in accordance with FAR 16.505(a)(4) unless a brand name justification was previously approved for the contract in accordance with 6.302-1(c) or the base Indefinite-Delivery Contract was a single-award contract awarded under full and open competition.

1. Agency and Contracting Activity (FAR 16.505(b)(2)(ii)(B)(1). U.S. Department of the Interior, Bureau of Reclamation.

2. Nature/Description of Action (FAR 16.505(b)(2)(ii)(B)(2). This action is a logical follow-on task order award to Booz Allen Hamilton for technical Industrial Control System (ICS) cybersecurity analysis for ICS Security Operations projects and tasks.

3. Description of Supplies/Services (FAR 16.505(b)(2)(ii)(B)(3). Reclamation has a requirement for a logical follow-on task order for technical ICS cybersecurity analysis services for ICS Security Operations projects and tasks. This includes the providing of recommendations for implementing technical security controls within ICS networks;

managing ICS security operations projects; conducting research on new and existing technologies; providing leadership in incident response activities, providing recommendations regarding cybersecurity tools, solutions, and system architecture;

improving USBR’s continuous monitoring capabilities; and creating and reviewing standard operating procedures and technical documentation. The prior task order award number is 140R8122F0179. The period of performance is estimated to be 06/01/2023 through 09/30/2023.

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4. Identification of the exception to fair opportunity (FAR 16.505(b)(2)(ii)(B)(4) and (FAR 16.505(b)(2)(ii)(B)(10).

Authority Exception ☐ FAR 16.505(b)(2)(i)(A) The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

☐ FAR 16.505(b)(2)(i)(B) 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.

☒ FAR 16.505(b)(2)(i)(C) The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order.

☐ FAR 16.505(b)(2)(i)(D) It is necessary to place an order to satisfy a minimum guarantee.

☐ FAR 16.505(b)(2)(i)(E) For orders exceeding the simplified acquisition threshold, a statute expressly authorizes or requires that the purchase be made from a specified source.

☐ 16.505(a)(4) It is essential to the Government’s requirements to restrict consideration to an item peculiar to one manufacturer (e.g. a particular brand-name, product, or a feature of a product that is peculiar to one manufacturer).

A. Proposed Contractor Name. Booz Allen Hamilton.

B. Rationale Supporting the Exception to Providing Fair Opportunity.

The original order award number is 140R8122F0179 (140R8118D0006). This task order was competed among all the Information Technology (IT) Risk Management Indefinite- Delivery Indefinite-Quantity (IDIQ) holders. This task order was competed in fiscal year (FY) 2022 and all IDIQ holders were given fair opportunity. A logical follow-on has not previously been used for this task order.

The current contractor, Booz Allen Hamilton, has been conducting work for the Risk Management Services division through the original task order for the last eleven months.

Booz Allen Hamilton is currently working on three tasks for the Risk Management Services Division (RMSD) that will be continued via the tasks identified in this order.

The first task is to research and evaluate network taps for eventual use in the ICS Asset Visibility Project. As a result of this effort, Booze Allen Hamilton has direct experience configuring and administering the chosen taps for Reclamation use cases. The second task is to research and evaluate data diodes for eventual use in the ICS Zones Project.

Like above, this work gave Booze Allen Hamilton direct experience configuring and

140R8123Q0168 Page 3 of 4 managing the chosen data diode for Reclamation use cases. Lastly, Booz Allen Hamilton is providing SCRUM coaching services for five BOR-wide projects. The SCRUM coach has integrated with all the project teams, learned the project scopes and objectives, and provided SCRUM training to project leads. As a result of all the above work, Booze Allen Hamilton has comprehensive knowledge and experience with the technologies supporting ongoing Risk Management Services Division projects as well as the project management frameworks and strategies these projects are following. This knowledge and experience is necessary to successfully continue to execute the tasks identified in this order.

Booz Allen Hamilton has the intricate understanding and institutional knowledge of the projects related to the tasks identified in this order through the work that they have accomplished during the last eleven months. If Reclamation were to compete the additional work, the oncoming contractor would need to obtain this knowledge and get hands-on experience with the project technologies, become familiar with disparate Reclamation ICS environments and how the technology use cases should be deployed in each, and get up to speed on all five ongoing Risk Management Services Division projects. This would add at least twelve months of additional time to even start the new task order work (including one month for a competitive procurement). This would increase the costs to the Government needed to complete the tasks since Reclamation would be required to reimburse the contractor for their time to duplicate the working knowledge that BAH has obtained up to this point in time.

5. Determination of Fair and Reasonable Cost (FAR 16.505(b)(2)(ii)(B)(5)). The Contracting Officer will determine prices to be fair and reasonable prior to award by utilizing the IDIQ pricing that was already determined to be fair and reasonable at contract award.

6. Any Other Supporting Facts (FAR 16.505(b)(2)(ii)(B)(6)). N/A

7. Actions Taken to Remove Barriers to Competition (FAR 16.505(b)(2)(ii)(B)(7)). This requirement is for a logical follow-on to a task order under the current contract. Future requirements will be fulfilled via the new competitive follow-on contract for the Risk Management program, which is currently in the pre-solicitation phase.

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PREPARED BY:

CONTRACTING OFFICER (CO) CERTIFICATION (FAR 16.505(b)(2)(ii)(B)(8)): (All Values) This justification is accurate and complete to the best of my knowledge and belief.

CHIEF of the CONTRACTING OFFICE CONCURRENCE (CCO) (FAR 16.505(b)(2)(ii)(C)(1) and DOI-AAAP-0024)): (> $250K)