Department of the Air Force: Justification for Other Than Full and Open Competition

CUI

May 2026 Page 2 of 5May 2026 Page 2 of 5

I. Agency and Contracting Activity (RFO 6.104-1(a)(1)):

Agency: United States Air Force/Installation: Joint Base Lewis-McChord (JBLM) Contracting Activity: 375th CONS/PKB2/Scott Air Force Base (AFB)

II. Nature and/or description of the action being approved (RFO 6.104-1(a)(2)):

This document approves the award of a firm-fixed price on a Brand-Name Justification basis to be determined to an authorized distributor of TC Communications for the purchase of TC Communications TC8000 series fiber optic transport and TC3800 series JumboSwitch equipment, as well as the installation of outside plant (OSP) fiber optic cables, in support of the RAWS ATCALS (Radar, Airfield & Weather Systems / Air Traffic Control and Landing Systems) modernization project at JBLM.

This justification is made on an Individual basis.

III. Description of supplies/services required to meet agency needs (RFO 6.104-1(a)(3)):

1. Description of Supplies/Services:

The 627th Communications Squadron requires the procurement of commercial-off-the-shelf (COTS) telecommunications equipment and the associated installation of outside plant (OSP) fiber optic cables at Joint Base Lewis-McChord (JBLM).

Specifically, this requirement is to upgrade the Radar, Airfield & Weather Systems/Air Traffic Control and Landing Systems (RAWS ATCALS) infrastructure. The legacy degraded copper and outdated "channel bank" fiber transport equipment will be replaced to modernize the network and posture the systems for migration to the Defense Information Systems Network

(DISN).

2. Major Items and Quantities:

This acquisition requires the Brand Name procurement of TC Communications networking equipment. Major items include:

TC8000 Series Fiber Optic Transport Equipment (Various quantities as defined in the SOW)

TC3800 Series JumboSwitch Equipment (Various quantities as defined in the SOW)

Associated hardware, transceivers, and licensing/IP necessary for baseline operation of the equipment.

Turn-key installation services for OSP fiber optic cabling, testing, and integration.

3. Estimated Value:

The total estimated value of this acquisition is . Within this total, the specific brand name equipment portion (TC Communications hardware) accounts for .

4. Anticipated Contract Type & Funding:

The anticipated contract type is a Firm-Fixed-Price (FFP) contract. The action will be funded using procurement funds. The planned funding amount covers the full estimated value of , and there are no anticipated option periods for this turn-key installation and equipment delivery.

IV. Statutory Authority Permitting Other Than Full and Open Competition (RFO 6.104-1(a)(4)):

10 U.S.C. 3204(a)(1), Only one responsible source and no other supplies or services will satisfy agency requirements.

RFO 12.201-2, Other procedures - 10 U.S.C. 3204(a)(1)

V. Rationale for Use of Authority (RFO 6.104-1(a)(5)):

The use of the cited authority (10 U.S.C. 3204(a)(1), as applied to a Brand Name restriction) is necessary due to the specific nature of this acquisition and the unique technical requirements of the Air Force's Air Traffic Control and Landing Systems

May 2026 Page 3 of 5May 2026 Page 3 of 5

(ATCALS).

Currently, the RAWS ATCALS community is operating on degraded copper and legacy fiber transport equipment (commonly referred to as "channel banks") that consistently fail, have exceeded their lifecycle, and are no longer logistically supported.

To rectify this, HQ Air Force Flight Standards Agency/Air Force Engineering and Technical Services (AFFSA/AFETS) has mandated the modernization of these systems to posture them for migration to the Defense Information Systems Network

(DISN).

The nature of this acquisition requires the exclusive use of TC Communications equipment (specifically the TC8000 series fiber optic transport and TC3800 series JumboSwitch) for the following reasons:

Per the United States Air Force memorandum dated 27 December 2024, TC Communications equipment is certified and approved by HQ AFFSA. Because this equipment is formally certified to meet the strict security and interoperability requirements of the ATCALS network, no other products are currently authorized for this specific application without undergoing a lengthy, costly, and mission-impacting re-certification process.

Standardization and Interoperability: TC Communications equipment has already been successfully fielded, tested, and integrated at several other Air Force bases. Procuring the same equipment at JBLM ensures a standardized enterprise solution across the ATCALS community.

DISN Migration Capability: The TC Communications hardware natively supports the specific interconnectivity requirements over fiber optics necessary to migrate these critical air traffic control systems to the DISN.

Avoidance of Unacceptable Delays and Duplication of Cost: Procuring an alternative manufacturer's equipment would result in unacceptable delays in fulfilling the agency's requirement. A different system would require extensive new engineering, testing, and certification by HQ AFFSA to ensure it meets strict aviation safety and network security standards, duplicating costs already expended on certifying the TC Communications solution.

While the requirement mandates the use of TC Communications brand name equipment, competition will still be maximized to the maximum extent practicable by soliciting authorized distributors of the manufacturer to provide the hardware and perform the associated outside plant (OSP) installation.

VI. Integrated Market Analysis and Efforts to Solicit Competition (RFO 6.104-1(a)(6), (8), and (10)):

1. Market Research (RFO 6.104-1(a)(8)):

Market research was conducted collaboratively by the technical experts at HQ AFFSA/AFETS, the 627th Communications Squadron, and the 375th Contracting Office. The technical evaluation by HQ AFFSA determined that only the TC Communications brand (TC8000 and TC3800 series equipment) can meet the Air Force’s requirement for DISN migration and interoperability with already fielded ATCALS infrastructure without incurring unacceptable delays or duplication of testing costs. However, market research into the commercial marketplace confirmed that TC Communications relies on a network of authorized distributors.

Therefore, while restricted to a specific brand name, the acquisition can still be competed among these authorized vendors.

TC Communications was successfully fielded, tested, and integrated at several other Air Force bases, including Tinker AFB and Shaw AFB as the standard solution for DISN migration, utilizing the same brand name equipment at JBLM standardizes the hardware footprint.

Market research indicates there are multiple small businesses capable of performing the installation; however, competition will be limited to vendors who are authorized resellers of the TC Communications JumboSwitch to ensure warranty and system integrity.

2. Efforts to Solicit Competition (RFO 6.104-1(a)(6)):

To ensure offers are solicited from as many potential sources as is practicable, the Government intends to post a solicitation

May 2026 Page 4 of 5May 2026 Page 4 of 5 to the Government-wide Point of Entry (GPE) via SAM.gov. In accordance with FAR 5.102(a)(6), this Brand Name Justification will be published alongside the solicitation. This strategy will maximize competition by allowing any authorized TC Communications value-added reseller or distributor to submit a proposal for both the equipment and the required turn-key installation services.

3. Sources Expressing Interest (RFO 6.104-1(a)(10)):

A Sources Sought / Request for Information (RFI) was posted to SAM.gov. Multiple vendors expressed written interest and submitted capability statements, demonstrating that there is adequate competition among authorized resellers to support a Small Business Set-Aside."

VII. Determination of Fair and Reasonable Cost (RFO 6.104-1(a)(7)):

The Contracting Officer is responsible for evaluating, determining, and documenting the anticipated contract cost/price is fair and reasonable in accordance with RFO Subpart 15.4, Contract Pricing.

VIII. Any Other Facts Supporting the Justification (RFO 6.104-1(a)(9)):

While this acquisition is not categorized as a follow-on to a major system development or an unusual and compelling urgency action, the following additional facts support the restriction to the TC Communications brand name:

1. Operations, Maintenance, and Training Efficiencies:The RAWS ATCALS infrastructure is operated and maintained by specialized Air Force technicians. Because TC Communications equipment has already been fielded at several other Air Force bases at Tinker AFB and Shaw AFB as the standard solution for DISN migration, utilizing the same brand name equipment at JBLM standardizes the hardware footprint. Introducing a different manufacturer's equipment would require RAWS personnel to undergo new, separate training programs to learn different proprietary interfaces, troubleshooting procedures, and maintenance protocols.

2. Cybersecurity and Network Certification:Any telecommunications equipment connecting to the Defense Information Systems Network (DISN) must undergo rigorous Risk Management Framework (RMF) and cybersecurity assessments to receive an Authority to Operate (ATO). The TC Communications solution has already been vetted for this specific ATCALS architecture by HQ AFFSA. Introducing a new brand of hardware would force the Government to duplicate thousands of man-hours in engineering, vulnerability testing, and security authorization processes. While an exact dollar figure for this duplicated effort is difficult to quantify without a specific alternative system to evaluate, the historical cost of certifying new telecommunications hardware for DISN connectivity is substantial, and the associated delays would severely impact the JBLM ATCALS modernization timeline.

IX. Actions to Overcome Barriers to Competition (RFO 6.104-1(a)(11):

The primary barrier to full and open competition for this requirement is the necessity for standardization, interoperability, and network security certification as directed by HQ AFFSA/AFETS for the RAWS ATCALS DISN migration. To remove or overcome barriers to competition for future acquisitions of similar supplies or services, the agency will take the following actions:

1. Continuous Market Research:

The requiring activity, in coordination with HQ AFFSA/AFETS, will continue to monitor the commercial telecommunications marketplace. As industry technologies evolve, the Government will evaluate emerging Commercial Off-The-Shelf (COTS) fiber optic transport systems and network switches to determine if other manufacturers can meet the strict DISN connectivity and interoperability requirements without duplicating unacceptable certification costs.

2. Vendor-Level Competition:

While the manufacturer is restricted to TC Communications for this specific modernization effort, the Contracting Officer will mitigate the barrier to competition by soliciting the requirement among multiple authorized distributors and value-added resellers. By posting the requirement on the Government-wide Point of Entry (or applicable competitive contract vehicle)

May 2026 Page 5 of 5 alongside this justification, the Government will ensure competitive pricing is achieved for both the hardware and the associated installation services.