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U.S. Department of Transportation

Federal Railroad Administration

U.S. DEPARTMENT OF TRANSPORTATION FEDERAL

RAILROAD ADMINISTRATION SOLE SOURCE

JUSTIFICATION

1. Identification of the agency and the contracting activity

Department of Transportation (DOT), Federal Railroad Administration (FRA), Office of Acquisition (RAD-30) , 1200 New Jersey Avenue, S.E., Washington, DC 20590.

2. Nature and/or description of the action being approved

This action is a 12-month, sole source, bridge order to the incumbent vendor, Strongbridge, for continued DevOps Support Services under the Department’s internal Software Engineering Support BPA. . This bridge will extend the period of performance from June 30, 2026, to June 30, 2027. This contract action is necessitated by the United States Department of Transportation’s USDOT’s reorganization of its Information Technology (IT) function into a digital factory model under the 1DOT organization.

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

The FRA requires continuous DevOps Support Services to maintain mission-critical systems and applications. This includes automated software deployment, cloud infrastructure management, and continuous integration/continuous delivery (CI/CD) pipeline maintenance.

• Estimated Value: $3,480,398.40

• Critical Need: These services are essential for the integration of FRA and NHTSA IT teams under the new Digital Factory model mandated by the FY26 THUD Appropriations Act – passed as section D of the Consolidated Appropriations Act, 2026, Consolidated Appropriations Act, 2026 (P.L. 119-75).

4. Statutory authority permitting other than full and open competition

The authority to extend this order without full and open competition is located under GSAR 538.7104-3. The pertinent authority is GSAR 538.7104-3(b)(ii) provides an exception to fair opportunity where “only one source is capable of providing the products, services, or solution required at the level of quality required because the products, services, or solutions are unique or highly specialized.”

5. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited

• The nature of the acquisition requires the use of this authority due to the FY26

THUD Appropriations Act, enacted as part of the “Consolidated Appropriations Act of 2026 on February 3, 2026, which mandates a department-wide IT consolidation under the DOT CIO.

• Unique Knowledge: Strongbridge possesses the highly specialized, institutional knowledge of FRA’s legacy DevOps environment required to facilitate the transition into the S-93 Digital Factory model.

• Unacceptable Risk: Awarding to any other source at this stage would cause unacceptable delays in meeting the statutory mandate. A new vendor would require a 90–120-day transition period, during which the migration of mission systems under shared product lines would be stalled, creating significant security and operational vulnerabilities.

• Strategic Misalignment: A full competition now would likely result in an award that does not align with the final DOT CIO operating model, leading to substantial duplication of costs through inevitable contract restructuring or early termination once the consolidation is finalized

6. Description of Efforts Made to Ensure that Offers are Solicited from as Many

Potential Sources as Practicable

In accordance with GSAR 538.71, this justification will be posted on the Government-wide Point of Entry (beta.SAM.gov) within 14 days of award. Additionally, in support of this action market research was undertaken:

1. Market Research Techniques and Sources Market research was conducted between

March 1- 17, 2026 to assess the availability of DevOps support services and determine if any source other than the incumbent could satisfy the Federal Railroad Administration’s (FRA) requirement during the mandatory DOT IT consolidation period. Research methods included:

• Database Queries: Review of GSA MAS (Information Technology Category) and the NASA SEWP V database to identify vendors with similar technical capabilities in automated CI/CD pipelines and cloud management.

• Government-wide Vehicle Analysis: Analysis of existing DOT-wide vehicles and the S-93 Digital Factory "shared service" capabilities to determine if immediate transition was possible.

• Review of Historical Performance: Evaluation of past solicitations for FRA DevOps services to identify firms with railroad-specific mission system experience.

• SME Consultation: Interviews with technical leadership from the DOT Chief Product & Technology Officer (CPTO) and S-93 Digital Factory to validate the timeline for the integrated FRA/NHTSA operating model.

2. Results and Analysis While the research identified numerous highly qualified firms capable of providing DevOps services generally, none were found that could provide the required support within the constraints of the FY26 THUD Appropriations Act mandate without causing a lapse in mission-critical service.

• Unique Environment Interdependency: The market research confirmed that a new source would require a minimum of 90–120 days for system familiarization and security clearance onboarding. This "ramp-up" period is incompatible with the immediate, ongoing integration of FRA systems into the Digital Factory model.

• Moving Target Requirements: Because the final DOT CIO operating model is still being finalized, the research concluded that a competitive solicitation today would lack the precise labor categories and governance structures required for the future consolidated environment.

• Technical Risk: No other source possesses the institutional knowledge of FRA's existing "siloed" legacy architecture, which is essential for the "bridge" phase to ensure no loss of data or service during the migration to shared product lines.

3. Conclusion Based on these findings, it is determined that only Strongbridge possesses the unique technical readiness and historical context to provide the necessary stability through 30 June 2027. A competition at this stage would not result in a viable, long-term solution and would introduce unacceptable operational risks during a statutory reorganization.

7. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable

The Contracting Officer determines that the anticipated cost for this one-year extension will be fair and reasonable.

Pricing for this extension are based on the labor rates previously vetted and established under the master BPA/Order agreement 693JJ319A000016/693JJ621F000034. The Government will perform a detailed price analysis comparing the proposal against the

Independent Government Cost Estimate (IGCE) and historical pricing to ensure the final negotiated price remains advantageous to the Government.

8. Description of the market research conducted and the results or a statement of the reason market research was not conducted

Market research was conducted using the Fedmine (GovSpend) federal procurement intelligence platform to analyze recent federal contract activity associated with the Department of Transportation (DOT) Software Engineering Solutions (SWES) BPA and related DevOps and software engineering support services. The research reviewed FY2024 procurement data for DOT, including prime contractor participation, NAICS classifications, competition levels, and overall contract obligations.

The analysis identified fourteen vendors currently performing similar IT development, DevOps, and engineering support services within the DOT SWES environment. The data shows that these services are primarily associated with NAICS codes such as 541511 (Custom Computer Programming Services), which represented the largest portion of obligations within the reviewed contracts. Additionally, the report identified multiple vendors supporting DOT IT initiatives, including Spatial Front Incorporated, Strongbridge LLC, Halvik Corp, and CollabraLink Technologies.

The research confirmed that while several vendors possess capabilities in software engineering and DevOps support, the incumbent contractor, Strongbridge LLC, already maintains significant operational involvement within the DOT SWES environment and possesses the institutional knowledge of FRA’s current systems and DevOps infrastructure required to support the ongoing transition to the DOT CIO Digital Factory model.

Based on the results of market research and the current statutory consolidation effort, it was determined that continuing services with the incumbent contractor during this transitional period presents the lowest operational risk and best supports continuity of operations for FRA mission systems.

9. Other facts supporting the use of other than full and open competition

Additional factors support the use of other than full and open competition for this requirement. The FY26 Transportation, Housing and Urban Development (THUD) Appropriations Act mandates a department-wide consolidation of IT functions under the DOT Chief Information Officer. FRA systems and applications must transition into the DOT S-93 Digital Factory operating model during this period.

The incumbent contractor currently supports the FRA DevOps environment and possesses extensive institutional knowledge of FRA’s systems, development pipelines, operational processes, and security architecture. This knowledge is essential to ensure continuity of operations while systems are transitioned into the Department’s consolidated IT framework.

Awarding this requirement to a new contractor would require a transition period estimated at 90–120 days, during which the incoming vendor would need to obtain system knowledge, access, and operational familiarity. Such delays would disrupt ongoing DevOps activities and delay migration of mission systems into shared product lines under the Digital Factory structure. This would create unacceptable operational and cybersecurity risk for systems supporting FRA regulatory oversight and safety programs.

Additionally, conducting a full competition at this time would likely result in a contract structure that does not align with the final DOT CIO Digital Factory operating model. Once the Department finalizes the consolidation framework, any newly competed contract may require restructuring, duplication of costs, or early termination. Continuing with the incumbent contractor provides the most efficient and lowest-risk approach during this transition period.

10. Listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

No additional sources have expressed written interest in this requirement. Market research identified several vendors capable of performing similar DevOps and software engineering services within the DOT SWES environment; however, no vendors have formally expressed written interest in this specific acquisition.

11. 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 required.

The use of other than full and open competition for this requirement is limited to the current transitional period associated with the Department of Transportation’s (DOT) Department-wide IT consolidation under the Office of the Chief Information Officer (CIO), as directed by the FY26 Transportation, Housing and Urban Development (THUD) Appropriations Act. Once the DOT CIO Digital Factory operating model and supporting acquisition framework are finalized, future requirements for DevOps, software engineering, and application support services will be aligned with the Department’s enterprise acquisition strategy.

FRA will coordinate with the DOT CIO and the S-93 Digital Factory governance structure to ensure that future service requirements are competed through the appropriate Department-wide contracting vehicles and product line structures. This will allow the Government to leverage enterprise capabilities, expand vendor participation, and promote full and open competition for future development and operations support services.

In the interim, this limited-source approach ensures continuity of operations for FRA mission systems while the Department finalizes the enterprise IT operating model and acquisition strategy. Once the transition to the consolidated environment is complete, FRA anticipates that future requirements will be competed in accordance with federal acquisition regulations and Department-wide procurement policies.

12. Certification/Approval Signatures

I certify that the information provided in this justification is complete and accurate to the best of my knowledge and belief.

Based upon the preceding information, I hereby recommend approval of this Justification for Other than Full and Open Competition to award a 12-month bridge contract to Strongbridge for DevOps Support Services. This recommendation is predicated on the critical need for uninterrupted DevOps operations during the Federal Railroad Administration’s (FRA) integration into the S-93 Digital Factory model. As documented, the recent passage of the FY26 THUD Appropriations Act has created a unique statutory requirement to reorganize modal IT services, rendering a standard competitive procurement currently both impractical and counterproductive to the Department’s long-term shared-services strategy.

Awarding this bridge contract to the incumbent is the only viable method to:

• Maintain Zero-Day Continuity: Ensure mission-critical CI/CD pipelines and security protocols remain active during the complex organizational realignment of FRA and NHTSA IT teams.

• Protect the Government’s Fiscal Interest: Avoid the substantial duplication of costs associated with onboarding a new contractor for a short-term, 12-month period that would ultimately be superseded by the finalized DOT-wide operating model.

• Mitigate Technical Risk: Leverage Strongbridge’s unique institutional knowledge of FRA’s legacy architecture to facilitate a stable migration to the consolidated DOT core without the 90–120-day learning curve required by an outside source.

Accordingly, it is determined that the use of GSAR 538.7104-3(b)(ii) is justified, and this action represents the most advantageous path for the Government to satisfy its immediate requirements while transitioning toward full and open competition under the revised DOT IT governance structure.

Technical Requirements Certification:

I certify that the technical requirements and technical justifications are accurate and complete to the best of my knowledge and belief.

Christina Morris Contracting Officer’s Representative Date

APPROVAL:

Based upon the preceding information, I hereby recommend approval of this Justification for Other than Full and Open Competition to award a 12-month bridge contract to Strongbridge for DevOps Support Services. This recommendation is predicated on the critical need for uninterrupted DevOps operations during the Federal Railroad Administration’s (FRA) integration into the S-93 Digital Factory model. As documented, the recent passage of the FY26 THUD Appropriations Act has created a unique statutory requirement to reorganize modal IT services, rendering a standard competitive procurement currently both impractical and counterproductive to the Department’s long-term shared-services strategy.

Matthew M. Carr Date Contracting Officer, RAD-30

Paul Syzmanski Date Chief of the Contracting Office

Joshua Jordan Date Head of Contracting Activity Competition Advocate

1. Identification of the agency and the contracting activity

2. Nature and/or description of the action being approved

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

The FRA requires continuous DevOps Support Services to maintain mission-critical systems and applications. This includes automated software deployment, cloud infrastructure management, and continuous integration/continuous delivery (CI/CD) pipeline m...

Estimated Value: $3,480,398.40

Critical Need: These services are essential for the integration of FRA and NHTSA IT teams under the new Digital Factory model mandated by the FY26 THUD Appropriations Act – passed as section D of the Consolidated Appropriations Act, 2026, Consolidat...

4. Statutory authority permitting other than full and open competition

5. Demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited

The nature of the acquisition requires the use of this authority due to the FY26 THUD Appropriations Act, enacted as part of the “Consolidated Appropriations Act of 2026 on February 3, 2026, which mandates a department-wide IT consolidation under th...

Unique Knowledge: Strongbridge possesses the highly specialized, institutional knowledge of FRA’s legacy DevOps environment required to facilitate the transition into the S-93 Digital Factory model.

Unacceptable Risk: Awarding to any other source at this stage would cause unacceptable delays in meeting the statutory mandate. A new vendor would require a 90–120-day transition period, during which the migration of mission systems under shared pro...

Strategic Misalignment: A full competition now would likely result in an award that does not align with the final DOT CIO operating model, leading to substantial duplication of costs through inevitable contract restructuring or early termination onc...

6. Description of Efforts Made to Ensure that Offers are Solicited from as Many Potential Sources as Practicable

7. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable

8. Description of the market research conducted and the results or a statement of the reason market research was not conducted

9. Other facts supporting the use of other than full and open competition

10. Listing of the sources, if any, that expressed, in writing, an interest in the acquisition.

11. 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 required.

12. Certification/Approval Signatures

12. Certification/Approval Signatures

I certify that the information provided in this justification is complete and accurate to the best of my knowledge and belief.

Based upon the preceding information, I hereby recommend approval of this Justification for Other than Full and Open Competition to award a 12-month bridge contract to Strongbridge for DevOps Support Services. This recommendation is predicated on the critical need for uninterrupted DevOps operations during the Federal Railroad Administration’s (FRA) integration into the S-93 Digital Factory model. As documented, the recent passage of the FY26 THUD Appropriations Act has created a unique statutory requirement to reorganize modal IT services, rendering a standard competitive procurement currently both impractical and counterproductive to the Department’s long-term shared-services strategy.

Awarding this bridge contract to the incumbent is the only viable method to:

Maintain Zero-Day Continuity: Ensure mission-critical CI/CD pipelines and security protocols remain active during the complex organizational realignment of FRA and NHTSA IT teams.

Protect the Government’s Fiscal Interest: Avoid the substantial duplication of costs associated with onboarding a new contractor for a short-term, 12-month period that would ultimately be superseded by the finalized DOT-wide operating model.

Mitigate Technical Risk: Leverage Strongbridge’s unique institutional knowledge of FRA’s legacy architecture to facilitate a stable migration to the consolidated DOT core without the 90–120-day learning curve required by an outside source.

Accordingly, it is determined that the use of GSAR 538.7104-3(b)(ii) is justified, and this action represents the most advantageous path for the Government to satisfy its immediate requirements while transitioning toward full and open competition under the revised DOT IT governance structure.

Technical Requirements Certification:

I certify that the technical requirements and technical justifications are accurate and complete to the best of my knowledge and belief.

Christina Morris Contracting Officer’s Representative Date

APPROVAL:

Based upon the preceding information, I hereby recommend approval of this Justification for Other than Full and Open Competition to award a 12-month bridge contract to Strongbridge for DevOps Support Services. This recommendation is predicated on the critical need for uninterrupted DevOps operations during the Federal Railroad Administration’s (FRA) integration into the S-93 Digital Factory model. As documented, the recent passage of the FY26 THUD Appropriations Act has created a unique statutory requirement to reorganize modal IT services, rendering a standard competitive procurement currently both impractical and counterproductive to the Department’s long-term shared-services strategy.

Matthew M. Carr Date Contracting Officer, RAD-30

Paul Syzmanski Date Chief of the Contracting Office

Joshua Jordan Date Head of Contracting Activity Competition Advocate

CHRISTINA

MORRIS

Digitally signed by

CHRISTINA MORRIS

Date: 2026.06.17 10:48:21 -04'00'

MATTHEW MARTIN

CARR

Digitally signed by MATTHEW

MARTIN CARR

Date: 2026.06.17 11:02:44 -04'00'

JOSHUA JAMAL JORDAN

Digitally signed by JOSHUA JAMAL

JORDAN

Date: 2026.07.01 14:48:46 -04'00'

Date:

Paul Syzmanski:

Date_2:

Joshua Jordan:

Date_3:

2026-07-13T08:23:08-0500

PAUL MICHAEL SZYMANSKI