Networking_-_JA_Template_over_SAT_redacted.pdf

FOR OFFICIAL USE ONLY

Control No: 2019-0008

Justification Review Document for Other Than Full and Open Competition

Program/Equipment: Purchase of CommScope cabling products for the Colorado Army National Guard’s new Space Battalion Readiness Center.

Authority: 10 U.S.C.2304(c)(1), FAR 6.302-1(a)(2)(iii)

Amount: $450,000

Prepared by:

Typed Name: Andrew Gray DSN/Commercial: 720-250-1103 Title: G6 Plans & Policy Date: 05/21/2019 E-mail: Andrew.s.gray.civ@mail.mil

Contracting Officer:

Typed Name: Sabrina DeRamus DSN/Commercial: 720-250-4032 Date Reviewed: 21 May 2019

Technical Representative:

Typed Name: Andrew Gray DSN/Commercial:

Title: Date Reviewed:

Requirements Representative:

Typed Name: Andrew Gray DSN/Commercial:

Title: Date Reviewed:

Reviews: I have reviewed this justification and find it adequate to support other than full and open competition.

Program Manager Typed Name: COL Isaac Martinez DSN/Commercial: 720-250-1100

Signature: Date: 06/04/2019 mailto:Andrew.s.gray.civ@mail.mil

Control No: 2019-0008

Justification and Approval for Other Than Full and

Open Competition

1. Contracting Activity: USPFO-CO, 660 S. Aspen St, Bldg 1005, Buckley Air Force Base, Aurora, CO 80011

2. Description of Action: This is for a new contract to continue critical services for an expiring open market circuit and telecommunications contract. Operation and Maintenance funds will be used to fund a 6 month contract to allow for more acquisition time after being unable to convert to EIS in December and determining that available GSA Networx pricing is not in the best interest of the tax payer and would cost the government nearly 50% more versus utilizing an open market solution.

3. Description of Supplies/Services: COARNG requires Metro Ethernet (MOE), Optical Wavelength Service, Plain Old Telephone Service (POTS), Fiber +, Primary Rate Interface and Fiber to building installs. Estimated cost for 6 months of network services is estimated at

Type Requirement QTY MOE Mandatory 25 Circuits OWS Mandatory 1 Circuit POTS Mandatory 100 Lines w/Features Fiber + Mandatory or alternative 25 Circuits

PRI Mandatory Circuits, Channel Termination, DiDs SR/ALI private switching

4. Authority Cited: 10 U.S.C. 2304(c) (1) and FAR 6.302-1(2) Only one responsible Source.

5. Reason for Authority Cited: Due to the critical nature of our long haul circuits and other telecommunication needs only the current provider is the only reasonable source at this time with the mandated acquisition requirements. Century link has provided quality service and is willing to assist in a 6 month extended transition period to allow for sufficient solicitation and to prevent a gap in COARNG operations. Typically, it takes about 45 day to transition a circuit and 60 days for HQ review of a long term acquisition package which in total would put us past our deadline to have a transition in place before our current contract expires. Any other source would also require a reengineer of our entire infrastructure and at this time would pose a burden on our operations and pose a definite failure risk to operations. The COARNG supports critical federal and State missions and cannot risk a severance in operations or maintaining life safety requirements and the protection of property. After the completion of this acquisition, full and open competition will be provided going forward.

6. Efforts to Obtain Competition: COARNG attempted a GSA EIS transition in December 2018 to allow all potential circuit vendors to bid on the requirement. At the last moment GSA, DISA and NGB mandated we pull the requirement from EIS as GSA and the vendors were not accredited to provide the services under that contracting vehicle. At that time COARNG was forced to extend its contract by an additional 6 months with its last available extension. During that time we began to seek guidance on the way ahead and sought another open market or the potential of leveraging the existing Networx vehicle. COARNG has been on the GSA Networx vehicle with Century Link since its creation after determining fair and reasonable pricing with various network requirements. Our big push to leave the Networx vehicle came down to overall price and capability offered. The open market vehicle allowed us to improve capability by getting fiber and improved bandwidth to our facilities for a significant amount less than what we were paying under Networx. After evaluating pricing to this day it is still 50% more to acquire service under Networx and the vehicle does not provide all the required capability we need to operate or network in an efficient manner.

Given the short time frame we have to get a multiyear contract in place by the beginning of August would be a difficult and rushed task. This type of acquisition requires a significant amount of planning and transition time. To prevent failure of our entire operation and to work within our fiscal constraints we have no available alternative but to resume services as usual with our current provider. At the end of this contract, full and open completion will be offered or we will be transitioned to an HQ solution on the EIS vehicle.

7. Actions to Increase Competition: The COARNG will begin the immediate re-development of an acquisition package that will have enough lead time and transition planning to get through the review process and allow for a successful transition with minimal outages to operations.

8. Market Research: Please see market research attachment.

9. Interested Sources: Century Link and Verizon have both expressed interest in this acquisition. Century Link provided and open market and Networx opportunities. Verzion provided only a Networx opportunity as that was what was being sought during market research.

Both Networx Presentations lead us to paying 50% more than what is already in place and was concluded not to be a viable option for fiscal constraints and in the best stewardship of tax payer dollars. However, due to contracting constraints in our organization a long term vehicle cannot be sought at this time. Only a short term contract to fulfill the current need until a firm solution can be put in place. To allow competition now would impose a rushed transition now and a potential transition again upon the solicitation of the long term contract. The COARNG does not have the capacity or manpower to even entertain the possibility of two transitions in such a short period of time as the sure result will render us unable to perform our mission.

10. Other Facts: Discuss any other facts supporting the use of other than full and open competition, such as the following:

a. Procurement history. Previously competed unrestricted open market under contract W912LC- 15-P-0024 in 2015 with 1 base with 4 option years. Century Link was the lowest bidder out of two interested sources. The other interested source was Granite Technologies. Verizon, L3 and

AT&T did not quote. It took several months to transition all Century Link Networx services over to the open market vehicle. This cost the government almost an additional $60,000 to maintain both services while the transition was completed. The COARNG would have to do this twice if any other vendor was selected imposing a financial burden on the agency in the next 12 months.

This is not fully a vendor restriction but a restriction on the agency to be able to coordinate all the critical requirements necessary to transition in less than a 30 to 45 day window for over 25 plus sites.

11. Technical Certification: Include the following statement:

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

Typed Name: Andrew Gray Date: 06/04/2019

GRAY.ANDREW.STEVEN.1 Digitally signed by

Title: G6 Plans & Policy Signature: 266280307

GRAY.ANDREW.STEVEN.1266280307

Date: 2019.06.04 10:42:40 -06'00'

12. Requirements Certification: Include the following statement:

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

Typed Name: Andrew Gray Date: 05/21/2019

Digitally signed by

GRAY.ANDREW.STEVEN.126628030

Title: G6 Plans & Policy Signature: 7 Date: 2019.06.04 10:43:15 -06'00'

Only the most senior persons within the organization responsible for acquiring the supplies or services described in the justification (e.g. program manager, depot commander, or senior program engineer) and with specific knowledge of the individual requirement (commodity, technology, and/or function) shall sign the technical and requirements certifications.

13. Fair and Reasonable Cost Determination: Include the following determination:

I hereby determine that the anticipated cost to the Government for this contract action will be fair and reasonable.

Provide the basis for this determination (e.g., describe techniques to be used to determine fair and reasonable price, such as cost analysis, price analysis, audit, should cost, independent Government estimate, etc.). As part of the basis, indicate whether certified cost or pricing data will be required or if one of the exceptions in FAR 15.403 applies.

Typed Name: Date:

Title: Signature:

DERAMUS.SABRINA.M.

1034325134

Digitally signed by

DERAMUS.SABRINA.M.1034325134

Date: 2019.07.03 14:05:19 -06'00'

GRAY.ANDREW.ST

EVEN.1266280307

sabrina.m.deramus 2019-07-03 20:07:38 I cannot edit this document, therefore a Price Fair and Reasonable Determination will be added to the file separately.

379394

14. Contracting Officer Certification: This certification shall be made by the contracting officer who will sign the contract resulting from this justification and approval. Include the following statement:

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

Typed Name: Date:

DERAMUS.SABRINA. Digitally signed by

DERAMUS.SABRINA.M.1034325134

Title: Signature: M.1034325134 Date: 2019.07.03 14:04:42 -06'00'

Note: It is recommended for the contracting officer to annotate at the bottom of each J&A page the following marking, as appropriate, prior to posting on the internet: “For Official Use Only”.

Approval

(The approval statement is drafted on a separate page from the certifications and tailored to the instant contract action)

Based on the foregoing justification, I hereby approve the procurement of (state equipment/services being procured) on an other than full and open competition basis pursuant to the authority of 10 U.S.C. 2304(c) (insert authority and general title), subject to availability of funds, and provided that the services and property herein described have otherwise been authorized for acquisition.

Date: Signature:

Digitally signed by

MARTINEZ.ISAAC.B MARTINEZ.ISAAC.BENITO.1154

ENITO.1154379394 Date: 2019.06.18 14:42:03 -06'00'