022. METTS III_MSFC JOFOC No.25-129__Approved 2026.04.30 __REDACTED.pdf

Rev.: 4/2026

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

GEORGE C. MARSHALL SPACE FLIGHT CENTER (MSFC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Marshall Engineering Technicians and Trades Support (METTS) III Contract 80MSFC23CA004

1. Federal Acquisition Regulation (FAR) 6.104-1(a)(1) – Identification of the agency and the contracting activity, and specific identification of the document as a “Justification for other than full and open competition.”

This document is a justification for other than full and open competition prepared by the National Aeronautics and Space Administration (NASA) Marshall Space Flight Center

(MSFC).

The procuring Agency is NASA, and the contracting activity is MSFC.

2. FAR 6.104-1(a)(2) – The nature and/or description of the action being approved:

This justification provides the rationale for contracting by other than full and open competition to award a new work modification with extension to contract number 80MSFC23CA004 METTS III with RSi-Quantitech Joint Venture (RSi-QT JV) for the purpose of (1) increasing the contract ceiling value in order to account for existing and future cost overruns expected to be incurred in performance of the Contract, due to higher-than-estimated expenses and increased work driven by accelerated efforts to return Americans to the moon with the Artemis program, which is within scope; and (2) extending the contract for 12 months, structured as two 6-month option periods. This increase and extension are also required to support time-critical manufacturing and testing for the Vulcan Centaur 5 Upper Stage and associated RUAG payload and interstage adapter hardware, which are integral to future SLS mission architectures and are on the critical path for upcoming launch campaigns.

3. FAR 6.104-1(a)(3) – A description of the supplies or services required, to meet the Agency’s needs (including the estimated value):

The METTS III contract delivers direct, mission‑critical engineering technician and trade support, i.e., welders, machinists, calibration and test stand configuration,to the MSFC Engineering Directorate, the Facilities Management Office, and a wide range of MSFC programs and projects. This support spans multiple technical organizations, including the Materials and Processes Laboratory, Space Systems Department, and Test Laboratory, with additional capabilities supporting the Propulsion Systems Department and the Spacecraft and Vehicle Systems Department. Through this broad integration, technicians and trade support under METTS III provide the hands-on activities and hardware which is vitalto sustain and

MSFC JOFOC No. 25-129 advance complex engineering, testing, and development activities essential to NASA’s mission portfolio.

To meet the high demand and diverse requirements of these organizations, METTS III provides a comprehensive suite of technical services. These include contamination control;

test support for the Environmental Test Facility and Experimental Fluid Dynamics Test Facility; Structural Strength Test Laboratory support; fabrication outsourcing for research and development spaceflight hardware; electrical fabrication, testing, and assembly;

metrology and calibration management; environmental effects and structural dynamics testing; special test equipment design support; and management of the Materials and Processes Technical Information System. Additional specialized capabilities—such as optics support, metals engineering, nondestructive evaluation, advanced nonmetallic materials and manufacturing, propellant and pressurant operations, and Propulsion Test Laboratory support—further strengthen MSFC’s ability to execute demanding engineering and test programs.

A significant portion of METTS III support is dedicated to the Space Launch System, for which MSFC holds primary responsibility. The contract provides critical contributions across numerous SLS efforts, including the Block 1B Exploration Upper Stage Structural Qualification Test, Block 1B Transportation Frame, liquid hydrogen tank testing, Mobile Launcher Dynamic Stabilizer testing, Core Stage Thermal Protection System testing, and Spacecraft Payload Integration and Evolution Office hardware such as the Launch Vehicle Stage Adapter, Multi‑Stage Adapter, Payload Adapter Fitting, and Core Stage Battery Test. It is also anticipated that METTS III will be performing support activities for the United Launch Alliance (ULA) Vulcan Centaur 5 Upper Stage, which is planned to replace the Exploration Upper Stage (EUS) and Interim Cryogenic Propulsion Stage (ICPS) in future SLS flights. METTS III’s support of the Centaur will be primarily focused in the area of manufacturing of adapter rings to support integration into the SLS.

METTS III provides specialized manufacturing and test support for the ULA Vulcan Centaur 5 Upper Stage, including precision fabrication of SLS adapter rings and associated integration hardware. These activities require tightly controlled processes, non-destructive evaluation sequences, and mission-specific fixtures that have been developed and matured under the incumbent contract. METTS III also supports RUAG payload and interstage adapter structural and functional testing at MSFC, with these campaigns closely tied to Centaur and SLS integration schedules.

In parallel, METTS III supports the International Space Station Program through fabrication, refurbishment, assembly, precision cleaning, and testing of Environmental Control and Life Support System hardware, including the Four‑Bed Carbon Dioxide Scrubber, Universal

Waste Management System, Universal Pretreated Concentrate Tank, Mini Potable Water Dispenser, and the Fluid Relocation on Gateway system.

Beyond these flagship programs, METTS III provides continuous, 24/7 mission‑critical support for Propellant and Pressurant Services and Valve and Component Services, ensuring safe and reliable operations across all MSFC testing and facilities. The contract also supports Commercial Crew and other aerospace initiatives requiring fabrication, modification, and testing, with representative efforts spanning projects for SpaceX, Blue Origin, Boeing, Lockheed Martin, Sierra Space, United Launch Alliance instrumentation and Centaur V testing, and RUAG payload and interstage adapter testing. Collectively, these integrated services enable MSFC to meet current mission demands while advancing future exploration objectives, including Artemis and other high‑priority NASA initiatives.

The METTS III contract is a hybrid, predominately cost-plus-award-fee (CPAF) and cost-plus-fixed-fee (CPFF), Indefinite Delivery, Indefinite Quantity (IDIQ) type contract. The METTS III contract was competitively awarded to RSi-QT on December 27, 2022, with a one-year base period and four, one-year options for a total potential period of performance (PoP) of five (5) years. The two 6-month extensions have a potential value of $150 million, increasing the estimated dollar value from $294,882,027 to $444,882,027 and will extend the Period of Performance (PoP) end date from 12/31/2027 to 12/31/2028. The CPAF/CPFF IDIQ contract framework allows for fluctuation in tasks across the METTS scope and remains the most suitable contract type.

During contract performance, the METTS III contract has seen higher-than-anticipated costs/expenses; primarily driven by higher costs of personnel wages because of competitive labor market creating challenges in recruitment and retaining talent. Currently, the METTS III contract is experiencing accelerated cost utilization within its existing scope for Option Periods 3 and 4, due to a significant surge in demand for contractor support on Artemis II (post-launch activities), III, and IV, and Centaur missions. This increase is primarily driven by (1) the Agency’s expedited efforts to return Americans to the Moon, which has intensified mission priorities, expanded workloads across the Center, and directed additional responsibilities to the Contractor; and by (2) higher costs of contractor personnel wages.

Current projections indicate that this heightened demand for Artemis and Centaur support will continue to grow in the coming years and will exceed the remaining PoP and funding capacity of the METTS III contract which will necessitate an extension of the PoP end date (option periods 5 and 6). A breakdown of the sought value ceiling increase is presented in the following table:

strategic imperative for the United States, influencing global leadership in space exploration and advancing scientific and technological innovation for decades to come.

The incumbent contractor, RSi-QT, possesses unique qualifications that cannot be replicated without significant cost and schedule impacts. Since award of METTS III on January 1, 2023, RSi-QT has consistently delivered exceptional performance, averaging approximately work-year equivalents. The contractor has developed deep institutional knowledge of hazardous operations, fabrication, testing, and specialized processes across MSFC’s Engineering Directorate and Facilities Management Office. This expertise enables RSi-QT to execute complex tasks without the learning curve or ramp-up time that a new contractor would require.

Additionally, a notable share of the METTS III effort is aligned with Artemis program objectives, underscoring the criticality of this contract to NASA’s lunar exploration strategy.

This significant allocation of resources reflects the complexity and scope of Artemis-related tasks, including hardware integration, manufacturing support, and post-flight analysis essential for mission assurance. Given that various Artemis and Non-Artemis support activities occur adjacent to one another and can involve multiple interdependent tasks, it is not practical to separate the contract between Artemis and non-Artemis support, as the same workforce supports both types of activities interchangeably. Attempting to bifurcate these efforts by operational performance would introduce inefficiencies, increase administrative burden, and risk disrupting mission-critical work. Maintaining RSi-QT’s involvement ensures that these high-priority tasks are executed without delay, safeguarding national objectives and preserving the integrity of NASA’s schedule for returning humans to the lunar surface.

Transitioning to a new contractor at this juncture would result in unacceptable delays and substantial duplication of cost that cannot be recovered through competition. The nature of the acquisition—continuation of highly specialized services integral to Artemis mission success—requires leveraging the incumbent’s proven capabilities to ensure continuity and avoid disruption. Approval of this extension will guarantee stability in the engineering technician and trades workforce, safeguarding MSFC’s ability to meet Agency objectives and national priorities.

NASA Administrator, Jared Isaacman, issued a new directive February 2026 titled, "Workforce Directive: Restoring NASA’s Core Competencies." This directive establishes actions to rebuild internal talent, strengthen contractual provisions, and foster a culture of technical resilience. Regarding the workforce competency approach for this action, MSFC will manage this as part of the IDIQ requirements for this contract. MSFC will conduct future requirement scaling on IDIQ tasks as core competencies are assessed for option periods.

6. FAR 6.104-1(a)(6) – A description of the efforts made to ensure that offers are solicited from as many potential sources as practicable, including whether a notice was or will be publicized as required by part 5 and, if not, which exception under part 5 applies:

A notice to the Government Point of Entry (GPE) website (Sam.gov) was published on August 22, 2025, in accordance with FAR Part 5.1. This posting informed potential sources of NASA’s intent to award this sole-source modification/extension to RSi-QT, under the METTS III contract number 80MSFC23CA004. The results of this synopsis are summarized in Section 10 below.

7. FAR 6.104-1(a)(7) – A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The Contracting Officer’s signature on this document indicates that the Contracting Officer has determined that the anticipated cost to the Government will be fair and reasonable. The Contractor will be required to submit a proposal to be evaluated and negotiated by the Government. Prior to execution of the contractual instrument, a proposal analysis will be performed, which will ensure that the final agreed-to price for the contract action is fair and reasonable.

The Government has determined that there are sufficient adequate cost data resources available to determine if the anticipated cost is fair and reasonable. Historical costs and financial reports are available for use to assess proposed cost and effort requirements. An Independent Government Cost Estimate will be provided based upon this information to analyze the contractor’s proposal. A team of NASA technical experts will perform a quantitative technical evaluation of the proposed labor, materials, equipment, travel, and training requirements. Costs and labor rates will be evaluated against current market costs and labor rates of a similar nature and experience level.

8. FAR 6.104-1(a)(8) – Description of the market research conducted, and the results, or a statement of the reasons market research was not conducted (e.g., urgent, and compelling requirement):

As stated above in Section 6, a Request for Information (RFI) was published on SAM.gov to gauge the interest and ability of vendors to perform the required services. As a result of the RFI, NASA/MSFC received two (2) submissions deemed responsive.

1) One respondent submitted a capability statement in response to the subject RFI.

However, in evaluating its submission, NASA/MSFC determined that this respondent was not able to perform the requirements of the METTS III contract under NAICS Code 541715, which is the designated NAICS Code for this contract.

2) A second respondent submitted a capability statement in response to the RFI and demonstrated the ability to perform engineering services under NAICS 541715, with strong past performance in CPARS and an apparent ability to meet the Performance

Work Statement (PWS) requirements. Their submission emphasized delivery of high‑value, cost‑effective solutions and the use of advanced risk‑management tools (e.g., Failure Modes and Effects Analysis (FMEA) and Design for Six Sigma (DFSS)).

Notwithstanding these strengths, NASA determined that transitioning to this respondent at this time would introduce material cost, schedule, and mission risk beyond the phase‑in effort is estimated at a minimum of $150,000 and 45 calendar days, reflecting ramp‑up labor, onboarding/badging, training and re‑qualification, re‑establishment of quality and safety controls, and transition management activities. In particular, the respondent does not possess the Centaur specific adapter manufacturing heritage and RUAG adapter testing experience established under METTS III at MSFC, making transition for these campaigns especially high risk from a cost, schedule, and mission assurance standpoint.

The Government could face additional costs potentially reaching into the tens of millions if incumbent personnel are not retained and must be replaced and re‑qualified.

Current incumbent employees possess highly specialized expertise in hazardous chemicals handling, propellant operations, and flight hardware test stand procedures— skills that are mission‑critical and safety‑critical, and that require experience-based currency to perform without increasing risk. The new respondent would also need to rapidly address labor and security prerequisites. If a Collective Bargaining Agreement (CBA) is in effect, immediate negotiation and alignment with successor labor obligations would be required; while nondisplacement policies and Service Contract Labor Standards help preserve workforce continuity, they do not guarantee acceptance of employment offers by incumbents. Additionally, if classified requirements apply, the contractor would need to obtain timely approvals for Visit Access Requests (VAR) and meet DD254‑driven clearance requirements for covered personnel through the cognizant security office. Any delay in securing clearances or badging would further extend the phase‑in timeline and is likely to present mission impact.

Given these factors, there is a high likelihood of a lapse in service if a transition is attempted during this critical time, therefore, a follow-on recompete is not anticipated until fiscal year 2028. A breakdown in these specialized services would directly affect MSFC’s ability to conduct critical operations and flight hardware testing in accordance with safety and mission schedules, thereby jeopardizing Agency mission objectives and national interests. Thus, it is the Government’s determination that the proposed transition would likely result in unacceptable delays and cost duplication not recoverable through competition, and therefore does not represent a prudent course of action at this juncture.

9. FAR 6.104-1(a)(9) – Any other facts supporting the use of other than full and open competition:

None.

10. FAR 6.104-1(a)(10) – A listing of the sources, if any, that expressed an interest in writing in the acquisition:

As stated above in Section 8, a combined RFI/Synopsis was posted on the GPE website (Sam.gov) per FAR Part 5.2 (See Section 6 above). The notice was posted on August 22, 2025, and was closed on September 8, 2025. Below is a list of sources that expressed interest:

• Respondent 1: Respondent 1 submitted a Capability Statement. Upon evaluation, it was determined that this vendor is not able to perform the requirements under the contract’s NAICS Code (541715); therefore, the vendor was determined to not be capable, and the statement was not evaluated further.

• Respondent 2: Respondent 2 submitted a Capability Statement. The statement was evaluated, and the vendor was found to be responsive and capable. However, any transition to a new contractor for an extension would pose the risk of excessive cost and delay to critical programs, due to duplication of effort.

11. FAR 6.104-1(a)(11) – A statement of 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:

In light of the accelerated pace required to meet NASA’s commitment to return Americans to the lunar surface—culminating in the planned 2028 launch of Artemis IV—continuous, uninterrupted contractor support under METTS III is essential. The Artemis II (post-launch activities), III, and IV missions demand a sustained level of technical expertise and mission‑critical execution that cannot tolerate gaps in service or the introduction of schedule risk. Given the volume and complexity of work required to maintain the Artemis III and IV schedules, it is anticipated that the competitive follow‑on acquisition while conducted in parallel, would not be prudent to award during a critical launch period.

Any interruption in support during this period of heightened activity would substantially increase the risk of mission delays, degrade the quality and reliability of engineering technician and trade services, and jeopardize NASA’s ability to meet national objectives tied to the 2028 lunar landing. The incumbent contractor’s unique qualifications, deep institutional knowledge, and proven performance are indispensable to sustaining the accelerated workflow necessary to keep Artemis III and IV on track.

At present, there are no viable alternative solutions capable of assuming these responsibilities without incurring unacceptable cost, schedule, and performance impacts. Nevertheless, the Agency remains committed to maintaining full compliance with competition requirements and will continue to assess the market for emerging capabilities or new sources prior to executing any subsequent acquisitions for these same requirements.

MARSHALL ENGINEERING TECHNICIANS AND TRADES SUPPORT (METTS) III

Contract 80MSFC23CA004

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

I certify that the facts presented in this justification are accurate and complete.

James Booker, ET01 Technical Representative

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

Jane Bush, PS50 Contracting Officer

CONCURRENCES:

Adrian Clayton, PS01 Competition Advocate Marshall Space Flight Center

APPROVAL:

Kristina Parmenter, PS01 Head of Contracting Activity (HCA) Marshall Space Flight Center

Rev.: 4/2026

JAMES

BOOKER

Digitally signed by JAMES

BOOKER

Date: 2026.04.29 10:08:47 -05'00'

Jane Bush Digitally signed by Jane Bush Date: 2026.04.29 10:02:54 -05'00'

Adrian Clayton

Digitally signed by Adrian Clayton Date: 2026.04.30 09:58:24 -05'00'

Kristina Parmenter

Digitally signed by Kristina Parmenter Date: 2026.04.30 13:04:48 -05'00'