15. 195A_ D-Code Final Signed Justification for Other than Full and Open Competition (JOFOC)-Ball_Aerospace 12062023.pdf

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Rev.:4/2023

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Marshall Space Flight Center (MSFC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Imaging X-ray Polarimetry Explorer (IXPE) / Contract NNM15AA18C

1. Federal Acquisition Regulation (FAR) 6.303-2(b)(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 National Aeronautics and Space Administration (NASA) George C. Marshall Space Flight Center (MSFC).

The procuring agency is the National Aeronautics and Space Administration (NASA) and the contracting activity is George C. Marshall Space Flight Center (MSFC).

2. FAR 6.303-2(b)(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 an extension to contract number NNM15AA18C with Ball Aerospace for the Imaging X-ray Polarimetry Explorer (IXPE) project. The current period of performance ends July 9, 2024, and this action seeks to extend the contract out through April 1, 2026. This period of performance adjustment is a result of a 20-month extension approved by NASA Headquarters (HQ) as a result of the Mission Success Performance Review that was conducted in May 2023 (see attached “IXPE End of Prime Mission” memo from HQ SMD/Astrophysics Division Director). During the extension period, mission operations will support an IXPE General Observer (GO) program (also known as Guest Observers Program) with proposals being solicited openly through the Research Opportunity for Space and Earth Science (ROSES) solicitation. Ball contractual requirements and interfaces will remain unchanged and consistent with current effort being performed by the contractor under the baseline mission.

3. FAR 6.303-2(b)(3) – A description of the supplies or services required, to meet the

Agency’s needs (including the estimated value):

The IXPE project is continuing its study of X-ray production in stellar object, including neutron stars, nebulae and supermassive black holes. To that end, IXPE seeks to maintain and develop its current lines of communication for the proper and efficient selection of stellar targets for observation as well as the continued development of neural networking techniques to improve IXPE’s polarization sensitivity.

As a result of the 20-month extension to the IXPE contract, Ball Aerospace will continue to provide mission operations leadership, and planning, with mission operations execution through a Ball subcontract with University of Colorado, Center for Atmospheric and Space Physics. The prime contract also includes Ball Aerospace subject matter experts on the spacecraft to support data trending analysis, provide anomaly support and develop corrective actions, and assess spacecraft subsystem health. The estimated value for the 20-month Phase E extension is $6M. A 6-month Phase F shutdown period will follow the Phase E extension, which was a part of the baseline mission plan.

4. FAR 6.303-2(b)(4) – An identification of the statutory authority permitting other than full and open competition:

The statutory authority permitting other than full and open competition is 10 U.S.C.

3204(a)(1), as implemented by FAR 6.302-1, Only one responsible source and no other supplies or services will satisfy agency requirements. In accordance with FAR 6.302-1, services may be deemed to be available only from the original source in the case of a follow-on contract for the continued provision of specialized services when it is likely that award to any other source would result in substantial duplication of cost to the Government that is not expected to be recovered through competition.

5. FAR 6.303-2(b)(5) – A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

The rationale supporting the use of 10 U.S.C. 3204(a)(1), is as described below:

The IXPE satellite bus was developed by Ball Aerospace, and the mission operations team has extensive expertise on the Ball Configurable Platform (BCP)-small spacecraft platform and how it functions, to include knowledge of Ball Aerospace-proprietary Flight Software (FSW). Ball Aerospace responsible engineers also possess unique expertise gained through development, design reviews, testing, and 21-months of mission operations experience with this satellite.

Ball Aerospace maintains a shared-use mission critical spacecraft software test bench (i.e., partial spacecraft simulator) that replicates the spacecraft avionics and is used to validate changes to software and procedures prior to uploading to the spacecraft. Introducing a new contractor would create a significant cost impact to the project to develop a duplicate operations center in parallel to continuing mission operations for the mission through the Ball Aerospace contract. MSFC would also need to purchase a duplicate software test bench, proprietary to Ball, that can be used by an alternate operations center (or MSFC). This is standard practice for mission operations to validate commanding on the ground as risk reduction to the mission, so that first-use of the commands/procedure aren’t tested on the flight Observatory.

Ball Aerospace provides the IXPE Mission Operations Center through its subcontract with The University of Colorado’s (CU) Laboratory for Atmospheric and Space Physics (LASP) CU- LASP, its Mission Operations Partner’s facility. CU-LASP has existing ground hardware, ground software, and software tools to operate the satellite. The cost to operate the satellite through CU- LASP is very low because of the staffing concept enabled by the software tools at CU-LASP and use of students to supplement the operations team.

Based on the experience transitioning the Chandra mission to an alternate mission operations center, it would take approximately 2 years to develop the system and transition mission operations. This would also include an overlap “checkout” period (approximately 3 months) until the new system would be deemed operational. There would certainly be a loss of mission-specific knowledge and FSW expertise that would be a risk to successful mission execution after a transition. The IXPE mission operations concept relies heavily on existing tools and ground software to allow for automated ground contacts during unstaffed night and weekend shifts. This would all have to be duplicated for a new mission operations center and extensive knowledge of the IXPE Ball-proprietary flight software would also be required. If the project had to develop an alternate mission operations center and transition operations, the estimated cost of duplicated work that could not be recovered through competition would be more than $5M.

6. FAR 6.303-2(b)(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 Subpart 5.2 and, if not, which exception under 5.202 applies:

A notice to the Government Point of Entry (GPE) website (Sam.gov) was published October 11, 2023 through October 26, 2023, in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to award this sole-source extension to Ball Aerospace. The results of this synopsis are summarized in Section 10 below.

7. FAR 6.303-2(b)(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 shall 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. The proposal analysis will ensure that the final agreed-to price for the contract action is fair and reasonable. The negotiation and establishment of a fair and reasonable price will be done in accordance with FAR Part 15. Additionally a Certificate of Current Cost or Pricing Data will be obtained.

8. FAR 6.303-2(b)(8) – Description of the market research conducted, and the results, or a statement of the reasons market research was not conducted:

This action is for an extension to an existing contract that was awarded competitively, which included a potential 12- month extension as part of the original solicitation. The planned 20-month extension leaves an 8-month gap, which is not covered by the original solicitation.

Market research was conducted via publication to the Government Point of Entry (GPE) website (Sam.gov) from October 11, 2023 through October 26, 2023, in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to award this sole source extension to Ball Aerospace. Two interested parties requested consideration. One company was not considered further based on their company's business focus IT solutions, and the other company is a Small Business and HUBZone Certified whose capability statement was provided to the IXPE contractors for their consideration in subcontracting opportunities.

The spacecraft provider, Ball Aerospace, was competitively selected by the NASA Science Mission Directorate (SMD) after releasing the Announcement of Opportunity (AO)- Astrophysics Explorers Program-NNH14ZDA013O to solicit Principal Investigator (PI)-led space science investigations for the Astrophysics Explorers Program. Response to this solicitation served as the basis for a more detailed interaction including site visits with all interested parties that replied and could provide the services necessary for the proposal in response to 2014 Small Explorer’s Program Announcement of Opportunity-NNH14ZDA013O.

Based on the 3 subsequent responses received, Ball was selected as the IXPE industrial partner.

The Mission Operations Partner, CU-LASP, was selected based on a competition and Request for Information (RFI) sent to several potential mission operations partners who had expressed interest in participating in the mission. The responses to the RFI served as the basis for the choice of partner. Ball Aerospace and CU-LASP were critical partners that were included in the IXPE 2-Step selection process which ultimately led to the prime-subcontractor relationship that currently exists.

9. FAR 6.303-2(b)(9) – Any other facts supporting the use of other than full and open competition:

No technical data packages, specifications, engineering description, statements of work, or purchase descriptions suitable for full and open competition have been developed. Given the nature of the IXPE program, the maturity level, and the collaboration between the IXPE partners to fulfill the program requirements, full and open competition is not a viable solution.

If the project had to develop an alternate mission operations center and transition operations, the estimated cost of duplicated work that could not be recovered during the 20-month period would be more than $5M above the $6M Government estimate for a total of $11M to perform the scope as indicated below.

Mission Operations Center development: >$3M Development of a software test bench: $750K-$1M (components are long-lead items) Training/certification of new operations team members: $250K (2 months training/rehearsals/certification X 11 personnel) Checkout period where mission operations centers overlap (estimated at $300K per month x 3 months): $900K

10. FAR 6.303-2(b)(10) – A listing of the sources, if any, that expressed an interest in writing in the acquisition:

A notice to the Government Point of Entry (GPE) website (Sam.gov) was published October 11, 2023 through October 26, 2023, in accordance with FAR Subpart 5.2 (See Section 6 above). This posting informed potential sources of NASA's intent to award this sole-source extension to Ball Aerospace.

Two interested parties requested consideration:

• KPaul: a Service-Disabled Veteran-Owned Small Business was not considered further as their focus was on IT solutions.

• The Bailey Collaborative Solutions (BCS): BCS is a Small Business and HUBZone Certified. The BCS capability statement was provided to the IXPE contractors for their consideration in subcontracting opportunities.

11. FAR 6.303-2(b)(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:

There are no other actions the Agency may take to remove or overcome barriers to competition for this lifecycle mission. The Agency will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements.

Imaging X-ray Polarimetry Explorer (IXPE) / Contract NNM15AA18C

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

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

AMY

WALDEN

Digitally signed by AMY

WALDEN

Date: 2023.11.15 09:52:34 -06'00'

Amy L. Walden, IXPE Project Manager Technical Representative

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

Mary Cooper

Digitally signed by Mary Cooper Date: 2023.11.15 13:23:57 -06'00'

Kathryn Cooper Contracting Officer

CONCURRENCE:

Jennifer Mccaghren

Digitally signed by Jennifer Mccaghren Date: 2023.12.06 15:53:11 -06'00'

Jennifer B. McCaghren Division Director Space Systems & Human Exploration Development and Operations Division

John Cannaday

Digitally signed by John Cannaday Date: 2023.12.11 15:18:20 -06'00'

John E. Cannaday Director Office of Procurement

APPROVED:

Joe L. Leopard Competition Advocate Associate Director Marshall Space Flight Center