80ARC021D0001 - JOFOC_Redacted.pdf

Rev.:10/2025

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):

This JOFOC documents the justification for executing a sole-source extension to the current PESS II contract for a period of up to two years.

The PESS II contract is critical and supports more than twenty (20) active, mission-driven projects at NASA ARC. These include but are not limited to: BioSentinel, IRIS, HelioSwarm, Advanced Composite Solar Sail System (ACS3), Starling, Astrobee, the Spaceflight Autonomous Multigenerational Microbial Sequencer (SAMMS), RADREADS, Luminescence Imager for Exploration (LIfE), Microfluidic Icy-world Chemical Analyzer (MICA), Wide Field of View (WFOV) System Engineering Support, the Lunar Explorer Instrument for space biology Applications (LEIA), Neutron Spectrometer System (NSS) Development, Near Infrared Volatile Spectrometer Subsystem (NIRVSS), CubeSat Laser Infrared Crosslink (CLICK), Extractor for Chemical Analysis of Lipid Biomarkers in Regolith (ExCALiBR), SOAREX/TechEdSat Series projects, the Lunar Flashlight project, and the Advanced Capabilities for Emergency Response Operations (ACERO) project.

PESS II supports critical functions across all project phases, including systems engineering, electrical and mechanical design, bioengineering, thermal and cryogenic systems engineering, software development, IT and cybersecurity, orbital and flight dynamics, fabrication, assembly, and environmental testing of flight hardware. It supports the daily operations of key programs such as the NASA Flight Opportunities Program and the Small Spacecraft and Distributed Systems Program while also supporting a wide range of directorates and divisions, including the Aeronautics, Engineering, Exploration Technology, and Science Directorates at ARC. The contract ensures compliance with NASA Procedural Requirements and mitigates operational risk by maintaining technical continuity and institutional knowledge that are vital to project success and infrastructure readiness.

The PESS II contract provides engineering support services to meet NASA’s mission goals.

It includes requirements for support of the design and proposal of new mission concepts, design, development, manufacture, and demonstration of cost-efficient engineering products.

The contract also provides support in operation of ARC’s critical state of the art research facilities including research laboratories, aerospace/aeronautics facilities (e.g., airfield/hangars, wind tunnels, arc jets, and simulators), computer laboratories, ballistic ranges, general testing facilities, fabrication facilities (e.g., machine shops, metal shops, and model shops), flight/mission operations facilities, and test chambers.

PESS II consists of three components: Contract Management Office (CMO), core requirements, and IDIQ task order requirements. The PESS II CMO requirements provide management and administrative functions necessary to effectively and efficiently manage the work performed under this contract for Core Requirements and IDIQ Task Orders. The PESS II Core and IDIQ task order requirements support three main areas: Projects/Facilities;

Project Support; and Metal Fabrication, Machining, and Instrumentation. Core Requirements contain multiple sub-elements (work packages) and are based on the period of performance for the base and option periods. Due to the dynamic nature of R&D, the contract will experience variations in workload. IDIQ task order requirements are within the scope of the SOW but are presently undefined and will accommodate changes in the Center’s program, project, research, and budget requirements over time. The period of performance for the IDIQ task order requirements will be specified in the individual task orders.

needed for continued mission success. It maintains specialized institutional knowledge crucial to supporting existing NASA projects, including advanced engineering practices and proprietary technical methodologies.

Transitioning to a new contractor at this critical juncture would introduce significant operational risk and disruption, potentially jeopardizing mission timelines, technical integrity, and project outcomes. No other source currently possesses the combined specific experience, highly specialized personnel, or the proven capability to seamlessly continue performance without substantial delays or risk to mission-critical objectives.

In accordance with FAR 6.103-1 authority, NASA requires continuation of these specialized project and engineering support services from the incumbent contractor to ensure mission continuity, maintain established operational standards, and avoid unacceptable delays or risks associated with transitioning these highly specialized tasks to a new provider. This extension is required to ensure the continuity of engineering tasks that support ARC’s critical programs contract while follow-on solutions are strategized to adhere to streamlining and efficient contracting through strategic contracting vehicles in support of administrative order initiatives which experienced delays due to lapse in appropriations.

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 Subpart 5.2 and, if not, which exception under 5.202 applies:

A notice to the Governmentwide Point of Entry (GPE) website (Sam.gov) was published on April 1, 2025, in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to award this sole-source extension to Millennium Engineering and Integration Services, LLC. The results of this synopsis are summarized in Sections 6,8, and 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 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 analysis of the proposal for the contract extension will be conducted in accordance with FAR 15.404, and include a detailed cost element analysis, a comparison to the IGCE, and other appropriate cost and price evaluation techniques to ensure the final agreed-to cost and fee is fair and reasonable. Pre-negotiation objectives will be prepared prior to the initiation of negotiations and will be approved in accordance with FAR 15.406 prior to the conduct of negotiations. In accordance with FAR 15.406, a certificate of current cost or pricing data will be obtained from the contractor as required and a price negotiation memorandum will also be prepared to document the outcome of the negotiation.

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):

Market research was performed in April 2025, which included a synopsis posted to the Governmentwide Point of Entry (GPE) Sam.gov on April 1, 2025. The purpose of the synopsis was to: (1) notify industry of NASA’s intent to extend the PESS II contract on a sole-source basis; and (2) solicit information about interested sources that can provide the required support during the extended period of performance. Interested parties were requested to submit their capabilities and qualifications in writing. The Contract Specialist received two responses to the notice of intent. The first was from Black Light Consultation, a Minority-owned, Service-Disabled Veteran-Owned, and Veteran-Owned business. The results of this synopsis are summarized in Section 10 below.

The second response came from Nine East Tech Services, a women-owned small business.

This vendor submitted a capability statement; however, their communication primarily expressed interest in collaborating with MEIS rather than addressing the specific requirements. Upon review of their submission, it was concluded that the vendor does not have the necessary capabilities to fulfill a majority of the requirement.

Additional research was completed which included reviews of the following Government databases:

A search was conducted in the Small Business Administration (SBA) Dynamic Small Business Search (DSBS) database using the NAICS Code 541715 with the key words “research and development engineering”. The search yielded one SB companies’ results:

Paladin Robotics Inc. Upon technical review of the profiles and capabilities narrative, this company has limited capabilities that does not demonstrate the full range of the PESS II technical work requirement.

A search of the NASA Vendor Database (NVDB) was conducted using NAICS code 541715 with the keyword " Research and Development Engineering." This search yielded no results.

Contractdirectory.gov - Performed a search on the Interagency Contract Directory Portal using the keyword "Research and Development Engineering". The search returned no results.

Based on the review of the Market Research Results, it is clear that while there are engineering firms in the industry, the scope of highly specialized work that is required can only be accomplished by the current contractor under the proposed extension without creating unacceptable delays in fulfilling the agency's requirements.

A NASA Form (NF) 1787A was prepared to document the Market Research conducted and was routed to the ARC Small Business Specialist for concurrence.

Market research indicates that in accordance with FAR 6.302-1(a)(2)(iii)(B), MEIS is the only responsible source that can provide the highly specialized services described in Section 5 above without creating unacceptable delays in meeting mission critical agency requirements.

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

FAR 6.103-1(c)(2)(ii):

Conducting an additional competition for a two-year bridge contract would require additional technical, procurement, legal, etc. personnel which would result in substantial duplication of cost. An estimated rough order of magnitude (ROM) for these additional costs is $2M as derived by applying the NASA agency agreement indirect rate of 4% to the estimated value of a two-year bridge contract. In addition, programmatic costs would include the retraining of personnel, redevelopment of proprietary technical documentation and processes, onboarding, and transition inefficiencies. Based on historical transition costs from similar NASA acquisitions, the duplicated cost for this size of contract is estimated to be in the range of several million dollars, encompassing both direct costs such as training and indirect costs like loss of productivity and delays in project timelines. These costs associated with the acquisition process for a bridge contract represent a substantial duplication of cost to the Government that is not expected to be recovered through competition. Therefore, MEIS is the only responsible source via this extension to the current PESS II contract that can reasonably satisfy the current requirements.

If this contract extension action is not executed, NASA faces potential significant disruption to ongoing project schedules, technical integrity, and mission-critical milestones. Failure to execute the contract extension would likely result in substantial operational harm, such as delays in key project timelines, loss of critical institutional knowledge, and negative impacts on technical capability and mission outcomes. These disruptions represent not only financial harm but also considerable risk to mission success, justifying the critical necessity of extending the incumbent contractor’s performance to maintain continuity and operational integrity.

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

A notice of NASA’s intent to award this sole-source action was synopsized on the GPE website (Sam.gov) per FAR Subpart 5.2 (See Section 6 above). The notice was posted on April 1, 2025, with a closing date of April 15, 2025. As noted in Section 8, two responses were received. The first was from Black Light Consultation, a Minority American-owned, Service-Disabled Veteran-Owned, and Veteran-Owned business. The company’s capabilities were reviewed, and it was determined that the company primarily offers cybersecurity consulting services and does not possess the full range of capabilities to meet the complex engineering scope of work required on PESS II.

The second response was submitted by Nine East Tech Services, a women-owned small business. While this vendor did provide a capability statement, their communication focused more on exploring a potential collaboration with MEIS rather than addressing the specific requirements outlined in the notice. After reviewing the submission, it was determined that the vendor does not possess the necessary capabilities to meet all aspects of the requirement.

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:

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.