JOFOC JA-FY25-J13 REDACTED.pdf

Rev.:9/2025

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Ames Research Center (ARC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Material Property Testing of Thermal Protection System (TPS) Materials Blanket Purchase Agreement (BPA) 80ARC023AA001

1. Federal Acquisition Regulation (FAR) 6.104-1(a)(1) Identification of the agency and for other than full and open

This document is a justification for other than full and open competition prepared by National Aeronautics and Space Administration (NASA), Ames Research Center (ARC).

The procuring agency is the NASA, and the contracting activity is ARC Code JAI. This JOFOC is recorded in the ARC JOFOC Log as JA-FY25-J13.

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 an increase in the ceiling value for BPA 80ARC023AA001 with KRATOS Defense & Rocket Support Services, Inc. (KRATOS) located at 10680 Treena Street, 6th Floor, San Diego CA. The total current maximum value of this BPA is $2,450,000.00. The current period of performance is November 7, 2022, through November 6, 2027. An estimated increase in value is for an additional $4,550,000.00 which changes the maximum value for this BPA to $7,000,000.00.

ARC awarded this BPA 80ARC023AA001 sole source to KRATOS on November 7, 2022, to conduct high quality and high accuracy material property characterization of NASA-provided TPS materials ranging from low density conformable or flexible materials to fully densified composites. The testing will support the Entry Systems and Technology (TS) Division at ARC including but not limited to the following projects: the Mars Sample Return Earth Entry System Aeroshell TPS (MSR EEV TPS) project, the Phenolic Impregnated Carbon Ablator -Domestic (PICA-D) project, the Conformal PICA (C-PICA) project, and the Orion/Artemis project and various internal research and development (IRAD) projects within TS Division. A JOFOC was approved on September 14, 2022 for the sole source award to KRATOS with a five-year period of performance and a maximum value of $2,450,000.00.

3. FAR 6.104-1(a)(3) A description of the supplies or services required, to meet the

Currently, five BPA calls have been awarded under this BPA with the following original amounts:

- BPA Call#1, 80ARC023FA002, to conduct high quality and high accuracy material property characterization of NASA-provided 3D Mid Density Carbon Phenolic (3MDCP)

Rev.: 9/2025

TPS materials and its constituents for the Mars Sample Return (MSR) Earthly Entry System (EES) project, awarded at $734,900.00.

- BPA Call #2 80ARC023FA007 to conduct high quality and high accuracy material property characterization of NASA-provided C-PICA for the Thermal Protection Materials and Systems Branch, awarded at $159,104.00.

- BPA Call #3 80ARC023FA046 to conduct high quality and high accuracy material property characterization of NASA-provided PICA-D for the Thermal Protection Materials and Systems Branch, awarded at $635,885.00.

- BPA Call #4 80ARC024FA015 to determine the susceptibility of virgin and charred Avcoat TPS to the passage of high-pressure gases through the material and thermal conductivity in the through the thickness (TTT) material orientations for NASA Shared Services Center (NSSC) awarded at $144,591.08.

- BPA Call #5 80ARC025FA044 to conduct thermal characterization testing on the permeable molded Avcoat for the NASA Orion project awarded at $284,728.35.

Total for all BPA Calls is $1,959,208.43.

The increase in the maximum value of $4,550,000.00 (from $2,450,000.00 to $7,000,000.00) will allocate adequate contract value to enable NASA ARC to expand upon the testing of identified properties to increase statistical significance; reduce errors in the reported results;

and to benefit flight projects by increasing material property modeling fidelity.

4. FAR 6.104-1(a)(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 6.103-1, Only one responsible source and no other supplies or services will satisfy agency requirements.

5. FAR 6.104-1(a)(5) 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), as implemented by FAR 6.103-1, only one responsible source and no other supplies or services will satisfy agency requirements, is as described below.

ARC has previously awarded five BPA Calls to KRATOS as shown in Section 3 above.

Additional testing within scope of several of those BPA Calls require additional costs above the original approved JOFOC value of $2,450,000.00 in order to meet the Government requirement.

To ensure the continuity of test results, prior test results will be compared with results of current testing for the same or similar materials. Past experience within the ARC technical organization shows that when different facilities test materials with nominally the same techniques, they get different results since there are nuances the testing requires that comes only through experience. No other contractor has the past experience testing of these unique TPS materials that have significant flight heritage on NASA missions that have flown in space. The continuity between test procedures used on same or similar materials in previous material performance with existing NASA databases and material response models, thus reducing programmatic risk.

KRATOS is the only US company with the facilities and personnel with technical skills capable of providing reduced pressure guarded hot plate (GHP) testing and comparative rod (CR) tests for materials of low thermal conductivity (<0.09 W/m*K). An example of KRATOS s unique (built in-house) testing capabilities includes tensile test fixtures with air bearings for 100% frictionless alignment for high accuracy mechanical testing. The techniques and in-house equipment KRATOS have developed are not known to exist anywhere else in the United States.

Because of the need to maintain traceability of new/developmental TPS materials with materials that have flight heritage, NASA requires special attention to quality assurance during the course of current and future test efforts. KRATOS has the requisite process

-D, HEEET, etc.) immediately without the need to purchase and/or modify capital equipment or facilities. This capability will allow NASA to meet critical SMD milestones in support of the Mars Sample Return (MSR) Earth Entry Vehicle (EEV), MSR Sample Return Lander (SRL) and Dragonfly projects.

In summary, no other contractor can provide the unique facilities, technical capabilities, and associated engineering experience by the NASA need dates currently required by the various projects as mentioned in section 2, which are expected to launch in year 2025-2026.

Therefore, it is reasonable to conclude that the TPS testing requirements of NASA ARC can only be satisfied by the unique capabilities available from only one responsible source, KRATOS.

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 26, 2025 in accordance with FAR part 5. This posting informed potential sources of increase the ceiling of the BPA which was awarded as a sole-source BPA to KRATOS of San Diego. 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:

(CO) signature on this document indicates that the CO has determined that the anticipated cost to the government will be fair and reasonable. The basic agreement already includes a Firm, fixed-priced (FFP) pricing list for the test procedures anticipated to be ordered by NASA ARC for the remaining two years of performance of the BPA. Also, prior to executing each FFP BPA call, the Contractor shall be required to submit a proposal to be evaluated and negotiated by the Government. Certified pricing data will not be required since the exception at FAR 15.403-1(b)(3) applies. However, the CO will require the contractor to submit sufficient information to evaluate, through price analysis, the reasonableness of the prices of the commercial testing services, in accordance with FAR 15.403-1(c)(3)(ii). The price analysis will be performed by comparison of the proposed prices to historical prices paid by the Government in accordance with FAR 15.404-1(b)(2).

The price analysis will ensure that the final agreed-to-price 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. Price Negotiation Memoranda will be drafted and approved following the completion of negotiations prior to each BPA call being awarded.

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 at the end of August 2025 through September 2025 which included a sources sought notice posted in the GPE Sam.gov on August 26, 2025, as stated in Section 6 above. The purpose of the synopsis was to increase the ceiling of the sole sourced BPA awarded to KRATOS.

The CO received three capability statements in response to the synopsis one from KRATOS, one from BHPE LLC (BHPE) and one from Sure-Biochem Laboratories, LLC (SBL). Of the three statements, only KRATOS can perform the work required. BHPE is a private equity firm and while they are registered in SAM their website did not list any of the required test capabilities needed under this BPA. Similarly, with SBL, their services listed were for chemistry testing, particle counting, bacterial and pathogenic testing also none of which are thermo/physical properties required by NASA. In summary, the capabilities statements submitted by BHPE and SBL combined with the reviews of publicly available data on the website did not demonstrate their ability to perform the NASA requirements by the need dates.

Additional research was completed which included a search in the following databases:

- Department of Veterans Affairs website (www.vetbiz.va.gov) for any potential vendors who had experience with Federal contracting, using NAICS code 541380 and key words

0 results.

awardee, KRATOS.

multiple award contracts and OASIS but none of the listed companies are capable of completing the requirement.

After reviewing the market research r are additional firms in the industry, unique facilities and specialized TPS materials are crucial to complete this requirement.

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

In accordance with FAR 6.103-1(c)(2), for DoD, NASA, and the Coast Guard, services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in substantial duplication of costs to the Government that is not expected to be recovered through competition, or unacceptable delays in fulfilling the responsible source that can reasonably satisfy the requirements.

The existing BPA has BPA Calls that will take another year to complete. Conducting a competition would incur delays in ongoing testing and would cause unacceptable delays in

ARC will save a considerable amount of time, which can typically take 120 days for competitive procurement of the same value and complexity. No single vendor can perform all of the requested testing that KRATOS can. A minimum of three separate contracts would need to be awarded to cover the testing that can all be done by KRATOS. Conducting a single competition would incur approximately $107,694.00.

Therefore, to award three independent contracts to cover the testing services that KRATOS can perform would cost the government 3 x $107,694 or approximately $323,082.

Additionally, these costs, along with the learning curve and replication of work KRATOS has already performed, would result in duplication of costs, if awarded to any other contractor, that would not be recovered through competition.

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 intent to award this sole-source action was synopsized on the GPE website (Sam.gov) per FAR part 5 (See Section 6 above). The synopsis provided instructions for interested organizations to submit capabilities and qualifications to perform the requirements. The synopsis was posted on August 26, 2025 with a response/closing date of September 4, 2025. The Government received three capability statements in response to the synopsis 1 from KRATOS, 1 from BHPE LLC and 1 from Sure-Biochem Laboratories, LLC. Of the three companies, only KRATOS can perform the work required. BHPE LLC is a private equity firm and while they are registered in SAM, their website did not list any of the required test capabilities needed under this BPA. Similarly with Sure Biochem their services listed were for chemistry testing, particle counting, bacterial and pathogenic testing also none of which are thermo/physical properties required by NASA.

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.

Material Property Testing of Thermal Protection System (TPS) Materials Blanket Purchase Agreement (BPA) 80ARC023AA001

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

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

Matthew J. Gasch Technical Representative

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

Wilma L. Estrada Contracting Officer

APPROVED:

Lauren Johnson Competition Advocate Ames Research Center