JOFOC Starling Follow On_Redacted_06042026.pdf

JOFOC— Page 2 of 6

The statutory authority permitting other than full and open competition is 41 U.S.C. 3304(a)(1), as implemented by FAR 6.103-1, Only one responsible source and no other supplies or services will satisfy agency requirements. This authority was renumbered from the legacy FAR 6.302-1 to FAR 6.103-1 effective March 2026 under the Revolutionary FAR Overhaul.

5. FAR 6.104-1(a)(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 41 U.S.C. 3304(a)(1) and FAR 6.103-1 is that EraDrive, Inc. is the only responsible source capable of performing the required software modifications within the schedule bounded by the Starling mission end-of-life on January 20, 2027.

EraDrive developed and integrated the proprietary StarFOX flight software baseline currently operating on the four Starling CubeSats under predecessor contract 80ARC025CA006. EraDrive owns the source code, build environment, and integration interfaces with the Starling spacecraft avionics necessary to perform the work. These proprietary assets are not available to other contractors.

The institutional knowledge of the software architecture, including the autonomous control algorithms, spacecraft interface protocols, and flight-proven ground testing procedures, resides exclusively with EraDrive personnel who performed the original development and integration. Transfer of the proprietary information to an alternate contractor would require EraDrive's consent under the data rights provisions of the predecessor contract and would introduce schedule delay associated with a new contractor learning the existing software baseline, establishing a build environment, and conducting the ground testing necessary to validate flight readiness.

Within the seven-month period of performance bounded by mission end-of-life, no alternate contractor could perform the work without unacceptable risk to mission outcomes. The mission-driven schedule provides no margin for competitive solicitation lead time or contractor transition activities. Award to any other source would result in unacceptable delays in fulfilling the Agency's requirements under FAR 6.103-1(b)(2).

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 5.1:

A notice to the Government Point of Entry (GPE) website (SAM.gov) was published on April 13, 2026 (Notice ID 80ARC026R0004) and updated on April 26, 2026, in accordance with FAR Subpart 5.1. This posting informed potential sources of NASA's intent to award this sole-source contract to EraDrive, Inc.

and requested capability statements from interested sources demonstrating the ability to perform the requirement within the period of performance constrained by the Starling mission end-of-life of January 20, 2027. The response deadline was April 28, 2026. No responsive capability statements were received establishing an alternative source. The results of this synopsis are summarized in Section 10 below.

JOFOC— Page 5 of 6

Future autonomous spacecraft software acquisitions on different platforms would not face the same barriers because they would not be bound to the proprietary StarFOX baseline or the existing on-orbit hardware. NASA Ames will incorporate lessons learned from the Starling mission into future acquisition strategies, including consideration of Government-purpose rights or unlimited rights to flight software baselines on future missions to preserve competitive options. DRD 005 (Final Rights Assertion and Restricted Computer Software Schedule) under this contract documents the contractor's data rights assertions and provides the Government with visibility into the extent of proprietary restrictions for future acquisition planning.

The Agency will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for similar requirements.