REDACTED GMACC-2 Justification for Other than Full and Open Competition (JOFOC).pdf

Rev.:4/2026

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Glenn Research Center (GRC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Glenn Multiple Award Construction Contract 2 (GMACC-2)

80GRC020D0008

80GRC020D0009

80GRC020D0012

80GRC020D0013

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 National Aeronautics and Space Administration (NASA) Glenn Research Center (GRC).

The procuring agency is NASA, and the contracting activity is GRC.

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

This JOFOC, and a continuation of services, is needed because a follow-on Multiple Award Construction Contract (MACC) will not be ready for award prior to the GMACC-2 Period of Performance (PoP) end date of September 30, 2026.

This justification provides the rationale for contracting by other than full and open competition to award an extension to the following active GMACC-2 contracts:

80GRC020D0008 - PPW Builders, Inc.

80GRC020D0009 - Erie Affiliates, Inc.

80GRC020D0012 - Pinnacle Construction Development Group 80GRC020D0013 - R.J. Runge Company, Inc.

Two (2) six-month extensions are requested to provide time for a follow-on MACC to be developed and awarded. The current GMACC-2 PoP, inclusive of all options and six-month extension, is April 1, 2020, through September 30, 2026. This is a time only extension and the contract value will not be increased. GRC is requesting the following extension periods:

• Initial six-month extension ----------------------- October 01, 2026, through March 31, 2027

• Optional six-month extension ------------------ April 01, 2027, through September 30, 2027

Rev.: 4/2026

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 GMACC-2 contract is needed to meet the continuing construction and facility maintenance requirements at GRC, consisting of both Lewis Field in Cleveland, Ohio and Neil A. Armstrong Test Facility (ATF) in Sandusky, Ohio. GMACC-2 is the primary contract vehicle for GRC’s construction needs and provides new construction, rehabilitation, and modification of facilities and infrastructure, such as:

• Structural: The work activities in this area shall include, but are not limited to, fabrication, rigging, and installation of structural steel, wood, or engineered products.

• Civil: The work activities in this area shall include, but are not limited to, underground infrastructure installation, site development, soil removal, and soil relocation.

• Mechanical: The work activities in this area shall include, but are not limited to, HVAC systems, plumbing systems, gas systems, high- and low-pressure steam systems.

• Electrical: The work activities in this area shall include, but are not limited to, high voltage, low voltage, substations, motors, and process control systems.

• Environmental: The work activities in this area shall include, but are not limited to, hazard assessments, hazardous soil removal, and asbestos, mercury, and lead abatement.

• Architectural: The work activities shall include, but are not limited to, carpentry, finishes, roofing and cabinetry.

• Other Specialized Services: Specialized services shall include, but are not limited to, cryogenic, vacuum, acoustical systems, and other construction related work activities not otherwise mentioned above.

These construction requirements are continuing and ongoing. The two six-month extensions are necessary because a follow-on MACC will not be awarded prior to GMACC-2’s PoP end date of September 30, 2026.

GMACC-2 retains sufficient value to support construction requirements throughout the extension. Facilities Directorate personnel confirmed that the remaining available value is expected to meet all construction needs during the deviation period.

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 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements. The active GMACC-2 contract holders will provide uninterrupted services without substantial duplication of cost and unacceptable delays that would otherwise be incurred if GRC were to award to another source in the interim period.

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 10 U.S.C. 3204(a)(1) is that the active GMACC-2 contract holders are the only responsible source to continue providing the necessary construction services required by the Government until implementation of a follow-on MACC, as described below.

The active GMACC-2 contractors are the only responsible source to provide the essential construction services to GRC during the deviation period. Due to the active GMACC-2 contractor’s distinctive expertise, specialized knowledge, and proven ability to perform these services, they are the sole responsible source to continue the construction services until a follow-on MACC is awarded. Specifically, discontinuing GMACC-2, and attempting to find new contractors without GRC construction experience, will result in substantial construction delays, diminished contractor performance, and elevated project costs. The time that would be required for other contractors to transition into this role is neither practical nor feasible, especially considering the length of the deviation request and the length of time it would take for other contractors to learn and start managing the statement of work requirements. Any expedited phase-in of another contractor without knowledge of unique NASA GRC facilities required to perform these essential services would pose a high probability of a disruption or lapse in services at NASA GRC. Additionally, the phase-in costs could potentially cause undue burden on a small business that they may not recover within the short period of time these services are needed until the follow-on contract is awarded. Thus, attempting to procure these services from other sources for the deviation period requested likely would lead to duplication of costs and unacceptable issues in the performance of construction services at

GRC.

Construction Delays: The active GMACC-2 contracts provide uninterrupted services without delays in fulfilling the Agency’s requirements. A follow-on MACC is not expected to be awarded before the GMACC-2 performance end date, and without the GMACC-2 deviation, necessary construction and maintenance services would have to be procured via individual contracts. Given the compressed GRC construction season during the Summer Shutdown, the time and effort needed to solicit, evaluate, and award separate contracts, rather than streamlined Task Orders, is impractical. Standalone contracts would lead to extended lead times and unacceptable delays in delivering critical facilities support to GRC.

Diminished Contractor Performance: The active GMACC-2 contract holders possess the specialized knowledge and familiarity with the center’s operations required to deliver critical construction services safely and effectively. This institutional knowledge enables the contractors to efficiently complete GRC’s specialized construction projects, such as wind and icing research tunnels, advanced material laboratories, custom propulsion chambers, and cryogenic laboratories, while complying with the applicable Federal, State, and local regulations. Bringing in new contractors at this stage could result in performance and safety concerns, jeopardizing the quality and continuity of the projects, and negatively impact testing and mission. The active GMACC-2 contractors’ experience, knowledge, and capability to deliver these construction services makes them the only responsible source to continue providing these services until a follow-on MACC is awarded.

Elevated Project Costs: Failure to extend the contract would result in substantial duplication of effort and increased costs, as each construction project would require a full and open solicitation rather than issuance through task orders. Awarding to new contractors, not familiar with GRC facilities, would require additional procurement, mobilization, and demobilization efforts, increasing overall project costs. Using the active contracts under GMACC-2, rather than awarding individual contracts, results in significant cost savings because the active GMACC-2 contractors are already familiar with GRC and have been competitively bidding and providing construction services for five years. Extending the active contract avoids unnecessary expenditures and ensures cost-effective and timely project completion.

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 and, if not, which exception under 5.101 applies:

A notice to the Government Point of Entry (GPE) website (SAM.gov) was published on July 1, 2026, in accordance with FAR Subpart 5.1. This posting informed potential sources of NASA’s intent to award a sole source to the active GMACC-2 contract holders. At this time, no SAM.gov responses have been received by the Government.

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 must 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.

Price reasonableness is determined at the TO level. Proposals are evaluated for technical acceptability by the Contracting Officer’s Representative (COR) and Project Engineer/Technical Representative, and a price analysis is conducted by the CO in accordance with Revolutionary FAR Overhaul (RFO) 15.404(a). Based on these evaluations, the price of each TO is determined to be fair and reasonable prior to the award of each TO.

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):

The GMACC-2 deviation relies upon the market research conducted in 2024 and 2025 for the follow-on MACC.

The follow-on MACC market research identified numerous small businesses through a SAM posted sources sought, a query of the Dynamic Small Business Search (DSBS), discussions with NASA construction CORs and Project Managers, and a search of the NASA vendor database. Numerous small businesses were identified, and market research ultimately determined that only a MACC contract vehicle can meet the Government’s construction needs. The market research concluded that separate contracts were not a viable option because individually solicited, evaluated, and awarded contracts would result in delays, reduced performance, and increased costs.

The Government approved the Procurement Strategy Meeting (PSM) for the follow-on MACC and scheduled a tentative award date of September 2026. However, the Agency directed a pause in Source Evaluation Board (SEB) activities regarding the follow-on MACC while the Agency assessed its budget and mission priorities, which consequently has delayed the follow-on MACC. The pause has been lifted, but there is insufficient time to complete the SEB and award the follow-on MACC before September 2026. Based on the above findings, it is determined that only the active GMACC-2 contracts can successfully meet the Government’s requirements.

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:

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). At this time, no SAM.gov responses have been received by the Government.

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. Before or by the end of the deviation period, it is anticipated that a follow-on MACC will be awarded with a start date on or about October 1, 2027. The follow-on MACC will encourage maximum participation and promote competition among small businesses.