80GSFC17C0015 P00111_JOFOC_FE.pdf

Rev.:5/2024

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Goddard Space Flight Center (GSFC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Safety and Mission Assurance Services II (SMAS II)/80GSFC17C0015

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) Goddard Space Flight Center

(GSFC).

The procuring agency is the National Aeronautics and Space Administration (NASA) and the contracting activity is GSFC.

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 extend contract number 80GSFC17C0015 with Axient LLC for continuation of services.

SMAS II ends May 31, 2025. GSFC must extend the current contract effective ordering period by an additional six (6) months to November 30, 2025, while the Government Accountability Office adjudicates the protest of its follow-on contract, SMAS III. The estimated resolution date for the protest is July 30, 2025.

The SMAS II contract provides Safety and Mission Assurance (SMA) services to GSFC’s programs and projects, and a lapse in service would incur unacceptable delays and mission risk to all current and upcoming projects. Significant delays would occur in the development of flight, ground, instrument, and launch systems, including the launch operations resulting in unacceptable programmatic risk and financial losses.

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 scope of work of the existing contract requires the contractor to provide on/off site mission assurance services, pursuant to task orders issued by the Contracting Officer (CO).

These services include the personnel, facilities, and materials (unless otherwise provided by the Government) to accomplish the tasks.

SMAS II services support flight projects such as Origins, Spectral Interpretation, Resource Identification, Security-Regolith Explorer (OSIRIS-REx), the James Webb Space Telescope, and NASA collaborations with the National Oceanic and Atmospheric Administration, including the Joint Polar Satellite System-1(JPSS-1) and Geostationary Operational Environmental Satellite (GOES) program. Other supported projects include the Wide Field Infrared Survey Telescope (WFIRST), the robotic satellite servicing spacecraft Restore-L, and NASA’s most advanced global ocean color and aerosol mission to date, the Plankton, Aerosol, Cloud, ocean Ecosystem (PACE) satellite.

The services that Axient LLC will provide during the 6-month ordering period extension are for a continuation of these services under the existing contract. The current maximum ordering value is $188M, with total obligations of $158M, as of the latest modification P00108. The estimated value to cover 6-month extension is $13M and there is $30M in available ceiling. Therefore, an increase to the maximum ordering value is not required to cover the extension.

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 will satisfy agency requirements.

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 only one responsible source, and no other type of service will satisfy the needs of the agency as described below.

A sole source award is necessary due to the nature of the work to be performed under this contract. Axient LLC has the combined training, experience, work force, and expertise to provide uninterrupted continuation of mission critical support. This mission critical support provides systems reviews, systems safety, reliability, software assurance, quality assurance, audits and assessments and related services, to numerous NASA/GSFC programs and projects, including flight projects that are currently under development and in operation.

Flight project schedules would be negatively impacted due to the transition to a new management team, staff, schedules, systems, and time it would take for phase-in and to gain the expertise needed to fulfill the requirements of NASA/GSFC’s missions. For example, the Space Weather Follow On – L1 (SWFO-L1) mission is scheduled for launch September 2025. Any interruptions of mission support due to lack of experience, expertise, and training will threaten this launch date. This would not only impact NASA/GSFC, but also all collaborated efforts coordinated with other agencies, especially NOAA.

If NASA/GSFC attempts to procure these services from any other source for this interim period, it would cause a lapse in service that will incur unacceptable delays and mission risk to all current and upcoming projects. Roman Space Telescope (RST) is a complex space telescope that is going through extensive testing. Knowledge of its systems, history, and risk factors are key elements to meeting schedule deadlines, cost constraints, and technical risk management. Staffing from other sources will not have the knowledge and expertise in RST’s systems. Decisions have to be made on a daily basis about testing anomalies, manufacturing defects, etc. that require this knowledge and expertise. Significant delays would occur in the development of flight, ground, instrument, and launch systems, including the launch operations resulting in unacceptable programmatic risk and financial losses.

Specifically, such delays would directly affect the design and development of systems associated with Roman Space Telescope (RST), software assurance support for the Dragonfly mission, Senior Review Board Support for the Multi-slit Solar Explorer (MUSE) and Compton Spectrometer and Imager (COSI) missions, and management systems quality engineering and auditing support (MSQE) for the Joint Polar Satellite System (JPSS).

Projects such as these have been in the design and fabrication stages for years with an extensive history of issues, risk mitigations, and corrective actions that have been required.

These projects have extremely tight budget and schedule restrictions. Flight project schedules would be negatively impacted due to the transition to a new management team, staff, schedules, systems, and time it would take for phase-in and to gain the expertise needed to fulfill the requirements of NASA/GSFC’s missions. New staffing would require many months to learn the systems and would drastically affect the projects’ budget plans and schedules. In each instance, failure to avoid a break in service would dictate harmful schedule delays and cost growth impacts.

Additionally, the SMAS III follow-on contract has been protested and due for adjudication no-later-than July 30, 2025. The protest timeline plus phase-in period would cause a lapse in services that would further aggravate the aforementioned risks. Therefore, Axient LLC is the only responsible source with the combined training, experience, work force, and expertise to successfully perform through the protest period.

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 on April 29, 2025, in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to award this sole-source extension to Axient LLC. 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 awarding Contracting Officer’s (CO) fair and reasonable determination still stands, as Contract Year (CY) 6 rates cover performance through November 30, 2025; therefore, CY6 rates proposed at award were already analyzed, evaluated, and competitively awarded. The awarded CY6 rates cover this extension period and no further determination is needed.

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 (e.g., urgent, and compelling requirement):

The awarding CO’s market research and source evaluation from award still stands, as CY6 performance will cover this extension through November 30, 2025; therefore, the market research, analysis, and evaluation is still applicable to this action and no further analysis is needed.

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

None.

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 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 synopsis was posted April 29, 2025, and closed May 15, 2025. There were no interested party responses received.

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 barriers to competition for these services. The follow-on for SMAS II (SMAS III) was competitively awarded but halted for protested. This action will have no effect on future actions and no further action is required to remove barriers to future competitions.

Safety and Mission Assurance Services II (SMAS II)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

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

Tray Eason Technical Representative

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

APPROVED:

Anthony Z. Lyas Jr.

Contracting Officer