JOFOC_FDSS III Extension FINAL.pdf

Rev.:5/2024

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

GODDARD SPACE FLIGHT CENTER (GSFC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For FLIGHT DYNAMICS SUPPORT SERVICES (FDSS III) 80GSFC19C0072

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.

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

Space Flight Center.

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 award an extension to contract number 80GSFC19C0072, with OPR, LLC for a period of six (6) months. The estimated value of this extension is $19,800,000.00, which can be absorbed in the current maximum ordering value. The Flight Dynamics Support

Services (FDSS) III contract currently expires on April 30, 2025. Award of the FDSS IV contract was originally anticipated to occur February 2025, followed by a 60-day phase-in period resulting in an estimated effective date in April 2025.

The contract extension period requested herein is based on the need to continue performance and critical support as a result of the delayed award of the follow–on contract, FDSS IV, because of the government proactively taking tangible steps to encourage a wider range of companies to bid as well as a pertained change in the North American Industry Classification

(NAICS) code from previous FDSS iterations. As these changes are identified below:

1. Previous FDSS iterations reflected the NAICS code titled 541330 Engineering

Services with Exception 1 (Military and Aerospace Equipment). It was determined that NAICS code 541330 Engineering Services without the exception is the appropriate NAICS code to utilize.

2. Orbital Safety Analysis (OSA) work on the current FDSS-III contract was identified as a competition barrier given the highly specialized technical expertise required and the corresponding Department of Defense security clearance requirements. As such the government removed this work from the FDSS-IV SOW and it will be its own sole source procurement.

3. The Draft Request For Proposal (DRFP) was released on July 8, 2024, and Industry

Day was held on July 17, 2024. Based on Industry feedback the Government assessed certain areas of the DRFP and as a result determined that the DRFP would be canceled and released at a later date. Some of the DRFP revised areas included the following:

a. Transitioning from three Representative Task Orders (RTOs) to two Scenarios

b. Removing instructions that offerors are to respond to ALL areas of the SOW and limit it to the critical areas.

c. Reduce the past performance threshold from $5M average annual cost to

$2.5M

Based on the above, it is anticipated that the follow-on contract will now be awarded by

August 30, 2025, with a 60-day phase-in period ending October 30, 2025, and an estimated contract effective date of October 31, 2025. This extension will allow for continued performance and continuation of mission critical services under the FDSS III contract through October 2025.

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 principal purpose of this contract is to provide Flight Dynamics Support Services (FDSS) for the Navigation and Mission Design Branch (NMDB) and the Attitude Control Systems

Engineering Branch (ACSEB) within the Mission Engineering and Systems Analysis (MESA)

Division at GSFC. The NMDB flight dynamics support services provide for the planning, designing, implementation, enhancement, evaluation, integration, testing and conducting of the flight dynamics services and systems provided at GSFC. The flight dynamics discipline support includes spacecraft navigation (orbit determination), trajectory control, mission design, attitude determination, attitude dynamics and attitude control. Operational mission support and network services are also provided. Flight dynamics mission support efforts involve the determination of mission flight dynamics requirements and the planning necessary to satisfy the mission/project needs. Technology development is performed in the areas of navigation, trajectory design and flight dynamics automation. Flight regimes supported include single satellite and satellite formations in low-Earth, high-Earth, gravity assist, libration point, non-Earth planetary and interplanetary orbit. Operational facility modernization planning, development, implementation and sustaining services are also provided.

NASA GSFC is requesting to extend the current contract effective ordering period by 6 additional months to allow for continued performance and support through October 31, 2025.

The current FDSS III maximum ordering value is $194,700,000.00. The estimated value for this 6-month extension is $19,800,000.00. However, no increase in the contract maximum ordering value is necessary, as the $19,800,000.00 can be absorbed within the current contract maximum ordering value.

The 6-month extension is needed to cover a broad range of flight dynamics disciplines work requirements as well as allows for continued performance and continuation of mission critical services under the FDSS III contract, the completion of the Source Evaluation Board (SEB) evaluation process, award of the FDSS IV contract and completion of the phase-in process.

The vast majority of the current FDSS III tasks were expected to transition to the FDSS IV contract by April 30, 2025 and are expected to maintain or increase their current levels of support for the next year. As a result of the delays to award the FDSS IV contract, it is now necessary to extend the FDSS III contract beyond the current end date of April 30, 2025, to allow for uninterrupted support for most of the tasks currently on the contract. In particular, the FDSS III contract allows for the continuation of crucial support provided by NMBD’s

Flight Dynamics Facility (FDF) and Conjunction Assessment Risk Analysis (CARA).

The FDF provides spaceflight navigation operations that keep missions flying safely and science and human exploration to continue. The FDF is 100% supported by the FDSS-III contract and without contractor personnel, FDF space flight support would come to a halt.

Operational missions the FDF supports includes the TDRS fleet, which provides navigation services to many other missions such as JWST, LRO, HST, GOES, Landsat, STEREO, Aqua, Aura, Terra, DSCOVR, TESS, TIMED, and MMS, to name a few. Examples of mission launches FDF currently supports include several interplanetary missions such as

IMAP/SWFO and ESCAPADE, and the Crew-11 and Starliner-1 crewed missions to the

International Space Station (ISS).

The FDSS contract also provides critical support to government personnel for CARA services for all NASA uncrewed spacecraft. This support includes providing continuous monitoring of real-time spacecraft operations to determine threats posed to mission customers and ascent/deorbit/disposal/special maneuver operations. Their continuous monitoring and analysis of the earth orbiting spacecraft keep the missions safe from collision with other spacecraft or debris. This element requires the contractor to hold a Top-Secret clearance for performing work in government-owned classified facilities, thus requiring uniquely qualified individuals to fill these roles.

A potential contractor change at this stage would highly disrupt the ability to deliver the work on schedule because it would require a steep learning curve if new personnel were to be brought on board. The administrative costs for both the government and a new contractor would be considerable. The projects are at critical points where they need to execute their schedules to keep their deliverables and commitments to the agency.

The specialized flight dynamics disciplinary nature of this contract’s support, and the mission-critical support requirements often demand specialized engineering manpower and procurements of ground system hardware with specialized operational software such as

STK, FreeFlyer, or GMA that require engineering expertise to properly execute. The FDSS

III contract must be able to react quickly and readily provide uninterrupted support for these high priority projects. Project requirements depend upon the specialized skills and flexibility of the broad range of flight dynamics engineering services. The FDSS III contract extension will allow for the needed continuity of services for these projects as they are in critical stages while allowing for any unexpected delays that these programs may experience. Without an extension, NASA GSFC would be precluded from continuing current ongoing support requirements and issuing further new short-term task orders for services under this contract.

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 on other supplies or services 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. 2304(a)(1) is that a contract extension to the incumbent, OPR, LLC, is necessary due to the nature of the work to be performed, the short duration of the extension period, and because NASA currently has a competitive follow-on procurement underway, as described below.

As the incumbent contractor, OPR is uniquely qualified to provide services required under the interim period. Services are needed for a short period until the 5-year follow-on contract is awarded. Increasing the maximum ordering value is NOT required as the ordering value is able to absorb the estimated costs for this extension. Furthermore, OPR is able to continue performing services without requiring a startup period and/or the normal learning curve typically encountered by new incoming contractors. Should these services be interrupted, NASA will be unable to perform and fulfill critical multidiscipline engineering support and related services, specifically: operational support required by FDF for ISS and over thirty operational missions; critical real-time operations from CARA to perform risk analysis of daily screening results to determine threats posed to mission customers; operational support for the Earth Science Mission Operations (ESMO) missions Aqua, Aura, Terra, and PACE;

and key mission development for the RST and other missions currently in development, enabling them to remain on schedule. In determining a solution that represents the least amount of risk to the government, stability and continuity are critical factors. OPR is considered the only contractor that can meet GSFC’s needs, given short amount of time remaining under the current contract. These services clearly function as integral parts of

NASA’s Earth Science Mission Operations and Space Science Mission Operations projects, crewed spaceflight programs including the ISS and Artemis, and Landsat and NOAA programs which include but not limited to JWST, LRO, HST, GOES, Landsat, STEREO, Aqua, Aura, Terra, DSCOVR, TESS, TIMED, and MMS.

The unique skills required to support such critical missions and milestones cannot be readily replaced without a learning curve. The highly technical and varied activities associated with the FDSS III contract require a highly specialized set of skills, which were built up over the years. The learning curve that is required to cultivate the necessary across-the-board skills pertaining to the FDSS III contract could take several years to overcome and at considerable cost. The incumbent already possesses the necessary skills required for uninterrupted performance. Therefore, NASA believes that the incumbent contractor, OPR, is the only contractor capable of providing the necessary and specific skills, experience and expertise required for the ordering period extension.

If NASA attempts to procure these services from any other source in lieu of extending the contract, the combination of delay due to the competitive process and the time required to transition a new management team to coordinate staffing levels, schedules, and to become familiar with work requirements and systems would cause unacceptable delays in fulfilling

NASA’s mission. Based on the time and costs that would be involved in procuring and phasing in another contract, OPR is the only entity possessing the detailed knowledge necessary to provide seamless continuation of the services provided under the FDSS III contract without risk of an unacceptable interruption or delay of critical services.

In addition, allowing a short contract extension will avoid a substantial duplication of costs to the Government that would need to be incurred if a new contractor was brought onboard for this short timeframe. The additional and significant administrative costs of soliciting, negotiating, and awarding a short- term interim contract cannot reasonably be expected to be recovered through competition, especially when the competition process for the follow-on is already underway. This is unacceptable to the Government given that the duration of the performance for this interim contract extension is only six (6) months. In order for the

Government to avoid a substantial duplication of costs, as well as an unacceptable delay in performance of critical requirements, a six (6) month contract extension with OPR is required.

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

October 7, 2024, in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to award this sole-source extension to OPR, 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 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. This proposed extension does not require the addition of new labor categories or updated labor rates as CY6 rates were evaluated and determined fair and reasonable at contract award.

Since this is an IDIQ type contract, Task/Delivery orders will continue to be negotiated or extended in accordance with the pre-negotiated contract rates.Support from external organizations such as the Defense Contract Audit Agency may be utilized regarding determining Business Systems adequacy as 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):

Given the urgency of the need, and the immensity and complexity of the requirement, strategic market research which was conducted continuously throughout the acquisition process, the CORs knowledge and experience indicate that no other entities possessing the required knowledge and expertise necessary to perform these services currently exist. Within this limited time frame for implementing this contract extension, NASA GSFC does not believe any alternate sources can take on full contract responsibility without risk of an unacceptable delay to critical milestones. The Government would unnecessarily incur significant additional cost if another contractor were to perform this effort. A competitive

FDSS IV contract is expected to be awarded by August 30, 2025. An assessment of other existing current GSFC and NASA IDIQ contracts was made with the conclusion that no viable contract vehicles existed that could reasonably support the requirement. The requirement for

FDSS III continuity of operations and the need to meet critical mission milestones for flight project missions leaves no feasible alternative except to extend the period of performance of the FDSS III contract.

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 on

October 7, 2024 and closed October 21, 2024. The Government received 0 responses.

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:

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. The

Government is in the process of conducting a competition for the follow-on acquisition.

FLIGHT DYNAMIC SUPPORT SERVICES (FDSS III)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

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

Becky Mesarch

Technical Representative

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

Jacob Perez

Contracting Officer