80JSC022DA003 - JOFOC.pdf

Rev.: 10/2025

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Johnson Space Center (JSC) White Sands Test Facility (WSTF)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC) for

Test Evaluation and Support Team (TEST3) Contract 80JSC022DA003

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) Johnson Space Center (JSC) White Sands Test Facility (WSTF), the procuring agency and contracting activity respectively.

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 extend the Test Evaluation and Support Team 3 (TEST3) contract (80JSC022DA003) with Sierra Lobo, Inc. (small business) for up to 2 additional years. The current contract period of performance ends January 31, 2027. The proposed extension will include a 12-month base period and a 12-month option period to allow sufficient time for successful completion of two large-scale construction projects at WSTF funded by the Working Families Tax Cuts Act (WFTCA), formally known as the One Big Beautiful Bill Act (OBBBA).

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):

WSTF has been allocated $19 million in WFTCA/OBBBA infrastructure funding which must be obligated prior to the end of fiscal year ‘26. Upon approval, WSTF will obligate these funds to the TEST3 contract, enabling these projects to start immediately. WSTF utilizes the contractor, in accordance with the contract scope, to fulfil all onsite construction requirements. This approach leverages the contractor’s local expertise, the dedicated personnel required to manage projects of this scope and complexity, and their ability to provide the site wide integration necessary to support these projects.

The estimated value for this extension is $266 million, which includes the aforementioned $19 million and an additional $247 million to cover TEST3 support during the period. The estimated contract value is reflective of the average annual Indefinite-Delivery Indefinite- Quantity usage observed under the current contract and the infrastructure improvements in the WFTCA/OBBBA.

4. FAR 6.104-1(a)(4) – An identification of the statutory authority permitting other than full and open competition:

Rev.:10/2025

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) – 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) as described below.

WSTF received funding for two infrastructure projects under OBBBA. The scope of the two projects is to replace the Heating, Ventilation, and Air Conditioning (HVAC) for WSTF’s main administrative Buildings 100 and 101 and upgrade the 250 Control Room. Specific work for the HVAC project includes HVAC system and ducting replacement, reroofing, asbestos abatement, electrical upgrades, safety and quality support, logistics, and network re-routing. The HVAC project will be an extensive large-scale project and includes plans to vacate Building 100 and 101 for several months to allow the construction Contractor to complete the work. The 250 Control Room Upgrade replaces a dilapidated metal shed that was converted to a control room decades ago. Critical hazardous testing is completed in the 250 Area in the areas of Oxygen Compatibility with particle impacts in systems, as well as large scale flammability testing in oxygen enriched environments. This testing supports multiple NASA Programs and ensures the safety of all human spaceflight. The new control room will provide more space and a configuration that will promote much greater efficiency for the engineers and technicians that are performing testing. These projects involve highly complex facility rehabilitation and improvements, and it is possible the construction efforts could take up to two years to complete. Therefore, a one-year contract extension with an one-year option provides the Government schedule flexibility, should it be required.

Ensuring the successful completion of these projects is crucial as it significantly helps reset the aging infrastructure clock at WSTF and will position the site to continue to provide critical hazardous testing support for the NASA mission for many years to come. Timely obligation of the WFTCA/OBBBA funding is essential to start these projects and serves the best interest of the American taxpayer. Extending the current TEST3 contract represents the most efficient and effective means of ensuring successful completion of these projects.

Sierra Lobo, Inc. is the only contractor that has the immediate expertise and capability to support these construction projects in a timely manner. This extension supports the effective utilization of the WFTCA/OBBBA funds by ensuring that the projects are conducted timely and are overseen and implemented by the experienced TEST3 contractor workforce who are already familiar with the site’s operational needs and project plans. The TEST3 contract provides fully integrated support to WSTF for all the hazardous testing activities and all the support/enabling capabilities to include infrastructure maintenance and construction. This integrated approach is critical to meet the operational requirements of WSTF in an effective and efficient manner. Therefore, attempting to utilize any other contractor would result in significant inefficiencies, disrupt the site-wide synergies achieved through a fully integrated contract and increase the risk of successful completion of these projects. Extending the

TEST3 contract eliminates transition risks, promotes cost-efficiency, and ensures that the infrastructure improvements are completed within the timelines stipulated in the Act.

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 website (Sam.gov) was published on January 23, 2026. The posting informed potential sources of NASA’s intent to award this sole-source extension to Sierra Lobo, Inc. 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:

The Contracting Officer, by virtue of signing this JOFOC, has determined that the anticipated cost to the Government will be fair and reasonable. A Request for Proposal will be issued to Sierra Lobo, Inc. for submission of a proposal which will be evaluated and negotiated by the Government. Prior to execution of the contract modification, 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.

Historical cost data, Defense Contract Management Agency information, and certified cost or pricing data submitted by Sierra Lobo, Inc. will be used to obtain a fair and reasonable cost.

Any escalation rates proposed will be negotiated using the NASA recommended labor and general escalation rates, obtained from IHS Markit Economic, as a guide. The current labor rates and ceilings for indirect rates were established at the time of contract award through competitive procurement procedures. Over the course of the contract, rates have only been adjusted as a result of revisions to prevailing labor rates provided by the Secretary of Labor and in accordance with the escalation increase identified in the Collective Bargaining Agreement.

8. RFO 6.104-1(a)(8) – Description of the market research conducted, and the results, or a statement of the reason market research was not conducted (e.g., urgent, and compelling requirement):

Market research has identified several companies capable of completing these construction projects; however, a competitive procurement would not meet the time restrictions associated with the WFTCA/OBBBA funding, nor would it address the synergies the site receives with a fully integrated contract. NASA considered completing the projects using in-house resources but determined this approach to be infeasible, as it does not have the dedicated personnel required to oversee projects of this scope and complexity. The contractor is the only responsible source capable of performing all onsite construction activities while providing the integrated management, technical expertise, and coordination necessary to support the projects from award through completion. Utilizing any other approach would still require NASA to procure a separate contract to provide the necessary architectural-engineering expertise and additional technical personnel required to support the design build proposal evaluations, as well as the supervision, inspection, and evaluation services during the construction phase. This would result in substantial duplication of cost and inefficiencies, as this expertise and supplemental support is already available on TEST3. In summary delaying this contract extension to pursue other alternatives would result in increased performance risk to the overall WSTF mission operations and would pose significant risk to the timely obligation of the WFTCA/OBBBA funding and completion of these critical construction projects for WSTF.

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

The contract extension is necessary to avoid serious impact on the Government’s mission.

WSTF has been allotted $19 million in WFTCA/OBBBA infrastructure funding which can be immediately obligated to the TEST3 contract and enables project efforts to immediately begin. The WFTCA/OBBBA funding is time-sensitive, with funds required to be obligated by September 30, 2026. Once the funding is obligated to the TEST3 contract and the projects start, construction would extend beyond the current contract expiration date of January 31, 2027. Transitioning these two major construction projects in the middle of project execution to a new follow-on contractor would create significant performance, cost, and schedule risks that would jeopardize timely and successful completion of these time critical WFTC/OBBBA projects. A contract transition would risk loss of institutional knowledge, introduce inefficiencies, and require extensive coordination between the outgoing and incoming contractors.

NASA considered awarding the work under separate task orders under TEST3 that could extend beyond the base contract period of performance. However, due to the workforce climate and finite number of highly and technically skilled workforce available in the Las Cruces and surrounding area, this approach introduces significant workforce retention risks for the TEST3 and the site. The contract employees that would be assigned to support these special construction projects would only be guaranteed work for limited finite time, whereas the remainder of the TEST3 incumbent workforce would be working through contract transition to a new TEST4 follow-on contract with a guaranteed longer period of employment. This workforce challenge puts timely and efficient completion of these critical WFTCA/OBBBA at risk. Additionally, executing closely integrated construction, safety and management functions across multiple contractors while simultaneously working with the TEST contractor on overall WSTF mission requirements would introduce coordination inefficiencies, increase execution risk, and create the potential for cost and schedule performance risks on not only these WFTCA/OBBBA construction projects but also the human spaceflight missions WSTF is responsible for supporting. Therefore, extending the TEST3 contract would mitigate these issues through single point accountability, enabling stability for the integrated workforce and minimizing the risk of successful completion of these critical WFTCA/OBBBA funded projects.

Additionally, the contract extension supports continuity of services and project management during a period of significant infrastructure activity across the WSTF site. Specific projects include upgrades to the site’s water system, natural gas distribution system, and primary access road with durations exceeding two years. These efforts are further complicated by ongoing civil servant attrition, increasing reliance on TEST3 for consistent oversight and technical expertise.

In summary, this extension is essential to maintain momentum on these critical infrastructure projects, mitigate transition risks, and ensure responsible stewardship of federal resources.

The extension represents the best value to the Government and supports national priorities outlined in the WFTCA/OBBBA and the Administration’s Space Policy.

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 Government Point of Entry website (Sam.gov) per RFO part 5 (See Section 6 above). The synopsis was posted on January 23, 2026, and closed on February 7, 2026. NASA responded to one response which sought clarification on the posting, but no other companies expressed interest.

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 of the supplies or services required:

No additional actions are necessary, as the Government plans to seek maximum competition by competing the TEST4 acquisition through competition. An Industry Day has occurred in preparation for the TEST4 acquisition. However, it is anticipated that any additional TEST4 activities will be postponed as a result of TEST3 being extended. This sole-source justification is necessary to allow sufficient time for the TEST3 contractor to complete WFTCA funded construction projects at WSTF.