80JSC022DA022_xEVAS_CLIN5_Hardware_Production_and_Delivery_JOFOC_Public_Release.pdf

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Johnson Space Center (JSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

For Contract 80JSC022DA022 with Axiom Space - Exploration Extravehicular Activity Services (xEVAS), Contract Line-Item Number (CLIN) 5 - Hardware Production and Delivery

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) JSC.

The procuring agency is NASA, and the contracting activity is JSC/BL – Lunar and Planetary Exploration Programs Procurement Office.

This justification is prepared pursuant to FAR Subpart 6.103-1(b) and 10 U.S.C. 3204(a)(1).

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

The xEVAS contract was awarded to procure safe, reliable, and cost-effective EVA services to meet NASA’s EVA availability requirements for the ISS, Artemis and advanced human spaceflight missions. Extravehicular Activity (EVA) Services provide NASA the capability to perform EVAs with the use of contractor-delivered spacesuits, tools and equipment, vehicle interfaces, and support to training and real-time operations. xEVAS was awarded as a multiple-award Indefinite-Delivery-Indefinite-Quantity (IDIQ) contract with Firm-Fixed- Price (FFP) task orders. Two contracts were awarded on May 31, 2022, to Axiom Space and Collins Aerospace.

This justification provides the rationale for contracting by other than full and open competition to award a new work modification to contract number 80JSC022DA022 with Axiom Space for the addition of CLIN 5 for hardware production and delivery including:

development, upgrades, and enhancements; hardware sustaining and maintenance; and repair and refurbishment. Because the xEVAS contract is a service contract, an approved JOFOC is required to add a supply CLIN to the Axiom contract on a sole-source basis.

This action enables timely procurement of hardware to maintain mission schedule resilience and continuity during the remaining Period of Performance (PoP), through May 30, 2032.

This action supports schedule resilience for Artemis consistent with national policy milestones set forth in Executive Order 14369, “Ensuring American Space Superiority” (return to the Moon by 2028 and initial lunar outpost elements by 2030). Consistent with those milestones, market research emphasizes sources’ ability to meet compatibility and schedule requirements under the existing architecture; the EO is cited to document the schedule context only.

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):

NASA requires the addition of a capability via CLIN 5 that allows the Government to accept delivery of hardware and supplies under the xEVAS contract. To meet mission needs for ISS, Artemis, and future human spaceflight programs, the Agency must obtain delivery of xEVA System Hardware and related equipment essential for system development, testing, training, and mission execution.

The required hardware and supplies include:

• Delivery of xEVA System Hardware, encompassing all xEVA suit hardware and software, Flight Support Equipment, the EVA Tools and Crew Aids (ETCA), and any other ancillary hardware or software necessary to support the xEVA system architecture.

• xEVA Subsystem, Components, and Parts Hardware, including all specialized subsystems, life‑support assemblies, wearable components, avionics, structural elements, and replacement or sustaining parts required to maintain xEVA system performance throughout development and mission operations.

• Delivery of Ground Support Equipment (GSE), which includes all tools, fixtures, handling equipment, and support hardware required for ground operations related to EVA training, testing, mission development, and integration activities.

• Test Support Equipment (TSE) and other xEVA test hardware, including any instrumentation, measurement devices, test articles, and specialty equipment required to perform developmental, qualification, certification, and performance‑verification testing for the xEVA system.

These supplies are necessary to ensure NASA can sustain xEVA system development and maintain readiness for mission schedules aligned with national objectives, including those supporting Artemis lunar surface operations. Delivery of these items under a Government-ownership model provides NASA with the flexibility and resilience needed for hardware integration, maintenance, and long‑term mission planning.

Because NASA will begin receiving and accepting hardware under this new structure, the contract must also incorporate additional scope necessary to support the full lifecycle of Government‑owned xEVA assets. This scope includes the design, development, testing, certification, delivery, and support of upgrades and enhancements to the xEVA system and its components; sustainment, processing, refurbishment, and certification of xEVA hardware and support equipment (inclusive of hardware and software) developed or maintained under the contract; and rework or repair of damaged or non‑functioning xEVA hardware, including all ancillary and ground equipment. These capabilities are required to ensure mission‑ready hardware throughout the contract period of performance and to maintain the safety, reliability, and availability of the xEVA system for NASA’s exploration objectives.

The xEVAS contract has not previously included hardware delivery items. After approval of the JOFOC, a new CLIN 5 will be added to the contract to incorporate the following requirements: hardware production and delivery including: development, upgrades, and enhancements; hardware sustaining and maintenance; and repair and refurbishment. This additional scope is consistent with the NASA Administrator’s March 18, 2026 Directive to:

“…secure, as appropriate, data rights, repair rights, interface control, and access to tooling and software necessary to perform repairs and track vendor performance to meet America’s Space Superiority policy.” Additionally, a new delivery order will be issued, and hardware items will be added to this order as requirements are identified.

Collins has not expressed an interest in this requirement for CLIN 5 hardware items.

Consequently, the Axiom xEVAS contract will be modified to add the terms and conditions, and reporting requirements that are required to order, inspect, accept, and account for CLIN 5 items that may be requested by NASA via delivery order. The period of performance for the CLIN 5 requirements will start when the contract modification is issued throughout the duration of the Axiom xEVAS contract ordering period end date of May 30, 2032. This action does not extend the xEVAS period of performance.

The xEVAS ordering limit is $3.1 billion, and this ordering limit will not be increased as a result of adding CLIN 5. Delivery orders associated with this action will remain within the boundaries of the existing contract ceiling. Hardware production and delivery items will be individually negotiated and incorporated into CLIN 5 as the corresponding requirements are formally identified throughout the xEVAS period of performance. Therefore, no immediate obligation will result from adding this CLIN 5.

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

The statutory authority for this JOFOC is 10 U. S. C. 3204(a)(1) as implemented by Federal Acquisition Regulation (FAR) 6.103-1(b), which enables the use of other than full and open competition procedures in cases when the supplies or services required are deemed to be available from only one or a limited number of responsible source(s) and no other supplies or services will satisfy agency requirements.

Supplies/Services may be deemed to be available only from the original source for the continued development and production of a major system or highly specialized equipment, including major components thereof, when it is likely that award to any other source would result in substantial duplication of cost to the Government that is not expected to be recovered through competition, or unacceptable delays in fulfilling the agency’s 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) is only one responsible source and no other supplies or services will satisfy agency requirements as described below.

Spacesuit development is a uniquely specialized endeavor that effectively produces a human-sized spacecraft, requiring highly integrated life-support systems, pressure garment engineering, mission-critical avionics, and certification processes that only a contractor already developing an operational EVA system can satisfy. Axiom Space is the only xEVAS contractor currently in active development of a lunar-capable xEVA system. xEVAS is the contract through which NASA procures the full suite of EVA system capabilities needed for Artemis, and future missions, and is designed to provide “the full suite of capabilities for NASA’s spacewalk needs during the period of performance.”

Because xEVAS is the Agency’s existing contractual vehicle for acquiring EVA system capabilities for exploration beyond low-earth orbit, the addition of Government-owned hardware delivery necessarily results in a change in scope to the contract because the xEVAS contract is a services contract. The new requirement for NASA to receive, own, sustain, upgrade, certify, and repair xEVA system hardware must be added to xEVAS to remain aligned with the architecture, integration responsibilities, and technical baseline already under Axiom’s cognizance. Additionally, this JOFOC is required because xEVAS is a multiple-award IDIQ and NASA intends to add new scope only to the Axiom contract.

Given that Axiom alone is producing the operational suit architecture, NASA cannot obtain these hardware capabilities from any other responsible source without incurring unacceptable schedule delays, duplicative non-recurring engineering, and incompatibility with the existing system design. Therefore, modifying the xEVAS contract with Axiom on a sole-source basis is warranted and essential to meet Agency mission requirements. Axiom is the only xEVAS contractor currently capable of meeting NASA’s technical and schedule requirements for the lunar EVA missions.

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 June 11, 2026, in accordance with FAR Subpart 5.1. This notice informed potential sources of NASA’s intent to issue a sole‑source contract modification to add CLIN 5 to the Axiom xEVAS contract. The notice described the umbrella scope and the order‑level pricing approach. NASA evaluated responses for maximum practicable competition consistent with FAR Part 10 and NFS guidance, focusing on the ability to meet integration and schedule constraints. The results of this notice 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’s signature on the individual delivery orders will indicate that the Contracting Officer has determined that the proposed price to the government is fair and reasonable. Because the xEVAS contract is structured as an IDIQ mechanism, the contract ceiling value will not change, and price reasonableness will be assessed at the individual order (or order revision) level. For each order, the Contractor will be required to submit a proposal with sufficient detail to support analysis, and the Government will conduct that analysis in accordance with FAR Subpart 15.4 prior to award. Delivery orders associated with this action will remain within the boundaries of the existing contract ceiling.

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):

NASA has conducted market research consistent with FAR Part 10 and the NASA FAR Supplement Companion Guide (CG) 1806 as part of the planned sole‑source addition of CLIN 5 (Hardware Production and Delivery) to the xEVAS contract. The purpose of this research is to assess whether sources exist that can deliver hardware fully compatible with the Axiom xEVAS suit architecture within Artemis integration, certification, and schedule constraints.

Market research conducted for this acquisition included a review of publicly available internet resources; searches of the Government’s System for Award Management database (sam.gov); input from the NASA Contracting Officer’s Representative (COR), who possesses relevant industry knowledge; and consideration of market information received in response to the notice published for this acquisition on sam.gov, the Government’s official point‑of‑entry website, on June 11, 2026. NASA posted a notice to Sam.Gov, evaluated the responses for maximum practical competition, and summarized the results in Section 10 below.

Market knowledge indicates that many relevant OEM items are designed to be integrated through the xEVAS prime, and that introducing alternate sources at the hardware level would likely require duplicate integration and certification effort that the Government would not recover through competition. NASA will use any additional industry exchanges, and order‑specific analyses to validate assumptions, inform commercial item determinations, and support price analysis for individual orders. Documentation of market‑research activities and proposal analyses are maintained in the official acquisition file for this JOFOC.

No sources other than Axiom were identified that can satisfy the integration, schedule, and compatibility constraints.

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

This action also aligns with the NASA Administrator’s March 18, 2026, Directive to:

“…secure, as appropriate, data rights, repair rights, interface control, and access to tooling and software necessary to perform repairs and track vendor performance to meet America’s Space Superiority policy.” Accordingly, the contract will be updated to include requirements for the repair and refurbishment of hardware items.

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 posted on the GPE website (Sam.gov) per FAR Subpart 5.2 (See Section 6 above). The notice was posted on June 11, 2026 and closed on June 22, 2026.

Collins Aerospace was individually notified of the posting on June 12, 2026, and did not express an interest in competing for this work.

A company expressed an interest in writing but then withdrew their capability statement after a discussion of the requirements with the Contracting Officer and Contracting Officer Representative.

There are no alternative sources capable of meeting the xEVAS requirements and schedule.

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.