JOFOC_signed.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

1. This document is a justification for other than full and open competition prepared by the National Aeronautics and Space Administration (NASA), John F. Kennedy Space Center

(KSC).

2. The nature and/or description of the action being approved:

NASA KSC proposes to negotiate a sole source contract with Entco Government Software LLC to procure engineering services and support for the Launch Control System (LCS) project under Exploration Ground Systems (EGS) to transition from Entco Government Software Operations Manager for Linux (OML) version 9 to the newer Operations Manager i (OMi) tool version 10 to support the Exploration Module 1 (EM-1) mission and for the development of the EM-2 mission starting in 2019 with launch in 2022.

Over the past eight years, NASA KSC has been using Micro Focus Government Software recently merged with Hewlett Packard Enterprise’s (now ENTCO) software business who were the previous owners for the OMU software products. NASA has worked with MFGS/HPE in the development of LCS capabilities. The LCS is entering the last two major builds to support the Exploration Module 1 (EM-1) mission scheduled to launch in June 2020. As the system enters the final stages prior to deployment and the OMU version being used today has reached end of life, ENTCO (previously known as MFGS) support, including their historical knowledge of the LCS system architecture and MFGS/HP products, has become even more vital. Based on the above, and due to the proprietary nature of MFGS/HP systems, it is crucial that we enter into a sole source contract with Entco Government Software LLC, to obtain support during LCS key milestones to transition the current OMU to the OMI using their technical expertise and Entco Government Software LLC tools.

3. Description of the supplies or services required (including the estimated value):

Entco Government Software LLC will provide professional services and support as it relates to MFGS products being used by SCCS/LCS to transition from MFGS Operations Manager for Linux (OML) to the newer Operations Manager i (OMi) tool. Entco Government Software will provide subject matter expertise on both the LCS architecture and LCS usage of Entco Government Software products. The Period of Performance (POP) is 6 months from date of award.

The estimated price is $XXXXXX

Period of Performance: Dec 2018 Thru June 2019

4. Statutory authority permitting other than full and open competition:

The statutory authority permitting other than full and open competition is 41 U.S.C. 2304(c)(1) as implemented by Federal Acquisition Regulation (FAR) 6.302-1, Only One Responsible Source and No Other Supplies or Services will Satisfy Agency Requirements and 41 U.S.C.

3305 as implemented by FAR 13.5, Test Program for Certain Commercial Items. The latter FAR subpart authorizes, as a test program, use of simplified procedures for the acquisition of supplies and services in amounts greater than the simplified acquisition threshold but not exceeding $7 million if the contracting officer reasonably expects, based on the nature of the supplies or services sought, and on market research, that offers will include only commercial items. This requirement meets the definition of a commercial item in accordance with FAR 2.101.

5. A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

In accordance with FAR 6.302-1(a)(iii), these services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in both:

(A) Substantial duplication of cost to the Government that is not expected to be recovered through completion; and

(B) Unacceptable delays in fulfilling the agency’s requirements.

A trade study was done over eight years ago at the early stages of the program and the results showed only MFGS/HP met all of the LCS Project’s requirements for compatibility, functionality and performance. Consequently, MFGS/HP was integrated and tested on platforms and other commercial off the shelf products being used within LCS. To change out the MFGS/HP product now would lead to substantial duplication of cost and would also lead to unacceptable delays to the first unmanned vehicle launch under the Exploration Ground Systems (EGS) Program planned for June 2020.

The Space Port Command and Control System (SCCS) has over 100 developers and testers on the LCS project, which has integrated test procedures, design documents, and requirements being met by MFGS/HP products. Moreover, NASA KSC LCS has spent over $1M for MFGS/HP licenses to support LCS operating system platforms and continued MFGS/HP Engineering Services. These costs would be duplicated if NASA KSC went with another contractor, along with schedule to implement. If MFGS/HP is not selected, new software would be needed for the LCS this would drive the need for a new trade study to determine if any other software could meet the LCS requirements. If other software is identified that could meet the requirements it would take an unacceptable amount of time to re-architect and re-design the LCS which will invalidate hundreds of system requirements that have already been verified and validated over the last eight years. This would greatly increase the risk that a new product would not meet the requirements for compatibility, functionality, and performance. In addition to the duplication of costs associated with procuring new software and re-designing the LCS, the LCS would also have to go through extensive re-testing to ensure it operates as required. This would impact vehicle and ground system customers who are also using the current system for their interface testing and for developing launch applications as they are using system emulators. This would also significantly increase the risk the LCS will not be ready in time to support the EM-1 June 2020 launch date.

6. Description of the efforts made to ensure that offers are solicited from as many potential sources as practicable:

In accordance with FAR 5.203(a)(2), NASA KSC publicize the requirement on the Government Wide Point of Entry (GPE) on the Federal Business Opportunities.

7. 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 the Contracting Officer has determined that the anticipated cost to the government will be fair and reasonable. Prior to execution of the contractual instrument, a proposal analysis will be performed in accordance with FAR 15.404. The proposal analysis will be used to verify the total proposed price is fair and reasonable.

8. Description of the market survey conducted and the results, or a statement of the reasons a market survey was not conducted:

A trade study was conducted in 2010-2011 timeframe early on in the LCS project lifecycle. The technical evaluation concluded that MFGS/HP products met the project’s performance, health and monitoring needs over other vendors.

From the trade study conducted early on in the project, MFGS/HP was proven the best fit. The Government does not have the money nor schedule margin to test and re-evaluate new software.

Moreover, it would take months to re-architect and re-design the existing software which will invalidate hundreds of system requirements that have already been verified and validated. This would impact vehicle and ground system customers who are also using the current system for their interface testing and for developing launch applications as they are using system emulators. This software is being used to monitor the health and status of our system to launch the first unmanned mission EM–1 planned for June 2020. Changing the underlying vendor software and vendor engineering support for such a vital piece of the system at this stage in the program would be detrimental to the schedule and very costly.

9. Other facts supporting the use of other than full and open competition, such as:

A substantial duplication of costs to the Government that is not expected to be recovered through competition in accordance with FAR 6.302-1(a)(2)(iii) is detailed in paragraph 4. The vendor engineering support is needed to meet the EM-1 Launch date of June 2020 and help support any issues that arise during any testing events leading up to the system readiness for operational use six months prior to launch date.

MFGS/HP is the only company that is capable of fulfilling the Government’s requirement. If this action was competed, it would not only have a significant impact to the price as previously explained, it would also have a significant impact on the schedule. Under the current schedule, in addition to the support previously discussed, LCS needs MFGS/HP on-site support for transition work with the old to new product, which will include major integration events during the 6-month period to help integrate this upgraded product prior to delivery of SCCS 6.0 to support launch of EM-1.

10. A listing of sources, if any, that expressed in writing an interest in the acquisition:

Not applicable.

11. A statement of the 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:

At this time, the Agency does not anticipate any actions can be taken to remove or overcome barriers to competition before any subsequent acquisition for the subject software services.

However, NASA KSC will assess the situation prior to any future acquisitions, and take appropriate actions if competition becomes feasible.

Justification for Other than Full and Open Competition for: Entco Government Software LLC for OMU Transition.

Technical Officer: I certify that the supporting data presented in this justification are accurate and complete.

Jennifer Boelke 11/27/18 Jennifer Boelke (Date) Contracting Officer Representative

Contracting Officer: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Nancy S. Cuty 11/27/2018 Nancy S. Cuty (Date) Contracting Officer