JOFOC Rev 1 - Copy.pdf

Rev.:10/2025

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

GEORGE C. MARSHALL SPACE FLIGHT CENTER (MSFC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN

COMPETITION

(JOFOC)

For Spirent Federal Systems PNT-X Series GNSS Procurement

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) Marshall Space Flight Center (MSFC).

The procuring agency is the National Aeronautics and Space Administration (NASA), and the contracting activity is Marshall Space Flight Center (MSFC) located in Huntsville, Alabama.

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 award a sole source purchase order to Spirent Federal Systems, Inc (CAGE Code 1VBX4) for the acquisition of Information Technology (IT) GPS (Global Positioning System) and software package (including the PNT-X Series GNSS (Global Navigation Satellite System) Simulator, part number: PNTX-B-1272 with PNT X GPS L5 Feature Key, part number: PNTX-3003; PNT X Flexible Signal Definition Feature Key, part number: PNTX-3300; PNT X Spoofing Feature Key, part number: PNTX-3200; PNT X Interference L1 Feature Key, part number: PNTX- 3101; PNT X Interference L2 Feature Key, part number: PNTX-3102; PNT X Interference L5 Feature Key, part number: PNTX-3103; PNT X Spatial Awareness Feature Key, part number: PNTX-3330R; PNT X 3D Multipath Feature Key, part number: PNTX-3310; FPGA (Field Programmable Gate Array) Module, part number SF1001-13; SimORBIT Software Tool, part number: SimORBIT-0001; Add PNT X SDR Card to RF1, part number: PNTX-B-0061; Add PNT X SDR Card to RF2, part number: PNTX-B-0062; Classified software package part number: SimSAAS; AES (Advanced Encryption Standard) M-Code facility part number: 2004-4300R; and Classified Modernized Navstar Security Algorithm (MNSA) part number:

SimMNSA). Spirent Federal Systems products support the avionics system testing and development within MSFC’s Integrated Avionics Test Facilities (IATF), which includes nine laboratories located within the System Integration Laboratory (SIL), Software Development Facilities (SDF) and System Integration Test Facilities (SITF). The primary purpose of these laboratories is simulation, which is critical to

NASA’s mission success. They perform the required integration, testing, and simulation exercises of avionics systems and flight software for new launch vehicles.

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):

The proprietary Spirent Federal Systems PNT-X Series GNSS Simulator and software are required to support the IATF laboratories under the Vehicle Integration project within the Space Launch System (SLS) program. The total estimated cost of this effort is and the estimated lead time for delivery is 6 to 8 weeks.

4. FAR 6.104-1(a)(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 6.103-1, “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) is that Spirent Federal Systems is the only vendor capable of providing the required GPS system as described below.

MSFC owns multiple Spirent Federal Systems GPS Simulators and based on their company proprietary information, support from any other manufacturer is totally incompatible with their products and upgrades. The Spirent Federal Systems GPS Simulators include their proprietary simulation software SimGEN™. By procuring the simulators from Spirent Federal, it allows the end users to preconfigure and set up simulation scenarios without impacting the SLS launch schedule. The existing GPS Simulators in the IATF (Integrated Avionics Test Facilities) are currently in use and locked in place by configuration control and cannot be shared with other systems. Spirent exclusively provides the maintenance for their GPS Simulators.

Spirent Federal’s PNT-X Series GNSS Simulator simplifies comprehensive testing and delivers definitive results from mission-critical scenarios. The PNT-X is powered by SimGEN™ which now includes cutting-edge 3D scenario support elevating the user experience. Like the existing MSFC Spirent Federal Systems GPS Simulators, the PNT-X model brings together more signals from more sources reducing the lab footprint while maintaining optimal results. The PNT-X model provides ultra-low latency for hardware-in the-loop configurations. It offers a configurable, intuitive approach to defining CRPA (Controlled Reception Pattern Antenna) scenarios providing flexible and powerful jamming and advanced spoofing capabilities.

The GPS Simulators are used to create realistic, controlled, and repeatable testing environments for GNSS receivers in the IATF labs. They enable engineers to test the performance and functionality of GNSS receivers in a controlled environment, providing more comprehensive and reliable results than real-world testing. These simulators can simulate a wide range of scenarios including challenging conditions like ascent, occultation or jamming, as well as verify functionality, improve product quality, and ensure reliability in applications ranging from launch vehicles to low Earth Orbit satellites.

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 (GPE) website (Sam.gov) was published On October 19, 2025. in accordance with FAR part 5. This posting informed potential sources of NASA’s intent to award this sole source Spirent Federal Systems. 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’s signature on this document indicates that the Contracting Officer has determined that the anticipated cost to the government will be fair and reasonable. The Contractor shall be required to submit a proposal to be evaluated and negotiated by the Government. Prior to execution of the contractual instrument, a proposal price analysis (based on a comparison of the proposed price to published catalog price lists, pricing of other similar systems, and historical prices of previous purchases) will be performed to ensure that the final agreed-to price for the contract action is fair and reasonable.

8. FAR 6.104-1(a)(8) – Description of the market research conducted, and the results, or statement of the reasons market research was not conducted:

Market research and product evaluations were conducted by MSFC ES40 end user.

An online research of the current 2017 line-up GPS simulator was conducted in addition to the review of the GPS World publication GPS Simulators Buyer Guide.

This publication gave the end users a synopsis of all the companies. The System Integration Lab and Software Integration Testing Facility (SIL/SITF ) needs a Radio Frequency Satellite Signal Simulator capable of generating 6 “antennas”, and worth of GPS L1, L2, and L5 signals (mi (minimum of 18 satellites per antenna output, with 3 frequencies per satellite). MSFC requires the radio to have both Standard Positioning Service (SPS) as well as Precise Positioning Service (PPS) signals, with real-time hardware-in-the-loop remote-control capability, and vehicle models for launch vehicles, orbital vehicles, and terrestrial vehicles. Also, all six antenna outputs tied to one single vehicle (SLS), or to any combination of multiple vehicles for formation flights in LEO, MEO, or HEO. After an estimated four (4) evaluations and very detailed research, the market research indicates that the GPS Simulators required by this acquisition resulted in Spirent Federal Systems being the only one capable of meeting all the above mentioned Government requirements.

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

Full and open competition are not viable due to the proprietary nature of Spirent’s SimGEN™ software. If the government was able to compete this requirement for the GPS Simulators deemed essential by engineers within the IATF, they would impact the launch schedule due to the delay in the time critical testing using this equipment. Operation and configuration of GPS Simulators is quite complex, and requires knowledge not only of GPS signal characteristics, but also detailed knowledge of the characteristics and operational capabilities of the simulation hardware and software being used. GPS Simulator Systems have a steep learning curve, and it took the GPS experts at MSFC years to become fully proficient with all of the subtleties and nuances associated with proper set-up and configuration of various simulation scenarios. Because of the established familiarity with the Spirent GPS Simulators, users save time that would be lost learning a new system.

As both ongoing and new programs approach the ES organizations for support and recommendations on GPS receiver selection and performance aboard their spacecraft, being able to be responsive to the needs and requests means another GPS Satellite Signal Simulator System is needed for laboratory and mission use. This new unit could serve as a back-up system, in case the primary system within the IATF fails.

Multiple adverse issues would present themselves if a competing brand’s product were to be selected for procurement. These issues include… (a) It would take the satellite signal simulator system operator 1-2 years to become fully-proficient with the new system, at an associated cost of approximately $410K for contractor workforce labor costs, in addition to the 1-2 year schedule penalty; and, (b) MSFC would lose the benefit of having satellite signal simulator system redundancy in that multiple compatible GPS simulator platforms would not be available, in case one of the systems became inoperative. Having a primary and backup GPS Simulator system helps ensure continuity of operations for the programs and projects supported.

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 GPE website (Sam.gov) per FAR Subpart 5.2 (See Section 6 above). The Intent to Sole Source synopsis was posted on October 17, 2025 and closed October 31, 2025.

There were two responses received, VCloud Tech and New Tech Solution. The responses were forwarded to the Technical Point of Contact to perform a technical evaluation on the responses. It was determined that both responses are technically unacceptable.

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:

Currently, there are no additional actions that the agency may take to remove or overcome barriers to competition before any subsequent acquisition for the required systems is sought.

NASA will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements.