ALICE JOFOC Approved clean.pdf

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA)

JOHNSON SPACE CENTER (JSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Aircraft Maintenance, Logistics, Integration, Configuration Management, and Engineering (ALICE) 80JSC018D0002

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 “JOFOC.”

This document is a JOFOC prepared by the NASA JSC.

The procuring Agency is NASA, and the contracting activity is JSC.

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 a sole-source modification to increase the contract value by $60 million to the ALICE contract, 80JSC018D0002, with Yulista Tactical Services, LLC. This requested increase is required to support continued work and additional in-scope requirements that will exceed the current contract value. The cumulative effect of these requirements is a $60 million increase in contract value from $264.5 million to $324.5 million. The increase will allow the contractor to continue contract performance through February 28, 2023, when the contract expires.

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):

NASA JSC requires continued operation of the ALICE contract to provide critical Aircraft Operational Support Services for aircraft at JSC, Langley Research Center (LaRC), Goddard Space Flight Center (GSFC), Wallops Flight Facility (WFF), and other NASA Centers or Government Agencies through agreements with NASA. This support includes remote sites, domestic, and foreign, where services are required. The services include flight operations, flight aircrew support and training, maintenance, repairs, and alterations, and provides engineering services for a variety of airframes, engines, and support equipment during the period until a follow-on contract is awarded.

The ALICE contract supports a diverse and unique aircraft fleet with many of the aircraft being one-of-a-kind that operate out of JSC, LaRC, GSFC, WFF, and other NASA Centers or Government Agencies. The unique fleet of aircraft NASA operates supports Astronaut Space Flight Readiness Training, High Altitude Research, Human Spaceflight Support, Earth Science, and Aerospace Cargo Transport. The fleet includes high performance jet aircraft requiring ballistic ejection system knowledge and experience.

Revision: 01/2021

80JSC018D0002 ALICE JOFOC

Per the requirements of NASA FAR Supplement (NFS) Appendix A 102.7, Aircraft Operational Support Services, additional in-scope Aircraft Operational Support Services requirements were added from other NASA Centers, which were not previously estimated in the original ALICE contract value. In addition, NASA has protected critical NASA personnel during the COVID-19 pandemic by utilizing commercial aviation services by transporting these individuals on smaller contained aircraft rather than domestic air travel.

These unplanned flights were purchased through the ALICE contract and further reduced available contract value that would have otherwise been utilized for critical planned activities. Finally, additional mission requirement purchases for the International Space Station (ISS), Spaceflight Crew Operations, and other NASA stakeholders, further depleted available contract value.

As a result, the ALICE contract value is currently insufficient to meet NASA’s continued Agency-wide Aircraft Operational Support Services requirements for its aircraft fleet. If flight operations are interrupted, NASA risks its critical ongoing support roles and delaying customer programs. The timeliness, quality, and consistency of maintenance is critical to NASA Aircraft Operations Division (AOD) success. Substandard support can result in damage or loss of equipment and aircraft, and personnel injury or loss of life.

The period of performance for the ALICE contract will not be extended.

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 United States Code (U. S. C) 2304(c)(1). As implemented by the provisions of FAR 6.302-1(a)(2)(iii), only one responsible source and no other supplies or services will satisfy Agency requirements. This authority allows for other than full and open competition when the supplies and services are deemed to be available only from one responsible source when it is likely that award to another source would result in unacceptable delays in fulfilling the 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(c)(1) is that only Yulista Tactical Services, LLC, possesses the unique qualifications to provide and satisfy the continuity of the current ALICE effort. The services include flight operations, maintenance, repairs, and alterations, and provides engineering services for a variety of airframes, engines, and support equipment. Yulista Tactical Services, LLC, has the unique knowledge of the aircraft required to support the ISS program, the Artemis program, NASA Commercial Crew, airborne science, aeronautics research, other NASA missions, and other activities as designated by the Government through the contract period, February 28, 2023. In addition, the aircraft NASA operates support Astronaut Space Flight Readiness Training, High

Altitude Research, Human Spaceflight Support, Earth Science, and Aerospace Cargo Transport.

Safely executing complex flight operations using NASA’s unique fleet requires specialized knowledge. These specialized knowledge requirements stem from the flight operations at JSC, LaRC and WFF, which are critical to the continued and uninterrupted support required during the ISS program, the Artemis program, NASA Commercial Crew, airborne science, aeronautics research, and other NASA missions. All flight operations, including maintenance and modification of the aircraft, are safety and life critical. Safety risks associated with transitioning to a new contractor, cannot be accepted at this time due to the criticality of timing and support requirements.

Aircraft operational services supporting spaceflight require the operations, maintenance, and continuous upgrade of NASA’s diverse and complex aircraft. These aircraft must be readied for instruction, astronaut, crew, academia, and other Governmental organization activities on a very tight schedule and to exacting safety of flight standards. Any deviation to aircraft configuration can result in negative crew training and the inability of a mission to be performed in a timely and safe manner. The potential loss of knowledge and skills due to a previously unanticipated transition could result in unacceptable delays to carrying out current ISS, Orion, and commercial crew operational support and schedules.

These services support a diverse and unique aircraft fleet, including many one-of-a-kind aircraft that operate out of JSC, LaRC, WFF, and temporary worldwide locations. The current aircraft fleet at JSC consists of 18 Northrop T-38N, three General Dynamics WB- 57F, one B377 SGT Super Guppy, one Gulfstream GIII, and one Gulfstream GV. The current aircraft fleet at LaRC consists of one Beechcraft King Air B200, one Cirrus SR-22, one Lancair Columbia LC-40, three Gulfstream GIII (one active, two parts aircraft), and one Gulfstream GIV. The current aircraft fleet at WFF consists of three P-3 Orion (one flyable aircraft and two spare parts aircraft), one B-200 King Air, and one HC-130H Hercules. The fleet includes high performance jet aircraft requiring ballistic ejection system knowledge and experience.

Furthermore, NASA maintains and supports all necessary operability requirements for these high-performance aircraft jet engines, gearbox, and unique avionics systems. This requires an in-depth knowledge and experience in the full life cycle issues of these systems. This expertise is required to allow NASA to meet the unique and dynamic customer-driven mission requirements and aircraft availability needs. The aircraft have specialized upgrades to the standard configuration which drive significant differences in the maintenance and repair of NASA’s aircraft compared to similar aircraft in the commercial and Government world. In addition, the age of the aircraft being used for NASA’s specialized missions requires aircraft maintenance requirements and scheduling that varies considerably from those normally used by other Government Agencies and in the commercial sector. With small and diverse fleets such as these, maintenance issues develop where there is no known technical data from either the original equipment manufacturer or other Government Agencies. Therefore, NASA relies on knowledge of the specific aircraft and in-house troubleshooting techniques to return the aircraft quickly and safely to service.

Yulista Tactical Services, LLC, has successfully performed the ALICE contract services for 4-years. Transitioning these services to another contractor for a limited period of performance would be impractical as it would pose a high risk to NASA’s ability to execute its Aircraft Operational Support Services and result in delayed support services and a substantial duplication of costs. It would take an estimated 2-years to recompete and establish a new contract to fulfill these requirements. Insufficient time to perform the acquisition process for the remaining period of performance of the ALICE contract could compromise safety, performance, or schedule. There is also a safety risk associated with an unanticipated transition, which cannot be accepted at this time due to the criticality of the current schedule, timing, and support requirements. The potential loss of knowledge and skills due to an unanticipated transition could result in unacceptable delays to support services required for carrying out upcoming missions on schedule. The need to maintain synergistic management and integration of aircraft support across the enterprise to avoid duplication of efforts are critical to the continuation of services.

Furthermore, transitioning in-progress work to another contractor could result in substantial performance delays and duplication of work to JSC, LaRC, GSFC, WFF, and other NASA Centers or Government Agencies. It is critical to not have a lapse in support, as continuity of the services is vital to all NASA Centers. Increasing the contract value by $60 million will allow for the continuance of these critical functions and support until the NASA follow-on, CompreHensive Aircraft Readiness, Lifecycle, Engineering, and Support (CHARLES) contract, is awarded.

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 March 15, 2022, in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to increase the ALICE contract value. Contract Number 80JSC018D0002 with Yulista Tactical Services, LLC, pursuant to the authority of 10 U. S.

C. 2304(c)(1) as implemented by FAR 6.302-1, only one responsible source and no other supplies or services will satisfy Agency requirements. 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 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 the execution of the contractual instrument, 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. In accordance with FAR 15.404, the Government will use various price analysis techniques such as comparison of the proposed prices to historical prices paid to ensure a fair and reasonable price. Further, the Contracting Officer will ensure inputs from the Contracting Officer’s Representative are incorporated in the evaluation, along with other information that is available to the Government at the time of evaluating the contractor’s proposal.

8. FAR 6.303-2(b)(8) – Description of the market research conducted, and the results, or a statement of the reasons a market research was not conducted:

In addition to the synopsis posted on March 15, 2022, which did not receive any responses, market research was conducted utilizing existing knowledge within the Government. AOD maintains close contact with NASA's aircraft operations maintenance Chiefs and other U.S.

Federal Agency's maintenance management representatives. AOD confers with these representatives several times a year on the current trends and state of industry standards and practices. These maintenance management representatives have knowledge regarding the maintenance, repair, support services, overhaul and other areas of aircraft maintenance including operational support. Based on the information gathered, it was determined the cost to transition another company to perform the services for only an 11-month period of performance would be cost prohibitive and any course of action other than using the existing contract would result in unacceptable delays fulfilling the Agency’s requirements and not be in the best interest of the Government.

9. FAR 6.303-2(b)(9) – Any other facts supporting the use of other than full and open competition:

Per the requirements of NFS A-102.7, JSC added additional in-scope Aircraft Operational Support Services content from other NASA Centers, which was not previously estimated in the original ALICE contract value. As a result, the ALICE contract value is currently insufficient to meet NASA’s Agency-wide Aircraft Operational Support Services requirements.

Implementation of NASA’s Enterprise Service Delivery model embraces the concept of category management principles by managing spending through the use of the Office of Management and Budget Best-in-Class contract solutions. The strategy procures and manages institutional services and a small subset of program/project support services through the creation of product service lines with specific procurement assignments and buying locations.

In accordance with the Enterprise Service Delivery model and per NFS A-102.7 Aircraft Operational Support Services, the ALICE contract is designated as one of NASA’s mandatory contracts to satisfy in-scope requirements for Aircraft Operational Support Services, which includes maintenance, parts, and repair for aircraft (Federal aircraft and unmanned aircraft systems as defined in 1847.200-70) and aircraft components, flight aircrew support and flight aircrew training. While other Product Service Line (PSL) contracts may perform a portion of the work, there would be substantial duplication of cost and time to the Government that cannot be expected to be recovered if portions were to be allocated on other PSL contracts. The ALICE contract obtains the critical skills and specialized knowledge to perform the complexity of this work.

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 for this effort was posted on March 15, 2022, and closed on March 30, 2022, with no responses received.

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:

No further actions are anticipated. The Government has formulated a competitive strategy for the ALICE follow-on contract. ALICE contract requirements have been incorporated into NASA JSC’s new competitive follow-on procurement, the CHARLES contract (see sam.gov, Solicitation number: 80JSC021CHARLES.)