Distribution A_SSCPA 1997_SBS005504 FOE Redacted.pdf

This is a Justification for an Exception to Fair Opportunity under FAR 16.505(b)(2)(i)(B), submitted by the United States Space Force Space Systems Command/CMK (COMSO) for a sole-source award to SpaceX.

The procurement seeks a Firm-Fixed-Price task order under the Proliferated Low Earth Orbit (PLEO) Low Earth Orbit Satellite-Based Services Multiple Award Contract (MAC) vehicle for specialized commercial satellite communications services. The order covers an anticipated performance period from December 5, 2025, through December 4, 2026, with an optional period from December 5, 2026, through December 9, 2027. Required items include: (1) Operational Packaged PLEO Service with Starshield service plans supporting non-aviation operations; (2) Operational Customer Specific PLEO Service with Starshield group service plans; and (3) Starshield Aviation PLEO Terminals including Aeroterminal Tile Mini Antenna, Aeroterminal Tile Antenna, Aeroterminal Full Kit, and non-aviation terminals. The justification argues that SpaceX is the sole capable source based on unique and highly specialized equipment developed under an Undefinitized Contract Action (UCA) awarded April 25, 2024, involving substantial investment in research, development, testing, and evaluation of the Starshield mini aperture design. The government asserts that replicating this capability through alternative sources would result in substantial cost duplication (estimated at double the original investment), unacceptable delays of 1–2 years, and mission readiness degradation. The Contracting Officer determined the anticipated cost to be fair and reasonable based on historical pricing, Independent Government Cost Estimate, and current market conditions, representing the lowest overall cost while maintaining mission continuity and operational performance standards.