EraDrive_JOFOC_80ARC026R0008_Redacted_for_Posting_9292026.pdf

REDACTED FOR PUBLIC RELEASE

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Ames Research Center (ARC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

For EraDrive Autonomy Modules (Era-A), Ground Support Equipment, and Associated Services under the Accelerate the Procurement and Fielding of Innovative Technologies (APFIT) Program

Solicitation No. 80ARC026R0008

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 the National Aeronautics and Space Administration (NASA), Ames Research Center (ARC), Research Centers Procurement Office, JAZ Branch, Moffett Field, California. The procuring agency is NASA, and the contracting activity is NASA ARC.

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 new firm-fixed-price, definitive commercial contract on a sole-source basis to EraDrive, Inc., Palo Alto, California, for the production and delivery of flight-qualified spacecraft autonomy modules and associated ground support equipment and services. The estimated value is $11,890,000 and the period of performance is from the date of award through December 31, 2028 (the end of the first quarter of fiscal year (FY) 2029), corresponding to final delivery of the autonomy modules.

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).

EraDrive, Inc. will deliver two (2) flight-qualified EraDrive Autonomy Modules (Era-A), one optical hardware-in-the-loop stimulator for software- and hardware-in-the-loop validation and operator training, and one electrical ground support equipment (EGSE) kit with integration, test, verification, and validation tooling, together with associated nonrecurring engineering to productize the capability and upgrade key components for Medium Earth Orbit and Geosynchronous Orbit environments, and engineering support services. The Era-A module is an integrated hardware and software product providing vision-based, Global Positioning System (GPS)-independent positioning, navigation, and timing; autonomous onboard maneuver planning; and autonomous optical detection, identification, and orbit determination of resident space objects. The capability was demonstrated to Technology Readiness Level 9 aboard NASA’s Starling small spacecraft swarm. NASA ARC is the servicing, awarding, and administering agency under an Economy Act reimbursable interagency agreement with the Office of the Under Secretary of War for Research and Engineering (OUSW(R&E)), formerly the Office of the Under Secretary of Defense for Research and Engineering (OUSD(R&E)), which is funding this effort under its Accelerate the Procurement and Fielding of Innovative Technologies (APFIT) program. The estimated value is $11,890,000.

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. This is a commercial acquisition conducted under the procedures of FAR Part 12. Consistent with FAR 12.102(b) and Table 12-1, a commercial acquisition that restricts competition and exceeds the $9,000,000 ceiling for simplified procedures under FAR 12.201-1 cites the applicable statutory authority in FAR 6.103; the authority cited for this action is FAR 6.103-1.

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.

EraDrive, Inc. is the only responsible source capable of satisfying this requirement, for the following reasons:

Limited rights in data and proprietary technology. The autonomy module implements EraDrive’s proprietary vision-based navigation and swarm autonomy software. EraDrive holds the rights to this software, technical data, source code, and algorithms. The Government does not possess, and is not licensed to provide to a third party, the technical data or software that another contractor would require to produce flight-qualified modules.

Exclusive knowledge and the only flight-proven capability of its kind. EraDrive’s module is the only GPS-independent optical positioning, navigation, and timing and autonomy capability of its kind with demonstrated on-orbit flight heritage, validated to Technology Readiness Level 9 aboard NASA’s Starling small spacecraft swarm, on orbit since July 2023 and still operational. EraDrive’s personnel developed, flew, and continue to operate the on-orbit capability and uniquely possess the validated algorithms, flight software, and operational knowledge required to produce flight-qualified modules. No other source possesses a fielded or flight-demonstrated equivalent.

The nature of the acquisition requires this source. The requirement is for flight-qualified modules delivered within the program window. No other source could develop, qualify, and validate an equivalent GPS-independent optical navigation and autonomy capability to the maturity already achieved within the time the requirement allows, and any attempt to do so would result in unacceptable delay in fulfilling the agency’s requirement.

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 of NASA’s intent to award this sole-source contract to EraDrive, Inc. was published to the Government Point of Entry (GPE), SAM.gov, on June 16, 2026, informing potential sources of NASA’s intent and inviting capability statements. The notice closed July 1, 2026. The results of this notice are summarized in Section 10 below. Publication of the notice was required for this action: the exception at FAR 5.101(b)(2) for actions using other than full and open competition does not extend to the authority at FAR 6.103-1. The notice published on June 16, 2026 satisfied this requirement and confirmed the absence of other capable sources.

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 will be required to submit a proposal to be evaluated and negotiated by the Government. Prior to execution of the contractual instrument, a proposal analysis will be performed to ensure that the final agreed-to price is fair and reasonable in accordance with FAR Subpart 15.4, including comparison with EraDrive’s commercial pricing for its autonomy modules and services, the prior Starling/StarFOX award adjusted for scope, and pricing for similar commercial guidance, navigation, and control products. A commerciality determination does not in itself establish price reasonableness.

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.

Market research was conducted in accordance with FAR Part 10 from June 1, 2026 through July 13, 2026 and consisted of review of commercial product catalogs and datasheets, industry announcements and financing disclosures, prior procurement history, and technical consultation with the Starling project office, and is documented on NASA Form 1787A. The research identified commercial vendors offering spacecraft guidance, navigation, and control products and autonomy software of the same general type.

The research confirmed both that products of this type are offered in the commercial marketplace, which supports the companion commerciality determination, and that none of these vendors offers a GPS-independent optical navigation and autonomy module with demonstrated on-orbit flight heritage capable of satisfying this specific requirement within the mission window. The market surveillance did not identify a feasible alternative source.

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

EraDrive developed and owns the vision-based navigation and autonomy technology, which has operated aboard NASA’s Starling swarm since the mission’s July 2023 launch. NASA first contracted with EraDrive in FY25, when Starling spacecraft were degrading and the swarm risked losing mission capability: a sole-source contract valued at $1,000,000, justified under the unusual and compelling urgency authority (now implemented at FAR 6.103-2), for a software update to the on-orbit spacecraft that stabilized the degrading swarm, which remains operational. Because the total period of performance under that authority may not exceed one year, NASA awarded a separately justified follow-on contract valued at $420,000 in June 2026 for continued development of the on-orbit flight software. The present action acquires the flight-validated capability in production-qualified form. The statutory purpose of the APFIT program is to accelerate the procurement and fielding of innovative technologies already demonstrated, and the funding sponsor selected NASA Ames as servicing agency expressly in the interest of expertise, given NASA’s existing technical knowledge of the capability gained through Starling operations and the prior actions described above. This justification rests on FAR 6.103-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements; it does not rest on the follow-on ground described at FAR 6.103-1(c)(2), and the duplicated-cost estimate required by FAR 6.104-1(a)(9) when that ground is cited is therefore not applicable.

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 published on the Government Point of Entry (GPE) website, SAM.gov, per FAR Subpart 5.1 (see Section 6 above). The notice was posted on June 16, 2026 and closed July 1, 2026. No companies expressed interest in writing, and no capability statements were received in response to the notice.

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. This award is for a single, defined demonstration quantity. Any future recurring production requirement is separately funded, not yet appropriated, and may be addressed by future modification or a new acquisition once funding and the supporting interagency agreement are in place. Before any such subsequent acquisition, the contracting officer will reassess the availability of competitive sources, monitor the maturing commercial spacecraft autonomy market identified in the market research, and pursue appropriately scoped data or interface rights to enable competition.

Joshua Taggart Digitally signed by Joshua Taggart Date: 2026.08.11 10:45:36 -05'00'

Lauren Johnson Digitally signed by Lauren Johnson Date: 2026.08.11 12:06:45 -05'00'