ETIS III Extension JOFOC (APPROVED).pdf

Rev.:5/2024

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Goddard Space Flight Center (GSFC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Environmental Test and Integration Services (ETIS) III/80GSFC19C0060

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 “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) Goddard Space Flight Center

(GSFC).

The procuring agency is the National Aeronautics and Space Administration (NASA) and the contracting activity is Goddard Space Flight Center (GSFC).

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 an extension and increase the maximum ordering value by $13.2M to contract number 80GSFC19C0060, with Peraton Inc. The Environmental Test and Integration Services (ETIS) III contract currently expires on March 31, 2025. Award of the ETIS IV contract is currently anticipated to be awarded by October 1, 2025, followed by a 60-day phase-in period resulting in an estimated contract effective date of December 1, 2025.

The contract extension period request is based on the need to continue performance and critical support as a result of the delayed award of the follow–on contract, ETIS IV (inclusive of the 60-day phase-in period), because of the government proactively taking tangible steps to encourage a wider range of companies to bid, which included strategy meetings with Center Leadership. As these changes are identified below:

1. Updating the ETIS IV Scenario and routing through Center Leadership for approval.

2. Adding Industry Day, which was held on September 16, 2024, with 52 participants. In addition, one-on-one meetings were offered to attendees in which 19 contractors requested. These meetings were scheduled and held within two weeks of Industry Day.

An option period is also being requested in the event that additional delays are encountered (i.e. the contract is not awarded on initial proposals and would need to go into competitive range). As a result of this delay, an extension to the contract’s period of performance and an increase to the maximum ordering value are being requested as follows:

*The estimated value to cover the 8-month base period extension is $38M. All but $3.2M can be absorbed within the current maximum ordering value.

This action, inclusive of the option, will potentially extend the current contract period of performance by up to ten (10) months and increase the maximum ordering value by a total of up to $13.2M. The option will only be exercised if additional time is needed to award the ETIS IV contract. This will allow for continued performance and continuation of mission critical services under the ETIS III contract.

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):

The principal purpose of this contract is to provide Environmental and Test Integration Services and other laboratory operations for the Environmental Test Engineering and Integration Branch of the Engineering and Technology Directorate’s (ETD) Mechanical Systems Division at GSFC. The ETIS III contract support includes the following:

Operation, maintenance, and upgrade of environmental test equipment and facilities located in the GSFC Building 7/10/15/29 complex, Area 300 Magnetic Test Site, and other technical facilities located at various locations within GSFC including the manufacturing and electroplating equipment and facilities primarily located in GSFC Building 5/10/21 shops

Mechanical and optical integration of spacecraft, flight experiment components, instruments, sub-assemblies and systems

Fabricate, manufacture, and assembly of custom spacecraft, flight experiment components, instruments, sub-assemblies and systems

Design, manufacture, and operation of ground handling equipment and fixtures Design, manufacture, and operation of optical alignment and calibration systems Design, manufacture, and installation of space flight thermal blankets Design, manufacture and installation of space flight and ground support system cable harnesses Design, manufacture, and installation of technical facilities including buildings, building elements, utility systems, and technical equipment and systems Define, analyze, and resolve electromagnetic radiation issues relating to facility and satellite ground support equipment operation within the test complex. Support spectrum signature analysis to ensure interference-free and safe operation of all facility-located near electromagnetic wave sensing devices.

Test and Integration Engineering and engineering analysis Cleanroom operation and maintenance

Base Period April 1, 2025 –

November 30, 2025 Eight (8) months $3.2M*

Option Period 1 December 1, 2025 –

January 31, 2026 Two (2) months $10M

Contamination control services Maintenance and operation of certain physical plant systems such as processed water, emergency power, LN2/GN2 storage systems, conditioned cleanroom air HVAC and humidity systems

Facility and operations safety Data acquisition and analysis system development and management.

NASA GSFC is requesting to increase the maximum ordering value by an amount of $3.69M and extend the current base contract effective ordering period as shown in the table above, to allow for new and continued performance through January 31, 2026 (if necessary). The contract extension and ceiling increase are needed for the continuation of mission critical multidisciplinary work requirements under the ETIS III contract, the completion of the ETIS IV Source Evaluation Board (SEB) evaluation process, award of the ETIS IV contract, completion of the 60-day phase-in process, and any unforeseen circumstances.

The vast majority of the current ETIS III tasks are expected to transition to the ETIS IV contract and are expected to maintain or increase their current levels of support for the next year. As a result of the delays experienced during the ETIS IV solicitation process, it is now necessary to extend the current ETIS III contract beyond March 31, 2025, and increase the maximum ordering value to allow for uninterrupted support for most of the task’s orders currently on ETIS III. In particular, the ETIS III contract extension allows for continuation of critical NASA mission related work such as facility engineering, operations and maintenance of the Environmental Test Engineering and Integration test facilities to ensure that the facilities are operational and can support flight project test campaigns. For example, modifications to the Space Environment Simulator (SE) chamber are currently being performed in preparation to support the test configuration of the Roman Space Telescope (RST)’s Spacecraft and Integrated Payload Assembly (SCIPA) environmental testing. Flight blanket fabrication for the RST Outer Barrel Assembly (OBA), Solar Array Sun Shield (SASS), flight closeout blankets, optical engineering and integration support for Dragonfly Mass Spectrometer (DraMS), and OSAM-1 closeout are ongoing, as well as the integration of several RST subsystems and components, including SASS, OBA, Wide Field Instrument (WFI), and Lower Instrument Sun Shade (LISS) are also ongoing. This contract extension allows for the continued assembly, integration, harness and blanket fabrication, and test support for those missions currently in Phase D/system assembly, integration, and test in the complex.

RST integration and testing activities are at a critical stage of integrating the full RST Observatory in the Space Systems Development and Integration Facility (SSDIF) and requires personnel, facility engineering and logistics support from the ETIS III contract to meet these critical milestones. Continued contamination control and purge support for RST is also critical with the delivery and integration of RST’s Wide Field Instrument (WFI) into the spacecraft. Test facility modifications for the Space Environment Simulator (SES) environmental testing are also ongoing and need to be completed to support the RST SCIPA Pathfinder thermal environmental test. A potential contractor change at this stage would highly disrupt the ability to deliver the work on schedule because it would require a steep learning curve if new personnel were to be brought on board in addition to significantly increasing risk. The administrative costs for both the government and a new contractor would be considerable. The projects are at critical points where they need to execute their schedules to keep their deliverables and commitments to the agency.

The multi-discipline nature of this contract’s support, and the mission-critical support requirements often demand specialized engineering manpower and specialized knowledge of the fully integrated RST subsystems (LISS, OBA, SASS, and communication system).

In addition, specialized knowledge of the unique integration and test facility systems require engineering expertise to properly execute as RST continues to integrate these subsystems into the overall RST Observatory in preparation for SCIPA environmental testing and launch. These milestones are directly on the critical path for RST mission’s success prior to launch. The ETIS III contract must be able to react quickly and readily provide uninterrupted support for these high priority projects. Project requirements depend upon the specialized skills and flexibility of the multidiscipline engineering services provided by this contract. The ETIS III contract extension will allow for the needed continuity of services for these projects as they are in critical stages while allowing for any unexpected delays that these programs may experience.

Without an extension and maximum ordering value increase to the ETIS III contract, NASA GSFC would be precluded from continuing current ongoing support requirements and issuing further new short-term task orders for services under this contract.

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 U.S.C.

3204(a)(1), as implemented by FAR 6.302-1 Only one responsible source and no other supplies or services will satisfy 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. 3204(a)(1) is that a sole-source award to Peraton, Inc. is necessary, due to the nature of the work to be performed, the short duration of the extension period, and because NASA currently has a competitive follow-on underway.

As the incumbent contractor, Peraton is uniquely qualified to provide services required under the interim period. Services are needed for a short period until the 5-year follow-on contract is awarded. Peraton is able to continue performing services without requiring a startup period and/or the normal learning curve typically encountered by new incoming contractors. Should these services be interrupted, NASA will be unable to perform and fulfill critical multidiscipline engineering support and related services, specifically: mechanical integration and assembly of the Roman Space Telescope, critical real-time contamination control, facilities and maintenance operations of the Space Systems Development and Integration

Facility (SSDIF) and several cleanrooms where RST subsystems are being integrated, functionally tested, and prepared for integration into the overall RST Observatory, facility modification of the Space Environment Simulator to accommodate RST’s Spacecraft and Integrated Payload Assembly (SCIPA) environmental space simulation test configuration.

The SCIPA test campaign is a series of integrated, system level functional and operational testing to ensure that that all the flight instruments and systems that comprise the RST Observatory work together. SCIPA is the final environmental test campaign for RST that verifies the integrated function and operation of the observatory prior to launch, so the concurrent support and performance of these interrelated activities enables RST to remain on schedule. In determining a solution that represents the least amount of risk to the government, stability and continuity are critical factors. Peraton, Inc is considered the only contractor that can meet GSFC’s needs, given short amount of time remaining under the current contract. These services clearly function as integral parts of the end-to-end integration and testing of NASA’s Earth Science Mission Operations and Space Science Mission Operations projects, including RST, PACE, Dragonfly, and other missions.

The unique skills required to support such critical missions and milestones cannot be readily replaced without a steep learning curve. The highly technical and varied activities associated with the ETIS III contract require a very specialized set of skills which were built up over the years. This includes an in-depth knowledge of the operation and maintenance of the test facilities, as well as project-specific processes and requirements that were developed over the course of the integration and test campaign. The learning curve that is required to cultivate the necessary across-the-board skills pertaining to the ETIS III contract could take several years to overcome and at considerable cost. The incumbent already possesses the necessary skills required for uninterrupted performance. Therefore, NASA believes that the incumbent contractor, Peraton, is the only contractor capable of providing the necessary and specific skills, experience and expertise required for the ordering period extension.

If NASA attempts to procure these services from any other source in lieu of extending the contract, the combination of delay due to the competitive process and the time required to transition a new management team to coordinate staffing levels, schedules, and to become familiar with work requirements and systems would cause unacceptable delays in fulfilling NASA’s mission. Based on the time and costs that would be involved in procuring and phasing in another contract, Peraton is the only entity possessing the detailed knowledge necessary to provide seamless continuation of the services provided under the ETIS III contract without risk of an unacceptable interruption or delay of critical services.

In addition, allowing a short contract extension will avoid a substantial duplication of cost to the Government that would be incurred if another contractor was brought onboard for this short timeframe. The additional and significant administrative costs for soliciting, negotiating, and awarding a short-term interim contract, in addition to negotiating and awarding a considerable number of task orders, cannot reasonably be expected to be recovered through competition, especially when the competition process for the follow-on is already underway. This is unacceptable to the Government given that the duration of the performance for this interim contract extension could be as little as eight (8) months. In order for the Government to avoid substantial duplication of costs and to avoid unacceptable delay in performance of critical requirements, an eight (8) month base and two (2) month option contract extension with Peraton, Inc. is required.

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 November 12, 2024, in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to award this sole-source extension to Peraton, Inc. 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 that the anticipated cost to the government will be fair and reasonable. This proposed extension and maximum ordering value increase is to accommodate additional work that is within the current contract scope and does not require the addition of new labor categories or updated labor rates. As CY6 rates were evaluated and determined fair and reasonable at contract award. Task Orders will continue to be negotiated or extended in accordance with the pre-negotiated contract rates.

Support from external organizations such as the Defense Contract Audit Agency may be utilized regarding determining Business Systems adequacy as needed.

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

Given the urgency of the need, and the immensity and complexity of the requirement, strategic market research which was conducted continuously throughout the acquisition process, the COR’s knowledge and experience indicate that no other entities possessing the required knowledge and expertise necessary to perform these services currently exist.

Within this limited time frame for implementing this contract extension, NASA GSFC does not believe any alternate sources can take on full contract responsibility without risk of an unacceptable delay to critical milestones. The Government would unnecessarily incur significant additional costs if another contractor were to perform this effort. A competitive ETIS IV contract is expected to be awarded by October 1, 2025. An assessment of other existing current contracts was made with the conclusion that no viable contract vehicles existed that could reasonably support the requirement. The requirement for ETIS III continuity of operations and the need to meet critical mission milestones for the flight project missions leaves no feasible alternative except to extend the period of performance of the ETIS III contract. The synopsis was posted on November 12, 2024, and closed on November 27, 2024. The Government received no responses.

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

N/A

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 was posted on November 12, 2024, and closed on November 27, 2024. The Government received no responses.

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:

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. The Government is in the process of conducting a competition for the follow-on acquisition.

ENVIRONMENTAL TEST AND INTEGRATION SERVICES (ETIS III)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

I certify that the facts presented in this justification are accurate and complete.

Mellina Espiritu Technical Representative

I hereby certify that the above justification is complete and accurate to the best of my knowledge and belief.

Eboni Washington Contracting Officer

APPROVED:

Competition Advocate Goddard Space Flight Center

Rev.:5/2024

Jennifer Elkins Digitally signed by Jennifer Elkins Date: 2024.12.18 19:49:58 -05'00'