Final JOFOC - 80KSC019C0016 - 8.11.26 (signed)redacted_Redacted.pdf

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Justification for Other than Full and Open Competition (JOFOC) Unusual and Compelling Urgency ii

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Base Issuance Date: 6/22/2026

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NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Kennedy Space Center (KSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

UNUSUAL AND COMPELLING URGENCY

For Kennedy LX Support Services III (KLXS III)

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).

The procuring agency is NASA, and the contracting activity is Kennedy Space Center.

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 ARES Technical Services for the Kennedy EGS Program (LX) Support Services Contract- Three (KLXS-III)- 80KSC019C0016 for a period up to one year.

This requirement is critical to NASA�s Artemis campaign and its overall mission to safely land humans on the lunar surface.

The Artemis campaign�s timeline, and its included mission dates, are a vital component of the government�s need. For reasons discussed below, delays to mission execution as a result of developmental challenges are likely to result in mission failure. This contract is necessary to ensure that development of a lunar landing capability is complete in time to support NASA�s Artemis missions.

a. The Artemis Campaign and National Strategic Interests.

The Artemis campaign consists of several interconnected NASA programs, encompassing multiple contracts and international efforts. Each component of the campaign is required to reach the agency�s end state of landing humans on the lunar surface. Among these programs are: the Space Launch System (SLS), NASA�s primary space launch capability; Orion, NASA�s solution for transport of crew from low-earth orbit to cis-lunar orbit; Extra-Vehicular Activity (EVA) suits and the Human Landing System (HLS). Each of these programs depends upon the timely development and success of the others to perform its role, and delays within one program have a cascading effect upon the others.

NASA�s Artemis campaign explores the Moon for scientific discovery, technological advancement, and to learn how to live and work in another world in order prepare for human missions to Mars. The

Artemis campaign collaborates with commercial and international partners to establish the first long-term presence on the Moon. These efforts support several vital national strategic interests including national security, solidifying the United States� leadership and influence in space, supporting scientific and technological development, and supporting space commercial development.

To support these interests and ensure continued American superiority in space exploration, it is critical that the United States return to the lunar surface before its global competitors. By completing a lunar landing mission in advance of our global competitors, the United States can shape rules, policy, priorities, and the overall geopolitical landscape of future space exploration. This will provide the United States with the initiative needed to best advance related national interests and maintain its role as the global leader in space exploration. Falling behind our global competitors in this effort cedes this initiative, and our nation�s leadership in space exploration, to our global competitors. This will result in unacceptable impacts to the United States� geopolitical position and its national security.

Currently, China is actively developing a human crewed Moon landing mission. China has recently experienced significant success in development of space exploration technologies, including launch and landing of the country�s first reusable orbital rocket in 2025. China�s significant space technology progress has established the country as a near-peer competitor to the United States for space exploration. China�s recent progress also includes significant developments in the country�s crewed lunar program, including successful liftoff and landing tests of a crewed lander. These developments place China on target to meet their current goal of landing two astronauts on the lunar surface before 2030.

It is critical to the national interests of the United States, and therefore to NASA�s mission, that the Artemis program return American astronauts to the Moon before China reaches this milestone and seizes the initiative and global leadership role in human space exploration. NASA plans to launch its first mission to return humans to the Moon (currently titled �Artemis IV�) by 2028. This launch schedule is critical to NASA�s mission and the national interests it supports.

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):

A. The KLXS III contract provides specialized expertise for Exploration Ground Systems (EGS).

These services support human-rated launch, recovery, and post-flight integration operations and are mission-embedded within EGS activities. The scope of required services includes, but is not limited to:

Ground systems and launch systems integration support

Systems engineering, requirements management, and verification support

Ground operations planning and execution support for launch and recovery campaigns

Configuration management and change control

Schedule, budget, and risk analysis Program and mission integration across EGS functional areas

Technical, programmatic, and strategic communications in support of the EGS Program Office

Performance of these services requires continuous coordination across engineering, operations, safety, and program management disciplines within a high-reliability operational environment. These services are required during a mission phase in which ground systems requirements, processing approaches, and operational risk postures continue to evolve as successive Artemis missions incorporate additional human-rated systems, new mission elements, and increased integration with commercial and other partners. Execution of the required services includes the capture, analysis, and incorporation of lessons learned from prior launch and recovery campaigns into subsequent mission planning, ground processing, and execution activities. Based on these reasons it is in the Government�s best interest to extend the KLXS III contract for one year.

b. The anticipated cost for this action is expected to be

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)(2), as implemented by FAR 6.103-2, Unusual and compelling urgency.

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)(2) is as described below.

The agency�s need for mission embedded support through the Kennedy EGS Program (LX) Support Services Contract-Three (KLXS-III) is of such an unusual and compelling urgency that the Government would be seriously injured, both financially and in terms of significant negative impact to the national interests discussed herein, if it is not permitted to limit the number of sources from which it solicits proposals.

In order to return to the lunar surface before our global competitors and advance the United States� national interests in space exploration and leadership, NASA must return American astronauts to the surface of the Moon as quickly as technological development will safely allow. Current Artemis mission timelines require a lunar landing mission by 2028, with capability demonstration mission milestones planned for Fiscal Year 2027.

Though this mission timeline places NASA close to the developmental timelines and mission goals of our global competitors, this timeline ensures that the Agency is able to support the country�s space policy objectives and related national interests. Further delay to this timeline would place the United States unacceptably close to ceding its leadership in space exploration to our global competitors � significantly harming the national interests of the United States, including national security, scientific advancement, technological maturation and superiority, and other critical Government priorities.

The incumbent workforce also possesses detailed familiarity with safety-critical systems, hazard mitigation procedures, operational constraints, and historical anomaly data. This experience enables rapid identification of potential issues, effective risk assessment, and timely coordination with Government personnel to implement corrective actions. Introducing a new contractor without this established knowledge base would increase the risk of operational inefficiencies, delays in anomaly resolution, and potential misinterpretation of safety-related data.

Following Artemis II, the program transitioned to support Artemis III, which under the current mission architecture is planned to conduct crewed operations in low Earth orbit rather than a lunar landing mission. Despite this updated mission profile, Artemis III remains a critical operational milestone requiring continued integration of flight and ground systems, coordinated launch processing activities, and rigorous verification of safety and mission readiness criteria. Beyond these initial missions, NASA is working toward a steady-state operational posture that supports an increased mission cadence for the Artemis program. Maintaining continuity of KLXS III contractor support during this transition will help streamline launch preparation activities, preserve experienced personnel, and improve operational efficiency as the program moves toward more frequent missions.

Transitioning to a new contract vehicle during these critical phases could disrupt established technical processes, introduce schedule risk, and slow operational momentum at a time when the Agency is working to increase launch cadence. Approval of this deviation will ensure continuity of expertise and operational stability, enabling EGS to safely execute upcoming Artemis missions while supporting the program�s transition to sustained operations.

The contract extension is an efficient method of execution regarding the current environment of the Artemis Program. Currently, the NASA Administrator is requesting and reviewing a Workforce Assessment on core capabilities and alignment between contractor and Government roles and responsibilities. The Exploration Ground Systems Program is developing its strategic approach across all the Program requirements and how they align the Administrators� directive. The Government must remain focused on immediate mission execution requirements for Artemis III and associated EGS operations.

Allowing full and open competition would open the program to risk. Performance of the required services relies on personnel who possess current facility access, certifications, and familiarity with EGS-specific governance, safety, and operational decision processes, developed through direct participation in human spaceflight ground systems operations. Integration of new personnel into these environments involves a non-trivial learning, certification, and re-integration process, particularly within launch control, vehicle processing, and ground operations contexts. Transition to a different contractor during active mission phases may affect operational timelines and risk profiles during periods of heightened mission activity. Effective execution of successive Artemis missions depends on the timely application of lessons learned from prior launch and recovery campaigns. Certain aspects of EGS support rely on contextual, experience-based knowledge developed through direct participation in these campaigns and through ongoing interaction with evolving processes and systems. Transition during an interim period may require time to re-establish this operational context within safety-critical environments. The considerations described above are specific to the timing, operational context, and mission phase associated with an interim requirement. They do not preclude future competition once operational conditions, mission tempo, and transition risk profiles change, nor do they represent a determination regarding long-term acquisition strategy. Due to the nature of the requirement for this capability, every day in the developmental timeline is absolutely vital for ensuring that a lunar landing capability is completed in time for NASA�s established mission dates.

Each day added to this timeline � including the significant time that would be required for a full and open competition � places the United States closer to ceding its space exploration leadership to our global competitors.

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:

The contracting officer has determined in accordance with FAR 5.101(b)(1) that this action is exempt from the notice required in FAR 5.101, because unusual and compelling urgency precludes competition to the maximum extent practicable and the Government would be seriously injured if the agency complies with the publicizing and response time periods specified in FAR 5.101(d).

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 must 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. The proposal analysis will 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 a statement of the reasons market research was not conducted (e.g., urgent, and compelling requirement):

Based on the unusual and compelling urgency of NASA�s requirement and the authority of FAR 6.103-2(b), additional market research was not conducted The Government possesses substantial in-depth knowledge of the marketplace based on prior acquisitions and ongoing performance under KLXS III, which indicates that the incumbent contractor is uniquely positioned to meet the near-term requirements within the required timeframe. In accordance with FAR Part 10, while market research is generally required to identify commercial solutions or alternative sources, delaying award to conduct market research would have posed risk to Artemis III mission preparation and execution and would not have changed the acquisition strategy. Accordingly, the decision to proceed without conducting market research is reasonable, justified, and in the best interest of the Government.

Through the use of previous competitive activities, including the already established market research, and consultation with knowledgeable individuals in Government relative to aerospace activities, the contracting officer has determined that ARES Technical Services is capable of performing this requirement in the required timeframe.

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

This action aligns with the Executive Order 14369, Ensuring American Space Superiority, directive to return humans to the lunar surface no later than 2028. It also supports national priorities to ensure American leadership in space exploration by returning humans to the lunar surface before our international competitors.

The interim requirement coincides with active and upcoming Artemis human spaceflight campaigns, during which Exploration Ground Systems (EGS) are characterized by elevated mission complexity, evolving processing flows, and increased integration demands. During this period, mission-embedded support is important to enable immediate support for launch, recovery, and post-flight integration activities without extended phase-in periods or parallel �shadow� operations.

Performance of the required services relies on personnel who possess active certifications, and in-depth understanding of EGS-specific governance, safety, and operational decision-making processes, expertise developed only through direct participation in human spaceflight ground systems operations. Integration of new personnel into launch control, vehicle processing and ground operations requires significant learning, qualification and reintegration period, during which operational efficiency, schedule adherence, and risk posture may be adversely affected. Transitioning to a different contractor during active Artemis mission phases would increase operational risks and introduce potential delays at a time when mission-embedded continuity is essential to sustaining safe and timely ground systems execution.

Effective execution of successive Artemis missions depends on the timely application of lessons learned from prior launch and recovery campaigns. Certain aspects of EGS support rely on contextual, experience-based knowledge developed through direct participation in these campaigns and through ongoing interaction with evolving processes and systems. Transition during an interim period may require time to re-establish this operational context within safety-critical environments.

Transition of an interim requirement may involve duplication of certain Government investments, including onboarding, training, certification, access authorization, and re-integration activities associated with safety-critical ground systems support. During an interim operational period, these duplicative efforts may not be offset by the benefits of competition due to the limited timeframe and elevated mission demands.

The considerations described above are specific to the timing, operational context, and mission phase associated with an interim requirement. They do not preclude future competition once operational conditions, mission tempo, and transition risk profiles change, nor do they represent a determination regarding long-term acquisition strategy.

10. FAR 6.104-1(a)(10) � A listing of the sources, if any, that expressed an interest in writing in the acquisition:

Based on the unusual and compelling urgency of NASA�s requirement and the resulting use of NASA�s authority under 10 U.S.C. 3204(a)(2), the Agency did not conduct public Requests for Information and thus received no responses. NASA also did not receive any unsolicited proposals to support a different approach to the Agency�s requirements.

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:

NASA�s future approach to acquisitions related to human space exploration is intended to establish a robust, competitive space economy. NASA has engaged in a parallel developmental contract structure in part to ensure completion of future Artemis missions and to support a sustained contractor base for future competitive lunar transportation requirements.

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.