JA - SB003526 Redacted.pdf

JA25-073-PLEO Task Order – USSF Ground Bounce Starshield KaHTS Service for FY 2025-

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2. NATURE/DESCRIPTION OF ACTION(S):

New task order under "Task 2 – Operational Customer Specific PLEO Services" of the Proliferated Low Earth Orbit (PLEO) multi-award contract (MAC) managed by the CSCO of SSC COMSO. This is a Firm Fixed Price task order to be funded by Operations and Maintenance funds. The estimated value (including options) is with a base order of

3. DESCRIPTION OF SUPPLIES/SERVICES:

This task order shall provide operational, packaged, PLEO broadband data transport services with global coverage and internet connectivity for fixed sites. This includes equipment, reporting, and service management for each operational service, as well as on-site installation and operational support as directed.

This requirement includes a service variant that features a 1Gbps CIR in each direction, coupled with a right to increase the CIR to 10Gbps CIR in each direction for a single month out of a 12-month commitment/subscription. The latency requirement is under 200 milliseconds end to end between Guam and the contiguous United States (CONUS), which only a LEO-based service can satisfy.

Also included in this requirement are installation services and operational support services at each site where the 1-10Gbps-capable user equipment is located. This service variant, installation, and support are required to continue operation of an existing site in Guam, with options to install and support one additional site. This task order will have a base Contract Line Item Number (CLIN) and optional quantity CLINs. The period of performance for this task order will be for 12 months from the date of award.

4. SUPPORTING RATIONALE, INCLUDING A DEMONSTRATION THAT THE

PROPOSED CONTRACTOR’S UNIQUE QUALIFICATIONS OR THE NATURE OF THE

ACQUISITION REQUIRES USE OF AN EXCEPTION TO FAIR OPPORTUNITY:

(a) Exception to Fair Opportunity. Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

(b) Justification.

(1) Description of the Justification and discussion regarding cause of the sole source situation.

The only PLEO service currently available in the market that can support data rates 1 Gbps and higher is the Starshield KaHTS service. While a number of announced PLEO systems predict an ability to support throughputs of 1Gbps and higher when they become available, Amazon's Kuiper, Telesat's Lightspeed, and Rivada's OuterNET are only planning to start offering service at lower data rates in 2026, 2027, and 2028 respectively, with 1Gbps and higher data rates starting in subsequent years.

Therefore, Space Exploration Technologies Inc (SpaceX) is the only Indefinite

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Delivery / Indefinite Quantity (ID/IQ) awardee that can provide Starshield KaHTS service at the required data rates, customize it to the required variant, provide KaHTS equipment, and support installation and operation in response to this task order. No other ID/IQ awardees are authorized resellers of Starshield KaHTS service and equipment, and no other ID/IQ awardees are capable of supporting installation and operation of this proprietary service.

(2) Minimum Government requirements.

The supplier must provide equipment and service for existing and anticipated new installations. The service provided must be sized and priced for operation at 1Gbps CIR per direction, with an included option to increase the service throughput to 10Gbps CIR, per direction, for one month per year. The supplier must also offer on-site installation support for new equipment purchases and on-site operational support for each active terminal location. The satellite backhaul capability required in this task order is required to provide a backup route for maintaining high-volume connectivity between the remote U.S. Indo-Pacific Command location(s) and CONUS in the event of undersea fiber disruption. To back up lost or impaired multi-Gbps fiber connectivity (40Gbps or more), the highest available satellite data rates are required. The 10Gbps peak throughput required in this task order represents the maximum data rate available in the market today for low-latency, backhaul connectivity via satellite. The 1Gbps base throughput required in this task order represents the lowest standby data rate available on the market today using the same equipment that achieves the 10Gbps peak.

(3) Proposed sole source contractor and demonstration of unique source.

SpaceX is the only contractor that can provide service and equipment meeting these requirements. As this system and network is solely owned by SpaceX, there is no mechanism to compel them to allow other vendors to resell this capability.

(4) Procurement discussion.

As noted above, the specific and unique technical requirements make SpaceX the only supplier able to meet the requirements of this task order.

SpaceX is a PLEO MAC awardee, therefore a PLEO task order is the preferred path to procure performance of the required services and equipment with minimal contracting effort.

(5) Impact.

This task order provides a backup multi-gigabit/second communication path for maintaining high-volume connectivity between U.S. Indo-Pacific Command locations (one existing site and a planned new site) and CONUS, in the event of undersea fiber disruption. Without this exception to fair opportunity, SSC would be unable to continue operating its existing KaHTS site when its current service contract (see 8(a) below) expires on 31 May 2025. Without this service, there will be no backup to the primary undersea fiber communication path. Since undersea fiber disruption is now a relatively frequent tactic of peer and near-peer adversaries, if this service is not

Page 4 of 6 Pages available, an unacceptable vulnerability to the Indo-Pacific Command operations would be introduced. In addition, there would be no benefit to government from not approving this exception to fair opportunity since market research has shown that currently only one provider can deliver the extremely high data rate satellite communication service to both the existing and new sites, and deliver the hardware and engineering support required to commission an additional site with the same capability.

5. COST/PRICE FAIR AND REASONABLE DETERMINATION:

To evaluate pricing fair and reasonableness the price of the required custom service will be compared to the current on-ramped version of KaHTS service available on the PLEO ID/IQ.

Furthermore, the Contracting Officer shall compare the proposed price with previous prices paid and comparisons with the published price of the identical hardware for the commercial equivalent of the Starlink Community Gateway. Based on the analysis and comparisons, in accordance with FAR 15.404-1(b), the anticipated price will be further determined to be fair and reasonable based on the installation and site operational support service pricing provided for similar items under the Broad Agency Announcement (BAA) contracts.

6. MARKET RESEARCH:

Market research for this task order was conducted from December 2024 to April 2025 and included references to information provided by the PLEO ID/IQ awardees that provide global broadband satellite services, as well as a search of companies outside the PLEO ID/IQ that might offer comparable capabilities. This requirement is for very high data rates and no competitor in the market at this time can meet the Government's need. Further, this requirement is for proprietary products and/or product support and no competitor functional replacement products exist in the market at this time to meet the Government's need. The results of the market research revealed that the only service available on the market today that can satisfy the requirement for a low-latency LEO-based data transport service and bidirectional data transport at 1Gbps, with the ability to surge up to 10Gbps, is the KaHTS. The Government will continue to conduct market research to determine if there are changes in the marketplace that would enable future competitive actions.

Amazon's Kuiper, Telesat's Lightspeed, and Rivada's OuterNET are slated to start offering service at lower data rates in 2026, 2027, and 2028 respectively, with 1Gbps and higher data rates starting in subsequent years. None of these are available in the timeframe required for the current task order.

7. ANY OTHER SUPPORTING FACTS: None to cite.

8. ACTIONS THE AGENCY MAY TAKE TO REMOVE OR OVERCOME BARRIERS

THAT LED TO THE EXCEPTION TO FAIR OPPORTUNITY:

(a) Procurement History. This procurement is the first of its kind on the PLEO ID/IQ. A related prior award to SpaceX under SSC's "FreeSol" BAA (FA8819-19-R-1002)

Page 5 of 6 Pages established the Guam KaHTS site and provided services to it. A follow-on (FA8819-24-C- 1005, also awarded to SpaceX) under a continuation of the same BAA provided site operational support for the past year. As an open BAA, this acquisition was considered competitive, so no J&A was created. The PLEO task order to which this justification applies is effectively a transition to operation from Research Development Testing & Equipment of the capability established under that BAA award.

(b) As the first requirement of this type on the PLEO ID/IQ, no actions have previously been proposed to remove barriers and avoid future exceptions for this specific procurement.

While the proprietary nature of the currently established equipment and it’s supporting it means future renewals are unlikely to be competitive in the immediate term, CSCO will continue to track the market. Our ongoing market research indicates that competitive capabilities may emerge from other suppliers in the future. The government will actively monitor these developments, looking for alternative solutions with sufficiently low equipment and service costs to justify replacement of the installed hardware when it becomes feasible. CSCO will also continue to engage with the sole source provider regarding the potential to authorize resellers and thereby enable competition for this service.