JEFO TO4 80JSC026FA082 (xEVAS Contract 80JSC022DA022).pdf

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

LYNDON B. JOHNSON SPACE CENTER

Justification for An Exception to Fair Opportunity (JEFO)

Pursuant to Federal Acquisition Regulation (FAR) 16.505(b)(2)(i)(B)

Description of the action being approved:

This justification documents the basis for issuing a Task Order (TO) under the Exploration Extravehicular Activity Services (xEVAS) contract using an exception to the fair opportunity process in accordance with FAR 16.505(b)(2)(i)(B), Exceptions to the fair opportunity process.

In September 2022 Axiom Space (Axiom) was awarded a task order under xEVAS Sub Contract Line Item Number (SubCLIN) 2A, Artemis EVA Demonstration, for the development, testing, certification, integration, and operation of the Contractor’s xEVA System to support an EVA demonstration on the lunar surface in support of an Artemis mission. On February 27, 2026, the NASA Administrator announced that a second lunar mission will occur in 2028 and EVA capability will be required to support this mission. While the additional services needed to support a second 2028 lunar mission fall within the overall scope of the xEVAS contract, they are outside the scope of the currently awarded Artemis task order, which covers only a single demonstration mission.

Description of the supplies or services required to meet the Agency’s needs:

This action is a firm-fixed-price TO for Sub Contract Line Item Number (SubCLIN) 2B, Artemis EVA Services, to acquire from Axiom the commercial services and activities required to support a second lunar mission in 2028 under NASA’s Artemis Program. The objective of xEVAS CLIN 2B is to provide end-to-end EVA capability for Artemis missions, from mission planning through post-flight assessment, including response to unplanned events and inflight anomalies, to enable successful EVA execution with the lowest achievable safety risk.

Under xEVAS CLIN 2, commercial EVA services include providing certified spacesuits (life support, pressure garments, informatics, avionics, and communications), crew aids, vehicle interfaces, flight and ground support hardware, accessories, and contractor support for NASA training and real-time operations.

The total ceiling price of the proposed TO for SubCLIN 2B is $65,803,210. The estimated period of performance is authorization to proceed plus 34 months, which is the time expected to complete all required integration activities, joint testing, training support, real-time mission operations support, and all other activities required under SubCLIN 2B through a Post-Mission Assessment Review.

Identification of Exception to Fair Opportunity:

FAR 16.505(b)(2)(i)(B), 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.

Supporting Rationale:

The statutory authority for this JEFO, as implemented by FAR 16.505(b)(2)(i)(B), permits an exception to the fair opportunities process when only one awardee can provide the required supplies or services at the necessary level of quality due to their unique or highly specialized nature.

Spacesuit development is inherently unique and highly specialized, effectively resulting in a human‑sized spacecraft with stringent technical requirements. Axiom is the only xEVAS contractor currently in active development of an xEVA system, making it the sole provider capable of meeting these requirements.

Determination that the anticipated cost to the Government will be fair and reasonable:

The request for Axiom’s task order proposal will rely on the prices established in Table B.5.2, Artemis EVA Demonstration (SubCLIN 2B) Schedule for Calendar Year 2026, and the milestone prices in Attachment J-08, Work Plan, as the basis for negotiations. The Government previously determined Axiom’s pricing to be fair and reasonable at the time of the xEVAS contract award was competitively awarded on May 31, 2022. This determination was made by the the Contracting Officer (CO) through a price analysis conducted in accordance with FAR 15.305, FAR 15.404, and NFS 1815.305. There have not been any developments in the relevant market that have changed in the months since award of the xEVAS contract to indicate that the market for EVA services has changed.

In accordance with the terms and conditions of the xEVAS contract, under which the requirement for certified cost and pricing data was waived, the CO will require Axiom to provide data other than certified cost or pricing data. This information will be used to prepare a Pre-negotiation Position Memorandum (PPM) in accordance with NFS 1815.406-1. The PPM will document the CO’s price analysis, consistent with FAR 15.404, to determine a fair and reasonable price for the SubCLIN 2B services.

Any Other Facts Supporting the Justification:

A Notice of Intent letter was provided to the two xEVAS contractors on March 5, 2026, notifying them of the Government’s plan to sole-source a TO to Axiom for SubCLIN 2B, Artemis EVA Services. The letter stated that any issues regarding the strategy be provided to the CO by March 10, 2026. Collins Aerospace submitted an email response on March 6, 2026, stating that, due to the descoping of its xEVAS task orders, the company has no comments regarding NASA’s intent to proceed with negotiations with Axiom Space for the CLIN 2B task order.

On Feburary 27, 2026, NASA announced that it is accelerating its Artemis mission tempo to meet U.S. objectives for sustained lunar exploration and strengthen U.S. leadership in space.

This expanded cadence supports executing two lunar surface missions in 2028. Following this announcement, a directive was issued by NASA’s Exploration Systems Development Mission Directorate on February 27, 2026 requiring all Artemis programs to initiate all contract actions necessary to align with the increased mission tempo.

While xEVAS is a multiple-award, IDIQ contract, NASA publicly announced on June 26, 2024, that “NASA and Collins Aerospace have mutually agreed to descope the existing task orders on the Collins Exploration Extravehicular Activity Services contract.” NASA further explained in the same announcement that the descoping decision followed Collins’ determination that its development timeline could not support NASA’s mission objectives. As a result, while Collins is still a prime contractor on xEVAS, it is not actively developing an xEVA system capable of supporting a lunar mission in 2028. Accordingly, Axiom is the only xEVAS contractor currently capable of meeting NASA’s 2028 lunar EVA requirements.

A statement of the actions, if any, the Agency may take to remove or overcome any barriers that led to the restricted consideration before any subsequent acquisition for the supplies or services is made:

The CO will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements. Also, the xEVAS contract includes an “On-Ramp” clause that enables competition for future requirements not currently on contract by allowing qualified new service providers an opportunity to provide EVA services in the future.