JOFOC_CCF P3_Redacted.pdf

Rev.: 10/2025

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Kennedy Space Center (KSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

Modification to 80KSC020C0013, Converter Compressor Facility (CCF)

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), Kennedy Space Center.

The procuring agency is the 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 a new work modification to 80KSC020C0013 with Sauer Incorporated for the next phase of modifications to the Converter Compressor Facility (K7-0468), referred to as Converter Compressor Facility (CCF) Phase 3. This action supports the implementation of additional modifications necessary to integrate the helium recovery system and advance the next iteration of improvements at this mission-critical facility.

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):

This action will procure design-build construction services necessary to execute the next integration of the planned helium recovery system for Phase 3. These design-build construction modifications support NASA mission operations that rely on continuous supply of essential commodities provided by the facility, which also supports commercial partners such as SpaceX, Blue Origin, and ULA. The estimated value of this effort is with performance beginning 2026 and continuing through 2027.

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.

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 authority cited in 10 U.S.C. 3204(a)(1), implemented under FAR 6.103-1(c), applies when a follow-on contract for highly specialized services would result in substantial

Rev.:10/2025 duplication of cost to the Government that cannot be recovered through competition, or unacceptable delays in fulfilling agency requirements. Phase 3 constitutes the continued development of a major system and highly specialized equipment, specifically NASA’s mission-critical helium compression, transfer, and recovery system supporting cryogenic operations at KSC. The system includes legacy Shuttle-era low-pressure and high-pressure compressors, specialized gaseous helium (GHe) piping networks, recovery compressors, and integrated control-system software unique to NASA’s commodity-generation architecture.

These elements form an interdependent cryogenic mission system essential to launch vehicle operations and commercial partner support. The project also requires the continued provision of highly specialized engineering and controls-integration services, including development of new compressor control logic, interface alignment with liquid-helium pumping systems, recovery-cycle optimization, redundancy configuration, and fault-response tuning. These services directly extend the proprietary engineering baselines and software integration performed under Phases 1 and 2 of the existing contract. Accordingly, this effort meets all three conditions of FAR 6.103-1(c): (1) it is the continued development of a major system;

(2) it is the continued development and production of highly specialized equipment; and (3) it is the continued provision of highly specialized services. Although the Government previously conducted a full and open competition for Phases 1–2, the purpose of referencing the prior competition is not to assert current market limitations. Instead, it establishes the technical baseline and integration environment created under Phases 1–2, an environment uniquely understood by the incumbent contractor through direct execution of system development activities. Award to a new contractor would require the Government to re-establish the system-level engineering baseline, re-create integration logic, re-validate system interfaces, and repeat cryogenic controls development, resulting in substantial duplication of Government cost and unacceptable delays to mission-critical operations, including delayed realization of approximately $20M per year in helium-recovery savings.

For these reasons, the incumbent is the only responsible source capable of executing Phase 3 without causing substantial duplication of cost or unacceptable delay, fully satisfying FAR 6.302-1(c)(2)(i) and (ii).

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 part 5 and, if not, which exception under part 5 applies:

The Government conducted a full and open competition for CCF Phases 1–2, posting a presolicitation on October 9, 2019, and issuing the solicitation in January 2020. The Government received only two proposals. The current action is a modification to the existing CCF contract to accomplish Phase 3 as a logical extension of previously competed work.

Because this action is being processed under FAR 6.302-1(c)(2) as a follow-on and not as a new procurement, the requirements for issuing a new presolicitation notice under FAR Part 5 do not apply. The Government will comply with applicable JOFOC public-posting requirements under FAR 6.305.

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. The government will require the contractor to submit a complete proposal that includes the NASA Proposal Adequacy Checklist as prescribed in will also be required to provide certified cost or pricing data, as applicable, in accordance analysis, including evaluation of cost realism, verification of all proposed rates and supporting documentation, and assessment of the adequacy and accuracy of the data submitted. Pricing will then be negotiated to reach a fair and reasonable final amount prior to award. This process ensures that the final negotiated price reflects sound business judgment, compliance with regulatory requirements, and protection of the Government’s financial interests.

8. FAR 6.104-1(a)(8) – Description of the market research conducted, and the results, or a statement of the reason market research was not conducted (e.g., urgent, and compelling requirement):

Consistent with FAR 10.001 and NASA guidance, the Agency reviewed relevant information from the prior full and open competition and ongoing performance under the existing contract. Because the defining technical factors for Phase 3 relate to the incumbent’s accumulated facility-specific integration knowledge, rather than general industry capability, new market research would not meaningfully inform whether an alternate contractor could avoid cost duplication or schedule delay under FAR 6.302-1(c)(2). Engineering and facilities personnel with direct knowledge of system conditions and Phase 1–2 development validated that the incumbent remains uniquely positioned to continue the highly specialized work without technical, schedule, or integration risk. Based on this information, the Agency determined that new market research would not identify sources capable of performing Phase 3 without substantial duplication of cost or unacceptable interruption to mission requirements.

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

No other facts require identification at this time.

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

The only sources that expressed interest in writing for the original requirement were the two firms that submitted proposals in response to the full and open CCF solicitation in January 2020.

In November 2025, the Government issued a preliminary sources-sought notice to the MACC II contractor pool as part of broader OBBBA/WFTCA market research. This notice did not describe CCF Phase 3 or the specialized system-integration requirements unique to this follow-on effort. It conveyed only general project intent and budgetary context. The seven affirmative responses reflected general interest in future work, not demonstrated capability to perform Phase 3 or to assume continuation of the major system development initiated under Phases 1–2. As the Phase 3 requirement matured, the Technical Manager identified substantial, inseparable ties to the incumbent’s active engineering and controls work, including cryogenic integration, compressor system logic, interface development, and continuation of proprietary system baselines. No MACC II respondent received this information, nor demonstrated the specialized system-level knowledge required to undertake this highly specialized continuation effort without substantial duplication of Government cost or unacceptable delay. Taken together, the two original offerors and the seven preliminary MACC II expressions of interest represent all known potential interest in the acquisition.

Because the MACC II inputs were not informed by the actual requirement and did not address the continued development of this highly specialized mission system, those responses did not impact the Government’s rationale for proceeding under FAR 6.302-1(c)(2).

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.