NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

John F. Kennedy Space Center (KSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

UNUSUAL AND COMPELLING URGENCY

For Craft Labor and Corrosion Control Services

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 the KSC Office of Procurement.

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 sole-source contract to Met-Con, Inc. (CAGE 7S830).

The general purpose of the contracts is to obtain craft labor and corrosion control services here at Kennedy Space Center. Craft labor and corrosion control includes, but is not limited to, all tasks and resources necessary to install, field fabricate and modify ground support equipment systems/subsystems to execute repairs and configuration change activities in support of Spaceport customer project. Met-Con has historically provided this service, as a subcontractor, most recently to Amentum under the Consolidated Operations, Management, Engineering and Test (COMET) contract, providing personnel who have specialized experience at KSC for over 20 years. They possess a knowledge that is critical to the execution of the Artemis mission that no other company can provide to a schedule that supports mission success.

KSC's craft labor and corrosion control operations are reactive, requiring rapid adaptation as maintenance needs emerge during performance. Onboarding a new contractor would introduce schedule delays due to the learning curve and unfamiliarity with KSC-specific requirements. Met-Con is already established and integrated with the Kennedy Space Center team, making them the optimal choice for continuity. A sole-source award to Met-Con will maintain operational momentum while freeing Government resources to develop a competitive, long-term solution in support of the Administrator's direction.

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. These contracts are 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, technology advancement, and to learn how to live and work on 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.

b. Exploration Ground Systems (EGS) Program Background

For the past four years, the required services have been performed by subcontractors under the Consolidated Operations, Management, Engineering, and Test (COMET) contract. Due to the forthcoming reduction in the COMET contract’s scope at the end of FY26, coupled with the planned insourcing of multiple core operational requirements into Government performance, it is necessary for the Government to acquire craft labor and corrosion control services through a new procurement action to sustain uninterrupted operability of Kennedy Space Center facilities and systems. The specialized expertise, institutional knowledge, and technical capability provided by these skilled personnel are essential to supporting NASA’s Artemis activities and ensuring the Agency’s continued ability to meet its mission objectives, including the safe transport and landing of humans on the lunar surface.

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. As provided above, craft labor and corrosion control includes, but is not limited to, all tasks and resources necessary to install, field fabricate and modify ground support equipment systems/subsystems to execute repairs and configuration change activities in support of Spaceport customer projects.

It is anticipated there will be an immediate need for ironworking, pipefitting, electrical projects, and painting, and other various craft labor specialties, prior to the Artemis III launch, on the various launch facilities around KSC.

b. The anticipated cost for this action is expected to be approximately $15 million total.

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 craft labor and corrosion control 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.

Allowing full and open competition would result in Artemis III schedule delays due to the loss of continuity of services while requirements are being competed. Due to the cutting-edge nature of the technology required 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 COMET contract had previously competed these efforts at the original contract solicitation and the Government consented to the Contractor’s approach to subcontract with this company.

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 Met-Con is the only source 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.

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. It is NASA’s intent to competitively award the follow-on of this requirement following the short-term duration of the contracts.

Craft Labor and Corrosion Control Services

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

UNUSUAL AND COMPELLING URGENCY

SIGNATURE PAGE

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

Christie Livingston Technical Representative

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

Justin Fanney Contracting Officer

APPROVED:

Edwin Martinez Competition Advocate John F. Kennedy Space Center