Justification and Approval_ DC3GS_PoP Extension_Final_Redacted.pdf

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

AUTHORITY: FAR 6.302

Contract PIID #GS08Q17BPC0006

Pursuant to the requirements of the Competition in Contracting Act (CICA) as implemented by FAR 6.3 and in accordance with the requirements by FAR 6.303-1, the justification for the use of the statutory authority under FAR 6.3 is justified by the following facts and rationale required under FAR 6.303-2 as follows:

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.”

The General Services Administration (GSA) Federal Acquisition Service (FAS) Rocky Mountain Region 8 intends to extend an existing sole source contract (GS08Q17BPC0006) on behalf of the United States Space Force (USSF) Space Systems Command (SSC)/Space Sensing Product Support (SNP), Defense Meteorological Satellite Program (DMSP) Ground System (GS) for specialized engineering support services (including, but not limited to, maintenance and replacement of legacy hardware and software and of the security certification of the DMSP system connected to Government networks) to complete the technological update and maintenance of the aging computer system and sustain the Defense Meteorological Satellite Program C3 (Command, Control and Communication)) Ground System (DC3GS).

2. The nature and/or description of the action being approved.

Contract GS08Q17BPC0006 was awarded on March 29, 2017, as a base year plus four option year contract. The contract was awarded as a FAR Part 15: Contracting by Negotiation as a sole source contract. A justification for other than full and open competition was approved by the Head of Contract Activity (or designee) on February 27, 2017. This contract, originally awarded to Harris IT Services Corporation and novated to Peraton Inc. during performance, encountered delays on two non-severable Engineering Change Proposals (ECP) due to COVID-19 and Government Caused delays, requiring approval to extend this contract longer than five years. The two non-severable ECP’s are:

● ECP 03 – McMurdo Data Transfer system (MDTS) Technical Refresh

● ECP 08 – Communications Architecture Refresh

3. A description of the supplies or services required to meet the agency’s needs (including the total estimated value).

DMSP monitors meteorological, oceanographic, and solar-terrestrial physics for the United States Department of Defense (DoD). The program is managed by the USSF. The purpose of this contract is to provide continued DMSP ground segment (GS) sustainment for the DMSP constellation. This contract provides the continued, uninterrupted support necessary to sustain the command-and-control functions of the DMSP ground control segments, to continue the uninterrupted reception of telemetry and mission data, to identify and resolve ground system anomalies and deficiencies, to assist in resolution of space and user segment problems, and to maintain compliance with US Government cybersecurity issuances and requirements. These

There are no planned future launches to replenish the current DMSP constellation, so there will not be any further capabilities another contractor could introduce to make the system more reliable or robust. The current DMSP system must remain operational until the follow-on weather system is available. This is essential in order to maintain DoD weather capability to meet the needs of the warfighter and other National Users. There is only one responsible source capable of satisfying the requirements of the DC3GS program, as they have been working specifically with this system since 1979.

In 1994, per Presidential Decision Directive (PDD) / National Science and Technology Council-2, DMSP operations and ground system sustainment was assumed by the National Oceanic and Atmospheric Agency (NOAA) with the intent to replace DMSP with the DoD/NASA/DOC jointly developed follow-on polar satellite (NPOESS) capability. The fully documented and accredited ground system was transferred from the DOD to NOAA in May 1998. In Feb 2010, in accordance with (IAW) PDD 2010, NPOESS was restructured, and DMSP ground system sustainment returned to the USAF. Upon transfer the system was, and still is, largely undocumented. This was due to the intention of a full system replacement under the NPOESS system.

Many of the DMSP ground subsystems that command and control the DMSP constellation have not been technically refreshed in over twenty years and remain undocumented. Major components of the system were reused from legacy control centers and are considered obsolete.

Peraton Inc. continues to be the only company performing the services described in this justification for the DMSP GS since 1979. In early 2000s, while the DMSP system was under the responsibility of the National Oceanic and Atmospheric Administration (NOAA), it was generally believed that the DMSP system was going to be phased out and decommissioned. This viewpoint was supported by little to no funding being available to maintain the technological currency of the DMSP system.

When it became clear the DMSP system would continue operations, the USSF (formerly USAF) took over the DMSP system from NOAA in an effort to improve operations and to obtain a cybersecurity certification. Specifically, the USSF determined it needed to invest in upgrading subsystems within the antiquated DMSP system ensuring its continued ability to meet mission essential operational capabilities.

Description of why Peraton is the Original Source Peraton is uniquely qualified for the DC3GS sustainment effort as they were the original contractor for the design, development, test, launch, on-orbit operation, and sustainment of the DMSP constellation since 1979. Peraton has decades of ground system and operational experience and the documentation related to the ground system currently supporting the constellation. Due to Peraton’s design knowledge, they have provided decades of near-real time operational support. Peraton, both as the past and current contractor, provides historical and current knowledge of ground system health. Furthermore, decades of involvement on DMSP has resulted in Peraton having an established organizational structure for management and communication within the DMSP community, along with key expertise and knowledge that has proven to be successfully effective.

Description of why these services are considered “highly specialized services” Peraton is the only responsible source capable of providing the highly specialized unique services described in this justification. Peraton has qualifications not available from any other source.

Peraton has the unique experience, knowledge, and training to resolve anomalies on DC3GS. No other contractor possesses the detailed design knowledge of and the operational experience with DC3GS. This knowledge enables Peraton to provide continuation of the uninterrupted reception of telemetry and mission data, identification and resolution of ground system anomalies and deficiencies, assistance in resolution of space and user segment problems and compliance with cybersecurity issuances and requirements. The DMSP ground system is currently operating at more than two (2) times its design life. A majority of the hardware for the DC3GS system is either obsolete or has difficult to repair components, out of business vendors (e.g., Aiken Switch), failed test equipment, and greatly diminished spares. The system heavily relies on Peraton’s depot support to repair, and in some cases redesign, circuits and use alternate parts. The DC3GS sustainment relies heavily on Peraton Subject Matter Experts, many with 30-40 years of DMSP experience, to sustain all facets of the ground system. These functions are critical due to the importance of the program data in support of Space Force and international partner missions.

First, as the original designer of the ground system, Peraton has highly specialized knowledge of the design and its subsystems. That knowledge enhanced by years of operational experience deepens the uniqueness of the specialized services provided by Peraton.

The contractor performs sustainment activities consisting of on-going maintenance of the DC3GS, including depot repair, hardware and software maintenance, configuration management, anomaly resolution, documentation updates, systems engineering, and system upgrades. To perform these functions, Peraton understands the complete system, including the interfaces between the sensors and spacecraft systems.

Second, Peraton has specific insight into the integration and operations of all of the DMSP satellites.

The close working relationship with Lockheed Martin, Northrop Grumman, and other sensor providers facilitates rapid communications during off nominal situations. As the designer and manufacturer of the DC3GS, Peraton participated in the development of these interfaces. A new contractor would not have the understanding of the reasoning behind the decisions that were made in establishing the interfaces between the ground system and the sensors and spacecraft.

Third, much of the hardware dates back to the mid 1980’s and has not been updated. Although multiple DMSP system updates, along with the creation of more user manuals and technical data (models, drawings, associated lists, specifications, standards, performance requirements, quality assurance, software/hardware documentation and packaging details) for the technical data package (TDP) have occurred under the current contract, they only represent a small portion of the overall GS. The user manuals and TDP for much of the DMSP system are still either missing or obsolete.

The services required to meet SF needs to include the creation of more user manuals and technical data for the TDP along with additional DMSP system updates.

Fourth, as the original designer and sustainer of the DMSP GS since 1980, Peraton possesses extensive experience unique to the development, and maintenance of the existing ground system architecture that will allow Peraton to, among other things, compensate for the agency’s lack of system baseline documentation. They provide unique qualifications and capabilities not available from any other source and therefore the only choice to continue maintenance and Technical Refresh of what is essentially a one-of-a-kind legacy system supporting the only weather satellite constellation available to the DoD. Peraton’s DMSP maintenance experience is especially vital at the present time because the aging hardware components require substantially more operational support than in prior years. With respect to anomaly resolution, Peraton is the only responsible source that has in-depth knowledge and experience with the systems and processes described above in order to quickly identify and resolve any anomalies, preventing unrecoverable errors. This knowledge is not easily captured or transferable to another source because of the unique design and operation of the systems due to the fact that much of the DMSP system baseline documentation, as discussed above, was not retained, or maintained.

Finally, the long history of direct operational support to the spacecraft and sensor operators is a difficult knowledge base to transfer. The contractor must provide real-time operational support, including anomaly resolution, to contend with any situations arising during the orbital lifetime of the DMSP satellites. Once an anomaly occurs, it must be correctly isolated, analyzed, and resolved to restore the DMSP mission as soon as possible. Correctly isolating the cause of the anomaly requires in-depth knowledge of the complete DMSP satellite system (spacecraft, sensors, their interfaces, and command equipment). Correctly analyzing any anomaly isolated to DC3GS and recommending a course of action leading to resolution of the anomaly requires an extensive knowledge of the ground system to include changes and improvements.

Engineering Change Proposal (ECP) Overview Peraton was awarded nine non-severable ECPs on the subject contract. Seven of the ECPs have been completed. ECP 03 “McMurdo Data Transfer system (MDTS) Technical Refresh” and ECP 08 “Communications Architecture Refresh” have yet to be completed.

ECP 03 Background – “McMurdo Data Transfer system (MDTS) Technical Refresh” Contract modification 08 was issued on September 21, 2018. This modification added ECP 03 “McMurdo Data Transfer system (MDTS) Technical Refresh”. The Period of Performance (PoP) for ECP 03 is listed as September 21, 2018, through March 29, 2021 (which coincides with the end of Option Year 3). Contract modification 019, effective March 18, 2021, updated the PoP from September 21, 2018 - March 29, 2021, to: September 21, 2018 – March 29, 2023, at no cost. The extension incorporated by Mod 019 recognized a Government delay with Beneficial Occupancy Date (BOD) for the completion of the new Information Technology & Communications (IT&C) facility at McMurdo Station, Antarctica, slipping by two years. The extension past the contract’s initial PoP was an administrative oversight.

Currently, with the approval of this J&A, the contractor is requesting an extension of this ECP to March 29, 2024, the reasoning for the additional extension request is two-fold; one tied to COVID-19 and related travel restrictions that have pushed the IT&C facility BOD to 09/2023.

This has caused this ECP schedule to slip an additional year to March 29, 2024, at no additional cost to the Government.

Due to the non-severable nature of ECPs, value to the Government will not be recognized unless the ECP is fully completed. When this ECP was awarded, incremental payments based on milestones were established. To date, the contractor has been paid approximately % of the value of the ECP.

Based on the current status of the work in progress, the legacy systems and inherent knowledge Person possesses, they are the only source that could complete this ECP.

ECP 08 Background: “Communications Architecture Refresh”

ECP 08, “Communications Architecture Refresh” was established in contract modification 018, effective September 30, 2020. The PoP is listed as: September 30, 2020, through May 29, 2022.

Contract modification 022, effective August 26, 2021, extended ECP 08 for 9 additional months to February 28, 2023, at no additional cost. The milestone schedule was adjusted downward from simultaneously to adjust for the extra time.

Current program projections anticipate completion of ECP 8 on August 30, 2023, at no additional cost to the Government. The delay is primarily related to product availability with receiving specific parts. Peraton is considering a redesign and test in order to complete the ECP on time.

Due to the non-severable nature of ECPs, value to the Government will not be recognized unless the ECP is fully completed. Based on the current status of the work in progress, the legacy systems and inherent knowledge Peraton possesses, they are the only source that could complete this ECP.

Conclusion Based on the analysis above, Peraton is the only responsible source to complete these two non-severable ECPs by extending the PoP of the contract.

6. A description of efforts to ensure that offers were solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202 applies.

This requirement has been solely performed by Peraton Inc. for over four decades. Since this JOFOC requests extension of the current contract to complete two non-severable ECP efforts.

For the original award to Peraton in 2017, no responses to the notice publicized as required by FAR Subpart 5.2 were received for the sole source award. A synopsis is not required for this action since it has a $0 value.

7. A determination by the contracting officer that the anticipated cost (including the cost of options) to the Government will be fair and reasonable.

The awarded contract price was determined to be fair and reasonable. The CO utilized the following: historical prices, certified cost and pricing data, independent Government estimates, Defense Contract Management Agency recommendations and forward pricing rate recommendations/forward pricing rate agreements, and technical evaluations conducted by the USSF (formerly USAF).

This request is expected to be at no additional cost to the government. The prices for the ECPs were already determined fair and reasonable to the Government.

8. A description of the market research conducted (per FAR Part 10) and the results or a statement of the reason market research was not conducted.

Market research was completed at the time of this original contract award. The extension of the two ECPs is an extension of the original market research report. Furthermore, the Government researched and determined the completion of these two ECP’s was in the best interest of the Government. Finally, the recompete being conducted by GSA FAS R9 will include a full market research report for the follow-on contract effort

9. Any other facts supporting the use of other than full and open competition, such as:

None.

10. A listing of any sources that expressed a written interest in the acquisition.

None, other than Peraton (formerly HARRIS) expressed a written interest in the acquisition.

11. A statement of the actions, if any, the agency may take to remove or overcome any barriers to competition, before any subsequent acquisition for the supplies or services are required.

GSA FAS Region 9 is currently working on the reacquisition for this requirement. To remove or overcome any potential barriers to competition, FAS Region 9 is utilizing the Alliant GWAC and did not restrict the requirement to sole source. The request for proposals was issued in July 2022, no awards have been made as of the date of this J&A.

12. Contracting officer certification that the justification is accurate and complete to the best of the contracting officer’s knowledge and belief.

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

Contracting Officer Acquisition Operations Division (AOD) GSA Region 8 Federal Acquisition Service

13. Requirements personnel certification.

I certify that the technical data which forms a basis for this justification is complete and accurate and meets the Government’s minimum needs.

Contracting Officer Representative (COR) Space Systems Command (SSC)/Space Sensing Product Support (SNP)

14. Reviews and Approvals

Branch Chief Acquisition Operations Division (AOD) GSA Region 8 Federal Acquisition Service

Acquisition Director Acquisition Operations Division (AOD) GSA Region 8 Federal Acquisition Service

Competition Advocate GSA Region 8 Federal Acquisition Service

Regional Commissioner Head Contracting Activity (HCA) GSA Region 8 Federal Acquisition Service