Justification and Approval signed 23 Nov 2020.pdf

Justification and Approval (J&A) for Other Than Full and Open Competition

March 2020 Page 1 of 8

Was a J&A approved for the preceding acquisition? Yes No

! ! Attach the preceding J&A in the staff package for this J&A. The preceding J&A will be used as a reference document.

Is this a new or amended J&A Document? New Amended ( Prior to Award Only! )

Is this a Bridge Action as defined at AFFARS 5302.101? Yes No

Dollar Value of this Acquisition: < $700K > $700K and < $13.5M > $13.5M and < $93M > $93M

Contracting Activity: SMC/PCK

Purchase Request (if available): J&A #21-01

Program / Project (and PE, if applicable): Global Positioning System (GPS) Test Asset Program (GTAP)

Program Type (PEO, Enterprise, of Operational): PEO

Authority: 6.302-3 – 10 USC 2304(c)(3), Industrial Mobilization; Engineering, Developmental, or Research Capability; or Expert Services

Estimated Contract Cost (including options): $ 20M J&A Type: Class Individual

COORDINATION (AFFARS 5306.304(a) )

Date

06 Nov 2020

Program Mgr Lt Jose Aviles

SMC/PCE 310-653-3569

Signature

Date

06 Nov 2020

Contracting Officer Kevin Devine

SMC/PCK 310-653-0686

Signature

Date

09 Nov 2020

Local Legal Reviewer Allen Coe

SMC/JA 310-653-3564

Signature

Date Chief of the Contracting Office (COCO) Roy D. Lee

SMC/PCK 310-653-3212

Signature

Date Competition Advocate Michael S. Kennebrae, Col, USAF

SMC/PK 310-653-1785

Signature

Date Senior Contracting Official (SCO) Sara Lawlyes

SMC/PK 310-653-1185

Signature

Date PEO (delegated) John Morris

SMC/PCE 310-653-3006

Signature

DEVINE.KEVIN.T.129900

Digitally signed by

DEVINE.KEVIN.T.1299007282

Date: 2020.11.06 11:34:02 -08'00'

AVILES.JOSE.JR.154596

Digitally signed by

AVILES.JOSE.JR.1545968866

Date: 2020.11.06 14:24:39 -08'00'

COE.ALLEN.BERT.11246

36953

Digitally signed by

COE.ALLEN.BERT.1124636953

Date: 2020.11.09 07:20:34 -08'00'

LEE.ROY.D.1300725836

Digitally signed by

LEE.ROY.D.1300725836

Date: 2020.11.09 09:18:33 -08'00'

MORRIS.JOHN.R.114052

Digitally signed by

MORRIS.JOHN.R.1140520370

Date: 2020.11.09 15:56:09 -08'00'

KENNEBRAE.MICHAEL.S

HEA.1233318872

Digitally signed by

KENNEBRAE.MICHAEL.SHEA.1233318872

Date: 2020.11.12 08:47:05 -08'00'

Digitally signed by LAWLYES.SARA.E.1285023374 Date: 2020.11.13 16:11:48 -08'00'

March 2020 Page 2 of 8

APPROVAL (AFFARS 5306.304(a) )

Date Executive Director Joy M. White, SES, DAF

SMC/CA 310-653-5203

Signature

WHITE.JOY.M.10200673

Digitally signed by

WHITE.JOY.M.1020067310

Date: 2020.11.23 10:40:41 -08'00'

March 2020 Page 3 of 8

I. Agency and Contracting Activity.

Space and Missile Systems Center (SMC) Production Corps (PC) Global Positioning System (GPS) Test Asset Program (GTAP)

II. Nature and/or description of the action being approved.

This individual Justification and Approval (J&A) authorizes the award of a Sole Source Firm Fixed Price (FFP) contract to The Charles Stark Laboratory (Draper). The exception to Full and Open Competition is FAR 6.302-3 "Industrial Mobilization;

Engineering, Developmental, or Research Capability; or Expert Services".

III. Description of supplies/services required to meet agency needs (including the estimated value).

The Production Corps, Engineering Division, Test and Evaluation Branch (SMC/PCET) requires high-quality, cost-effective Modernized Receiver Test Asset (MRTA) / MRTA II / Modernized Signal Asset (MSTA) test support services to be the directorate's primary data source for government determination of GPS Signal-In-Space (SIS) compliance with Interface Control Documents (ICDs), specifications, GPS International Telecommunication Union agreements, and other international agreements. PCET will require the contractor to provide monthly State of Health (SOH) measurement sessions using the MRTA, MRTAII, MSTA and other signal collection assets to provide power, code delay, frequency content, and bandwidth to verify proper operation of the constellation. These test assets will be used to support testing efforts across the GPS enterprise, to include pre-launch verification, on-orbit testing events, on-orbit anomaly resolution, and control segment verification. These assets will also be utilized during the research and development testing of the new Next Generation Control Segment (OCX), the follow on GPS III Space Vehicle (GPS IIIF), and Military GPS User Equipment (MGUE). The collective operation, maintenance, and other contractual duties of the MRTA/MRTA II/MSTA systems in line with this effort will be known as the Global Positioning System (GPS) Test Asset Program (GTAP).

The proposed contract action will be under a predominantly Firm Fixed Price (FFP) contract with Cost Plus Fixed Fee (CPFF) Special Studies CLINs. All services acquired under the GTAP contract will consist of a basic period of one (1) year and four (4) additional optional years, commencing no later than 1 February 2021. The estimated cost of the GTAP contract is approximately $4 million per year, for a total value of $20 million. Budgeted funding consists of 3600, Air Force Research and Development funds. The services to be acquired are research and development services because GPS signal collection, verification, validation, and analysis using MRTAs, MRTA IIs, and MSTAs will be used as research in development efforts, such as GPS II Space Vehicles on-orbit checkouts and anomaly resolution, M-Code testing, and in the development of GPS military user equipment. This testing capability is considered an essential development capability in order to provide continued testing support for future capability advancements across the GPS enterprise. The operation of these test assets allows for advances in the Next Generation Operational Control Segment (OCX), Military Code (M Code), the GPS IIIF satellite, and other key developmental areas across the GPS enterprise.

MRTA, MRTAII, and MSTA are government owned/contractor operated test assets which provide the Production Corps (SMC/PC) with precise, real-time, satellite and simulator L-band signal measurements in support of GPS satellite ground testing, satellite on-orbit checkout and testing, control segment ground and live sky testing, user equipment live sky testing, and anomaly resolution. Use of MRTA, MRTAII, and MSTA is the only way to provide the precise L-band signal measurements necessary to accomplish testing required by the GPS Enterprise Test and Evaluation Master Plan (E-TEMP). No current substitutes have been identified; the MRTA, MRTA II, and MSTA provide the only test tool to provide precise L-band signal measurements and monitor modernized Military Navigation (MNAV) broadcasts.

The anticipated Period of Performance (PoP) of the GTAP contract is one base year and four options years. Including the base and options, the PoP is planned to be five years. The PoP is expected to commence in 1 February 2021 and continue until 31 January 2026, if all options are exercised.

IV. Statutory authority permitting other than full and open competition.

The Statutory Authority for this action is 10 U.S.C. 2304(c)(3), as implemented by FAR 6.302-3 "Industrial Mobilization;

March 2020 Page 4 of 8

Engineering, Developmental, or Research Capability; or Expert Services".

V. Demonstration that the contractor's unique qualifications or the nature of the acquisition requires use of the authority cited above (applicability of authority).

Draper has extensive knowledge of all of the test assets in this contract dating back to the inception of this capability and the development of the assets themselves to meet the needs of the Air Force and the intelligence community. Draper's fast response capabilities are necessary to allow the Air Force to respond to new and high priority short-term requirements. They have remained the sole provider for GPS test asset support of this nature, and have even worked to further develop and modernize these assets over the last three years. They remain the only contractor with the knowledge and experience of designing, building, maintaining, upgrading, operating, and further developing the test assets and their capability to further development of the GPS enterprise. Additionally, their combination of technical knowledge and independence from other areas of the GPS enterprise gives them a unique position. Draper has this unique capability that must be maintained in order to provide independent signal collection, verification, validation, and analysis across the GPS enterprise. Therefore the exemption at 10 U.S.C. 2304(c)(3), as implemented by FAR 6.302-3 "Industrial Mobilization; Engineering, Developmental, or Research Capability; or Expert Services" applies.

FAR 6.302-3(a)(2)(ii) states that the use of the authority of FAR 6.302-3 may be appropriate in situations "when it is necessary to award the contract to a particular source or sources in order -- To establish or maintain an essential engineering, research, or development center". Draper is considered a "Non-Profit Organization" that is "Tax exempt" according to the System for Awards Management (www.sam.gov).

FAR 6.302-3(b)(2) states that the use of authority of FAR 6.302-3 "may be appropriate when it is necessary to...(ii) establish or maintain an essential capability for engineering or developmental work calling for the practical application of investigative findings and theories of a scientific or technical nature; or (iii) contract for supplies or services as are necessary incident to paragraphs (b)(2)(i) or (iii) of this subsection." This acquisition requires that Draper apply scientific investigative findings: the results of these investigative findings will be the verification, validation, and analysis of GPS signals, including the analysis of signals containing M-code and the initial on-orbit checkout of GPSIII Space Vehicles as they are launched, as well as as on-orbit anomaly resolution. Draper will also perform services, such as maintenance of the MRTA, MRTA II, and MSTA, which are necessarily incident to the engineering work that encompasses the gathering of investigative findings (GPS signal collection) and practical application of these findings (GPS signal verification, validation, and analysis).

Independent GPS signal collection, verification, validation and analysis is an essential capability which provide objective and independent engineering support to the sponsor, DoD, and other Government agencies as approved that the Production Corps must maintain in order to comply with 10 U.S.C. § 2281, which requires that the Secretary of Defense sustain the Global Positioning System for military and civil purposes. All segments of the GPS Enterprise --i.e., the GPS satellite constellation, the ground infrastructure that controls the GPS satellite constellation, hundreds of thousands of fielded GPS receivers that enable military and civilian use of GPS signals --must perform properly in order to satisfy that mandate. In order to ensure the proper operation of all those segments of the GPS Enterprise free from organizational conflicts of interest, the Production Corps requires GPS signal collection, validation, verification, and analysis be provided by a source that is independent from contractors that develop or produce any of those segments. The Production Corps requires collection and characterization of GPS signal data resulting in state of health metrics that enable the Production Corps to determine the extent to which GPS signals are being transmitted as intended, which is described in various interface control documents, specifications, and international agreements. The Production Corps also requires a capacity for independent testing of Developmental systems, such as space vehicles and user equipment. Together, an independent GPS signal collection, validation, verification, and analysis capability enables verification of the proper functioning of all segments of the GPS Enterprise. It's also important to note that while the Production Corps owns the GTAP contract, the utility of these test assets extends beyond the Production Corps and SMC. These assets are also used to support civil developmental efforts within the FAA, as well as our international GPS partners across the globe.

Although Draper is not completely independent of all GPS contractors, Draper maintains unique qualifications and its independence from potential conflicts of interest. Draper does not currently hold any contracts supporting the space or ground segments of the GPS enterprise. Draper does currently support L3 Interstate Electronics Corporation (L3) in the development of Military GPS User Equipment (MGUE) under contract FA8807-12-C-0011, however Draper's role is focused on systems security, and does not involve development of the receiver cards themselves or any work with GPS specification compliance. Draper's involvement in testing the GPS signal under the proposed contract is to ensure that the signal meets several internationally-published Interface Control Documents (ICDs). These documents detail how all aspects of the GPS

March 2020 Page 5 of 8 enterprise will work together to create a functioning GPS enterprise. All MGUE vendors have access to these ICDs and are held to these same specifications, but that is outside of the scope of Draper's support of L3. Draper's purpose under the proposed contract would be limited to verifying and validating GPS adherence to these ICD specifications. It is not technically possible for Draper to demonstrate any type of bias when testing and reporting on a published specification that all MGUE vendors are tasked to comply with. Therefore, the government has determined there is no reason to believe that Draper's role in testing GPS signals is biased by its role in analyzing system security for MGUE.

Loss of this capability would greatly impact the progression of GPS ground, space, and user segments. Utilizing these testing assets allows the USSF to advance the GPS enterprise by verifying current and future technological upgrades. Without this capability, we would be unable to validate or improve essential advancements for GPS, and our ability to provide world-leading Precision Navigation and Timing (PNT) services across the DoD and civil communities into the future would be threatened. Additionally, Draper's ability to provide real-time on-orbit anomaly resolution allows for rapid response to potential issues surrounding the $1.5B GPS enterprise. This contract ensures that if something goes wrong, we have the means to investigate and recommend recovery actions in a safe and timely manner, possibly preventing the loss of a GPS satellite. The Government is the only one maintaining this capability via Draper and without this requirement Draper would not sustain this capability otherwise.

MRTA II, and MSTA are unique Government Property assets that MITRE (a Federally Funded Research and Development Center) developed to enable the GPS Directorate meet the need for independent signal collection, validation, verification, and analysis. The MRTAs, MRTA IIs, and MSTAs are the only Air Force test assets that test M-code, the modernized military GPS signal that provides enhanced anti-jamming and security. The MRTA design is a first-generation Air Force test asset. The MSTA design is a modification of the original MRTA design, which is calibrated to a 10-foot parabolic dish antenna, and is used to characterize a live sky environment. The MRTA II is the next-generation test asset, with additional functionality, including increased bandwidth capabilities, which enables collection and characterization of additional GPS signals. The MRTA II units are capable of replacing the original MRTA and MSTA units when the first-generation units become obsolete.

An element of the GTAP program will be to upgrade the existing MRTA hardware and transform those units into the more capable MRTA II unit. This effort will greatly increase the ability for Draper to provide enhanced testing capabilities across the GPS enterprise in the future. Draper's unique heritage of technical involvement in the development, enhancement, and maintenance of the MRTA, MRTA II, and MSTA systems paired with their ability to provide unbiased GPS testing support is why Draper remains uniquely qualified for the nature of this acquisition.

Draper has developed this essential capability that will be maintained by this contract through over a decade of similar engineering work. Specifically, in 2004, the U.S. Army Aviation and Missile Command (AMCOM) awarded Draper a sole-source Indefinite-Delivery-Indefinite-Quantity (IDIQ) contract to Draper (Contract W31P4Q-05-C-8210). Under that contract, which expired on 31 March 2012, Draper provided engineering and technical services to operate and maintain the MRTAs and, later, the MSTAs and performed a variety of verification, validation, and analysis tasks, including testing of GPS signal-in-space (SIS) compliance with international compliance documents (ICDs) and performance standard requirements in support of the warfighter and the GPS civilian user community. During its performance of that contract, Draper successfully utilized the MRTAs and MSTAs in over 50 test events. These tests included the following: compatibility tests for the Second Space Operations Squadron 2SOPS), Architecture Evolution Plan AEP software modification checkouts, satellite regression testing, Operational Baseline (OB) validation, factory tests, technical demonstrations, flexible power tests, jamming tests, eclipse tests, OCX data collection, anechoic chamber tests, GPS Ill Phased-Optimized Constant-Envelop Transmission (POCET) algorithm tests. Draper also used the MRTAs and MSTAs to perform a complete evaluation and verification of the GPS Block IIF space vehicle from demonstration through consolidated system testing to on-orbit checkout. In 2008, Draper became responsible for the operation of the MSTAs under that AMCOM contract.

On 27 September 2012, the Air Force awarded Draper a sole-source cost-plus-incentive-fee (CPIF) contract (Contract FA8807-12-C-0005). Under that contract, Draper successfully utilized the MRTAs and MSTAs during an additional 50-plus test events, including Integrated Systems Tests (ISTs), annual JAMFEST testing, Modernized User Equipment/M-code technology assessment exercises, and pre-launch testing of GPS space vehicles. Draper personnel, operating the MRTAs, have performed segment level development testing at GPS Ill space vehicle prime contractor facilities. Under that contract, Draper also fabricated five MRTA lls, which provide new capabilities required to test GPS Ill satellites, based on engineering designs from

MITRE.

In the previous MRTA/MSTA contract know as M3 (FA8807-18-C-0001), Draper was awarded a sole-source CPIF contract spanning three years from 2018 - 2021. During this time, Draper accomplished additional MRTA II upgrades, as well as

March 2020 Page 6 of 8 integrated these new MRTA II units into the MSTA system. Security upgrades were made to the MRTA/MRTA IIs to prevent tampering and potential COMSEC issues while shipping. In addition to the hardware updates, Draper supported over 30 tests across the GPS enterprise. This included developmental testing of the new next-generation GPS control segment, OCX, as well as the first on-orbit testing of the new block III GPS SV, SVN 74. Draper's performance of the AMCOM and Air Force contracts described above has contributed to its deep knowledge of GPS signal collection, validation, verification and analysis using the MRTA, MRTA II, and MSTA systems.

VI. Description of 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 5.2 and, if not, which exception under

FAR 5.202 applies.

In accordance with DFAR PGI 206.302-1(d), the contracting officer posted a sources sought synopsis (SSS), Solicitation posting #20-014, on 06 April 2020 with a response date of 06 May 2020. The SSS provided information on the MRTA/MSTA acquisition, including a description on the services needed and the anticipated period of performance. Additional, the SSS offered a Documents Library that included: ((1) a Performance Work Statement (draft), (2) a Government Furnished Property List (Draft), (3) Contract Delivery Line Item (CDRLs) (Draft), and (4) a Form DD 254 - Department of Defense Security Classification Specification (Draft). Three potential sources responded to the Beta.Sam.gov posting by submitting Statement of Capabilities (SOCs): (1) The Charles Stark Draper Laboratories (Draper); (2) Infinity Integrated Solutions (IIS), and (3) Cast Navigation. While the government is sure that Draper has the ability to meet the needs of this contract, a technical analysis of IIS's response to the SSS showed several areas were lacking. First, IIS lacks the specialized knowledge with the GPS test equipment itself. No IIS personnel are involved in operating the MRTA/MRTAII/MSTA systems, and significant familiarization training would have to occur in order to regain years of experience that Draper personnel already possess. Second, IIS's proposal identified this lack of core specialization by proposing to hire the specific personnel required directly from Draper and their subcontractor, SRI. This not only poses significant business risk in terms of feasibility, but also calls into question the value of IIS's experience if there is no inherent ability to support the contract as it stands. Finally, IIS is significantly involved in both space and ground segments of the GPS enterprise, which creates a significant risk for conflicts of interest, as indicated previously in this document. The third offeror, Cast Navigation, submitted their name only, and thus were not deemed a viable competitor due to their failure to provide any sort of technical information. Draper remains the only source capable of being technically able to support the contract while maintaining independent from other segments of the GPS enterprise.

A notice of contract action is not necessary as the exception at FAR 5.202(a)(10) applies.

VII. Determination by the Contracting Officer that the anticipated cost to the Government will be fair and reasonable.

The anticipated cost is based on historical data from the previous MRTA/MSTA contracts which were deemed fair and reasonable.

VIII. Description of the market research conducted and the results, or a statement of the reasons market research was not conducted.

As described in Section VI above, the acquisition team conducted market research, in accordance with FAR Part 10, by synopsis of the proposed acquisition advising industry of the pending acquisition and soliciting inquiries from interested parties.

In the previous MRTA/MSTA contract (FA8807-18-C-0001), market research indicated that there was only one source capable of meeting the requirements. For the follow on GTAP contract, a Sources Sought Synopsis was released to the public through beta.SAM.gov website on 6 April 2020. The posting described the requirements and offered a documents library, available to prospective offerers upon request. Three potential sources responded: The Charles Stark Draper Laboratory (Draper), Infinity Integrated Solutions (IIS), and Cast Navigation. Draper is the current contractor and has thus proven itself as a capable and experienced provider of the required services of this contract. IIS submitted a response detailing their

March 2020 Page 7 of 8 experience in the GPS community, however IIS is heavily involved in the development of other segments of the GPS enterprise. As the contractor supporting independent test and evaluation of GPS capabilities, there is significant reason for conflict of interest concerns with their ability to remain independent in this effort. Cast Navigation submitted nothing but their name as an interested party. Thus, the Production Corps deemed Draper the only source capable of meeting the requirements.

IX. Any other facts supporting the use of Other Than Full and Open Competition.

Not Applicable

X. List of any sources that expressed, in writing, an interest in the acquisition.

See Section VI above

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

This is likely to be a long-term sole source arrangement because of the need to maintain Draper's unique capabilities, independence in data collection, and the Government's need for Draper to maintain this capability for the Government.

XII. Certification by the Contracting Officer.

As evidenced by my signature above, I have determined this document to be both accurate and complete to the best of my knowledge and belief.

XIII. Certification by the technical/requirements personnel.

As evidenced by my (our) signature(s) above, I (we) certify that any supporting data contained herein, which is my (our) responsibility, is both accurate and complete.

The following page contains a suggested template for “International Agreement Competitive Restrictions (IACR)”.

The authority to prepare an IACR has been delegated from the HCA to the Contracting Officer.

(AFFARS 5306.302-4)