Justification for Other than Full and Open Competition (JOFOC) - Container addition_signed.pdf

Rev.:5/2024

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

JOHNSON SPACE CENTER (JSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For

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1. Federal Acquisition Regulation (FAR) 6.303-2(b)(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) JSC Office of Procurement.

The procuring agency is the National Aeronautics and Space Administration (NASA) and the contracting activity is the JSC Projects Procurement Office (BH).

2. FAR 6.303-2(b)(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 increase the value of a sole-source contract to Viavi, Inc. for the purpose of recoating and creating a shipping container the primary mirror of the Eugene Stansberry

Meter Class Autonomous Telescope (ES-MCAT) deployed on Ascension Island.

3. FAR 6.303-2(b)(3) – A description of the supplies or services required, to meet the

Agency’s needs (including the estimated value):

The Orbital Debris Program Office (ODPO) at NASA Johnson Space Center operates and maintains the 1.3-m ES-MCAT telescope at Ascension Island Auxiliary Airfield (AAF). The primary objective of the ES-MCAT mission is to extend observations of orbital debris in geosynchronous orbit (GEO) to smaller/fainter objects than can be tracked by the Department of Defense (DoD). The telescope’s components are regularly exposed to high humidity and sea spray conditions due to its location on Ascension Island, resulting in a need to recoat the primary mirror every few years. The current mirror coating has suffered rapid degradation due to a combination of environmental effects and an inferior-quality coating applied by the previous coating vendor in 2022. Observations are no longer useful to achieve ES-MCAT’s primary objective, leading to a lack of data available for building and validating orbital debris models. Therefore, the mirror needs to be recoated as soon as possible and earlier than expected due to the poor quality of the coating that was previously applied. After the mirror has been recoated by Viavi Solutions, it needs to be shipped back to Ascension Island. The original shipping container degraded severely upon arrival at Viavi’s location and it is no longer useable. The vendor will now be required to rebuild a new container that will fit the mirror and be able to withstand up to 30g’s of force. The total amount of the services are estimated to cost $390,356.00 (including the additional amount of $8,000 for the container), as indicated by an informal quote by Viavi based on the revised Statement of Work. The final mirror product will be delivered 4 weeks after receipt of tooling and approval of the qualification, which is approximately nine months After Receipt of the Order (ARO).

4. FAR 6.303-2(b)(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 6.302-1 Only one responsible source and no other supplies or services will satisfy agency requirements.

5. FAR 6.303-2(b)(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)1 is because Viavi is the only known source available that has the requisite knowledge, experience, staff, tooling, and capacity to meet the requirement of both recoating it to the prescribed specifications and building the necessary shipping container. Viavi already has the mirror in its possession and it is the only vendor available to handle the mirror and maneuver it into a new container without disrupting the clean room environment the mirror must be stored in after it is recoated.

Introducing a new company at this juncture introduces unknown contaminants into the cleanroom environment, which could introduce unknown contaminants onto the mirror surface after it has been recoated. In order for Viavi to guarantee a perfect coating, it must be the vendor that maintains control of the mirror, which also means controlling the manufacturing of the shipping container and the transfer of the mirror into the new container.

6. FAR 6.303-2(b)(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 5.2 and, if not, which exception under 5.202 applies:

A notice to the Government Point of Entry (GPE) website (Sam.gov) on January 7, 2026 whereby the Contracting Officer notified industry of this requirement under NAICS code

321920. The notice closed on January 14, 2026 at 12:00pm CST. The notice received no viable options, only general questions/inquiries. This solidifies that no other source is available or responsible to meet this requirement, satisfying the requirements found in FAR

6.302-1.

7. FAR 6.303-2(b)(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 shall 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 proposed price will be compared to historical prices paid to determine that the price proposed is in-line with industry averages and factoring in any potential inflation costs against the Consumer Price Index (CPI) data, in accordance with

FAR 15.404-1(b)(2)(ii).

8. FAR 6.303-2(b)(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):

A notice to the Government Point of Entry (GPE) website (Sam.gov) on January 7, 2026 whereby the Contracting Officer notified industry of this requirement under NAICS code

321920. The notice closed on January 14, 2026 at 12:00pm CST. The notice received no viable options, only general questions/inquiries. This solidifies that no other source is available or responsible to meet this requirement, satisfying the requirements found in FAR

6.302-1 and FAR Part 10.

9. FAR 6.303-2(b)(9) – Any other facts supporting the use of other than full and open competition:

None.

10. FAR 6.303-2(b)(10) – A listing of the sources, if any, that expressed an interest in writing in the acquisition:

A notice of NASA’s intent to award this sole-source action was synopsized on the GPE website (Sam.gov) per FAR Subpart 5.2 (See Section 6 above). No viable responses were received, only general questions/inquiries.

11. FAR 6.303-2(b)(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 new container being procured as an addition to this JOFOC is expected to last 10-20 years. If a new container is ever needed, additional market research will be conducted to satisfy this FAR part.

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ES-MCAT MIRROR RECOATING

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

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

Alyssa Manis, Ph.D.

Technical Representative, XI5

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

Stephen D. Noethen

Contracting Officer, BH2