Justification for Other than Full and Open Competition (JOFOC) KSC LASSO - Final 8.10.22 (REDACTED).pdf

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Kennedy Space Center

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Laboratory Support Services and Operations Contract (LASSO) Contract Number 80KSC017C0012

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) John F. Kennedy Space Center (KSC).

The procuring agency is the National Aeronautics and Space Administration (NASA), and the contracting activity is John F. Kennedy Space Center (KSC).

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 award a sole-source extension via modification to Amentum Services, Inc

(Amentum) for the Laboratory Support Services and Operations (LASSO) Contract, contract number 80KSC017C0012. The requested extension is for an additional period of up to 6 months, as authorized under contract clause I.11, FAR 52.217-8, Option to Extend Services (Nov 1999). This extension allows for the continued full scope of services provided under LASSO until the follow-on LASSO II contract is awarded. The LASSO II Source Evaluation Board (SEB) recently updated its schedule indicating the anticipated contract award date would be no earlier than October 2022, with start of performance on or about December 2022. This extension of services aims to cover the gap between the current end date of performance on LASSO (September 30, 2022) and the anticipated start of performance for LASSO II (December 2022).

This justification is required for compliance with FAR 17.207(f) – although the labor rates were evaluated as part of the initial competition, this option period for extending services due to delay of the follow on, while contemplated and advertised, was not specifically evaluated as part of the initial competition. The proposed modification will extend the services beyond the current end date of September 30, 2022 to ensure continuation of program management;

laboratory maintenance and support; operational laboratory services; and professional and technical support for scientific research and engineering analysis, test and evaluation in laboratory environments for the 2-month period of October 1, 2022 through November 30, 2022 with an option for a month-to-month extension for the remaining 4-month period of

December 1, 2022 through March 31, 2023.

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 services to be procured under this action are the continuation of program management;

laboratory maintenance and support; operational laboratory services; and professional and technical support for scientific research and engineering analysis, test and evaluation in laboratory environments. Specific tasks include:

• Program management for program control, safety and mission assurance, management information systems, work planning and control, and logistics

• Operational laboratory services to the KSC, NASA Programs, Spaceport customers, other NASA centers and other government agencies, including:

- Chemical Sampling and Analysis of fluid systems

- Component Cleaning and Refurbishment of aerospace components

- Calibration of ground support equipment (GSE) and tools

- Non-Destructive Evaluation of components, parts, systems and structures related to facilities, GSE, payloads and flight vehicles

- Electromagnetic interference testing, evaluation and troubleshooting for ground and flight systems

• Engineering, Scientific and Research (ES&R) professional and technical support for scientific research and engineering analysis, test and evaluation in laboratory environments.

- Primary focus is space flight and ground operations utilized for development and validation of enabling technologies for future exploration and science missions

- The following skills are representative of the work to be performed on LASSO:

▪ Cryogenics and Pneumatics

▪ Physical Sciences: Biology, Chemistry and Physics

▪ Life support and habitation systems

▪ Materials and Process Engineering

▪ Mechanical testing

▪ Environmental testing

▪ Corrosion evaluation and prevention

▪ Granular Mechanics

▪ Electrostatics

▪ Resource excavation, transport, processing, and utilization on extraterrestrial bodies

▪ Advanced Manufacturing using in-situ Resource Materials

▪ Autonomous Systems and Robotics

• Lab Maintenance and support services for designated KSC work areas, including:

- Equipment maintenance (preventative and corrective)

- Lab Safety and Health for occupational and operational safety, industrial hygiene, and health physics

- Hazardous waste management to characterize waste and interface with the KSC

Environmental Program

The Government has a continuing requirement to provide the laboratory services that are provided under this contract to support spaceport launch customers and engineering research and technology development until the follow-on contract is awarded. The LASSO contract provides laboratory services and support activities for the KSC Center Management and Operations (CMO), NASA Programs including, but not limited to, Ground Systems Development and Operations (GSDO), the International Space Station (ISS), Launch

Services Program (LSP), and the United States Air Force (USAF) 45 th Space Wing at Cape Canaveral Air Force Station. The LASSO contract also provides laboratory services and support activities for other NASA programs including, but not limited to, Advanced Exploration Systems (AES) and programs in the Space Technology Mission Directorate

(STMD); other NASA centers; KSC Spaceport customers; commercial entities; and other government agencies as designated by the Government.

Estimated dollar value for the 6-month Extension of Services available under FAR 52.217-8, Option to Extend Services, is . The initial 2-month period of October 1, 2022 through November 30, 2022 has an estimated value of ; the option period of December 1, 2022 through March 31, 2023 has an estimated value of per month.

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. 2304(c) (1), as implemented by FAR 6.302-1, which permits contracting without providing for full and open competition when supplies or services needed by the Agency are available from only one responsible source or only from a limited number of responsible sources, an no other type of supplies or services will satisfy the needs of the Agency. Due to c ircumstances beyond the control of the contracting office, there is only one responsible source available to provide the required services. In accordance with FAR 6.302-1(a)(2)(iii), services may be deemed to be available only from the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in unacceptable delays in fulfilling the Agency's 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:

Pursuant to FAR 6.302-1(a)(2)(iii), “services may be deemed to be available only from the original source…when it is likely that award to any other source would result in unacceptable delays in fulfilling the agency’s requirements.” Amentum was selected as the prime contractor through a competitive procurement process under NASA’s Laboratory Support Services and Operations Contract (80KSC017C0012). Over the past 5 years, Amentum has developed exceptional services, providing contract support and specialized skills to efficiently and successfully complete on-going mission activities.

Amentum has performed highly specialized services on the LASSO contract since performance began on October 1, 2017. Since then, it has contributed significantly to operating and maintaining a diverse set of laboratories, developmental shops and test facilities to provide services for KSC in support of multiple customers. NASA KSC has a continual need for laboratory capabilities. It is also important that KSC be able to provide laboratory services to KSC and multiple NASA Programs and customers, including the USAF. The LASSO contract provides the support services to manage and maintain 18 various KSC laboratories, developmental shops and test facilities; four operational laboratories; and supplement professional and technical support across the laboratories, development shops and test facilities.

This extension will allow continuity of support during what would have been a contract transition period and will help secure the availability of critical skills contained in the LASSO workforce, which are paramount for successful completion of the activities described above.

When considering the critical and specialized nature of the requirements performed across multiple NASA Programs, Amentum, the incumbent LASSO contractor, is the only company able to provide uninterrupted services without substantial duplication of effort and costs that would otherwise be incurred if NASA KSC were to procure new contracts for these services.

Exercising the option to extend services clause, FAR 52.217-8, on LASSO will allow time for the LASSO II SEB to complete critical acquisition milestones, significantly reducing the risks of disruption the NASA KSC’s current operations. As a result, this option will effectively provide for the services outlined above to be transitioned to the LASSO II contract, which is expected to be in place by the end of the requested LASSO contract extension option period.

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:

This option exercise is exempt from the FAR 5.201 synopsis requirements in accordance with FAR 5.202(a)(11). This option was previously included in the description of the basic contract synopsis in sufficient detail to comply with the requirements of FAR

5.207(c)(6). This synopsis was issued November 29, 2016 referencing the LASSO RFP

#NNK17600289R.

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 contract 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 cost will be evaluated based on comparison with historical data and the independent government estimate. The Contracting Officer will ensure the contractor proposes in accordance with the existing, previously evaluated, rates in the contract and adjusted only as a result of revisions to prevailing labor rates provided by the Secretary of Labor, as specified in FAR 52.217-8. In accordance with FAR 15.403-4, the Contracting Officer will obtain certified cost or pricing data as none of the exceptions in

15.403-1(b) applies.

8. FAR 6.303-2(b)(8) – Description of the market research conducted, and the results, or a statement of the reasons a market research was not conducted:

No formal market research was conducted to support this extension of LASSO. Generally, other known sources are capable of performing the requirements associated with LASSO – this is demonstrated in the proposals received in response to the LASSO II Request for Proposal. However, knowledge of the market also indicates that there is no source other than Amentum. that is capable of immediately providing the services required by KSC over the short duration needed until the services are transitioned to the follow-on contract.

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

Amentum is uniquely qualified for this requirement and continues to successfully perform the Laboratory Support Services and Operations requirement for NASA-KSC. A lapse or non-performance of the LASSO services would have significant and negative impacts on the continuity of operations and the unique missions of each Directorate listed above in section 3.

In addition to the time and manpower required by the Government to search for a qualified applicant for this short period, additional manpower and program costs would be required to search, train, and properly equip, qualified applicants unfamiliar with the unique knowledge, skills, and abilities to successfully perform the services required.

As the LASSO contractor for the last five years, Amentum fulfills the Government’s requirement in the execution of the contract and can also provide a substantial benefit to the LASSO acquisition life cycle by ensuring a smooth transition to the new contractor. Some significant processes and concepts must be planned, resourced, and executed to ensure an efficient transfer.

Due to the nature of the Government’s requirement, the transition will be a very complex process and required to be successfully conducted in multiple locations across NASA KSC.

There are multiple components that require the integration of government-furnished equipment and contractor-furnished equipment before execution. Additionally, newly hired applicants would require proper training on the operation, maintenance, and employment of the existing equipment and processes.

There are also personnel-related issues that a new contractor may encounter which will have a significant impact on the LASSO program. The program requires personnel that have a specific skill set to be available immediately for contract performance. This includes a broad range of occupational skills, some of which are in high demand or limited in availability, which poses a significant staffing challenge to a new contractor. The input from the incumbent contractor is the best "industry experience" that can be utilized in the transition phase and provides significant contributions to the continued success of the LASSO program.

Last, Amentum is a responsible source possessing the knowledge and resources required to manage the Government’s requirements effectively and efficiently. Amentum possesses the research experience; institutional knowledge; and personnel intimately familiar with the LASSO services contract that supports the agency’s mission.

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

See Section 6 above

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:

A competition for the follow-on contract, LASSO II, is currently being conducted. This extension will enable continued performance of the existing contract to cover the timeframe necessary for sufficient proposal evaluation, selection, award, and phase-in of LASSO II.

Accordingly, there are no other actions the Agency needs to take to remove or overcome barriers to competition.

Laboratory Support Services and Operations Contract (LASSO), Contract Number 80KSC017C0012

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

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

Technical Representative

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

Contracting Officer

CONCURRENCES:

Acting Procurement Officer

APPROVAL:

Center Competition Advocate