Justification for Other than Full and Open Competition (JOFOC) Northside.pdf

Rev.: 10/2025

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

NASA SHARED SERVICES CENTER (NSSC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Contract Natural Gas (Northside) Support under GSA – Areawide Public

Utilities, 47PA0426D0001

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) for services required at John C.

Stennis Space Center (SSC).

The procuring agency is NASA, and the contracting activity is the NASA Shared Services Center (NSSC), Office of Procurement.

2. FAR 6.104-1(a)(2) – The nature and/or description of the action being approved:

This justification supports awarding a sole-source utilities service contract to Delta Utilities under a GSA Areawide Utilities Contract.

NASA currently receives natural gas services under Contract No. 80SSC021FA001 with CenterPoint Energy. CenterPoint Energy notified NASA that Delta Utilities purchased their GSA Schedule contract for natural gas services, effective February 19, 2025.

After months of delays on receiving notification of a novation or name change, on September 17, 2025, NASA contacted the General Services Administration (GSA) to confirm Delta Utilities’ engagement in the GSA Schedule process and obtain an estimated timeline. GSA’s Public Buildings Service (PBS) clarified that a full novation of the existing CenterPoint Energy contract was not required. Instead, GSA would modify the CenterPoint contract to remove services and establish a new, separate contract with Delta Utilities, as Delta Utilities did not assume all business functions of CenterPoint Energy.

On December 19, 2025, GSA issued a new Areawide Contract (47PA0426D0001) for Delta Utilities, effective for 10 years (December 19, 2025 – December 18, 2035).

Based on this determination, NASA will issue an order under the GSA Areawide Contract 47PA0426D0001 with Delta Utilities to ensure continuity of natural gas services. Unlike the GSA contract, all services required by NASA under this requirement will be provided exclusively by Delta Utilities based on their buyer agreement. This new order will continue the services previously provided under CenterPoint Energy Order 80SSC021FA001. The

Rev.:10/2025 period of performance and all unexercised options under Order 80SSC021FA001 will be reduced to align with the start date of the new Delta Utilities order.

Period of Performance for Delta Utilities Order:

Base Period: Begins at the start of a month and ends on June 30, 2026.

Options: Five (5) one-year options.

Ultimate End Date: June 30, 2031, assuming all options are exercised.

Estimated order amount including options: xxx

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):

The services are to provide Natural Gas to the to the north side of John C. Stennis Space Center beginning Start of a Month 2026 through 30 June 2031 with an estimated value of $xxx inclusive of base and option periods.

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)(1), as implemented by FAR 6.302-1, Only One Responsible Source and No Other Supplies or Services Will Satisfy Agency Requirements.

5. FAR 6.104-1(a)(5) – A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

NASA Stennis Space Center (SSC) requires a reliable source of natural gas to support mission-critical operations and facility needs. Natural gas service for SSC is governed by the Mississippi Public Service Commission’s Certificate of Public Convenience and Necessity (Docket No. U-4741), issued in 1985, which established Service Area No. 2 in Hancock County, Mississippi. This area includes the NASA Rocket Test Facility (SSC) and was originally assigned exclusively to Entex, Inc. (later CenterPoint Energy) for construction, maintenance, and operation of natural gas infrastructure.

The certificate explicitly states that: No other utility offers the same kind of service in the area, and duplication of facilities would be uneconomical. Entex was authorized to construct and maintain the pipeline infrastructure necessary to serve the area.

As a result, CenterPoint Energy became the sole provider for SSC due to its ownership of the Northside pipeline and associated facilities. Following CenterPoint’s divestiture, Delta Utilities acquired these assets and assumed operational responsibility for Service Area No. 2, making Delta Utilities the only entity with the infrastructure and regulatory authority to deliver natural gas to SSC.

No other suppliers have the necessary infrastructure or legal authority to provide service in this geographic area. Therefore, Delta Utilities is uniquely qualified and is the only viable source for natural gas supply to NASA SSC in Area 2 of Hancock County, Mississippi.

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 part 5 and, if not, which exception under part 5 applies:

A notice was not publicized on the Government Point of Entry (SAM.gov) in accordance with FAR 5.101(b)(1)(vi), which provides an exception for utility services (excluding telecommunications) when only one source is available.

Due to pipeline ownership on the north side of John C. Stennis Space Center, Delta Utilities is the only viable source for natural gas supply to NASA SSC in Area 2 of Hancock County, Mississippi. Delta Utilities have an available GSA Areawide Utility Contract

47PA0426D000.1

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 proposed pricing for Delivery Order 80SSC021FA001 awarded to CenterPoint was evaluated and determined fair and reasonable based on a comparison to established GSA Schedule rates and historical prices paid under the predecessor Delivery Order NNS16AA29D. This analysis confirmed that the proposed prices are consistent with prior procurements and reflect market-based pricing.

For Delta Utilities, the proposed pricing will be compared against their Areawide utility contract. It is expected that the prior approved prices from the CenterPoint order will carry forward to the new Delta Utilities order. Accordingly, the proposed pricing is considered fair and reasonable for the scope of work required under this delivery order.

8. FAR 6.104-1(a)(8) – Description of the market research conducted, and the results, or a statement of the reason market research was not conducted (e.g., urgent, and compelling requirement):

Market research was conducted by contacting GSA directly regarding Delta Utilities Areawide Contract.

Accordingly, this requirement meets the criteria of 10 U.S.C. § 3204(a)(1) and FAR 6.302-1.

9. FAR 6.104-1(a)(9) – Any other facts supporting the use of other than full and open competition:

The order reflects the transfer of service responsibility from CenterPoint Energy to Delta Utilities, following Delta Utilities’ acquisition of the infrastructure and service rights for Service Area No. 2 in Hancock County, Mississippi. Because the underlying utility infrastructure and regulatory authority remain unchanged, and Delta Utilities is now the sole entity authorized and capable of providing natural gas service to NASA SSC in this area, issuing a new order under the GSA Areawide Contract ensures continuity of service without interruption.

10. FAR 6.104-1(a)(10) – A listing of the sources, if any, that expressed an interest in writing in the acquisition:

A notice of intent to award was not publicized in accordance with FAR 5.101(b)(1)(vi). The current contract expiring 30 June 2031 to provide natural gas to the north side of John C.

Stennis Space Center has been acquired by Delta Utilities.

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 will continue to monitor the market and evaluate alternative solutions or new sources prior to any future acquisitions for similar requirements. At the present time, due to pipeline ownership on the north side of John C. Stennis Space Center, Delta Utilities is the only viable source for natural gas supply to NASA SSC in Area 2 of Hancock County, Mississippi.

Rev.: 10/2025

Natural Gas (Northside)Support under the GSA-Areawide Public Utilities Contract

47PA0426D0001

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.

Technical Representative

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

Contracting Officer

APPROVED:

Competition Advocate

NSSC