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Control No: 2025-46

FAR Part 6 Justification and Approval for Other than Full and Open Competition

1. Requiring Activity: US Army Yuma Proving Ground (USAYPG), Army Test and

Evaluation Command (ATEC).

2. Contracting Activity: U.S. Army Mission and Installation Contracting Command (MICC) – Yuma Proving Ground, 301 C Street, Bldg. 2100, Yuma Proving Ground, AZ 85365-9498

3. Description of Action: Request approval to award a Cost-Plus-Fixed-Fee (CPFF) follow-on contract for W9124R21C0006 for the Global Positioning Integration and Navigation System (GPINS). The Government projects the award for May 2026.

Fiscal Year 2026 Research, Development, Test, and Evaluation (RDT&E) funds will be used. The estimated cost is $9.8M.

4. Description of Supplies/Services: The requirement for GPINS services is necessary to obtain the expertise and performance needed to support the ATEC test mission. This includes the development, maintenance, and expansion of Global Positioning System (GPS) instrumentation; the development of new advancements in the Improved Vehicle Tracking System (IVTS) and WindPack systems; and the customization and integration of GPS instrumentation for individual test programs, including but not limited to electronic warfare systems, ground combat systems, and ammunition systems located at USAYPG.

Over the years, the USAYPG mission, particularly as the only air delivery developmental tester in the U.S. Army, has made the GPINS services requirement critical due to the uniqueness of mission scenarios. USAYPG is at the cutting edge of air delivery instrumentation and data collection technology. The services requirement includes conducting research necessary to remain at the forefront of GPS instrumentation and its application to range instrumentation or operational navigation systems, incorporating integrated mission equipment packages and state-of-the-art technology to capture guidance, navigation, timing, and control data. This may also include the application of GPS radio frequency countermeasure technologies. Work may be performed at several

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because this requirement is a follow-on action for the continued provision of highly specialized services that can only be met by the incumbent responsible source.

Full and open competition is not feasible for this procurement because any contractor other than the incumbent would require substantial time and Government resources to gain the necessary understanding of the existing GPINS environment. A new contractor would need to reverse engineering system components, re-establish and validate interfaces, re-accredit security controls, and re-verify performance across the operational environment. These activities would introduce unacceptable delays in fulfilling the agency’s mission requirements and could disrupt ongoing operations that rely on continuous availability and reliability of GPINS. The Government cannot accept the operational risk associated with a break in service or degraded performance while a new contractor attempts to reach the incumbent’s level of proficiency. In addition, the incumbent’s specialized expertise is the result of years of direct development, integration, and sustainment work on this specific system. This experience cannot be replicated quickly or efficiently by another source, even one with general experience in similar technologies. The unique combination of system-specific knowledge, proprietary implementation details, and established working relationships with Government enables the incumbent to provide seamless continuity of operations. Attempting to compete this requirement at this time would jeopardize mission readiness and could result in operational gaps that are inconsistent with the Government’s obligation to maintain uninterrupted support. For these reasons, the nature of the acquisition—namely, a follow-on requirement for highly specialized services essential to the continued operation of GPINS—requires the use of the authority cited in Section 5. Conducting this procurement under full and open competition would create unacceptable risk to mission execution and is therefore not in the best interest of the Government.

a. Background: Cibola Information Systems (CIS) is the only responsible source capable of providing the required GPINS services due to its exclusive ownership of all proprietary software and technical data associated with the GPINS, IVTS, WindPack, and 6DVTS systems. CIS has been the sole developer and integrator of these systems for more than 25 years, during which it has built, upgraded, and maintained all operational units used by USAYPG. The systems are highly integrated, rely on interchangeable components, and operate through a unified architecture that only CIS has the technical knowledge to support.

CIS also possesses unique expertise in designing instrumentation capable of surviving extreme airdrop environments, a capability essential to USAYPG’s aviation, air delivery, UAS, C-RAM, EW, and ground combat test missions. No other contractor has the proprietary rights, historical knowledge, or specialized engineering experience required to perform this work.

CIS’s ongoing development efforts—such as enhancements to the WindPack system, completion of the 6DVTS to bridge GPS signal gaps during aircraft exit, and

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miniaturization of IVTS for small UAS demonstrate unique and innovative capabilities not otherwise available to the Government. These advancements address missionspecific technical gaps and do not resemble any pending competitive acquisition. Technical data packages, specifications, and engineering documentation suitable for full and open competition do not exist because the GPINS systems have evolved over decades through continuous proprietary development performed solely by CIS. The Government does not own the underlying technical data, and the complexity of the systems, particularly their operation in extreme test environments, makes it impractical to generate open, vendor-neutral specifications. The Government will continue to assess opportunities to document non-proprietary elements where feasible, but at present, only CIS possesses the technical capability and intellectual property necessary to meet mission requirements.

1) As described at FAR 6.103-1(b), full and open competition is not required when the supplies or services needed by the agency are available only from one responsible source, or—within DoD—from only one or a limited number of responsible sources, and no other type of supplies or services will satisfy agency requirements. This acquisition meets that condition. The required services are highly specialized and constitute a follow-on effort that relies on proprietary system knowledge, unique technical data, and specialized expertise developed exclusively by CIS. CIS is the only responsible source capable of performing this work without causing unacceptable delays, loss of continuity, or disruption to ongoing operations.

CIS is the only responsible source capable of performing the required work due to its direct development, integration, and sustainment of the GPINS system. The contractor holds proprietary knowledge of the system architecture, data structures, interfaces, and operational workflows that are not available to any other vendor. Years of hands-on experience with the system’s design, configuration, and mission-specific functionality have resulted in a level of expertise that cannot be replicated by another source within the timeframe required to maintain operational continuity. The contractor’s intimate familiarity with the system’s technical baseline enables them to provide immediate, uninterrupted support that no other vendor can match.

Although other contractors may offer general IT or engineering services, none possess the system-specific knowledge, proprietary access, or technical data required to assume responsibility for GPINS. Competing products or services cannot be modified to meet mission needs without extensive redevelopment, reverse engineering, and re-integration efforts. These activities would introduce unacceptable delays, increase costs, and jeopardize mission readiness. As a result, alternative products or vendors cannot meet the Government’s requirements.

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Technical data packages, specifications, engineering descriptions, and other documentation suitable for full and open competition have not been developed because the GPINS system contains proprietary elements owned and controlled by CIS. The Government does not possess sufficient rights to the underlying technical data to allow another contractor to assume performance. Developing a complete, competition-ready technical data package would require significant time and resources and would still not eliminate the operational risk associated with transitioning to a new vendor.

The Government will continue to assess opportunities to expand competition in future acquisitions. However, until the necessary technical data, documentation, and system knowledge can be developed or acquired, only CIS is capable of meeting the Government’s immediate operational requirements.

b. Alternatives.

1) Suspension of Contract Support: The GPINS services are ongoing and critical to mission accomplishment. Suspending these services would pose a significant, if not critical risk of delay in developing state-of-the-art GPS instrumentation for range instrumentation or operational navigation systems and would disrupt or cancel all Aviation and Electronic Warfare scheduled testing. Therefore, this alternative is not viable.

2) Use of In-House Resources: USAYPG does not possess the necessary manpower, technical expertise, or resources to execute the required services. The USAYPG has no plans to acquire such specialized personnel internally, and there is no foreseeable scenario in which the necessary capabilities could be developed within the Government. Any attempt to build this capacity in-house would result in unacceptable delays and critical mission failure. Therefore, this alternative is not viable under any reasonable timeline.

3) Replacing the existing GPINS, IVTS, WindPack, and associated ground station infrastructure is not a viable alternative. These systems represent more than two decades of Government investment in hardware, software, integration, and operator training. Replacing them would require complete redevelopment of instrumentation, re-certification of hardware, retraining of personnel, and re-establishment of compatibility with existing test range systems. The cost of replacement would far exceed the cost of continued sustainment, and the time required to field a replacement system would cause multi-year delays to Army and joint test programs. This alternative is therefore unacceptable from both a cost and schedule standpoint.

4) A competitive acquisition was evaluated but determined to be impractical. GPINS relies entirely on proprietary technology developed by CIS, including system architecture, hardware designs, software code, and integration methodologies. No other vendor possesses the technical data, proprietary interfaces, or system-specific knowledge required to assume performance. A new contractor would be forced to reverse engineering or redevelop the entire system, establish new developmental practices, and create compatible hardware and software from scratch. This would introduce unacceptable delays to ongoing test missions and require replacement of existing systems currently in use at USAYPG. Previous competitive attempts and recent sourcessought notices have not identified any qualified vendors capable of meeting the technical or compatibility requirements. Therefore, competition is not a viable alternative.

5) The only feasible alternative is to establish a noncompetitive contract with CIS to continue providing GPINS’ services. This approach ensures uninterrupted support, preserves mission continuity, and prevents degradation of data quality or operational capability. A CPFF arrangement remains the most appropriate contract type due to the variable and unpredictable nature of test mission requirements. This alternative best supports the Government’s need for flexibility, responsiveness, and technical continuity.

c. Impact.

1) This acquisition is not an interim contract or contract extension with the incumbent. Therefore, the considerations outlined in this subsection—such as start-up costs for a brief interim period, recruitment and relocation challenges, continuity of service during a short transition, or preparation of interim management plans—are not applicable to this requirement.

2) This acquisition is not the result of a protest received prior to or upon award of a follow-on service contract. No protest has been filed, and no protest-related delays, timelines, or actions apply. Accordingly, the requirements in this subsection—such as protest dates, protestor identity, basis for protest, likelihood of Government success, or protest-override considerations—are not applicable to this requirement.

d. Impact if Justification is not approved: Failure to approve this Justification would

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result in significant and immediate harm to Army and joint test operations. GPINS services are essential to the execution of Aviation, Electronic Warfare, and other mission-critical test programs conducted at USAYPG. Without approval to proceed with this noncompetitive acquisition, GPINS support would cease, resulting in the cancellation or indefinite delay of scheduled test events. These delays would disrupt customer program timelines, degrade data quality, and negatively affect overall readiness.

The absence of GPINS instrumentation and technical support would create operational gaps that cannot be mitigated by in-house personnel or alternative contractors. Mission failure is a likely outcome, as the Army would be unable to conduct required developmental and operational testing without these services. The resulting delays would impact test schedules, customer programs, and the Army’s ability to meet operational and developmental objectives.

7. Efforts to Obtain Competition: The Contracting Officer shall publish the notices required by FAR 5.101, and any bids or proposals received shall be considered.

Previous competitive attempts, as detailed in the procurement history, did not yield any viable sources capable of meeting the GPINS requirement. Recent market research and Requests for Information (RFI) further confirmed that no other contractors possess the proprietary technology, system integration capability, or technical expertise necessary to perform this work.

a. Effective Competition: Because this is a sole source action, effective competition is not appliable. The GPINS requirement relies on proprietary IVTS, WindPack, and ground station technologies developed exclusively by CIS over more than two decades.

No other contractor has demonstrated the ability to provide compatible systems or assume responsibility for the integrated GPINS architecture. As a result, effective competition cannot be achieved for this acquisition.

b. Subcontracting Competition: Subcontracting competition will be achieved by the Government ensuring that the prime contractor seeks competition to the maximum extent practicable in its subcontracting. Because this is a single sole source action and CIS is a small business, CIS is not required to submit a formal subcontracting plan.

However, for any subcontracted elements that may be necessary, the Government will require CIS to obtain competition for any subcontracted material, components, or services that are not proprietary or unlikely tied to CIS’s internal technologies. The Government will monitor subcontracting activity to ensure competitive opportunities are pursued whenever practicable.

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8. Actions to Increase Competition: USAYPG has taken, and will continue to take, all reasonable steps to assess the potential for competition in future acquisitions of GPINS-related services. Previous market research and current research conducted through recent RFIs consistently confirmed that no other vendors possess the proprietary technology, technical data, or system integration capability required to support the GPINS, IVTS, WindPack, or 6DVTS systems.

At this time, no additional steps are being taken to seek competition due to the GPINS requirement being directly tied to CIS’s proprietary technology and intellectual property.

Any attempt to develop a competitive alternative would require the complete replacement of the existing GPINS system framework, redevelopment of all instrumentation, retraining of personnel, and reconfiguration of ground station components. This would duplicate more than two decades of Government investment and introduce delays that would severely impact critical test missions.

The technical risk and operational disruption associated with replacing the existing system framework make such an approach impractical and not in the Government’s best interest. USAYPG will continue to monitor the market for emerging technologies that could potentially meet future requirements. If a new, non-proprietary solution becomes available that can satisfy USAYPG’s mission needs, the Government will evaluate the feasibility of transitioning to a competitive acquisition strategy. However, based on current market conditions and the specialized nature of the requirement, no viable competitive alternatives exist. Because CIS is the only responsible source capable of performing this requirement, the Government reviewed the actions identified in the previous justification and confirmed they were completed. In accordance with FAR 6.103-1, the previous justification is included to assist the approval authority in determining whether the planned actions to remove barriers to competition were accomplished.

9. Market Research: In accordance with Defense Federal Acquisition Regulation (DFARS) Procedures, Guidance and Information (PGI) 206.103-170(d), a RFI was posted to SAM.gov on January 22, 2025, to identify potential sources capable of supporting the GPINS requirement. The RFI remained open for 14 days. In addition to the public posting, an email was submitted directly to the incumbent contractor, CIS, requesting their participation and submission of an RFI response to ensure comprehensive market research. A Market Research as a Service (MRAS) posting was also issued on GSA.gov on January 28, 2025, and remained open for 8 days. The applicable NAICS code for this acquisition is 541330 (Engineering Services) with no exception applied, and the corresponding small business size is $47 million. The SAM.gov posting generated three responses, all from small businesses registered under NAICS 541330 The MRAS posting generated four responses; however, two respondents were not registered under the required NAICS code and were excluded from further consideration. Preliminary technical information submitted by the eligible

11. Other Facts:

Procurement History:

Contract no.: W9124R-21-C-0006 Contractor: Cibola Information Systems, INC Amount: $9.3 million Ordering Period: 1 Nov 2020 – 31 Oct 2025 Procurement method: Sole Source Authority – FAR 6.302-1, Only One Responsible Source.

Contract no.: W9124R-15-0006

Amount: $7.9 million Period of Performance: 1 Jun 2015 – 31 May 2020 Procurement method: Sole Source - FAR 6.302-1, Only One Responsible Source.

Contract no.: W9124R-11-C-0008

Amount: $4.3 million Period of Performance: 1 Apr 2011 – 31 Mar 2012 Procurement method: Total Small Business Set-Aside (FAR 19.502-2)

12. Technical Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

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13. Requirements Certification: I certify that the supporting data under my cognizance which are included in the justification are accurate and complete to the best of my knowledge and belief.

14. Fair and Reasonable Cost Determination: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable. This determination will be made using cost analysis. As part of the bases, certified cost or pricing data will be required.

15. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Amanda Ramirez Contracting Officer