Limiting-Competition-under-SAT_ACC (230627) S3I 25-106_Redacted.pdf

CUI

Version – July 2023

Memorandum for Record – Limiting Competition at or below the Simplified

Acquisition Threshold

1. Contracting Activity: CCAM-MZB-B

2. Description of Action:

Nature: X New Requirement Follow-on Requirement

Contract Vehicle: ELA/DOD-ESI/CHESS (Add platform)

X

GSA: BPA

Sole Source Purchase Order

Pricing/Contract Type: X Fixed Price Time & Materials/Labor Hours

Cost Reimbursable

Funds: Operations & Maintenance, Army (OMA) X Research and Development FY: _2025

Other Funds: FY:

Proposed Contractor(s), CAGE, UEI, Business Size:

SKAYL LLC., Cage Code:

Brand Name Buy: X Yes No

3. Description of Services or Supplies: The Combat Capabilities Development Command (DevCom), Aviation and Missile Center (AvMC), Software Simulation Systems Engineering and Integration Directorate (S3I) has a requirement to purchase Skayl’s Phenom Software software. This software will be used to develop systems in support of Project Manager (PM) Uncrewed Aircraft Systems (UAS) Command, Control, and Effects (C2E) Uncrewed Vehicle Control (UVC).

Desired Award Date: 30 September 2025 Total Value:

4. Authority:

FAR 13.106-(b)(1)(ii): For purchases not exceeding the simplified acquisition threshold (SAT), only one source reasonably available, urgency, exclusive licensing agreements, brand name, or industrial mobilization.

Or

FAR 8.405-6(a)(1)(i)(B) and 8.405-6(b)(1) Brand Name

FAR 8.405-6(a)(1)(i)(A) Urgency

FAR 8.405-6(a)(1)(i)(B) Only One Source is Capable

FAR 8.405-6(a)(1)(i)(C) Logical Follow-on

Or

FAR 16.505(b)(2)(i)(B) Only One Awardee is Capable X FAR 16.505(a)(4) Brand Name

FAR 16.505(b)(2)(i)(A) Urgency

FAR 16.505(b)(2)(i)(C) Logical Follow-on

FAR 16.505(b)(2)(i)(D) Minimum Guarantee

5. Reasons for Authority Cited:

a. Skayl PHENOM is the ecosystem for development, review, validation, and tracing of data, integration, and deployments models. Leveraging Skayl’s Future

Airborne Capability Environment (FACE) Conformant Domain Specific Data Model

(DSDM) in model construction increases interoperability across other systems and domain via previously modeled interfaces. PHENOM provides an intuitive modeling environment to build complex semantic data models in a collaborative environment. The information synchronizes with Cameo (which this program also leverages extensively), enables error-free modeling, and simplifies DSDM construction and use. This program uses Phenom to process UVC data models, generate corresponding FACE files, verify data model conformance to FACE technical standards, merge disparate models into one, update the model with real-time gratification of FACE conformance status, and auto generate FACE compliant code stubs that support the defined data model. All this aids the program in meeting the customer’s MBSE, MOSA, and FACE requirements.

Skayl’s Phenom Software product is pivotable in meeting the customer’s Model Based

System Engineering (MBSE), Modular Open Systems Approach (MOSA), and FACE

Technical Standard requirements for the Uncrewed Vehicle Control (UVC) project.

Phenom is specifically developed with FACE technical standards in mind and ensures that software components implemented using data models generated from Phenom is

FACE compliant, greatly reducing any verification efforts in meeting the FACE requirement for this program. It can also increase interoperability across other systems and domains via previously modeled interfaces, directly generate FACE code files for quicker integration into the UVC software baseline, promote easier collaboration between disparate software teams on the program, and synchronizes information with

Cameo, another modelling tool we are leveraging for MBSE efforts.

b. Two alternative toolsets for accomplishing the MBSE, MOSA, and FACE requirements for this project were reviewed. FAME by Tes Savi, and a strictly No Magic

Cameo approach (we are leveraging Cameo anyways) were considered. Cameo provides the most manual control of the FACE files, essentially a step above an xml editor; however, it requires expert-level users and takes the most time to build the data model products. Products created under this approach are often error prone as well as there is no handholding in correctness or completeness of making the data models.

FAME AWESUM is a data-model specific tool offering full-control over the data models, like Cameo, but with assistance to reduce the number of errors for compliance. FAME struggled to import CAMEO-generated files which makes it difficult to ensure the two systems are synchronized. It also had a Thread-Specific Storage (TSS) generator, but it was only for C programming language, and not compatible because of the required model artifacts necessary to generate TSS. Phenom is the most user-friendly tool. It is highly generative, so less time is spent telling it what the output artifacts should be, and it automatically generates the data model that will generate those products. Due to this, it has the least amount of manual control, but this also means it has the least amount of opportunity for error of the data products which is more important to the program.

Overall, this was deemed the most beneficial to the program to ensure success in delivering a FACE compliant software baseline for the UVC project.

c. Without this product, there could be potential cost and schedule implications due to the inability to efficiently satisfy the FACE compliance requirement and loss of code generation in helping to align disparate software teams; and inability to fulfill the FACE requirement to the customer, diminishing the customer’s confidence in the organization to deliver on the Army’s mission objectives. Skayl Phenom is already being leveraged and great time devoted in training disparate teams on its use for providing a collaboration mechanism in validating software components being developed are FACE compliant. Any other related tool would also incur cost and schedule implications given previous progress made and familiarity with this particular tool, on a project that cannot afford such significant hurdles. The process for implementing an alternate system would be costly, not proven effective, and an inefficient use of the government’s time and resources.

6. Publicizing Contract Actions: For FAR Part 13 actions, the public display and synopsis requirements of FAR 5.101 and FAR 5.203 do not apply due to the $ threshold, apply and will be followed, or

X do not apply due to an exception at 5.202(a)(6).

Requirement to post justification in accordance with FAR 8.405-6(b)(3), FAR 13.105(c), or FAR 16.505(a)(4)(iii)(A) as follows:

X Action is a brand name restriction, over $25K but less that simplified acquisition threshold. It will be redacted and posted with the Request for Quote/Solicitation.

Exceptions to posting:

Action is NOT a brand name restriction and is under $150K, Action is a brand name restriction, under $25K.

Action is a brand name restriction over $25K but will not be posted due to exception:

FAR 6.305(f)

FAR 8.405-6(b)(3)(A)

FAR 8.405-6(b)(3)(B)

FAR 8.405-6(b)(3)(C)

FAR 16.505(a)(4)(iii(C)

7. Market Research: On 21 July 2025, Enterprise License Agreement (ELA) and Department of Defense (DoD) Enterprise Software Initiative (ESI) were researched and no results returned. submitted Request for Quote # 539170 to the Computer Hardware Enterprise Software and Solutions (CHESS) Information Technology Enterprise Solutions – Software 2 (ITES-SW2) program (31 vendors) and received no responses. CHESS Statement of Non-Availability (SoNA) #216818614 was issued on 4 August 2025.

8. Technical/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.

Typed Name:

Date:

Title: Computer Engineer

Signature:

10. Contracting Officer Certification/Approval: I hereby determine that the anticipated cost or price to the Government for this contract action will be fair and reasonable based upon competitive pricing to determine lowest price technically acceptable.

I certify that this justification is accurate and complete to the best of my knowledge and belief, and that completing this purchase as a sole source is in the best interest of the Government. Additionally, I approve this justification to limit competition subject to the availability of funds and provided that the services or supplies herein described have otherwise been authorized for acquisition.

Typed Name:

Date:

Title: Contracting Officer

Signature: