4. Statutory Authority Permitting Other Than Full and Open Competition

The statutory authority permitting other than full and open competition for this effort is 10 U.S.C.

§ 3204(a)(1), as implemented by Revolutionary Federal Acquisition Regulation Overhaul (RFO) 6.103-1(b), “Only one responsible source and no other supplies or services will satisfy agency requirements” as well as RFO 6.103-1(c)(2), “Awarding a follow on contract for the continued development or production of a major system or highly specialized equipment where award to another source would result in substantial duplication of cost to the Government that is not expected to be recovered through competition or result in unacceptable delays in fulfilling the agency’s requirements.”

5. Rationale Justifying Use of Cited Statutory Authority

A. Unique Contractor Qualifications and Technical Complexity

The proposed source, Anduril Industries Inc., is the only known source to deliver fully compliant MTC Shelter Systems within the Government’s mandatory timelines.

The MTC Shelter System is not a simple commercial container procurement; it is a highly complex, integrated weapon system component. Beginning in 2024 through 2026, the Marine Corps Warfighting Laboratory, Science and Technology Division (MCWL S&T) invested approximately and in a prototype contract awarded through the Defense Technical Innovation Center (DTIC) with Anduril Industries to develop, engineer, and field-test the pre-production prototype shelters (Menace-I baseline). This prototyping effort matured the precise physical security integration, power architecture, and tactical mobility subsystems needed by the Marine Corps to perform key agency functions related to information, which no other sources can meet.

The MTC Shelter System operates as a fully integrated dual-shelter configuration. The eight (8) Operator Shelters serve as secure tactical workstations. To support sustained operations, these shelters incorporate highly efficient environmental control systems capable of maintaining stable temperature, humidity, and airflow levels to ensure personnel survivability and performance in extreme global climates. Operating in tandem with the operator units, the seven (7) Processing Shelters are dedicated to housing the core server infrastructure, high-density computing arrays, secure network routing hardware, and cryptographic equipment. Because of the intensive thermal output of continuous, high-performance computing, the Processing Shelters are equipped with specialized, high-capacity Environmental Control Units (ECUs) engineered to prevent thermal throttling and equipment failure under peak operational loads.

The Operator and Processing Shelters meet the stringent physical and electromagnetic security thresholds required to function as a rapidly deployable tactical Sensitive Compartmented Information Facility (SCIF) that is fully accreditable under the rigorous standards of Intelligence Community Directive (ICD) 705 and compliant with TEMPEST Level A specifications.

Further, the MTC Shelter System is fully ruggedized and compliant with MIL-STD-810H environmental standards required of equipment operating in expeditionary environments. This testing and compliance certification must verify reliable operation under extreme conditions, including blowing rain, high-velocity sand and dust, salt-fog corrosion in maritime zones, high humidity, and extreme operating and storage temperature ranges. Additionally, each shelter features integrated, heavy-duty mobilizers to support towed transport by standard military utility vehicles and methods of transportation to, from, and within austere operating environments.

Finally, the MTC Shelter System possesses complete off-grid power autonomy capable of rapid cold-start and power generation sufficient to power the whole system. Anduril’s system achieves this requirement in a manner that is fully compatible in form, fit, and function with the standard military equipment, logistics, and power sources.

Anduril is the only vendor known to have produced a shelter possessing, and capable of, all the above attributes, which are necessary to fulfill the agency’s mission.

Furthermore, Anduril possesses key unique technical information, capabilities, and skill that will enable them to manufacture shelters meeting the requirement that other vendors do not have including:

1. Proprietary ICD-705 & TEMPEST Level A Shielding Architecture: Market research confirms that no other commercial or defense source possesses a mature, qualified production baseline capable of simultaneously meeting both electromagnetic shielding and physical security standards within an expeditionary, road-transportable, and flight-certified shelter configuration. While alternative vendors fabricate standard shielded and towable enclosures, only Anduril holds the proprietary technical designs for the specific manufacturing and production processes tailored specifically to this deployable dual-shelter footprint. A deviation in manufacturing tolerances, wall composition, or weld integrity would immediately invalidate the baseline, requiring an extensive ground-up engineering redesign and recertification.

2. Integrated Mechanical Engineering and Tactical Power Architecture: Market research and technical evaluations conclusively demonstrate that no other vendor offers a pre-engineered, flight-certified tactical shelter that incorporates turnkey mechanical and electrical integration with the Government-specified MEP-1070 generator set.

Integrating a 60 kW multi-fuel generator directly into the structural envelope of an expeditionary shelter - while maintaining the precise center-of-gravity, axle load, and structural rigidity required for C-130, C-17, and C-5 air transportability and tactical vehicle towing - demands custom structural engineering. Through the MCWL S&T prototyping phase, Anduril developed, stress-tested, and validated the specialized chassis, shock mounts, turnkey MEP-1070 power distribution interface, and mobilizer systems required for both towed cross-country and highway transport. This mature baseline eliminates the need for external power conversion skids, drastically reducing the system’s operational and logistical footprint in forward-deployed environments.

For the above reasons, Anduril is the only responsible source for this requirement, and no other source will meet the Government’s requirements.

B. Substantial Duplication of Cost

As described by RFO 6.103-1(c)(2)(i), procuring alternative systems would result in substantial duplication of costs, including, but not limited to, extensive non-recurring engineering (NRE), design tooling, and qualification investments (estimated at upwards of ) to the Government that is not expected to be recovered through competition. The extensive developmental engineering, environmental testing (MIL-STD-810H), electromagnetic containment testing (TEMPEST A), and security accreditation (ICD-705) required to field a brand-new dual-shelter footprint would incur significant, non-recoverable duplicate capital expenditures.

A new contractor would be required to perform complete ground-up development or reverse engineering of the MTC physical, environmental, electrical, and structural systems. The initial investment through the MCWL S&T prototyping effort totaled approximately and in NRE. Duplicating this development effort across an alternative commercial source would require an estimated in associated engineering expenditures that could not be recovered across a 15-unit procurement. Furthermore, introducing a disparate, non-standard shelter configuration into the MTC baseline would create a split logistics footprint, requiring duplicate sparing pipelines, distinct separate technical manuals, unique provisioning data, and redundant maintenance training courses for Marine Corps operators and technicians, resulting in unnecessary duplication of lifecycle support costs exceeding . In total, selecting an alternative source would result in an estimated, non-recoverable duplicative cost of approximately , an expenditure that cannot be recouped through any realistic competitive process.

C. Unacceptable Delays

Under RFO 6.103-1(c)(2)(ii), transitioning this requirement to another source would result in unacceptable schedule delays in fulfilling the agency's mission-critical requirements and severely disrupting delivery schedules leaving forward-deployed forces without essential infrastructure.

The Maritime Targeting Cell program directly supports critical, forward-deployed maritime units with urgent operational deployment windows requiring immediate multi-sensor data correlation and fusion capability. Sourcing from an alternative vendor would cause severe, unacceptable delays in mission execution:

1. Production Ramp-Up and Engineering Lead Times: Designing, prototyping, and establishing qualified production-line tooling for an alternative ICD-705 and TEMPEST Level A compliant dual-shelter system would require an estimated before the first unit could enter physical manufacturing.

2. Testing, Accreditation, and Facility Backlogs: Re-executing the full batter of military environmental (MIL-STD-810H), electromagnetic (TEMPEST Level A), and physical SCIF (ICD-705) test matrices, combined with the associated scheduling backlogs at accredited Government-approved test facilities, would introduce an additional delay of

3. Total Operational Schedule Impact: Introducing a new contractor is estimated to delay the delivery of these critical MTC shelters by a minimum of . This multi-year delay is entirely unacceptable to the requiring activity, as it would create an operational capability gap, leaving forward-deployed forces without the essential maritime domain awareness and targeting capabilities required to support active, real-world operational plans.

D. Conclusion

Accordingly, Anduril Industries Inc. is the only responsible source, and no other source can meet the Government’s requirement. Furthermore, competitive efforts would not be capable of fulfilling this requirement without causing substantial duplication of cost ( ) and critical, mission-compromising schedule delays ).

6. Description of Efforts Made to Solicit Offers from as Many Offerors as Practicable

On 02 September 2026, the Government issued a combined Notice of Intent (NOI) and Sources Sought Notice (SSN) M6785426I0246 on the System for Award Management (SAM.gov) website. The NOI/SSN described the mandatory technical and operational requirements of the MTC Shelter Systems - including the ICD-705 SCIF compliance, TEMPEST Level A electromagnetic shielding (100 db RF attenuation), MIL-STD-810H environmental qualification, and the mobile 60kW multi-fuel power integration criteria. The NOI/SSN instructed all interested parties to submit capability statements before the submission deadline on 17 September 2026. The Government received and reviewed two (2) responses to the NOI/SSN. The market research concluded that only one source, Anduril, demonstrates the capability to provide a proven, commercial solution that meets all the Government's minimum threshold requirements as stated in the NOI/SSN.

The requiring activity and program management office conducted continuous market surveillance by actively participating in tactical defense technology symposiums, industry days, and joint-service capability demonstrations. Moving forward, PM ICO will continue active industry outreach to monitor emerging commercial shelter and power technologies. If other manufacturing partners demonstrate newly matured, qualified expeditionary structures capable of supporting the multi-fuel generator configurations within identical air-transport and physical security constraints, the MTC program office will incorporate these findings to foster competition in future follow-on procurements, tech insertions, and lifecycle support increments.

7. Determination of Fair and Reasonable Cost

The Contracting Officer will determine that the price for the MTC Shelter System and associated lifecycle support is fair and reasonable prior to award by leveraging the existing, pre-priced U.S.

Army-negotiated Anduril Enterprise Contract (Single Award IDIQ: W9128Z26DA001). These baseline rates were already evaluated, audited, and determined fair and reasonable by U.S. Army Contracting Command contracting officers, protecting the Marine Corps from pricing volatility.

8. Actions to Remove Barriers to Future Competition

The Government is committed to fostering competition to the maximum extent practicable for all subsequent lifecycle increments, modernization phases, and logistical support efforts related to the Maritime Targeting Cell (MTC) program. To remove barriers to future competition for these highly specialized tactical shelters, the program office is executing the following proactive strategies:

1. Acquisition of Interface Control Documentation (ICDs): PM ICO is actively working to procure and define open-architecture interface standards and detailed ICDs from Anduril. Establishing standardized mechanical, electrical, and data interfaces at the shelter boundaries, ensures the Government can competitively source future hardware upgrades, subsystem integrations, and computer processing hardware from alternative third-party vendors without disrupting the underlying structural or security baselines.

2. Negotiating Technical Data Packages (TDP): The Government is acquiring Government Purpose Rights (GPR) for all operations, maintenance, installation, training, and provisioning data deliverables under this delivery order. While Anduril retains proprietary rights in its core manufacturing methods and internal TEMPEST Level A / ICD-705 physical construction layers, the acquired GPR data package establishes the baseline specifications necessary to compete future lifecycle sustainment, depot-level repair, and component maintenance. Furthermore, the Government will evaluate the cost-benefit ratio of acquiring a modified TDP or licensing agreement for future procurements if the operational quantities expand beyond current projections.

3. Subcomponent and Logistics Competition: For future sustainment, field support, and ancillary equipment procurements (such as replacement ECUs, standard power distribution cables, and tow-mobilizer components), the Government will break out commercially available components for full and open competition, preventing long-term vendor lock-in on replaceable subcomponents and/or consumable hardware.

4. Ongoing Market Surveillance: In accordance with RFO Part 10, the MTC program office will continue to monitor the defense industrial base for emerging technologies and new expeditionary shelter manufacturers. The program office will review any incoming capability statements from upcoming SAM.gov notices and industry day engagements to identify alternative sources capable of meeting similar ruggedized physical security requirements in future procurement cycles.