MIT - JOFOC Jan2022 redacted.pdf

Rev.:01/2021

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

WALLOPS FLIGHT FACILITY (WFF)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Operations Support Services at the Westford Satellite Communications Site

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) Wallops Flight Facility (WFF).

The procuring agency is the National Aeronautics and Space Administration (NASA) and the contracting activity is Wallops Flight Facility (WFF).

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 contract to Massachusetts Institute of Technology (MIT) for operations associated with providing and sustaining a backup Ultra High Frequency (UHF) capability for NASA at the Westford Satellite Communications Site. The intent of this effort is to provide CubeSat command uplink and telemetry downlink for a set of spacecrafts in orbit. WFF requires an alternate UHF system for Small Satellite tracking during unplanned failure events. Periodic use of the system will ensure operational readiness and provide short offload intervals for the Wallops UHF system.

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):

Operations support services are being obtained from MIT for one year beginning March 1, 2022 through February 28, 2023, with two one-year option periods. MIT operations support includes management, system scheduling, technician, operator time, and consumables for coverage of Wallops outage and emergency operations and sustainment operations. The combined estimated value of this procurement is approximately [redacted]

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, “Only one responsible source and no other supplies or services will satisfy agency 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:

The rationale supporting the use of 10 U.S.C. 2304(c) (1) is that MIT has the combined training, experience, and expertise to provide uninterrupted mission critical operations support services and technology support to perform the requirements as described below.

MIT is the only responsible source for this acquisition due to previous work that makes MIT uniquely qualified. This unique expertise is based on MIT's related technical efforts with an existing NASA Heliophysics small satellite project under the VISTA contract. A UHF multi-mode phased array feed has been created by an MIT student and installed on the Westford telescope. The UHF feed is operational and has been successfully used for ghost tracking of several cubesat missions in receive-only mode. This engineering effort is being extended to put in place a more robust and higher performance antenna system that meets the requirement to provide and operate a UHF tracking capability as a backup to the WFF system.

Procuring these services from any other source would create unacceptable delays. Due to the expertise gained by MIT, transitioning this work to any other contractor will increase costs, impact schedules, and cause programmatic risk and delays to the smallsat tracking operations.

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:

A notice to the Government Point of Entry (GPE) website (Sam.gov) was published on November 18, 2021 in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to award a sole-source contract to MIT. The results of this synopsis are summarized in Section 10 below.

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 (CO) 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 contractual 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.

Since MIT has been used by NASA HQs and other NASA Centers before on previous small satellite operations support services for cube satellites, costs for tracking services will be used for comparison where applicable. The Contracting Officer’s Representative (COR) and the CO will review the contractor’s proposed estimates to determine that the direct labor rates, direct labor hours, skill mix, other direct costs, and indirect costs (exclusive of fee) are fair and reasonable prior to contract award. Also, the cognizant audit agency and ONR will also review and verify rates.

After the work is authorized, the COR will monitor performance. MIT will be required to submit both technical progress and financial management reports for review and analysis by the Government.

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:

A notice to Beta.Sam.Gov published on November 18, 2021 to announce NASA’s plans to issue a contract to MIT for the Operations Support Services at the Westford Satellite Communications Site to support the Wallops UHF satellite communications efforts with several spacecrafts for a one year period with two one-year option periods.

A formal market survey was not conducted because MIT is the operator of the Westford Satellite Communications Site. The expertise required for this requirement is unique, and specialized experience is required to support this procurement. Based on Wallops’ engineering knowledge of the market, MIT has participated in similar missions, it is felt there is no other viable source that could readily participate in the operations support for tracking these small satellites. To date, no alternate domestic sources has been identified.

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

None

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

A notice of NASA’s intent to award this sole-source action was synopsized on the GPE website (Sam.gov) per FAR Subpart 5.2 (See Section 6 above). The synopsis was posted on November 18, 2021 and closed on December 10, 2021. No companies responded to the synopsis for this requirement.

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:

MIT is the only known source with the necessary expertise and capability that meets the Government’s requirement. A subsequent acquisition of similar components and services for Small Satellite Operations Support Services at Westford Satellite Communications Site is not anticipated. Should a similar requirement develop in the future, it will be synopsized and competed to the maximum extent practical.

The Agency will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements.

RACHEL

Albertson

Digitally signed by RACHEL Albertson Date: 2022.01.04 15:17:23 -05'00'

Operations Support Services at the Westford Satellite Communications Site

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.

Rachel Albertson Technical Representative

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

Digitally signed by Lashawn Feimster Date: 2022.01.06 09:17:06 -05'00'

LaShawn K. Feimster Contracting Officer

Lashawn Feimster