NNG11FC20C HST_MOSES JOFOC Redacted.pdf

Rev.: 10/2025

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

GODDARD SPACE FLIGHT CENTER (GSFC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

For The Hubble Space Telescope (HST)

Mission Operations, Systems Engineering, and Software II (MOSES II)

Contract No. NNG11FC20C, 15-Month Extension

1. This 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) Goddard Space Flight Center

(GSFC):

The procuring agency is the National Aeronautics and Space Administration (NASA) and the contracting activity is NASA’s Goddard Space Flight Center (GSFC), Greenbelt, Maryland.

2. FAR 6.104-1(a)(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 extension to contract number NNG11FC20C with Lockheed Martin Corporation (LMC) for Hubble Space Telescope (HST) Mission

Operations, Systems Engineering, and Software support. The current period of performance of this contract is through June 30, 2026. This extension request for continued support is for

15 additional months (July 1, 2026 through September 30, 2027).

HST is a unique national treasure, an internationally acclaimed mission, and one of NASA’s most valuable and productive assets. If properly maintained and operated, HST should continue to produce extraordinary science and inspire the public for years to come.

Responsibility for mission operations, ground and flight software, and systems engineering must be assigned with the greatest care in order to ensure Observatory health and safety and to continue HST scientific productivity.

NASA and the scientific community have enjoyed the tremendous benefits of the telescope’s new and restored science instruments following an investment of approximately $900M for

Servicing Mission-4 (SM4). LMC’s team of engineers and managers is an integral part of the HST success story. Much of HST’s success is directly attributable to the LMC team’s leadership, technical creativity, and in-depth understanding of the HST Observatory and ground systems. Continued success will require continuation of the keen focus on safety, efficiency and cost-saving innovation that has been the hallmark of the mission for over 35 years. TEXT DELETED

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 scope of this contract includes conducting all elements of HST operations other than science operations and performing systems engineering tasks required to properly maintain

HST flight and ground systems. Mission operations responsibilities include safe and efficient control and utilization of the HST Observatory, maintenance and operation of HST-unique facilities and equipment, as well as creation, maintenance, and utilization of HST operations processes and procedures. Critical systems engineering responsibilities consist of optimizing mission system capabilities to maximize HST operations effectiveness and science productivity. This is accomplished by analyzing and resolving HST mission system anomalies, developing, integrating, testing, and maintaining HST flight software, ground systems hardware and software, and network infrastructure, and by operating and maintaining numerous HST-unique test facilities and systems. Systems engineering for the

HST mission includes operation and maintenance of an extensive and complex set of equipment and test facilities, ground and information systems maintenance, network and security administration, flight systems engineering, systems integration and test, system management, and flight software maintenance. Essential management requirements include providing a technical staff that possesses in-depth knowledge of HST’s varied, complex, and unique flight and ground systems, ensuring successful accomplishment of the diverse tasks necessary to effectively conduct HST mission operations and systems engineering, as well as managing and reporting contract element cost and schedule performance.

The contractor provides the following products and services: (1) spacecraft subsystem engineering across all disciplines, sustaining systems engineering in all areas of HST operations, including anomaly resolution; (2) flight software for all HST on-board computers including requirements analysis, design, implementation, verification and validation and documentation; (3) HST Ground Systems maintenance; (4) Systems Integration and Test to provide acceptance testing of flight software releases, ground systems releases, and Project

Reference Database (PRD) deliveries, and spacecraft configuration changes; and (5) mission flight operations and control.

Under this contract, the contractor is required to respond effectively to changing on-board conditions and provide creative solutions that enable continued viable HST operation and science productivity. As the HST observatory ages and degrades, operations and engineering personnel must be thoroughly knowledgeable in all aspects of operations and unique systems characteristics and constraints. This knowledge is essential in sustaining the highly productive HST science mission by ensuring timely and effective responses to system anomalies and successful adaptation of existing processes and procedures to address eventual or potential future system shortcomings. Process, procedures, and flight software updates are needed to alter the way HST is operated to mitigate component aging and the slow degradation of subsystems, as well as to provide new capabilities and modes of operation to work around future failures that might otherwise end the science mission. These changes are essential to preserve the future health and safety of HST, the longevity of onboard subsystems, and the high science productivity. Reducing risk of potential spacecraft failures and maximizing science efficiency requires the in-depth knowledge of control modes, software code, failure modes, and specific spacecraft constraints and restrictions unique to HST.

TEXT DELETED. As HST ages and begins to degrade, HST operations and engineering personnel must be thoroughly knowledgeable in all aspects of HST operations and unique systems characteristics and constraints. This knowledge will be essential in sustaining the

HST science mission by responding effectively to system anomalies and to successfully adapt existing processes and procedures to compensate for eventual system shortcomings.

The total cost of the above-listed products and services, to be provided over the 15-month period of performance from July 2026 through September 2027, is estimated at TEXT

DELETED.

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 Federal Acquisition Regulation Part 6 subpart 103-1, “Only one responsible source and no other supplies or services will satisfy agency requirements.”

5. FAR 6.104(a)(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. 3204(a)(1) is LMC’s critical knowledge and expertise to operate the HST spacecraft at maximum science efficiency as described below.

LMC became the prime contractor for HST operations and systems engineering soon after the Observatory launch in 1990. LMC has been responsible for all non-Shuttle aspects of

HST servicing preparation, including development and delivery of pre-launch spacecraft hardware, development and delivery of post-launch spacecraft hardware, hardware integration and test, HST flight operations, ground and flight systems engineering, and ground system and flight software development for the telescope. The full breadth and depth of LMC’s HST-unique knowledge and expertise makes LMC the only contractor capable of sustaining a safe and efficient HST mission operation and responding effectively to changing engineering requirements and priorities. Recreating the knowledge and experience base currently available under the existing contract could only be accomplished through a considerable duplication of costs already incurred by NASA.

LMC, acting by and through Lockheed Martin Space (LMS), alone possesses the unique and critical depth of HST observatory and HST ground system technical knowledge and expertise to concurrently and safely operate HST and effectively adapt to changing mission requirements and priorities to ensure complete and effective utilization of this national science asset. The HST ground system utilizes a unique, LMC-developed software suite rather than a mission-specific adaptation of widely available software (as is often the case with more-recently developed missions). The architecture of HST’s flight software is mission-unique and of 1970’s heritage. A multi-year LMC effort was required to complete the porting of the spacecraft computer’s original software into C-code in 1999, and the LMC team alone has since maintained and expanded this code. Without the intimate knowledge of the HST spacecraft and ground systems possessed by LMC’s critical and experienced personnel, NASA cannot continue to safely and reliably operate and maintain these HST-unique mission systems.

The unique familiarity of the LMC team with HST space and ground assets is an essential key to successfully achieving critical program goals. The LMC team has been HST’s mission contractor for more than 35 years. Some of the team’s members were involved in the original development of HST, and a significant fraction of the team has more than 25 years of experience with HST. The LMC team developed the HST ground and spacecraft operation systems as they exist today, and the LMC team is the only team with experience operating them. LMC has acquired unique experience and extensive knowledge resolving anomalies, developing workarounds, and modifying the procedures, techniques, and approaches used to operate the aging HST. The team’s unparalleled expertise makes LMC uniquely qualified to assess and understand HST subsystem anomalies, recommend actions and expeditiously resume the mission’s science operations. The HST mission architecture is complex, and its operations procedures, ground systems, and flight software are intricate. The subsystem and operations learning curves are steep and climbing them is resource-intensive and time-consuming. The “national asset” nature of the HST mission establishes a very high standard for the safe and correct conduct of operations and for the maintenance of maximum science productivity.

Regardless of available time, another contractor would not be able to approximate LMC’s

HST flight and ground systems expertise in maintaining the HST mission operation with a similar level of safety and efficiency. One example of this is in the area of HST test facility operation and maintenance. The HST project currently utilizes an extensive array of aging, complex, and unique test equipment, simulators, and modeling capabilities that an HST contractor must understand and be able to operate and maintain. A new contractor would need to expend substantial additional time and effort acquiring a minimally sufficient understanding of HST systems and infrastructure. To achieve NASA’s goals during the period covered by this contract, an experienced contractor with current HST-specific expertise in controls, operations, systems engineering, flight software, and related skills is essential.

Only LMC possesses the detailed, unique, HST-specific knowledge needed to assure the most efficient HST operation possible. HST operations, processes, and procedures is highly complex in comparison with newer highly automated satellites. The level of expertise needed to operate HST goes far beyond providing the day-to-day actions of a flight operations team necessary to monitor telemetry, playback science data, and complete command uplinks to

HST computers. The immense importance of the LMC team stems from the irreproducible wealth of experience possessed by the systems engineers who monitor the performance of the instruments and subsystems and can quickly recognize a non-nominal condition or engineering data that is trending abnormally. This expertise extends to the intimate knowledge these engineers have of Observatory performance characteristics, which assists their exploration of new control modes and subsystem management techniques. This further extends to the extensive experience the team has with unique, high-fidelity models of spacecraft and mode performance that they have developed which enable them to tune parameters and refine control algorithms quickly and effectively. The LMC team also includes ground and flight software developers who are intimately and critically familiar with the thousands of lines of code in the flight computers and the six million lines of code in the ground system that the team has written, integrated, revised, upgraded and maintained for many years. All of this knowledge and critical experience contributes to the high productivity and creativity that has sustained HST for more than 35 years. This, in turn, contributes to the unparalleled success of the HST mission and provides a platform from which future work can successfully be conducted. This is what makes continuity so vital to obtain low-risk progress. The experience and understanding gained from past, technologically challenging

HST-specific work are critical to a high-quality science operation, and even more critical to meeting the HST program goals and challenges that lie ahead to achieve maximum observatory life and science operations.

The body of knowledge accumulated by the LMC team during more than 35 years of on-orbit operation clearly demonstrates that LMC is the only known source with the critical experience necessary to assure an HST operation of peak effectiveness. Some examples of the resourcefulness and skill of the LMC team includes the implementation of the HST

Attitude Observer Anomaly (AOA) flight software mitigation and installation of a HST hybrid control mode. The HST AOA flight software mitigation, installed in 2011, extended the useful life of the gyroscopes. The HST hybrid control mode, installed in 2020, utilizes a

3gyro controller for large vehicle maneuvers between targets then transitions to a fine guidance sensor and single gyro controller for science observations. These types of innovations allow the 35-year on-orbit HST spacecraft to achieve maximum science productivity while minimizing disruption of HST science observations.

This development effort required simulations using high fidelity models written by the LMC team and major flight software designed to work with not only the nominal three gyro science mode, but also the One Gyro Science (OGS) mode that was specially developed during the Servicing Mission era to help ensure continued operations between Servicing

Missions, and is essential to the longevity of the mission now that Servicing is complete.

Each new development requires extensive testing of each operational mode available to ensure spacecraft safety. This work and future work could not be done without the team’s expert knowledge of HST system characteristics as observed on-orbit. The high- fidelity models that are essential to development and testing efforts have been modified and enhanced over the years by the LMC Team. The team has unique experience running these models and is the only team capable of generating hundreds of candidate test cases in a short timeframe.

The demonstrated knowledge and experience, which permeates the LMC team, is critical and indispensable to HST mission operations, ground system enhancements, sustaining engineering, flight systems engineering and software development. To maintain these systems and develop new capabilities, both talent and extensive knowledge of HST system designs, capabilities, and limitations is required. The LMC team is uniquely positioned to build on past experiences to devise best-case responses for future system anomalies in a timely manner. The success of future upgrades will rely heavily upon the system knowledge, technical expertise and creativity of the current highly knowledgeable LMC staff. Absent a sole-source award, implementations will be more costly and take longer to design and develop, thereby increasing risk to HST health, safety, and science.

LMC is the only organization with the critical knowledge and expertise to operate the spacecraft at maximum science efficiency. Doing so requires the in-depth knowledge of control modes, software code, failure modes, and specific spacecraft constraints and restrictions unique to HST. Only LMC possesses the HST-unique skill set necessary to maintain the high productivity and low risk postures of the HST mission. The selection of a new contractor team for these development tasks and flight operations would significantly and critically increase the risk of mission failure.

The assumption of operations by a successor contractor could be heavily impacted by loss of vital information from the outgoing contractor. Even the best documentation cannot capture the entire body of knowledge accumulated by LMC HST engineers over more than 35 years of work experience. It is also evident that this vast engineering knowledge cannot all be conveyed to a new contractor during a transition period. This situation could readily allow undocumented shortcomings or unique features of equipment and procedures to escape the attention of the new team, and thus greatly increase the program risk for development and science operations.

Certain current tasks on the contract are understood very well by the contractor’s incumbent employees. Competitors do not possess this knowledge and expertise. Should a competitor take over operations, it would need to ensure exact transfer of current information from the current contractor. Were the competitor not be able to retain incumbent employees through employment capture to a sufficient extent, it would need to duplicate a number of positions for at least a year to ensure correct and complete transfer of information from incumbent employees. This would likely generate several million dollars of duplicative cost to the contractor and the Government.

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 possible, 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 to the Government Point of Entry (GPE) website (Sam.gov) will be published on “TBD”, in accordance with FAR part 5. This posting will inform potential sources of NASA’s intent to award this sole-source modification to LMC. The results of this synopsis will be summarized in Section 10 below.

7. FAR 6.104(a)(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 has determined that the anticipated cost to the government will be fair and reasonable. LMC must be required to submit a proposal that the Government will evaluate and negotiate. Prior to execution of the contractual modification, a proposal analysis will be performed. The proposal analysis will ensure that the final agreed-to price for the contract modification is fair and reasonable. Specifically, LMC’s proposed costs, direct labor rates, direct labor hours, skill mix, other direct costs, indirect costs, and fee(s) will be evaluated to determine fair and reasonableness. This evaluation may also include support from auditing agencies or contracts, as needed. Because this action is an extension of the current contract, the Government will rely upon existing contract data along with auditing agencies.

8. FAR 6.104(a)(8) – Description of the market research conducted, and the results, or a statement of the reason market research was not conducted:

The market research conducted was based on in-depth market knowledge of Senior members of the project’s technical staff to identify and consider other potential sources for this procurement. The scope of HST engineering requirements is to operate and maintain the entire Observatory and ground-based support infrastructure. This demands much greater depth of understanding of HST-unique system characteristics and operating procedures, as well as flight and ground system code. The requirements for HST include daily flight operations and engineering analysis and also includes investigating onboard system anomalies and then designing and implementing effective corrections via procedures and flight software changes. The requirements for HST also requires ground system infrastructure and IT expertise to maintain a mission network enclave. The Contracting

Officer’s Representative (COR) is thoroughly familiar with the capabilities available in the market. The LMC team possesses unique HST spacecraft knowledge and skills to maintain the high productivity and low risk posture of the HST mission. Selection of a new contractor would increase the risk of mission failure. Recreating the knowledge of and experience base currently available under the existing contract could only be accomplished through a considerable duplication of costs already incurred by NASA.

Based on the COR’s knowledge and experience, no other current existing entity can sufficiently meet the entire range of the technical requirements of this procurement to achieve the HST project’s operation and engineering goals in order to maximize the productive scientific life of HST within a challenging budget environment.

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

As the first of NASA’s Great Observatories, the HST has clearly demonstrated the United

States’ leadership in space-based astrophysics and advanced space technologies, inspiring the global public to contemplate and engage with the cosmos in a scientific way. At 35 years of on orbit operations, the HST is still at peak performance in terms of efficiency and instrument performance and calibration, enabling a diverse community of users to open new discovery space via both new observations and archival data-mining activities. HST continues to excel in scientific productivity and remains a key element in the achievement of

NASA’s strategic goals and is continuing to meet the aspirations of the worldwide astronomy community. Hubble has clearly demonstrated the United States’ leadership in space astrophysics and utilization of advanced space technologies.

HST remains a facility that supports a cross-disciplinary, international community with wide-ranging scientific goals and objectives, and boasts the most extensive scientific publication record of any astrophysical initiative. Synergistic use of the telescope to complement other

NASA missions continues to be of great value and contributes significant benefit and return on investment. Over three decades after launch, and rejuvenated multiple times by servicing missions, HST remains the most famous telescope in the world, an icon of American scientific achievement. HST is NASA’s only telescope with ultraviolet imaging and spectroscopy.

HST has been designated a National asset by the Congress of the United States. No unmanned space mission in history has been as much in the public’s conscience worldwide, and no mission has returned as much new knowledge of the universe, or has played such an important role in public education. The importance of HST’s scientific return in the upcoming years cannot, therefore, be underestimated as the project and the Agency seek to operate it concurrently with the James Webb Space Telescope. Future operations will remain as challenging and dependent on the expertise of its operators and systems engineers as they have always been. The need to reduce costs while protecting performance in the face of future anomalies requires the continued availability of the experts that have made the past operation so successful. The HST mission operations and systems engineering objectives are challenging from a technology and cost perspective. Failures or delays in acquiring the products and services required in this contract due to inabilities of a potential new contractor and the subsequent loss of the incumbent’s unique HST expertise would increase the likelihood of non-optimal operations decisions and jeopardize mission success. LMC has the critical skills and the knowledgeable staff required to ensure a safe, full, and productive HST scientific lifetime.

The efficiency of HST operations is currently at or near maximum. Science results and productivity, as measured by publications and citations, remains one of the highest in astrophysics. The major technical obstacles that could compromise the efficiency and science mission operations over the five-year period are likely gyroscope failures and loss of fine- guidance sensor capabilities. The LMC team has taken a proactive stance on mitigating the likely failure modes and degradation in the telescope and instrumentation, which is crucial for maximizing the cumulative scientific impact of the observatory.

The time required to understand the complexities of HST are not typical in comparison with other satellites. HST engineers must understand the original design intent, have knowledge of hardware and software changes made over the past 35 years, and know how the system is operationally used. The Electrical Power System (EPS) is an example where LMC has added numerous charge modes and hardware boxes. Each of these is custom designed for HST. For

HST, all of the original science instruments have been replaced, yet many of the commands and telemetry points retain the names based on the original instruments. LMC understands the history of each science instrument position and the associated restrictions that are based on the characteristics of the predecessor hardware. The LMC team has typically had at least one engineer for each subsystem with over 25 years of HST experience who could provide the history if needed in that area. The anticipated retention rate for a new contractor is significantly lower than might otherwise be expected, and the risk of losing expertise is greater than that normally associated with a change in prime contractor. Introduction of an inexperienced management team and uncertainty in re-capture of critical staff pose a significant risk to continued successful HST operations and achieving mission objectives.

10. FAR 6.104(a)(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 will be synopsized on the GPE website

(Sam.gov) per FAR Part 5. (See Section 6 above). The synopsis will notify interested sources that this requirement will be issued on a sole-source basis and provide them an opportunity to submit their interest and capabilities to the contracting officer within 15 days of the synopsis publication. Responses to the synopsis will be provided in this section.

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:

HST is expected to operate as long as its science productivity is sufficiently cost effective. Future contracts will depend on the continued viability of the observatory, but at a minimum, the final data calibration and closeout period is anticipated to occur beyond this contract’s period of performance

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.