CMOE JOFOC for Aug 2025 - July 2026.pdf

Rev.:5/2024

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Langley Research Center (LaRC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Center Maintenance, Operations, and Engineering Contract NNL13AA14C

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) Langley Research Center (LaRC).

The procuring agency is the NASA and the contracting activity is LaRC.

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 an extension to Center Maintenance, Operations, and Engineering (CMOE) contract number NNL13AA14C for an additional twelve months, extending the period of period of performance (POP) no later than July 31, 2026.

The current CMOE period of performance is February 1, 2014 through July 31, 2025, inclusive of a 6-month extension previously exercised pursuant to Option to Extend Services (FAR 52.217-8) and previously approved JOFOCs for up to an additional twelve months. It is necessary for LaRC to extend the period of performance to align with anticipated effective date of CMOE II which will absorb the work currently performed under CMOE.

This extension will serve as a short-term bridge to allow for continuation of the specialized maintenance, operations, and engineering services provided under the CMOE until CMOE II contract becomes effective. LaRC intends to divide the 12-month period into a 6-month base period through January 31, 2026, and provide for the ability to extend for an additional 6-months to allow appropriate flexibility.

LaRC does not believe it is reasonable, nor cost effective, to conduct another SEB separate from the ongoing CMOE II procurement to issue a new contract for the existing CMOE requirements. Therefore, LaRC is issuing this JOFOC to extend the current contract to cover the potential gap in services and any unforeseen delays in award of the CMOE II contract and will serve to reduce the administrative burdens of submitting another JOFOC if further delays are incurred. Additionally, market research conducted by the LaRC CMOE II Requirements Development Team (RDT) and CMOE II SEB concluded there is no other existing enterprise contract with the specialized contractor expertise to accomplish the CMOE work.

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):

The CMOE contract was initially a single-award cost-plus-award-fee (CPAF) contract with a base/core and an Indefinite-Delivery Indefinite-Quantity (IDIQ) component to issue task orders (TOs) with Jacobs Technology, Inc. (Jacobs). On September 27, 2024 Jacobs experienced a corporate reorganization and is now known as Amentum Technology, Inc.

(Amentum). Pursuant to FAR clause 52.243-2, both parties agreed on a decision to switch the CMOE contract from CPAF to cost-plus-fixed-fee (CPFF) for Option Year 9 (starting October 1, 2023) and any contract extensions until the awarding of the subject contract’s follow-on contract (CMOE II). The current maximum contract value is $922.2M with a POP end date of July 31, 2025. The CMOE contract provides core support services in the areas of research operations, maintenance, and engineering. These technical services include:

Research facilities operations for highly specialized wind tunnels, laboratories, test stands, instrumentation calibration/repair;

Central utilities operations (e.g., steam, compressed air, electrical power distribution, potable water);

Technology development and administration for Facility Automation Systems (FAS) and

Data Acquisition Systems (DAS);

Research and institutional facility maintenance including preventive maintenance, trouble calls, Reliability Centered Maintenance (RCM), and Integrated Operations Center (IOC) maintenance; and

Facility engineering (e.g., design, construction, configuration management, tactical engineering, pressure system recertification, project management/planning support).

The value of the additional 12-month POP is approximately $95M, increasing the contract value from $922.2M to $1.017B; consisting of $65M for the 12-month extension through July 31, 2026. Also, $30M is included to cover any additional urgent and any unexpected IDIQ task orders necessary to meet LaRC’s mission. Upon approval of the JOFOC, a contract modification will be executed to extend the contract as described in this paragraph.

The proposed extension will allow CMOE to continue providing these specialized support services supporting vital NASA missions until the work can be transitioned to CMOE II.

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. 3204(a) (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. 3204(c)(1) is that the services needed are available only from one responsible source and no other type of service will satisfy the needs of the Agency as described below.

In accordance with FAR 6.302-1(a)(2)(iii), services may be deemed to be available from only the original source in the case of follow-on contracts for the continued provision of highly specialized services when it is likely that award to any other source would result in substantial duplication of cost to the Government that is not expected to be recovered through competition or unacceptable delays in fulfilling the Agency’s requirements.

In considering the diverse and specialized requirements as described in paragraph 3 above, the CMOE prime contractor, Amentum, is the only contractor that can provide uninterrupted services without substantial duplication of effort or costs that would otherwise be incurred if NASA LaRC were to attempt to procure a brand-new contract for these services. The 12-month period will also allow ample time to thoroughly analyze the offerors’ revised proposals in response to Amendment 00006 regarding DEI removal to be compliant with the above referenced EO. The cost of competing, awarding, and administering a brand-new bridge contract would create a substantial duplication of cost to the Government that is not expected to be recovered through competition.

Not being able to extend the CMOE contract up to additional 12 months will result in contract uncertainty. This uncertainty provides high risks with the retention of high-quality workforce under the CMOE contract. It is difficult for the contractor to hire new applicants since potential candidates may be hesitant to accept a position that appears temporary or unstable, especially if there is no guarantee of contract renewal. The workers that are qualified for work in NASA Langley’s state of the art wind tunnels often prioritize long-term job security. A role tied to a soon-ending contract may not meet their expectations, deterring interest. In addition, having small contract extensions coupled with the contract uncertainty is prompting several contractor employees to proactively seek more stable opportunities elsewhere. Replacing skilled workers is expensive, both in terms of hiring costs and loss of institutional knowledge. These risks could be mitigated with a longer contract extension because the longer contract extension will also allow the Government to exercise more complex tasks which are currently sidelined due to the soon-ending contract.

Further, transitioning specialized research operations and institutional facility-related maintenance and engineering support services in an ad-hoc manner and/or twice in a short period would be highly disruptive to current mission workflows. The CMOE contract supports the following LaRC organizations: Center Operations Directorate (COD), Research Directorate (RD), Engineering Directorate (ED), Science Directorate (SD), Safety and Mission Assurance Officer (SMAO), and Research Services Directorate (RSD), along with other NASA Centers and government agencies. Without the extension, the consequences would result in capability gaps and major impacts to LaRC infrastructure and its unique research facilities including:

LaRC is home to several wind tunnels and aeroscience facilities, including the National

Transonic Facility (NTF), Transonic Dynamics Tunnel (TDT), 8-Foot-High Temperature Tunnel (HTT), 14-by 22-Foot Subsonic Tunnel and the Langley Aerothermodynamics Laboratory (LAL). These facilities have a rich history of significant design contributions for many commercial transports, launch vehicles, military aircraft, and spacecraft. They also play a critical role in the development of future aircraft, the Orion Crew Exploration Vehicle, and advanced subsonic, supersonic, and hypersonic vehicles.

City Environment for Range Testing of Autonomous Integrated Navigation (CERTAIN) is an FAA-approved urban environment drone test range that allows researchers to reduce the risk of integrating unmanned aircraft systems into our national airspace.

The Air Traffic Operations Laboratory (ATOL) is used to test technologies to help improve air traffic management.

Scientific missions that collect data on Earth’s atmosphere and answer vital questions about our planet are facilitated through the Aerospace Flight Hardware Assembly and Integration facility, as well as the Flight Research Facility.

The Measurement Systems Laboratory, Building-2104, provides a 175,000-square-feet of world-class facility for research and development (R&D) of new measurement concepts, technologies, and systems. It houses 40 modular labs, including a state-of-the-art laser/lidar and electromagnetics lab.

The Katherine G. Johnson Computational Research Facility, Building-2103, improves data center efficiency and effectiveness by consolidating data centers, server rooms, and personnel into a 40,000-square-foot building.

In addition, the CMOE contract employs a highly specialized workforce that has unique knowledge of LaRC’s research facilities. Due to the age of the facilities, this specialized knowledge is essential for maintenance and particularly when complex repairs are necessary.

Repetitive contract transitions that are not intentionally planned nor offer sufficient time to effectively transition specialized knowledge could result in the loss of key senior technical workers, which would affect the continuity of the mission.

The CMOE II Source Evaluation Board (SEB) is currently implementing a corrective action plan, which NASA initiated resolving the General Accountability Office protest received associated with the contract award. In addition, on January 30, 2025 NASA LaRC issued Amendment 00006 to CMOE II Solicitation 80LARC23R0001, which removed the evaluation sub-factor MGMT 3 - Approach to Advance Diversity, Equity, Inclusion, and Accessibility (DEIA), Exhibit O - DEIA Plan, and the related Exhibit B – Data Requirements Document (DRD) C.29 because of the Executive Order (E.O.) titled, “Initial Rescissions of Harmful Executive Orders and Actions”, which repeals Executive Order 14035, Diversity, Equity, Inclusion and Accessibility in the Federal Workforce” that was signed by the President of the United States of America on January 20, 2025. Therefore, the CMOE II SEB, in addition to addressing the original corrective action, is currently reviewing the offerors’ revised proposals in response to the Amendment 00006.

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 April 28, 2025, in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to award a sole-source extension to Amentum. 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 has determined that the anticipated cost to the Government will be fair and reasonable. Each contract year, the Contractor submits an Annual Service Plan proposal that is based on O&M requirements (core support services) for LaRC. In addition, Amentum submits proposals for all IDIQ tasks. Price and cost analyses, as appropriate, and negotiations will be performed on each proposal to ensure the final agreed-to price for each contract action is fair and reasonable. In addition, LaRC will leverage cost data available from the prior ten years of performance under the CMOE contract to support the Contractor’s cost and pricing for both core support services and IDIQ tasks.

8. FAR 6.303-2(b)(8) – Description of the market research conducted, and the results, or a statement of the reasons market research was not conducted (e.g., urgent, and compelling requirement):

NASA recognizes that market research would produce offerors capable of providing the necessary research operations, maintenance, and engineering support services. However, as discussed in detail in paragraph 5, it is not practical, feasible, or cost effective to conduct a competition at this time to onboard a brand-new contractor, and satisfactorily ensure performance of a bridge contract without great risk of disruption or degradation of the mission. The costs and disruptions are greatly exacerbated since the follow-on CMOE II contract will absorb these requirements pursuant to the CMOE II procurement strategy.

Additionally, extensive market research was conducted by the LaRC CMOE II RDT and it determined that none of the existing or forecasted General Services Administration (GSA) schedule offerings or the contracts listed on the Acquisition Gateway are suitable to fulfill the requirements of the CMOE because a portion of the agency’s requirements fall outside the scope of the existing Best-in-Class (BIC) or other Government-wide contracts. In addition, the CMOE contract provides LARC the ability to demonstrate that highly specialized operational, laboratory, test and research facilities support critical mission operations, mission objectives and milestones such as space flight, flight hardware assembly and test analysis in support of NASA and partner missions. Given the specialized scope, mission urgency, and the need for tight integration of critical utility infrastructure, test equipment, industrial control systems, and building automation systems with NASA-managed systems, retaining the contract and contract administration within NASA ensures continuity, technical oversight, and cost efficiency. Transitioning the contract and contract administration to another government agency (i.e., GSA) would introduce delays, increase coordination complexity, and risk misalignment with critical milestones tied to numerous wind tunnel tests and mission support of the administration’s objectives.

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

None. The requirements of FAR 6.303-2(b)(9)(iii) are detailed in paragraph 5 above.

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 provided instructions for how interested organizations can submit their capabilities and qualifications to perform the required effort. The synopsis was posted on April 28, 2025, for at least a fifteen-day duration, with a response due date of May 13, 2025. No capabilities and qualifications response statements were received from industry for this CMOE Extension.

The synopsis notice of intent was not a request for competitive proposals, and a determination by the Government not to compete the subject procurement action on a full and open competition basis, based upon responses to the notice, was solely within the discretion of the Government.

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:

Following the transition of the work being conducted under CMOE to the CMOE II contract, NASA will continue to examine the market in the future for alternative solutions or new sources before executing any subsequent acquisitions for the same requirements.

CMOE

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.

Benjamin J. Curtis Technical Representative

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

Daphne G. Darden Contracting Officer

CONCURRENCES:

Jeffrey N. Davenport Office of the General Counsel Langley Research Center

Teresa M. Hass Competition Advocate Langley Research Center

APPROVAL:

Todd J. Pospisil Director, Office of Procurement NASA Research Center

Benjamin Curtis

Digitally signed by Benjamin Curtis Date: 2025.05.23 16:00:45 -04'00'

DAPHNE

DARDEN

Digitally signed by DAPHNE

DARDEN

Date: 2025.05.23 16:06:52 -04'00'

Jeffrey Davenport

Digitally signed by Jeffrey Davenport Date: 2025.05.27 08:31:36 -04'00'

TODD

POSPISIL

Digitally signed by TODD

POSPISIL

Date: 2025.05.27 10:08:34 -04'00'

Teresa Hass Digitally signed by Teresa Hass Date: 2025.05.27 14:55:26 -04'00'