Redacted_EUS.pdf

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA)

GEORGE C. MARSHALL SPACE FLIGHT CENTER (MSFC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

Pursuant to 10 United States Code (U.S.C.) 2304 (c) (1) and Federal Acquisition Regulation

(FAR) 6.302-1

Exploration Upper Stage (EUS)

1. 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 (JOFOC) prepared by the NASA Marshall Space Flight Center (MSFC) in accordance with Federal Acquisition Regulation (FAR) Part 6.3, Other Than Full and Open Competition, and NASA FAR Supplement (NFS) Part 1806.3, Other Than Full and Open Competition.

2. FAR 6.303-2 (b) (2) - Nature and/or description of the action beingapproved:

NASA's current Stages contract with The Boeing Corporation, NNM07AB03C, requires the Design, Development, Test, and Evaluation (DDT&E), production, and operation of the Stages launch system through Artemis 1 and 2. The Stages contract is a hybrid contract that includes Cost-Plus-Award-Fee (CPAF) / Cost-Plus-Incentive-Fee (CPIF) / Firm-Fixed-Price (FFP) / Cost contract line items.

This justification provides rationale for contracting by other than full and open competition for the continued development, testing, production, and evolution of the Stages launch system.

Approval of this JOFOC will allow MSFC to procure production and evolution support for eight Exploration Upper Stages (EUS). The contemplated acquisition of EUS will support the ESD architecture through the finalization of major CS and EUS DDT&E efforts following the first EUS flight, currently manifested as Artemis 4, and transition the program to low-rate initial production (LRIP) for Flights 5-12 (which can be a combination of Artemis and Science missions). Following the first EUS flight, the EUS program will support DDT&E efforts as identified and needed so that new capabilities and functions may be added to the base designs of the CS and EUS to meet mission-specific requirements and/or upgrades; these capabilities and functions will be defined by NASA during the period of performance, but are not intended to fundamentally alter the base design established by major DDT&E efforts. For Flights 5 - 12 the acquisition will also support sustaining engineering, ground, and flight operations.

3. FAR 6.303-2 (b) (3) - A description of the supplies or services required to meet theagency's needs (including the estimated value):

The Space Launch System (SLS) is the vehicle designed to send people and hardware beyond low earth orbit. The vehicle is an element of the overall Exploration Systems Development (ESD) architecture that includes the launch vehicles, spacecraft, mission systems and ground systems needed to embark on a robust human solar system exploration program. SLS Stages consists of a Core Stage (CS), integrated with Government furnished engines, and either an EUS, integrated with Government furnished engines, or an Interim Cryogenic Propulsion Stage (ICPS), which may be integrated with Government furnished engines. Stages also include all necessary hardware, avionics, and software.

This acquisition supports the transition from SLS Block 1 to Block 1B and finally to Block 2.

The initial SLS Block vehicle design, designated SLS Block 1, consists of a CS, ICPS, and two SLS five-segment solid rocket motors (Boosters). The SLS Block 1B configuration has two stages. The "first stage" or boost phase includes one CS and two boosters. One CS consists of a Liquid Oxygen (LOX) and Liquid Hydrogen (LH2) propulsion system integrated with four Government furnished engines, currently RS-25 engines. The vehicle ignites the RS-25 engines seconds before liftoff and then ignites the Boosters at liftoff. The Boosters burn out approximately two minutes into flight, while the RS-25 engines continue to burn until the desired cutoff point is achieved. The boost phase is of identical configuration to Block 1. The second stage is the Exploration Upper Stage (EUS). The EUS performs two functions: 1) following burnout of the Core Stage, the EUS powers the Orion and co-manifested payload to Low Earth Orbit. 2) Following two revolutions around the Earth, the EUS re-ignites the four engines and powers the Orion and co-manifested payload on Trans Lunar Insertion (TLI). The SLS Block 2 configuration is similar to the Block 1B version with the exception of the advanced boosters and common thrust vector control (TVC) system.

Integrated with the CS and EUS is an Avionics System. The Avionics System, along with Government Furnished Equipment (GFE) provided Flight Software, controls the vehicle throughout the mission. The Avionics System consists of the flight controls (flight computers, command and data handling, guidance, navigation & control, and operational flight instrumentation), communications and telemetry system (communications & telemetry controller, radio frequency hardware, engineering flight instrumentation, development flight instrumentation, and motion imagery system), electrical power system and the flight safety system. The Avionics System architecture is a one fault tolerant system for critical functions.

In its most basic form, the EUS consist of structural tanks, dry structure, an Avionics System, a Main Propulsion System (MPS), TVC for the engines, and a reaction control system (RCS). The EUS provides a large volume cryogenic (LOX/LH2) storage and fluid delivery to an engine complement. The EUS is also responsible for providing the Interstage which connects the EUS with the Core Stage. The Interstage is disposed with the Core Stage following Core Stage propellant depletion. There is general functionality and significant commonality between the CS and EUS in sizes, and materials and methods of fabrication. Additionally, the stages contain similar components and utilize similar, if not identical, supply chains.

The estimated value of this action, anticipated to be awarded as a task order under the Stages Procurement and Evolution Contract (SPEC), is FOIA Ex.5.

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) (l), 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 authoritycited:

The rationale supporting use of 10 U.S.C. 2304 (c) (l) is that the Agency's minimum needs can only be satisfied by unique services, which are available from one source with unique capabilities (reference FAR 6.302-l (b) (l)). EUS will require continued development and production of a major system that includes highly specialized equipment and major components.

DDT&E Investment

Boeing, as the incumbent contractor, is responsible for the DDT&E of the highly specialized Stages launch system through Artemis 2 and EUS 1. In this role Boeing has developed exclusive and critical knowledge and capabilities, which uniquely qualifies them to support ongoing DDT&E efforts. With the anticipated overlap between the current contract and EUS, as well as the overlap in production processes to address one flight per year after 2024, Boeing has the distinct expertise as the incumbent DDT&E contractor to ensure that knowledge gained on the current contract is effectively transferred into finalizing DDT&E and shifting the program into LRIP without the introduction of undue risk to crew safety and mission schedules.

NASA and Boeing have made large investments under the Stages DDT&E contract to develop a highly specialized workforce, critical infrastructure, and special tooling to produce materials and components for the CS and EUS. Boeing has established a workforce that is trained and certified to perform Stages-unique processes and operate Stages-unique infrastructure and tooling. They possess unique knowledge and insight into the EUS design, production process, and integration with other ESD systems such as Orion and (Exploration Ground Systems) EGS. The critical infrastructure and special tooling are unique to the 8.4-meter diameter SLS launch vehicle and are necessary to assemble the domes, barrels and large cryogenic LH2 and LOX tanks. In order to leverage manufacturing and production efficiencies, the EUS design incorporates significant commonalities with CS. Since the diameter of both the CS and EUS is 8.4-meters, they will utilize the same tooling and infrastructure already developed and in place.

To accommodate the challenges associated with manufacturing the EUS, critical infrastructure and special tooling are required for performing friction stir welding (FSW) operations at the Michoud Assembly Facility (MAF). The weld tooling is used for welding the rings, domes, barrel sections, tanks, and dry structures. These truly unique tools and equipment require specialized training and experience to operate. Modifications to accommodate EUS-specific lengths and weld land thicknesses have already been accomplished. The major tools are ready for both CS and EUS production now. The major SLS tools include:

Vertical Assembly Center (VAC) Vertical Weld Center (VWC)

Segment Ring Tool (SRT) Enhanced Robotic Weld Tool (ERWT) Circumferential Dome Welding Tool (CDWT) Gore Weld Tool (GWT) Mobile Plug Weld Tool (PWT)

The Government benefits greatly from the design and manufacturing commonalities that have been incorporated into EUS from the beginning. Separating the EUS from the CS would also inherently increase the cost of the remaining stage due to the extent of commonality across all functions, including supply chain. In addition to design and manufacturing commonalities, CS and EUS also benefit from the following common functions:

Quality Configuration Management Data Systems Drawing release systems Factory management Parts storage Receiving Supply Chain Avionics boxes Power Distribution Control Unit (PDCU) Redundant Inertial Navigation Unit (RINU)

The continued development and common production of the CS and EUS by Boeing enables manufacturing efficiencies to be realized since they are similar in overall scope, design, materials, and manufacturing processes. Utilization of common tooling and facilities minimizes both development and production costs. Furthermore, CS and EUS use similar supply chains, so procuring them from Boeing builds upon established streamlined efficiencies and maximizes economies of scale; this is very important given the limited planned flight rate of SLS. Although a source other than Boeing might be able to perform all of the work necessary to support EUS, it is likely that no source other than Boeing can do so in a manner that is not unacceptably disruptive to the launch schedule.

Manufacturing Process Investment

Some drawings and manufacturing processes generated under the current DDT&E contract were developed from Boeing-specific material and process standards. If a source other than Boeing were to be selected for award of EUS, the new contractor would have to rewrite any specification or process that ties back to a Boeing-specific material or process standard into a Government-approved specification or standard. This rewrite could jeopardize the current launch manifest since the new EUS contractor will have to review potentially thousands of documents, rewrite any that tie back to a Boeing standard or process, revalidate with an update that ties to a Government standard or specification, and subsequently perform testing and remapping to replace existing references with the rewritten standard or specification. Since this effort represents work that would only be necessary in the event of selection of an EUS contractor other than Boeing, all costs associated with such a review and remapping would represent substantial duplication of cost to the Government.

Vendor Supply Chain Investment

Boeing has established an extensive supply chain and developed unique expertise, component manufacturing and testing capabilities to meet these requirements. Performance of this supply chain under the current contract has led to the refinement of manufacturing, assembly, integration, and testing processes, thereby improving the reliability and safety of the Stages system. If a new contractor were to utilize alternate sources to those currently performing under the existing contract, additional costs and schedule delays would arise from the time needed to re-compete supplier contracts, establish and complete training of personnel to perform therelated processes, and the need to repeat the numerous design and technical reviews and testing required to achieve a certified design for human-rating with new suppliers. In addition, the use of different vendors and processes than those currently utilized on the Stages contract could introduce undue risk to the reliability and safety of futuremissions.

FAR 6.302-l (a) (2) (ii) (B) - Unacceptable delays in fulfilling the agency's requirements

In December 2017, the President of the United States signed Space Policy Directive-1 to return Americans to the moon and prioritize crewed missions to the lunar surface. "The directive I am signing today will refocus America's space program on human exploration and discovery," said President Trump. "It marks a first step in returning American astronauts tothe Moon for the first time since 1972, for long-term exploration and use. This time, we will not only plant our flag and leave our footprints -- we will establish a foundation for an eventual mission to Mars, and perhaps someday, too many worlds beyond."

The fifth meeting of the National Space Council took place in Huntsville, Alabama on March 26, 2019. Vice President Michael Pence chaired that meeting and issued the following direction, "I'm here, on the President's behalf, to tell the men and women of the Marshall Space Flight Center and the American people that, at the direction of the President of the United States, it is the stated policy of this administration and the United States of America to return American astronauts to the Moon within the next five years."

It is highly likely that award to a source other than Boeing would result in unacceptable delays in fulfilling the policy of the current administration and NASA's requirements. The delay estimates, listed below, are intended to represent the expected schedule impact resulting from a competition and selection of an awardee other than Boeing. The associated schedule loss is a one-time impact assessed to the 5th SLS Flight (Artemis or Science) launch date but would subsequently push all following launch dates to the right. Unacceptable delays in fulfilling the Agency's requirements for SLS would result from the: 1) At least an 18 month delay from conducting a full and open competition based on a completed design; and 2) 15 month delay resulting from significant critical path delays as a result of completing design analysis cycles (DACs) with the existing Orion and SLS elements to ensure load and environments are compatible with the existing designs. The duration is based on historical DACs run on the SLS program. Section 8 lists the types of analyses and models that would be required. Although some of the identified delays would run concurrently and begin prior to the end of the current Stages contract, any schedule loss is unacceptable to NASA per the Presidential directives.

6. FAR 6.303-2 (b) (6) - A description of efforts made to ensure that offers are solicited from as many potential sources as is practicable, including whether a notice was or will be publicized as required by Subpart 5.2 and, if not, which exception under 5.202applies:

A Sources Sought Request for Information (RFI) was posted to the Government Point of Entry (GPE), Federal Business Opportunities (FBO) webpage http://www.fedbizopps.gov (FBO), on October 30, 2017. This notice requested potential sources to express their interest in the SPEC requirements, which would require completion of DDT&E activities and reproduction of the CS and EUS with Government-provided data. In addition, a presolicitation synopsis was published IAW FAR Subpart 5.2 on February 23, 2018. A summary of the results of the two FBO postings, as well as those of an engineering study conducted in 2019, is found below under paragraph 8.

NASA’s ongoing evaluation of market conditions since the 2017 posting reveals that the marketplace has not changed appreciably since that time.

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:

A cost and price analysis will be performed in accordance with FAR 15.404-1(a) (3), Proposal Analysis Techniques, to evaluate the reasonableness of individual cost elements and to verify that the overall price is fair and reasonable. Boeing will submit a proposal that will be evaluated and negotiated by the Government. The proposed cost and price will be compared to an Independent Government Estimate.

8. FAR 6.303-2 (b) (8) - A description of the market research conducted (see Part 10) and the results or a statement of the reason market research was notconducted:

For this acquisition, the Government chose to utilize the approach outlined in FAR 10.002(b) (2) (iii), "Publishing formal requests for information in appropriate technical or scientific journals or business publications." The request for information was posted in the GPE, FBO, on October 30, 2017. This approach was chosen because it is an effective and cost efficient way to present the requirement to industry. Under FAR 5.102(a)(2) "The contracting officer is encouraged, when practicable and cost-effective, to make accessible through the GPE additional information related to a solicitation."

The Government received two responses to the Sources Sought RFI. A review of the two responses identified several barriers to competition and transition risks which would need to be overcome in order to support a competition. Such barriers and risks include transition; access to drawings, analysis, and other details created under the current Stages DDT&E contract; and finalizing DDT&E. These barriers to competition and transition risks, as well as the cost and schedule impacts of mitigating these barriers, were considered by the Government in the assessment of the available sources in the market for meeting the Agency's requirement.

The RFI responses also indicated a need to access all drawings, analysis, and other details created under the current Stages DDT&E contract, including those provided with limited rights to the Government. Unfortunately, there are numerous areas in which limited rights data have been incorporated into the design of the vehicle as a means to leverage cost savings and existing technology possessed by Boeing and its subcontractors. While the Government has the right to reproduce and use this data, the data may not be used for the manufacture of EUS by a new contractor.

In order to fulfill EUS requirements, a potential offeror would need to establish agreements with all suppliers that currently possess the limited rights data or to redesign those areas of the Stages launch system that were developed utilizing limited rights under the current Stages DDT&E contract. While the establishment of agreements between a new potential offeror and every supplier with limited rights on the current contract is conceivable, it would be challenging.

However, the time needed to establish such agreements could reasonably be anticipated to result in an extended phase-in period and potential delay to overall performance on the contract.

Should a new EUS contractor choose to redesign or procure subcomponents from vendors other than those currently performing on the Stages DDT&E contract, that new contractor would be required to perform DDT&E and qualification of the new design. The time necessary to complete DDT&E and qualification of new components could vary significantly, depending on the particular design, but it could be expected to substantially extend the normally anticipated 52 month production time.

Major DDT&E of the EUS will be complete after its first flight. Following completion of the initial major DDT&E activities, the program will support a transition to Block 2 at Flight 9. This transition is not anticipated to have a notable impact on the EUS design or construction. The configuration of the EUS for each flight may vary due to mission-specific kitting.

Based on the Sources Sought RFI responses, NASA posted a presolicitation synopsis to the GPE on February 23, 2018. NASA received two responses for the production and evolution of the Stages launch system. One alternate response for the EUS stage was received from Blue Origin.

The alternate response received appears to recommend the use of a commercial item as an alternate solution for the launch vehicle second stage. In the pre-solicitation synopsis, NASA stated it does not intend to acquire a commercial item using FAR Part 12, nonetheless, when the commercial item was suggested as an alternate solution, NASA analyzed whether the commercial item meets the government’s requirements. The alternate response received was reviewed in Spring 2019 as part of an SLS trade examining potential upper stage/engine configurations that were thought to feasible to meet the 2024 threshold for first launch. The trade examined technical, schedule, risk and cost factors. It was determined that the commercial item does not meet the requirements, that the commercial item cannot be modified to meet the requirements, and that the system requirements cannot be changed to accommodate the commercial item.

The SLS launch vehicle is a precision engineered, highly integrated system. The SLS program has allocated twenty-eight requirements to the EUS covering sizing, performance, command and control methods, and safety standards. Additional requirements are documented in the vehicle management specification including slosh damping, thrust vector control and attitude control and stability. In addition to requirements and functions allocated within the SLS launch vehicle, the EUS has interface requirements it must meet. These interfaces include with EGS and the new Mobile Launcher (ML) 2, the Orion program for functional and communication, the CS, the Universal Stage Adapter, and the RL10 engine. A change in the Upper Stage selection could result in impacts to these existing programs/elements. In fact, changes to diameter or height will immediately impact the ML2 procurement and build. Changes to interfaces represent additional risk to CS, Orion, and EGS. These requirements have been vetted through System Requirements Reviews and the design of the EUS has been reviewed at a Preliminary Design Review (PDR to ensure Stage compliance with the requirements set. A commercial stage would need to meet that requirement set in order for the SLS to perform as intended in the Block 1B configuration. If the commercial stage did not meet one of the intended functions or interfaces, the SLS (or partner program would need to make up that function, lose functionality, or increase risk to safety or mission success.

Information available to the Government through market research and independent research and analysis has indicated that the alternate response cannot meet several second stage performance requirements. Of the 7 EUS requirements analyzed, the following 3 criteria could not bemet:

- 10-mt co-manifested performance requirement.

- Total SLS stack height less than 390 ft to fit Vertical Assembly Building (VAB)door

- End of life acceleration limits on Orion/Service Module

Failure to meet the 10 mT co-manifested performance requirement adds risk that SLS cannot support its intended mission. Failure to meet stack height would result in modifications to the VAB building height and substantial cost and schedule delays. The higher stage thrust would result in an increase to the end of life acceleration of the Orion spacecraft, and a significant impact to the Orion solar array design. Failure to meet the other constraints/requirements results in cost increases outside of the SLS program in order to re-design or modify significant infrastructure.

ESD and SLS program would incur additional costs and schedule risk due to changes in the Design and Analysis Cycles. The alternate solution is a heavier stage with a different length and diameter than EUS. New wind tunnel models, load cycles, and integrated dynamics models would need to be produced and verified. Among the models that would be required to be developed are:

3 DOF Trajectory 6 DOF Trajectory Combined Loads Analysis Guidance, Navigation and Control Analysis Separation Model Aerodynamics model AscentAeroacoustics Vibration Shock Aero-thermal Shared Compartment Venting

These models have been developed for the EUS-based Block 1B. The existing elements and programs would need to evaluate the existing, qualified design against the new loads and environments. Discrepancies would need to be addressed either through additional analysis or re-design of the previously qualified hardware. In the initial development of SLS Block 1B, the detailed design analysis cycle took approximately 15 months and FOIA Ex 5 to allow the design cycle analysis to complete and determine impacts, if any, to the upper stage, other elements, or other programs. Changes to the stage or partner programs would take even longer to implement if necessary, resulting in delay to the next SLS Block 1B flight.

If the alternate upper stage design were selected, the existing interstage design would have to be modified to account for the diameter differences between the core stage and the alternate upper stage design. It was not clear from the presoliciation response whether the alternate solution intended to include that in the offer. If not, then that burden falls to a different supplier that must be determined.

The alternate upper stage design includes two dedicated BE-3U engines LH2/LO2 engines manufactured by Blue Origin. Use of that stage/engine combination would negate the investment made in DDT&E of the RL10 engines plus 1 set of four flight engines already procured for follow on EUS flights.

Potential additional costs are not limited to those defined here. However, these are costs NASA is aware of from its market research and independent research and analysis. When considering the Government's investment to-date in the CS/EUS overall commonality (see section 5), the DDT&E of the current EUS, completed PDR, the investment in RL10s and the investment that would be required to integrate the alternate second stage launch vehicle into the overall SLS launch vehicle, the Government would reasonably expect to incur significant duplication of cost that would not be expected to be recovered through competition and result in unacceptable delays in meeting the Government's requirements.

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

FAR 6.302-l (a) (2) (ii) (A) - Substantial duplication of cost to the Government that is not expected to be recovered through competition:

To date the Government has invested at least FOIA Ex5 in the development and manufacturing offlight hardware for Artemis 1 and 2 Core Stages and the development of EUS 1. Award of a contract to a source other than Boeing, for the work described in section 3, would likely result in substantial duplication of cost to the Government that is not expected to be recovered through competition. Costs not expected to be recovered through competition are related to the DDT&E investment, the manufacturing process investment, and the vendor supply chain investment.

Cumulatively, the duplication of cost described above is estimated to be in excess of FOIA Ex5.

NASA Authorization Act of 2010

The NASA Authorization Act of 2010 directed the Agency to develop, as rapidly as possible, replacement vehicles capable of providing both human and cargo launch capabilities to low- Earth orbit and to destinations beyond low-Earth orbit. The Act directed the Administrator to utilize, to the extent practicable, investments, workforce, industrial base and capabilities from the Space Shuttle Program (SSP), Orion, and Ares I projects for development of the SLS.

Stabilization of the Stages Base Vehicle Design

While the major DDT&E efforts will be completed by Flight 4, the Government anticipates that capability upgrades will be necessary during LRIP to ensure Stage's ability to meet specific mission requirements which have yet to be defined. Some of these upgrades will have a notable impact on the base vehicle design, and integration of the upgraded capabilities will cause evolution of the overall base vehicle design, as opposed to a modular addition to the existing design. It is anticipated that through the LRIP of the Stages launch system the upgrades needed to ensure the vehicle can meet critical mission requirements will be completed and incorporated into the base vehicle design, thereby maturing the design and preparing it for true build-to-print production.

Trained and Certified Workforce

Boeing has established a workforce that is trained and certified to perform Boeing-unique processes, and they possess unique knowledge and insight in the Stages launch system design, production process, and integration with other ESD systems such as Orion and EGS.

In the event a prospective new contractor for EUS were to utilize employees other than those working on the current Stages DDT&E contract during the transition to LRIP, schedule and safety risk would be introduced given the need to train, transfer and recreate knowledge and experience of the Stages launch system. Time would have to be allowed for these employees to become familiar with thousands of highly complex drawings and data that support the production and operations of the launch system.

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

As stated in items 6 and 8, a Sources Sought RFI was posted to the GPE on October 30, 2017.

This notice requested potential sources to express their interest in the SPEC requirements, which would require completion of DDT&E activities and reproduction of the CS and EUS with Government-provided data. Written responses were received from The Boeing Company and Lockheed Martin (LM).

As stated in item 8, a presolicitation synopsis was posted to the GPE on February 23, 2018.

Responses were received from The Boeing Company, LM, and Blue Origin.

11. FAR 6.303-2 (b) (11) - A statement of the 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:

Once major DDT&E activities cease, a consistent, stable, and efficient production process will be established as the program transitions from development to LRIP. This process will enable finalized CS and EUS design drawings and data to be made available to support a future full rate production competition. In addition, this transition will afford NASA the opportunity to obtain the appropriate level of data rights required to effectively compete Stages in the future. NASA may also consider requiring the delivery of detailed supply chain information related to the EUS in order to facilitate future potential offerors' abilities to mitigate cost and schedule risk associated with the establishment of a supply chain for a subsequent acquisition, as well as assess opportunities for licensing arrangements to reduce barriers to competition associated with limited rights data. These activities will contribute to the reduction of any barriers to competition associated with the incumbent's unique and critical knowledge of the Stages launch system, as the design and process data matured under the EUS LRIP can be made available to potential offerors.

12. I hereby certify the facts in this justification and any supporting data used for this justification are accurate and complete to the best of my knowledge.

JULIE

BASSLER

Digitally signed by JULIE

BASSLER

Date: 2019.08.21

08:50:32 -05'00'

8/20/2019 Julie A. Bassler Date Manager, SLS Stages Element Office

I hereby certify that the above justification is complete and accurate to the best of my knowledge and belief. In addition, I hereby determine that the anticipated cost to the Government will be fair and reasonable.

KELLIE

CRAIG

Digitally signed by

KELLIE CRAIG

Date: 2019.08.20 14:37:14 -05'00'

8/20/2019 Kellie D. Craig Date Contracting Officer

Digitally signed by WILLIAM

ROETS

Date: 2019.09.04 07:24:46 -04'00'

WILLIAM ROETS