RPOCV Ceiling Increase JOFOC.pdf

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION (NASA)

Lyndon B. Johnson Space Center (JSC), Houston, Texas

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Rendezvous and Proximity Operations Contract (RPOC) V Contract/80JSC023DA007

1. 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 NASA

JSC.

The procuring agency is NASA, and the contracting activity is JSC.

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 increase the ceiling value of the competitively solicited contract, number 80JSC023DA007, with Odyssey Space Research, L.L.C.

RPOC V is an Indefinite-Delivery, Indefinite Quantity (IDIQ) contract that allows Cost Plus Fixed Fee (CPFF) and Firm Fixed Price task orders awards. The Period of Performance is from February 1, 2023 through January 31, 2028. The current contract ceiling Not-To- Exceed value (NTE) is $48 Million.

Over the past several years, NASA’s workload under RPOC V has grown significantly due to expanding program requirements and the addition of new RPOC support functions. This increased demand has accelerated the rate at which the contract funding is being utilized Based on current spending trends and projected workload, NASA estimates that the contract ceiling will be reached by October 2026, well before the end of the ordering period date, January 31, 2028.

This earlier-than-planned exhaustion of contract capacity reflects the substantial rise in technical integration, engineering analysis, and mission support activities now required across ISS, Orion GNC, Human Landing System, Gateway, and other exploration initiatives.

Because this work is both ongoing and mission‑critical, the current ceiling no longer provides sufficient capacity to meet NASA’s needs through the remainder of the contract period.

To prevent any disruption of the high demand, mission critical RPOC services, and given the time remaining on the current contract, an increase to the RPOC V ceiling by $50M is required, raising the contract ceiling from $48M to $98M to allow for performance to continue through January 2028. An extension of the ordering period is not warranted or sought as the requirement is in the early stages of being reprocured competitively. The

Rev.:4/2026 increase will allow NASA to continue critical engineering support of ISS, Orion, Moon2Mars, Human Landing System (HLS), and Commercial Crew Programs. Without the increase, NASA would face negative schedule, technical, and integration risks to the mission.

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 RPOC V contract provides engineering support services (research, analysis, design, development, integration, verification, test, evaluation, and operations support) supporting GN&C, system engineering, and rendezvous proximity operations, and capture activities.

The scope of the tasks performed under the contract encompasses:

• Program architecture definition, analysis and development

• Entire spacecraft definition and development process including requirements development, concept development, technology development, system design, system and vehicle evaluation

• System and vehicle test, verification, integration and operations support

• Development of analysis tools, including modeling/simulation of space vehicles, vehicle subsystems, dynamics, and environment in a high-fidelity simulation environment

• Development of tools to support command and monitoring analysis including high fidelity graphics and user interfaces ISS RPOC integration support to ensure all cargo vehicles meet requirements for rendezvousing visiting vehicles

• Flight operations support

Programs and projects:

• ISS Rendezvous, Proximity Operations and Capture

• Exploration Systems Development and Space Operations Mission Program support and related exploration Initiatives

• Technology Development, Support, and Research

• Orion Program, Moon Base Program

• HLS Program, and related exploration initiatives

• Lunar/Mars Architecture Team and Pressurized Rover Team in support of JSC

Engineering Directorate’s Project Management and Systems Engineering division

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 United States Code (U. S. C.) 3204(a)(1), as implemented by FAR 6.103-1(c)(2)(ii), “Only one responsible source and no other supplies or services will satisfy agency requirements”.

5. FAR 6.104-1(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 that only one responsible source and no other supplies or services will satisfy Agency requirements.

As permitted under FAR 6.103‑1(c)(2)(ii), this authority may be used when award to any source other than the incumbent would result in unacceptable delays in fulfilling mission requirements. This justification demonstrates that Odyssey Space Research, LLC is the only responsible source immediately capable of providing the highly specialized engineering, modeling, simulation, operations, and spacecraft integration support required to meet NASA’s critical needs under the RPOC‑V contract.

The continuation of these critical services is mission essential due to the highly integrated nature of the rendezvous, proximity operations, GNC, flight operations, systems modeling, architecture development, and spacecraft evaluation. Odyssey personnel are embedded across multiple human‑spaceflight programs (ISS, Orion, Moon Base, HLS, Commercial Crew), and other exploration initiatives, possessing unique knowledge which cannot be rapidly transitioned to new personnel or acquired by any other contractor without introducing significant schedule and integration risk.

Odyssey has developed and maintained specialized modeling, simulation, analysis, and operations‑support capabilities underpinning mission‑critical engineering products for visiting vehicle integration, ISS proximity operations, Orion GNC development, lunar architecture maturation, and exploration mission planning. These capabilities require deep familiarity with spacecraft models, environment representations, subsystem dynamics, sensor behaviors, flight control logic, mission‑specific constraints, and legacy architectures evolved over Constellation, ISS, Moon Base, Artemis, and Commercial Crew engagements.

Significant portions of the modeling and simulation environment incorporate design approaches and integration methods unique to Odyssey’s engineering teams.

Transitioning these functions to another contractor would require extensive reconstruction, redevelopment, requalification, and reverification of models, interfaces, and simulation architecture, causing major delays and disruption to human‑spaceflight program schedules impacting:

• ISS visiting vehicle milestones

• Orion GNC development timelines

• Artemis mission preparations

• Moon Base integration cycles

• HLS readiness activities

Engineering artifacts and simulation baselines interact directly with flight‑critical and safety‑critical design and verification processes; any interruption or contractor transition poses unacceptable mission risk and threatens the continuity of essential services.

Over the years, workload increases have resulted in a realized annual cost growth of 69.3% in FY24, 27.1% in FY25, with a projected increase of 31.8% in FY26. This acceleration, primarily driven by (1) increased work across programs additions, and (2) additions of support functions. The contract burn rate has steadily increased: 12% in FY23, 20% in FY24, 26% in FY25 and a projected 34% in FY26. It is anticipated that the elevated burn rate will continue through the remaining contract period due to ongoing program demands and the contractor’s unique technical expertise which supports critical integration activities. At its current rate, it is estimated that the contract ceiling will be reached by October 2026, well ahead of the January 31, 2028 end date.

Since RPOC‑V award, demand for engineering, analysis, modeling, and operations support has grown significantly across multiple programs. Odyssey personnel currently lead efforts in rendezvous and proximity operations integration, high‑fidelity simulation tool development, spacecraft subsystem modeling, ISS and Orion operations support, architecture definition for Lunar/Mars initiatives, and cross‑program GNC analysis. These work products are intertwined with program baselines, certification processes, and operational readiness requirements. Transitioning these efforts would require lengthy knowledge‑transfer and reverification, delaying deliverables and mission objectives.

NASA has evaluated functions for civil service in‑sourcing. As part of this assessment, the 8% of the contract’s total 64 Work Year Equivalents (WYEs), or 5 WYEs, were approved for Tier 1 in‑sourcing. These roles were identified as suitable for transition while maintaining stability and avoiding operational risk. Additional insourcing would require substantial preparation that cannot be completed before the contract ceiling is reached. Remaining functions will continue under the follow‑on competitive contract. The contractor’s expertise has enabled critical milestones, particularly within Orion GN&C and ISS RPOC, keeping projects on schedule for Artemis II and III, and ensured the safe integration of multiple domestic and international visiting vehicles.

Maintaining the remaining WYEs is essential to sustain mission continuity, meet high-priority exploration objectives, and complete critical milestones while addressing increased internal requirements.

Since RPOC V’s inception, the European Space Agency awarded Low-Earth-Orbit Cargo Return Service contracts to two companies for commercial uncrewed cargo spacecraft, including a docking demonstration mission to the ISS. Increased support under RPOC V cover design oversite and any operations support needed from the ISS RPOC team, ensuring safe rendezvous for all visiting vehicles. Without an increase to the contract ceiling, schedules for H-II Transfer Vehicle-X (HTV-X), Starliner, SpaceX cargo and crew, and

Cygnus vehicle are at risk, along with the astronauts, science, and cargo supported by those vehicles.

Additionally, when the RPOC V contract was initially awarded, only a limited number of programs were utilizing its services. As the contractor has consistently delivered high‑quality work within the existing scope, additional programs, such as the Lunar/Mars Architecture Team and the Pressurized Rover Team, have begun requesting support under that same scope through JSC’s Engineering Directorate for Project Management and Systems Engineering Division. These teams are drawing upon capabilities already included in the contract’s “including but not limited to” provisions of the SOW. As a result, demand for RPOC V support has grown substantially beyond original usage levels, driving the need to increase the contract ceiling to accommodate this higher program demand while maintaining the existing, unchanged scope of work.

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 practicable, including whether a notice was or will be publicized as required by part 5.1 and, if not, which exception under part 5.101 applies:

A notice to the Government-wide Point of Entry (GPE) website (Sam.gov) was published on July 09, 2026, in accordance with FAR Part 5.1. This posting informed potential sources of NASA’s intent to award this sole-source contract modification to Odyssey Space Research, LLC. The results of this synopsis are summarized in Section 10 below.

7. FAR 6.104-1(a)(7) – A determination by the contracting officer that the anticipated cost to the Government will be fair and reasonable:

The Contractor shall continue performing in accordance with the contract, being required to submit a proposal for each Task Order requirement. The contractor’s proposed estimated cost for any subsequent task orders will be evaluated in accordance with FAR 15.404-2. The Government team shall evaluate each proposal to determine if the proposed costs are fair and reasonable prior to its execution. Proposed estimated costs will be analyzed verifying the contractor’s use of the negotiated rates in Section B - Supplies Or Services And Price/Costs of the contract, comparison of historical Task Order cost for similar work, including Technical Evaluators expertise, Contracting Officer Representative into the analysis, and any other pertinent information that available to the Government at the time of evaluating the Contractor’s proposal. The final cost to the Government will be determined by the negotiated task orders under the contract. A Certificate of Current Cost or Pricing Data will be required, as applicable.

The ceiling increase does not modify the contract’s existing rate structure.

8. FAR 6.104-1(a)(8) – Description of the market research conducted, and the results, or a statement of the reason market research was not conducted (e.g., urgent, and compelling requirement):

Market research was conducted by issuing a notice on SAM.gov informing interested parties of the Government’s intent to increase the ceiling value of the RPOC V contract. No responses were received to this notice. Based on the absence of interest from potential sources and due to the prioritization of ensuring continuity of ongoing human spaceflight program activities under RPOC V, no additional market research methods were conducted at this time. Additional market research market research for the long‑term follow‑on requirement is being conducted under the competitive RPOC VI acquisition.

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

None

10. FAR 6.104-1(a)(10) – A listing of the sources, if any, that expressed an interest in the acquisition in writing:

A notice of NASA’s intent to award this sole-source action was synopsized on the GPE website (Sam.gov) per FAR Part 5.2 (See Section 6 above). The notice was posted on July 09, 2026, and closed on July 24, 2026, with no sources expressing an interest in RPOC V.

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:

The purpose of this IDIQ contract ceiling increase is solely for addressing the higher program demands through the completion of the current RPOC V period of performance, which ends January 31, 2028. The increase is required based on a greater volume of the same services already completed and awarded under RPOC V. It does not introduce new requirements, alter the scope, and is only intended to bridge the Agency to the future follow-on competitive procurement entitled RPOC VI.