SACOM JOFOC.pdf

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

John C. Stennis Space Center/SSC

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION (JOFOC)

For Synergy-Achieving Consolidated Operations and Maintenance

(SACOM), NNS15AA01C

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): John C. Stennis Space Center (SSC).

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

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 additional Indefinite Delivery and Indefinite Quantity (IDIQ) value to NNS15AA01C with Syncom Space Services (S3) up to $300 million. The purpose of this request is to provide on-going facility and test operations for mission-critical requirements and ensure continuity of operations for SSC, Michoud Assembly Facility (MAF) and NASA as a whole.

In 2016, NASA selected S3to provide facility services at SSC, Mississippi and Marshall Space Flight Center’s (MSFC) MAF, Louisiana. Under SACOM, S3 provides facility services to both locations, SSC and MAF. S3 is responsible for providing all services, equipment and supplies, except as provided as Government Property, to implement the SACOM Performance Work Statement (PWS).

The SACOM PWS consists of Core Service Operations and IDIQ requirements spread among the following work elements: Contract Management, Logistics, Safety, Health and Environmental, Engineering, Manufacturing Support Services and Test Operations, Site Services, Facility Operations and Maintenance Services. The contract type is a performance-based, hybrid contract that includes Cost-Plus-Incentive-Fee (CPIF), Firm-Fixed-Price (FFP), Indefinite Delivery/Indefinite Quantity (IDIQ), with Award Term Options.

NASA may issue IDIQ task orders under the SACOM Contract on behalf of NASA, other Federal, State, and Commercial Tenants or non-Commercial Tenants. At the time of award, a Not to Exceed (NTE) dollar value was established for the IDIQ portion of the contract of $702M for the full potential period of performance of nine (9) years and five (5) months.

In the interest of schedule, economy, and efficiency the additional IDIQ value is needed to further develop, fulfill and enhance the future of NASA. This justification provides the rationale for contracting by other than full and open competition to S3 for continued support and enhancements of NASA’s mission.

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):

SACOM Overview The SACOM contract provides consolidated facility operations and maintenance services for institutional and technical facilities and provides test and manufacturing support services at NASA’s SSC and MAF. The SACOM scope consists of Core Service Operations and IDIQ requirements spread among the following work elements: Contract Management; Logistics; Safety, Health, and Environmental; Engineering, Manufacturing Support Services and Test Operations; Site Services;

and Facility Operations and Maintenance Services. The most significant IDIQ cost drivers have occurred in Engineering and Manufacturing Support Services. These activities have included:

Technology Development; Construction Support; Testing Services and Support; and Manufacturing and Fabrication Support. Unplanned maintenance to critical facilities has also driven new task orders.

The contract is reaching the end of Contract Year 6 of a 9-year, 5-month contract. Contract requirements forthcoming in Contract Year 7 through the end of the contract are anticipated at a similar rate as the past six years in support of SSC/MAF and NASA as a whole.

Artemis Program

During the Artemis program, NASA will land the first woman and first person of color on the Moon, using innovative technologies to explore more of the lunar surface than ever before. We will collaborate with our commercial and international partners and establish sustainable exploration for the first time. Then, we will use what we learn on and around the Moon to take the next giant leap – sending astronauts to Mars.

Both SSC and MAF play mission critical roles in supporting Artemis, namely in the manufacturing and testing of the SLS Core Stage, Exploration Upper Stage, and the engines that power those stages.

Since contract award, NASA has refined its Artemis schedule, and set more ambitious targets for production, testing, and launch. This national effort has been supported directly by SACOM. A more ambitious timeline has condensed the work to be performed and increased the government’s need in value of the contract’s IDIQ offerings.

In support of Core Stage Green Run Testing on the B2 Test Stand, SACOM has provided: test operations support, mechanical construction, mechanical and electrical on demand services, activation and stand-by support, and mechanical design and electrical research and development.

The amount of obligated dollars in support of the B2 Test Stand through the SACOM contract was approximately $61M. NASA anticipates similar requirements as we move forward with testing the Exploration Upper Stage, part of the SLS Block 1B configuration, designed to send larger cargos to the moon starting with the launch of Artemis III.

SACOM has also provided critical facility risk mitigation to the A-1 test stand in support of the RS- 25 engine. The RS-25 engine is one of the most tested rocket engine systems in history, with more than 3,000 starts and more than 1 million seconds of total firing time. The tests planned at present and in the future have pushed the envelope of previous history with more complex test requirements, higher power levels and simulation of new vehicle requirements. This project expects to experience unforeseen challenges that are typical to all complex propulsion test environments, as has been demonstrated during execution of the previous task orders. Presently, the SLS program has 16 flight engines and 2 development engines available for adaptation to SLS requirements in support of the first four flights. Similar IDIQ support is anticipated over the life of the SACOM contract; to date, ~$67M has been obligated on the SACOM contract to support this effort.

SACOM support has also been critical to SLS production at MAF, of which $164M has been awarded via SACOM task orders to support this mission. SACOM has provided numerous factory modifications for SLS Core stage and EUS production. This includes the procurement and manufacture of very specialized space hardware tooling and assembly areas to support the current Core Stage and EUS production schedules. SACOM has also supported: Marine Transportation and Handling; provided Facility Critical Systems Support; Pathfinder Vehicle Storage, Training and Transportation; Systems Support in Non-Core Hours; and provided essential Tug Services necessary to move the Core Stage from New Orleans to its launch site at Kennedy Space Center. As the Artemis Program advances and additional SLS Core Stages are produced, NASA anticipates similar IDIQ support will be necessary.

Weather

A significant cost driver leading to a necessary increase in IDIQ contract value has been inclement weather occurring along the Gulf Coast. In February 2017, MAF facilities experienced an EF-3 tornado. The west side of Building 110, the Vertical Assembly Building, was severely damaged.

Severe tornado damage also occurred on Buildings 103, 303, 114, 130, 131, 350, as well as the South Pipe Rack and other miscellaneous infrastructure. Further damage occurred in 2020 when Hurricane Zeta, one of six hurricanes in the Gulf that season, passed near MAF. A fan house from Building 114 was damaged and damaged the roof on Building 103 during that storm. Building 114 also suffered roof damage. All these weather-related incidents, as well as several smaller task orders at both locations, have increased IDIQ work. SACOM has been essential in executing rapid repair to mission critical facilities that have enabled minimal schedule impact. Given the uncertainty of future weather disturbances, NASA is planning to account for the potential of future rapid repair requirements resulting from tropical disturbances. To date, $115M has been spent on weather-related projects on the SACOM contract.

COVID-19

Another cost driver has been the unprecedented COVID-19 pandemic. NASA Safe at Work protocols have and continue to be implemented across all facilities. These protocols have driven an unplanned increase in labor cost, as premium pay is prescribed in various stages of SSC and MAF pandemic planning. Time lost due to employee illness and quarantine protocols have also presented schedule and cost challenges. Given the uncertainty of infection and vaccination rates moving forward, NASA is planning to account for the potential of increased labor costs on IDIQ requirements in future years of the SACOM contract. Weather and safety leave totals per year of the contract have been an impact of $15M in total, of which ~$5M has impacted our task order value and with the increasing COVID cases, NASA anticipates a similar trend over the remainder of the contract.

Conducting the scope of work on the SACOM contract, while staying on schedule and within budget, requires an experienced support contractor with a sophisticated understanding of the test stands, labs, facilities, systems, processes and the unique requirements that SSC and MAF possess and an understanding of how to adequately solve problems that arise with aging, technical infrastructure.

The intent of the contracts nine year, five month potential period of performance was to: allow SSC and MAF maximum potential to realize efficiencies and synergies; provide opportunity for offerors to compete for a larger, more desirable contract; realize a reduced fee due to the length of the contract period; and incentive contractor performance through the use of multiple award term options.

The period of performance was initially justified as it provided: Continuity for long-term strategic planning/execution; built expertise/judgment through site-specific applied understanding of relationship between facility design, maintenance and operations; allowed time to implement and realize savings from the consolidations; enhanced ability to attract, hire, retain, and train/develop highly skilled workforce. The long period of performance incentivized ownership/stewardship of facilities; supported capital investments (e.g., innovations, upgrades to business systems) to enhance performance and maximize cost effectiveness/efficiency; and has yielded lower costs. The experience developed thus far has also allowed for implementation of process improvements (policies and procedures) and helped strengthen local partnerships with industry (strategic sourcing) and fostered effective Government/Contractor integrated teaming. S3 has the unique capability to leverage existing experience to best meet the intent of the initial award in these areas. Moving to a new provider would jeopardize these objectives.

The SACOM contract will exceed the savings associated with contract consolidation predicted in the initial justification. As of Contract Year 6, contract savings are estimated to reach $130M, the predicted savings value after ten (10) contract years. If this trend continues, a savings of over $200M will be realized.

S3 has unique knowledge of SSC and MAF facilities, systems, and processes and has helped NASA design and construct the procedures necessary to meet aggressive Artemis milestones. Planning and executing an alternative source at this stage of the Artemis Program, would jeopardize schedule, safety and budget. NASA would certainly experience duplication in cost as new providers worked to learn/develop the experience, systems, and processes. SLS production and testing is dependent upon the operational support at both locations.

The remaining contract duration is ~three (3) years, six (6) months. Each task order will define the duration/period of performance separately. The time stated for completion shall include acceptance of all deliverables required in each individual task order issued under this Contract. (Commencement, Implementation, and Completion of Work for all task orders under this contract will be specified for each task order by date or in calendar days.)

The estimated total additional contract value needed is $300 million.

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 10 U. S. C. 2304(c)(1) as implemented by FAR 6.302-1(a)(2)(iii)(A), which enables the use of other than full and open competition procedures in cases when the supplies or services required are deemed to be available from only one or a limited number of responsible source(s) and no other supplies or services will satisfy agency requirements. Supplies/Services may be deemed to be available only from the original source for the continued development and production of a major system or highly specialized equipment, including major components thereof, 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.

5. FAR 6.303-2(b)(5) – A demonstration that the proposed contractor’s unique qualifications or the nature of the acquisition requires use of the authority cited:

The rationale supporting the use of 10 U.S.C. 2304(c)(1) as implemented by FAR 6.302-1 Only one responsible source and no other supplies or service will satisfy agency requirements is described below.

In accordance with FAR 6.302-1 (a)(2)(iii), for DOD, NASA, and the Coast Guard, services may be deemed to be available only from 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. For the reasons set forth below, S3 is the only responsible source that can reasonably satisfy the forthcoming requirements during this contract’s period of performance.

Utilization of any other contractor for work supported by the IDIQ component of SACOM outside of the existing SACOM contractor would result in inefficient and costly duplication of services and costs, as NASA would have to maintain two government interfaces with two separate management teams, separate and distinct contractor procedures, financial systems, emergency response functions, etc. This significant duplication over the interim period would be more costly and complex to manage and could hinder the continuity of operations, safety, and security of NASA and resident agencies during the transition. The duplication of effort would also jeopardize Artemis milestones. Had production and launch schedules been solidified at the time of contract award, weather and health challenges better understood, additional contract value would have been included.

If additional value is not granted to add to S3’s contract for future IDIQ work, NASA would be at a standstill as we would be limited to only Core work which negates the IDIQ mechanism allowed to accomplish other non-definitive scope for future requirements.

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 (beta.sam.gov) was published during the original award timeframe in 2014, in accordance with FAR Subpart 5.2. The posting was to perform market research for potential offers. The synopsis, market research, and proposal evaluation lead to the selection of S3 for the resultant contract. Procuring theses services from another firm, other than

S3, will likely result in substantial duplication of engineering, facilities support, cost and conflicts of interest if two companies were working to provide the same services at the same time. The Core portion of the contract is currently with S3 and if a task order is awarded to another contractor, it would cause friction within the processes and procedures.

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. The Contractor shall be required to submit a proposal for every new and revised task order and will be evaluated and negotiated by the Government. Prior to execution of the contractual instrument, a proposal analysis will be performed. The proposal analysis will ensure that the final agreed-to price for the contract action includes the agreed upon rates and will rely on cost/price analysis techniques as well as cost/pricing data are in line, fair, and reasonable.

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

No market research was conducted. It is in the best interest of the Government to utilize S3 for continued IDIQ requirements as S3 was determined to be the Successful Offeror to perform SACOM services. Please also see Section 5 above and Section 9 below for further justification of utilizing S3.

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

To date, ~$650 million of task order work has been awarded to S3 under this contract for similar work scope that is anticipated to be awarded in the future of this contract of which they have performed in an exceptional manner. S3 is familiar with the work scope, have worked through many obstacles and mastered the skills needed for the unique set of requirements for NASA and its customers.

SSC and MAF facilities and systems are unique and complex. As a result, there is a significant learning curve (time and effort) required to gain basic proficiency. Many of the task orders are on-going support to facilities and testing operations, where historical knowledge decreases cost and mitigates risk. Furthermore, successfully meeting these IDIQ requirements requires synergies with core services. Most significantly, S3 upgraded and consolidated the two locations instances of Maximo. Operations in both core and IDIQ support require understanding of the system. They also implemented a comprehensive approach for Logistics and Property Management, including a “just in time” delivery of supplies and parts; they established a Supplier E-mail of pre-approved supplies;

and a tailored Maximo inventory module to control and account for Government property. This approach uses a vehicle staging approach, delivering supplies to SSC and conducting a route delivery to customer locations, thereby consolidating the warehouse storage into a single warehouse at MAF.

An outside provider would have to duplicate these capabilities.

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

Not applicable.

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:

The current contract period of performance expires in 2025. NASA, at the Agency-level, has determined that future procurements involving facilities support will be procured through various Product Service Line contract mechanisms.

GERALD

NORRIS

Digitally signed by

GERALD NORRIS

Date: 2021.09.29 13:20:24 -05'00'

Digitally signed by MARY

MARY BYRD BYRD

Date: 2021.09.29

14:43:01 -05'00'

MICHAEL

TUBBS

Digitally signed by

MICHAEL TUBBS

Date: 2021.09.29 12:55:21 -05'00'

Synergy-Achieving Consolidated Operations and Maintenance

(SACOM), NNS15AA01C

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

SIGNATURE PAGE

I certify that the facts presented in this justification are accurate and complete.

Michael Tubbs Technical Representative

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

Adrianne Ragan Contracting Officer

CONCURRENCE:

Gerald Norris Procurement Officer

CONCURRENCE:

Mary Byrd Center Competition Advocate

CONCURRENCE:

William Roets Agency Competition Advocate

APPROVAL:

Karla Smith Jackson Senior Procurement Executive

ADRIANNE

RAGAN

Digitally signed by

ADRIANNE RAGAN

Date: 2021.09.29 12:57:55 -05'00'