TRAX JOFOC Final.pdf

Rev.:7/2022

NATIONAL AERONAUTICS AND SPACE ADMINISTRATION

Goddard Space Flight Center (GSFC)

JUSTIFICATION FOR OTHER THAN FULL AND OPEN COMPETITION

(JOFOC)

For Goddard Logistics and Technical Information II (GLTI II)

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)/Goddard Space Flight Center

(GSFC).

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

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 contract number 80GSFC17C0010 with TRAX International Corporation for the Goddard Logistics and Technical Information II (GLTI II) contract. The GLTI II contract is a 5.5-year Cost-Plus-Fixed Fee (CPFF) with Technical Performance Incentives contract that supports NASA Goddard Space Flight Center (GSFC), at Greenbelt, MD; Wallops Flight Facility, VA; and NASA Headquarters, Washington, DC locations, including some on-site tenant organizations and near off-site Government and contract locations.

The GLTI II contractor, TRAX International Corporation, provides support for the Center-wide mission responsibilities of the Information and Logistics Management Division (ILMD) by providing logistics support, technical information management and other services to Goddard Space Flight Center (GSFC) at its Greenbelt, MD location, including some on-site tenant organizations and near off- site Government and contract locations. Selected logistics services are also provided to GSFC at its Wallops Island, VA location and NASA Headquarters and occasionally support GSFC at other locations (e.g., the NASA Independent Verification and Validation Facility (IV&V) in WV and the Goddard Institute for Space Studies in NY). Logistic services provided include supply, property management, transportation, packing/crating, mail management and export control. Technical information management services include duplicating, printing, interior design, records management, and creative services.

The contract extension and increase in contract value is necessary to ensure continuity to operations and mission support to avoid significant impacts to NASA’s programs. The work performed under the GLTI II contract was initially going to be rolled into an Agency level contract, the Agency Logistics Support Services (ALSS) contract. However, at the end of March 2022, NASA Headquarters decided that the services that were going to be awarded under the ALSS contract will now go back to the Centers for contract award. Therefore, GSFC has to award their own separate logistics support contract. The extension is necessary to allow time for the development of a follow-on contract. This extension ensures that critical work will continue while the GLTI II follow-on procurement is completed. The GLTI II services and requirements depend on the existing contractor’s in-depth knowledge of GSFC Greenbelt and WFF operations. An interruption and restart of ongoing GLTI II work with a new contractor that is unfamiliar with the existing GSFC Greenbelt and WFF policies, procedures and technical requirements of the services provided would greatly jeopardize the success of the daily operations and mission goals. The proposed extension will provide continuity of performance from February 1, 2023, through July 31, 2023, with 2 option periods (two 3-month options). If GSFC attempts to procure these services through competition for this extension period, several ongoing efforts would be negatively impacted as a result of: 1) delay of the follow-on procurement anticipated award date; 2) time required to transition to a new management team; and 3) delays resulting from a new contractor's efforts to become familiar with new work requirements and systems.

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 Information and Logistics Management Division (ILMD) is responsible for providing logistics services that support Center-wide missions. The logistics services contract procures, packages, transports and provides quality assurance for NASA’s GSFC projects’ critical and sensitive spaceflight hardware, and Electrical, Electronic, and Electromechanical (EEE) parts, as well as, provides ground support equipment, transportation, technical information, records management, graphics, audio/visual, mail services, etc., at Greenbelt, MD, and Wallops Flight Facility, VA. Selected logistics services are also provided to NASA Headquarters, Washington, DC.

The extension of the period of performance will be from February 1, 2023 through July 31, 2023 with 2 option periods (two 3-month options). The current contract value is $361,784,474. The estimated cost for the total extension is $68,278,827, if all options are exercised. The extension is necessary to line up with the Goddard Logistics Services Contract (GLSC) follow-on procurement schedule. Award of GLSC is scheduled for December 2024 with a 30-day phase in period. This extension ensures that critical work will continue while the GLSC procurement is completed.

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) (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. 2304(c)(1), as implemented by FAR 6.302-1, “Only one responsible source and no other supplies or services will satisfy agency requirements.” as 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 unacceptable delays in fulfilling the agency’s requirements.

Logistics services include a high degree of coordination and integration between the various operations of the contract and throughout all phases of a flight project from cradle-to-grave.

For example, during a project’s concept development (Phase A) a preliminary logistics plan is created. The baseline plan is developed during final design (Phase C) and implemented during later project phases. Additionally, the contract operations involve complex regulations (e.g., hazardous materials handling and export control) that have serious consequences if not followed properly. This integration between many functions (e.g., supply, property management, transportation, and packing/crating) involving a high workload of complex operations necessitates that interfaces are simplified whenever possible and that continuity of personnel is maximized. It is essential that TRAX continue to perform the overall management, technical administration and coordination across all support functions and locations to ensure consistent and high-quality support, which is compliant with all laws and regulations.

This contract provides critical logistics services that support both flight project and daily Center operations that cannot be interrupted. Critical services provided include supply, property management, transportation, packing/crating, and export control. These services are highly technical in execution involving complex regulations and stringent quality requirements. One example of this highly technical work is for the flight project Volatiles Investigating Polar Exploration Rover (VIPER) with a launch date in 2024. Services provided include identifying an existing shipping container (a former instrument container) that is a suitable candidate to reutilize for this project. The contractor is refurbishing and reutilizing this equipment that will lead to a significant cost and schedule reduction for the project. Another technical flight project support example is for the Roman Space Telescope (RST) with an expected launch in 2026. The contractor is currently working the engineering design of the new shipping container. This shipping container will interface with the existing Space Telescope Transporter for Air, Road and Sea (STTARS) front and rear running gear to create a complete transporter system. In both the VIPER and RST examples the contractors experience, engineering capabilities, and institutional knowledge of the legacy or new transport system are unique and an invaluable to this process. For both examples, the projects will require instrument transportation between various contractor and NASA sites until launch. Any contractor turnover during this timeframe will negatively impact these project schedules and possibly delay launch. In addition, the contractor is currently working with more than 20 other smaller flight projects and instrument builds with strict schedules and launch dates to procure, receive, store and issue critical flight parts. There are currently 30K line items in storage valued at $91.6M awaiting issue to these supported projects. The storage and issue of these items require a skilled work force that manages an Electrical, Electronic and Electromechanical lab and participates in the counterfeit avoidance plan for the flight projects. Any disruption to this service with a new contractor could negatively impact project schedules. During the extension period of performance, it is estimated that another 7.5K line items valued at $22.7M will be purchased by the contractor for Center flight projects. The current contractor has developed a vendor base that has proven crucial to procuring critical space flight parts in a stressed supply chain environment that a new contractor would not be able to support. Daily Center operation support provided is also crucial. The contractor acts as the receiving and distribution hub for all government and other contractors on site. Expected number of lines per month during the extension is more than 30K. These items are received using kind count and condition criteria and then distributed throughout the Center. As part of the extension process, GSFC will update all terms and conditions to current regulatory requirements.

Authority to proceed with the proposed extension of services and an increase in the contract value would provide a continuity of logistics services unavailable on the open market without a significant learning curve that is time critical.

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 September 16, 2022, in accordance with FAR Subpart 5.2. This posting informed potential sources of NASA’s intent to award this sole-source extension to TRAX International Corporation. 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 Contractor shall be required to submit a proposal to be evaluated and negotiated by the Government. The proposal will contain sufficient information to determine reasonableness of the price prior award. 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 is fair and reasonable. By signature of this document, the Contracting Officer determines that the anticipated cost to the Government will be fair and reasonable. Defense Contract Management Audit Agency support will be requested as needed to evaluate cost data.

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:

Market research was not accomplished because a competition to award a follow-on contract is underway.

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

Conducting a competitive procurement for the continuation of these services would seriously impact current ongoing logistics services activities. Additionally, award to any other source for this interim period would delay NASA’s GSFC vital missions. The services provided under the logistics contract are essential for GSFC to meet its goals and objectives that directly affect mission success.

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 on September 16, 2022 with the closing date of October 3, 2022.

Only one company expressed an interest in writing in response to the synopsis. Bonner Private Security Firm, LLC., submitted a capability statement. The Contracting Officer and the Contracting Officer’s Representative reviewed the submission and agree that the company does not possess the capabilities to do this job. The company’s core competencies are in filing, correspondence, answering phones, legal assistance, security onboarding, travel assistance, security consultation and network security. On October 4, 2022, the Contracting Officer sent an email to the company thanking them for their interest and letting them know that they did not meet the requirements. The Contracting Officer also mentioned that they should follow SAM.gov for any information relating to the follow-on.

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 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. The completion of the follow-on contract is in process.