REDACTED Justification.pdf

CUI//SP-PROCURE//FEDCON

Control Number: HEC-26-0061

JUSTIFICATION AND APPROVAL REVIEW DOCUMENT

RFO Part 12 Justification and Approval for Other than Full and Open Competition

Program/Equipment: This requirement is for Skydio X10 Unmanned Aircraft Systems (UAS), software licenses, and ancillary power accessories in support of the USACE Aviation, Operations, and Airspace Program Office.

Authority: Title 41 United States Code (U.S.C.) §1901 as implemented by Revolutionary Federal Acquisition Regulation (FAR) Overhaul (RFO) 12.201-1, Simplified procedures.

Amount: $233,446.90

Prepared by: Giorgiana Chen Phone: 703-428-7131

Contract Specialist Date: 09/08/2026 Email: Giorgiana.chen@usace.army.mil

Contracting Officer: Douglas E. Pohlman Phone: 703-428-

Contracting Officer Date: 09/08/2026 E-mail:

Technical: Christopher S. Kernan Phone: 938-227-5804

Aviation Program Manager Date: 09/08/2026 E-mail: christopher.s.kernan@usace.army.mil

Requirements: Christopher S. Kernan Phone: 938-227-5804

Aviation Program Manager Date: 09/08/2026 E-mail: christopher.s.kernan@usace.army.mil

Controlled by: Army Controlled by: USACE - CEHEC CUI Category: General Procurement and Acquisition Distribution/Limited Dissemination Control: FEDCON POC: Christopher S. Kernan/ mailto:Giorgiana.chen@usace.army.mil mailto:christopher.s.kernan@usace.army.mil mailto:christopher.s.kernan@usace.army.mil

Center/District Reviews

I have reviewed this justification and find it adequate to support other than full and open competition.

Monique Holmes Office of Small Business Programs Phone: 202-934-1816

Randy Force Business Oversight Branch Team lead Phone: 703-428-6123

Office of Counsel

RFO Part 12 Justification and Approval for Other than Full and Open Competition

1. Requiring Activity: United States Army Corps of Engineers (USACE), Office of Aviation, Operations and Airspace, located at 441 G Street, NW, Washington, DC 20314-1000.

2. Contracting Activity: United States Army Corps of Engineers (USACE), Mission Support Battalion, 7701 Telegraph Road, Alexandria, Virginia 22315.

3. Description of Action: Approval is requested for a firm-fixed price purchase order for Skydio X10 Unmanned Aircraft Systems (UAS), software licenses, and ancillary power accessories in support of the USACE Aviation, Operations and Airspace Program Office.

4. Description of Supplies/Services: The USACE Office of Aviation, Operations and Airspace requires a standardized multirotor quadcopter small Unmanned Aircraft System (sUAs) fleet that accurately represents fielded systems to train new operators on the wide spectrum of USACE drone missions. This includes support for training and mission applications including infrastructure inspection, three-dimensional mapping, environmental modeling, disaster response, and operations in complex or GPS-degraded environments. The required acquisition includes:

• Five (5) Skydio X10 Enterprise Kits with Cellular Data in the VT300-L configuration, including a three-year cellular data service term;

• Five (5) Skydio 3D Scan software licenses for X10 with a twelve-month term;

• Ten (10) Skydio X10 150W batteries;

• Associated controllers, chargers, cases, accessories, software, remote operations services, and connectivity to be included with the kits.

Table#1: Estimated Price Allocation CLIN Description Part # Qty Unit Price Extended

Price 0001 Skydio X10 UAS System DR4ESKTENTVL3Y5G –

Skydio X10 Enterprise Kit with Cellular Data (VT300-L), 3- Year Term

5 $39,590 $197,950

0002 Skydio 3D Scan Software License (1-Year Term / Operational Capability License)

3DSSWDR4 -

Skidi 3D Scan for X10

5 $4,200 $21,000

0003 Skydio 150W Flight Battery (Intelligent Flight Battery for X10 Platform)

DR4ACCBAT - Skydio 150W Battery

10 $370 $3,700

0004 Shipping $796.90 Total Price: $233,446.90

5. Authority Cited: The authority for this justification is Title 41 U.S.C. §1901 as implemented by RFO FAR Part 12.201-1, Simplified procedures.

6. Reason for Authority Cited:

a. Background:

The USACE Aviation Program Office is responsible for conducting UAS Basic Qualification training for USACE military and civilian personnel deploying worldwide in support of civil works, emergency disaster response, infrastructure inspections, and OCONUS military operations.

The current training fleet consists of legacy Skydio X2 UAS platforms. The Skydio X2 is no longer in active production and has been formally replaced by the OEM with the Skydio X10 platform. Furthermore, existing X2 training units have experienced severe wear and tear, rendering portions of the training fleet flight-unworthy and several flight battery units unserviceable.

Skydio, Inc. (CAGE Code: 7F4H7; Unique Entity ID: C3L3B5X1YNL8), is an American autonomous flight hardware and software manufacturer with dedicated domestic manufacturing facilities in the United States. Skydio serves as a domestic provider of cyber-secure, NDAA-compliant small Unmanned Aircraft Systems (sUAS) for the Department of Defense (DoD), the U.S. Army Corps of Engineers (USACE), and interagency federal civil partners as follows:

Short Range Reconnaissance (SRR) Program of Record: Skydio was selected by the U.S. Army for the SRR Tranche 1 program (utilizing the Skydio X2D platform) to provide platoon-level situational awareness.

Defense Innovation Unit (DIU) Blue UAS Cleared: Skydio platforms (including the X2D and the new X10/X10D series) are vetted and cleared under the DIU Blue UAS program, verifying supply-chain integrity, cybersecurity compliance, and exemption from foreign adversarial component prohibitions.

Autonomous Intelligence & AI Flight Controls: Skydio specializes in 360-degree computer-vision navigation, GPS-denied flight navigation, AI-driven obstacle avoidance, and automated 3D infrastructure reconstruction (Skydio 3D Scan).

b. Justification:

The procurement of proprietary Skydio X10 Unmanned Aircraft System is strictly required to fulfills the Government’s minimum operational, safety, technical requirements and statutory mandates for close-proximity civil infrastructure inspections. The Program Office’s minimum need is not met by a generic sUAS with electro-optical and infrared payloads because the needed platform must provide the following:

a. Fleet commonality and training standardization across the USACE Program Office’s training and operational environment;

b. Advanced AI-assisted flight and dense 360-degree obstacle avoidance for safe close-proximity inspection of dams, locks, levees, bridges, and similar structures;

c. Effective operation in GPS-degraded and GPS-denied environments;

d. Radiometric thermal and electro-optical zoom capability suitable for infrastructure inspection;

e. Enterprise connectivity and integrated, repeatable three-dimensional scan and inspection workflow support; and

f. Weather-resistant field suitability, Automatic Dependent Surveillance-Broadcast (Receiver / Inbound) ADS-B In, and operationally relevant communications range. In small UAS (sUAS) operations, ADS-B In provides the remote pilot with direct airspace situational awareness and collision avoidance alerts to deconflict with low-flying crewed aircraft.

Because the X10 architecture incorporates fundamentally updated flight avionics, autonomous navigation engines, and controller interfaces, training pilots on legacy or alternate systems (such as the obsolete Skydio X2) induces negative habit transfer, creates operational latency, and introduces severe risk of pilot error during high-consequence inspections. Standardizing directly on the X10 ensures that student pilots master identical emergency response profiles, autonomous Return-to-Home (RTH) pathing behaviors, and visual-inertial odometry (VIO) failsafe logic under GPS-denied conditions. Furthermore, the X10’s native AI-assisted 3D Scan software provides automated sub-millimeter proximity scanning essential for structural engineering assessments of dams, locks, levees, and disaster zones without third-party software friction. Crucially, the Skydio X10 is fully vetted and compliant with all statutory federal supply chain mandates, including NDAA Section 848 (FY2020), NDAA Section 817 (FY2023), the American Security Drone Act of 2023, and the DoD Defense Innovation Unit (DIU) Blue UAS Cleared List, guaranteeing a verified, secure domestic supply chain free of covered foreign technologies.

Procurement of the brand-name Skydio X10 is required to guarantee strict, verifiable compliance with federal cybersecurity, supply chain integrity, and counter-foreign adversary statutory mandates. The Skydio X10 platform has been engineered, audited, and certified to meet the rigorous standards established under Sections 848 of the FY2020 National Defense Authorization Act (NDAA) and 817 of the FY2023 NDAA, which categorically prohibit the acquisition and operation of unmanned aircraft systems (UAS) containing critical components or sub-assemblies manufactured in covered foreign nations, most notably the People’s Republic of China (PRC). Furthermore, the X10 fully adheres to the federal procurement mandates set forth in the American Security Drone Act (ASDA) of 2023, ensuring all flight avionics, microelectronics, RF communications links, and software control stacks originate exclusively from trusted domestic and allied partners. Formally evaluated and cleared under the Department of Defense (DoD) Defense Innovation Unit (DIU) Blue UAS framework, the Skydio X10 guarantees validated zero-trust firmware security, encrypted telemetry, secure data-at-rest architectures, and complete supply chain transparency.

Deploying non-compliant or unverified commercial alternatives introduces critical vulnerabilities, including data exfiltration risks near critical infrastructure, exposure to remote telemetry interception, and immediate grounding due to statutory non-compliance. Training on legacy or disparate platforms establishes hazardous muscle memory and negative reflex patterns during live structural missions. Divergent emergency logic across mixed fleets leads to pilot spatial disorientation and increases mid-air collision hazards near civil works assets. Incompatible third-party platforms require manual capture geometry, resulting in inconsistent data overlap and extensive post-processing delays. Non-cleared platforms risk foreign supply-chain vulnerabilities, data exfiltration, and immediate operational grounding under federal policy.

Market research and comprehensive flight evaluations of commercial-off-the-shelf (COTS) alternatives (including the Parrot ANAFI USA and Teal 2 / Golden Eagle) demonstrated that only the Skydio X10 provides the proprietary onboard autonomy, navigation resilience, and native workflow integration essential to executing USACE mission requirements without unacceptable operational compromise, safety risk, or substantial cost duplication.

The specific impacts of failing to procure the brand-name Skydio X10 platform are categorized below:

Procuring disparate or legacy platforms deprives flight crews of the X10’s proprietary 360-degree computer-vision neural network and Visual Inertial Odometry (VIO) navigation engine. In GPS-denied environments (e.g., lock chambers, intake towers, and bridge undersides), non-brand alternatives experience spatial disorientation, control latency, and catastrophic positional drift. Furthermore, forcing aircrews to train on alternate or obsolete avionics introduces severe negative habit transfer, distorting pilot reaction time during high-risk failsafe overrides.

The mission mandate to inspect high-hazard civil works (dams, levees, spillways, and bridges) requires native, automated 3D photogrammetric proximity scanning (Skydio 3D Scan).

Alternative platforms lack integrated surface-tracking autonomy, requiring fragmented third-party software and manual flight lines. This results in uneven image overlap, missed sub-millimeter concrete defect detection, and an estimated 40% to 50% increase in on-site data acquisition timelines across operational districts.

The Skydio X10 is formally verified under the DoD Defense Innovation Unit (DIU) Blue UAS framework and complies with the American Security Drone Act (ASDA) of 2023 and NDAA FY20/23 Sections 848/817. Procuring unvetted commercial alternatives risks introducing covered foreign hardware, untrusted firmware, or non-encrypted telemetry pipelines into critical infrastructure airspace, violating statutory bans on covered foreign technologies.

Therefore, the brand-name Skydio X10 is the sole platform capable of satisfying USACE operational, engineering, and statutory mandates.

c. Alternatives:

The Skydio X10 is the recommended small Unmanned Aircraft System (sUAS) platform for civil works and critical infrastructure inspection missions. It provides decisive technical advantages over the Parrot ANAFI USA and Teal 2 / Golden Eagle in autonomy, GPS-denied performance, 3D workflow integration, and fleet commonality as described in Table#2 below.

Table#2: Analysis of Alternatives Evaluation Factor Skydio X10 Parrot ANAFI USA Teal 2 / Golden

Eagle

Fleet commonality / training continuity

Aligns with the Program Office’s standardized fleet approach and training environment

Different interface, workflow, and sustainment model

Different interface, workflow, and sustainment model

AI-assisted flight / obstacle avoidance

Provides advanced AI-assisted flight and dense all-around obstacle

Does not provide the same level of dense all-around obstacle avoidance for

Does not provide the same level of dense all-around obstacle avoidance close structural inspection avoidance for close structural inspection

GPS-degraded / GPS-denied operations

Strong suitability in obstructed and degraded GPS environments

Less suitable for degraded GPS inspection profiles

Less suitable for degraded GPS inspection profiles

3D scan / inspection workflow

Supports integrated, repeatable scan and inspection workflow

More dependent on alternate tools and processes

Less aligned to integrated inspection workflow

Thermal / EO inspection configuration

Best aligns with the full integrated thermal and EO inspection requirement

Partial alignment only

Partial alignment only

Enterprise ecosystem Integrated controller, software, connectivity, and support bundle

Different enterprise ecosystem

Different enterprise ecosystem

Infrastructure inspection training suitability

High suitability for dams, locks, levees, bridges, galleries, and confined areas

Partial suitability with operational compromise

Partial suitability with operational compromise

Skydio X10 maximizes pilot safety and data fidelity in high-risk, GPS-denied environments. The integrated sensor suite and automated 3D modeling workflows drastically reduce operational inspection times while maintaining strict fleet standard operating procedures. It decisively outperforms the Parrot ANAFI USA and Teal 2 / Golden Eagle across all critical mission parameters, specifically in AI-assisted obstacle avoidance, GPS-denied navigation, integrated 3D scan workflows, and alignment with standardized fleet training programs.

While the Parrot ANAFI USA and Teal 2 offer functional sUAS capabilities, their reliance on external software for scan workflows and lack of dense obstacle avoidance introduce unacceptable risk during close-proximity structural inspections around critical USACE infrastructure. Selecting either alternative platform introduces operational compromises:

• Asset loss & safety risk: Lack of dense, all-around obstacle avoidance increases collision hazards around complex steel superstructures and concrete faces.

• Workflow friction: Manual flight profiles and multi-vendor photogrammetry pipelines increase field data-collection times by an estimated 40–50%.

• Fleet fragmentation: Introducing divergent flight control interfaces disrupts training continuity across districts.

7. Efforts to Obtain Competition:

a. Effective competition: In accordance with (IAW) RFO FAR Part 10, market research was performed to determine if sources capable of satisfying the agency’s requirements exist. The brand-name Unmanned Aircraft Systems (UAS), software licenses, and ancillary power accessories are essential to the Government’s requirements, and market research, indicates other companies’ similar products lack the required functionalities and cannot be modified to meet the agency’s needs.

b. Subcontracting competition: The Government was not able to identify any opportunities for subcontracting for this requirement. In addition, the acquisition is below the statutory threshold of requiring the submittal of a formal Small Business Subcontracting Plan for this effort.

8. Actions to Increase Competition: The Program Office conducts market research on an annual basis to stay current. Although the Government is restricting the manufacturer to the Skydio brand to meet its minimum technical and regulatory requirements, competition for this specific procurement is not entirely precluded. To ensure the Government receives fair and reasonable pricing, fair opportunity will be provided to all authorized Skydio resellers.

9. Market Research: In accordance with RFO FAR Part 10, comprehensive market research was executed to ascertain the commercial landscape for the provision of specialized federal-sector legal research services.

UMSB Contracting issued two similar sources sought notices as follows:

1. Sources Sought Notice # W912HQ26S0071 was issued on SAM.gov on 02 September 2026 with a response due date of 9 September 2026.

2. Sources Sought Notice RFI1834759 was issued on GSA Schedule 334220 on 02 September 2026 with a response due date of 9 September 2026.

The Government received x responses as a result of issuing Sources Sought Notice # W912HQ26S0071. The Government received y responses as a result of issuing Sources Sought Notice RFI1834759. The responses were sent to the Program Office for technical evaluation purposes. The outcome of the technical evaluation is included in the table below.

Table#3: Results of Sources Sought Notice Issued on SAM.gov

10. Interested Sources: To date, no other sources have written to express an interest in this acquisition.

11. Other Facts:

a. Procurement history. This is a new requirement.

b. Other Facts: Not available.

12. Technical Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Christopher Kernan Aviation Program Manager

13. Requirements Certification: I certify that the supporting data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

Christopher Kernan Aviation Program Manager

14. Fair and Reasonable Cost Determination: I hereby determine that the anticipated price/cost to the Government for this contract action will be fair and reasonable. This determination will be made using comparison with an Independent Government Estimate and comparison of the proposed price to previous contract history.

Douglas Pohlman Contracting Officer

15. Contracting Officer Certification: I certify that this justification is accurate and complete to the best of my knowledge and belief.

Douglas Pohlman Contracting Officer

Approval

Based on the foregoing justification, I hereby approve the procurement of Skydio X10 Unmanned Aircraft Systems (UAS), software licenses, and ancillary power accessories for $233,446.90 on an other than full and open competition basis pursuant to the authority of 41 U.S. C. 1901 as implemented by RFO FAR 12.201, subject to availability of funds, and provided that the services herein described have otherwise been authorized for acquisition.

Signature: ________________________________Date: _______________ Type Name: ___Douglas Pohlman_______________Title: Contracting Officer