SBIRS Low

Space Based Infrared Systems (SBIRS) Organizational Conflict of
Interest (OCI)

Mitigation Plan for SBIRS Low Component Program

The purpose of the SBIRS OCI Mitigation Plan is to outline the actions the
government will establish and implement in the SBIRS High Component Program to
ensure objectivity and best value for the SBIRS Low Component Program. The SBIRS
OCI Mitigation Plan identifies procedures and processes to ensure fair
competition, protect proprietary data, and mitigate potential SBIRS High
Component Program Contractor bias or unfair advantages.

Lockheed Martin Missiles & Space (LMMS), the SBIRS High Component
Contractor, is responsible for two roles under Total System Performance
Responsibility (TSPR), 1) SBIRS High and 2) SBIRS System-of-Systems (SoS). SBIRS
High responsibilities include the GEO space segment, HEO sensors and
consolidated ground segment. SBIRS SoS responsibilities includes maintaining ORD
requirements flowdown to High/Low components, verification of combined High/Low
systems performance and defining external system interface requirements. Based
on a review of Federal Acquisition Regulation (FAR) Part 9.505-1 "Providing
systems engineering and technical direction", Part 9.505-3 "Providing technical
evaluation or advisory and assistance services", and FAR 9.505-4 "Obtaining
access to proprietary information", potential OCI issues only concern LMMS’s SoS
responsibilities. Therefore, the focus of this plan is on LMMS’s role as the SoS
Contractor.

FIREWALLS: Firewalls will preclude LMMS from unfairly influencing the
SBIRS Low competition by separating LMMS SBIRS SoS and designated High team
members from all potential SBIRS Low competitors, including the LMMS SBIRS Low
team. Firewalls will be maintained until SBIRS Low EMD contract award (see
figure below).

Actions associated with the firewalls include:

1) SBIRS SoS and designated High Team members will be restricted from
participating on or supporting the LMMS SBIRS Low Team.

2) SBIRS SoS and designated High Team members will be physically separated
from and share no resources with the LMMS SBIRS Low Team, except as identified
to the Government.

3) SBIRS SoS and designated High Team members will disclose SoS or SBIRS Low
competition sensitive or proprietary information only to the Government.

4) SBIRS SoS and designated High Team members, includingas well as any
consultants and subcontractors supporting SoS activities, will sign personal
non-disclosure statements , making them personally liable for disclosure of SoS,
competition sensitive, or proprietary information or products to any persons who
are not Government personnel, Government support contractors, or SBIRS SoS or
designated High Team members with a need to know.potential SBIRS Low
competitor.

5) SBIRS SoS and High Teams will be trained on protection requirements in
accordance with FAR 9.5, Organizational Conflicts of Interest.

PROCEDURES: Additional procedures and processes will mitigate
potential LMMS bias or unfair advantages.

These actions include the following:

1) The Government will establish an open access library. The LMMS SBIRS Low
Team will have access to SoS and High data, models, and software only through
the same processes as all other SBIRS Low competitors.

2) SBIRS Low qualified competitors will be invited to participate in
non-proprietaryopen sessions of the SBIRS High system-level design reviewsPDR
and CDR, Ground Segment majorIncrement 1 Final Ddesign Rreviews, and
Low-Component-to-High-ComponentHigh/Low Interface Control Worrking Group
meetings. The purpose of the Low-Component-to-High-Component ICWG is to define
the interface between the High and Low components and to provide timely exchange
of information between the SBIR High contractor and qualified potential SBIR Low
contractors about the SBIRS Ground Segment design and CONOPS.

3) In preparation for Pre-EMD and EMD, SBIRS Low qualified competitors will
be invited to review the Requirements Allocation Document (RAD), the Low
Component Cost Analysis Requirements Description (CARD), and Interface Control
Documents (ICDs). This process assists the Government in determining
affordability and performance goals for pre-EMD. As an example, the figure below
depicts the CARD review process.

4) Quarterly SBIRS Low Industry Forums will be held to provide qualified
potential SBIRS Low competitors information about the SBIRS Low program. Answers
to questions the government chooses to answer will be provided in writing to all
qualified potential Low competitors. Forums will include presentations by the
SoS contractor on the current status, data, and decision rationale on SBIR
High/Low architectures, trades, and requirements. During Industry Forums, SBIR
Low competitors may present to the Government proprietary and competition
sensitive data on their technical approaches, comments on the EMD acquisition
strategy, and comments on the driving requirements and their impacts.

5) An Independent Review Team (IRT) will be established to review perceived
or actual OCI as requested by industry and will be convened as needed by SMC/MT.
The IRT will assess the merits of the issue and define alternatives when
appropriate.

6) The SBIRS Testbed models will be provided to the SBIRS Low Pre-EMD
contractors on an equal basis. mpetitors, except for pProprietary models will
not be provided. Selected SBIR Low personnel, who have signed non-disclosure
agreements, will have access to the proprietary models at LMMS. LMMS will
provide reasonable technical support to each Low contractor while in the LMMS
facility to facilitate understanding and operation of the models. LMMS will not
provide technical support outside their facility nor provide testbed users’
manuals or technical support.

7) LMMS SoS involvement in the SBIRS Low EMD proposal process will be
restricted to operating the SBIRS SoS Testbed for the sufficiency review of Low
competitors’ High/Low performance against threshold requirements. During
Pre-EMD, the testbed operators will interact with all Low competitors to
accurately model their approach and will be separated from the remainder of the
LMMS SoS/High teams and will interact with all Low competitors to: a) accurately
model their approach and b) assist Low competitors in understanding and
operating the models. SoS involvement in the EMD proposal process will terminate
at Call For Improvements (CFI) proposal receipt. (see figure below)

8) The SBIRS High EMD contract will incorporate the "Avoidance of
Organizational Conflict of Interest (OCI) Regarding the SBIRS Low Component
Program" contract clause, requiring the "Plan for Avoidance of Organizational
Conflict of Interest (OCI) Regarding the SBIRS Low Component ProgramEnsuring
Fair and Open Competition for the SBIRS Low Component Acquisition" to be
contractually binding.

9) The Government will promptly inform the affected SBIRS Low
competitorcontractor(s) of all violations breaches of this pPlan, as defined in
8) above.

Approved by: _________/s/__________________ 27 Jun 97

JEFFERY A. QUIRK, Col, USAF Date

Deputy Program Director

Space Based Infrared Systems