SweetSense Inc holds a complete NSF SBIR sequence in its own name: Phase I award 1621444 ($224,562, July 2016 to July 2017) and Phase II award 1738321 ($1,313,725, September 2017 to October 2021), both titled Predictive Algorithms for Water Point Failure. UEI M9YULLTP4PH8.
That sequence carries SBIR Phase III authority under 15 U.S.C. 638(r). Any federal agency, including any DoD component, may award a sole-source contract for technology derived from that work, with no dollar ceiling, no time limit, and no justification and approval document. The competition NSF ran in 2016 and 2017 satisfies the competition requirement permanently.
This is the center of the strategy. Every other activity exists to create a sponsor who wants to use that authority.
| Organization | Status, 10 November 2026 |
|---|---|
| AFRL, 711 HPW | Formal testing of the unit received in May. One unit bought at $5,000 through a support contractor, so no contract history in our name. The 711 HPW risk management framework approval allows only a unit with no cellular radio and no GPS, wired to a standalone computer. A trial run this week precedes larger experiments next week. CRADA with Dr. Richard Agans: no email traffic since 6 October. |
| DEVCOM Soldier Center (Eric Brack) | CRADA signed by Virridy 21 October, at the Base Director for final signature. Two units shipped to Natick 22 October. Brack is sponsoring a sequential SBIR Phase II, about $2M over 24 months, focused on field testing with the 25th Infantry Division plus food-contact surfaces. The topic form and transition roadmap are drafted. The cross-agency route needs a written determination from both the Army and NSF. |
| 25th Infantry Division | Bailment signed 7 October, units shipped 8 October, training 16 October. Live data at thelume.ai/army. |
| NAVFAC EXWC, Port Hueneme | Call 21 October. We offered a loan unit and the Phase III route and sent the lineage memo. No reply since. |
| Colorado National Guard | Conversations under way. CU's Center for National Security Initiatives (Mike Bunting) recommends a funded pilot through the Guard's USPFO; see below. |
| MITRE (Caitlin Payne) | Sent a list of marketplaces and OTA consortia and offered to walk through them; see below. |
Virridy demonstrated at FY26 WaterPalooza, hosted by DEVCOM Ground Vehicle Systems Center and the 25th Infantry Division at Schofield Barracks, 15 to 17 September 2026. The lineage memo now carries CAGE 71HF3 and cites the NSF Phase II outcomes report, whose second objective was deploying tryptophan-like fluorescence sensors for microbial contamination.
The Army has no acquisition program of record for field water quality monitoring. The fielded capability is the Water Quality Analysis Set-Preventive Medicine, a colorimeter kit that performs presence/absence testing, held only by preventive medicine units. Standards come from TB MED 577. Bulk water equipment sits with Product Manager Petroleum and Water Systems, whose FY26 procurement line is $96M.
The DEVCOM sequential Phase II adds a DoD-funded SBIR award to the lineage, which strengthens any later Phase III, since the derivation no longer rests on NSF awards alone.
Every state Guard has a United States Property and Fiscal Officer, the federal officer accountable for the federal funds and property the Guard holds, with a purchasing and contracting office that buys on the Guard's behalf. Lume is a commercial product with published prices, so a Guard pilot is an ordinary commercial purchase and needs no prototype agreement.
| Pilot size | How the USPFO can buy it |
|---|---|
| Two units at $6,000 one-time ($12,000), or up to six on subscription at $2,400 per sensor per year | Government purchase card under the $15,000 micro-purchase threshold. No solicitation and no contract clauses. |
| Up to $350,000 | Simplified acquisition. A direct award to SweetSense Inc builds contract history in our name. |
The contracting office executes; it does not supply the need or the money. Mike Bunting's condition is that the Guard "can identify an appropriate funding source and operational requirement." Our Guard contacts have to name the unit or staff section that owns water quality, find federal or state money in this fiscal year, and bring the USPFO contracting office in. The requirement to propose is drinking water assurance during state emergency response (floods, wildfire, failed municipal systems), when the Guard supplies or treats water. That matches the drinking water focus of the AFRL and Army work.
Joe Kobsar at CU's Center for National Security Initiatives has run DoD program development and funding work and is the person to test the Phase III and consortium choices with. Because Evan holds a CU appointment while leading Virridy, confirm the conflict of interest management plan covers CU staff time spent on Virridy's DoD business before relying on it.
Caitlin Payne (MITRE, Cost Acquisition Management Solutions) sent these on limited information about Lume. Membership or a listing brings no money by itself; each one pays off only when a sponsor with funds chooses to buy through it.
Any Army office can post a challenge, and the 25th ID or DEVCOM SC could post one written around field water testing and award it there. The full challenge list is visible only after registering.
The sponsors are the Corps of Engineers and the Marine Corps, not DEVCOM. That suits installation water (the same Corps customer as the ERDC BAA) and expeditionary water for Marines. CMG passes solicitations to members and helps draft responses.
A video found awardable counts as competed under 10 U.S.C. 4021 to 4023 and stays on the marketplace for 12 months. Any defense office can then award research, prototype or production work from it, with no price ceiling. One video on field E. coli detection for troop water costs little and gives AFRL, DEVCOM SC or the 25th ID a competed vehicle to buy through.
This is the consortium Caitlin named. The site names no government sponsor or ceiling, and none of its technical areas covers water or health. Ask Caitlin who sponsors it before paying.
Nothing in scope touches shipboard or installation water, and the NAVFAC interest sits outside Dahlgren. Joining costs nothing, so it can sit as a listing until a Navy sponsor names it.
Bridge would matter only after a DIU award. The accreditation help is the part to remember if an installation's cyber approval of the cellular unit stalls, as AFRL's did.
Missing from her list and already identified here: NAMC (Detroit Arsenal OTA, petroleum and water systems area, $500 per year), the DEVCOM GVSC commercial solutions opening W912CH-24-S-0002, and SBIR Phase III. Questions for her walkthrough: how a contracting office would document Phase III derivation from NSF awards, and whether a consortium prototype would qualify for non-competitive follow-on production under 10 U.S.C. 4022(f).
Full analysis with citations is in the report DoD electronics sourcing rules (6 November 2026). This is research, not legal advice.
AR 70-79, paragraph 3-7 (26 March 2025): "Any small business that has received a prior SBIR/STTR Phase I or Phase II award is eligible for a Phase III award... Sole-source awards may be issued without further justification to the SBIR and STTR award recipients that developed the technology." Paragraph 3-7a removes the usual sole-source paperwork: no justification and approval, no synopsis, no cost or pricing data under TINA, and no independent government cost estimate.
Paragraph 2-7d makes use of the authority a duty rather than an option. Every Army PEO, command, laboratory and research, development and acquisition head is to "maximize, to the greatest extent practicable, the use of SBIR Phase III awards for follow-on RDA activities."
The ASA(ALT) memorandum SAAL-ZT of 27 August 2025, signed by the Director of Army Innovation Programs, asserts Phase III eligibility based on prior federally funded SBIR/STTR efforts and cites 15 U.S.C. 638(r)(4), SBA Policy Directive sections 4(c)(3) and 8(b)(4), FAR 6.103-5, FAR 6.302-5(a)(2)(i) and AR 70-79. Give this to a contracting officer rather than explaining the statute.
The Army SBIR/STTR Program Office does not approve Phase III contracts, and the SBIR Contracting Center of Excellence handles Phase I and Phase II only. The requiring activity, meaning the program executive office or program manager that wants the capability, works through its supporting Army Contracting Command or Mission and Installation Contracting Command office. The General Services Administration can also award an Army Phase III on a fee for service basis.
AR 70-79 paragraph 3-7b puts the package on the government side, in four parts: the requirement or need, the proposal from the firm, a memorandum from a government technical expert validating that the work derives from, extends or completes the prior SBIR/STTR effort, and the normal contract documents such as the statement of work, data item deliverables, DD Form 254 and quality assurance plan.
The Army publishes a Phase III Company Form for the company's half, which asks for the prior award number, the project title and a narrative under the heading "The following work derives from, extends, or completes efforts made under a prior SBIR/STTR funding agreement."
Every Army source refers to a prior SBIR/STTR funding agreement without naming an agency, which covers an NSF grant. No Army document addresses a non-DoD predecessor explicitly, so use the words "funding agreement" wherever a form asks for a contract number, and expect the derivation memorandum to carry more weight than it would for an Army-funded predecessor.
No ceiling applies. A Phase III may be funded from any appropriation other than SBIR funds, including procurement, operations and maintenance, construction and research, and may be any contract type, including a subcontract or a task order against an existing vehicle.
| Army Phase III awards, FY2021 onward | Value |
|---|---|
| Largest | $56.5M |
| Median of 21 awards | $10.9M |
| Smallest in the set | $8.4M |
Those figures come from the 100 largest DoD contracts since FY2021 whose descriptions name SBIR Phase III, so they are the large end; smaller awards exist below this range. DoD-wide the same set reaches $166M. Note that Army CATALYST, which offers up to $15M, is Phase II enhancement work and not a Phase III.
AR 70-79 paragraph 3-10a sets the SBIR data protection period at 20 years from contract award, after which the government holds government purpose rights. The Army's Phase III web FAQ still states five years and is out of date. Cite the regulation, and mark assertions under DFARS 252.227-7018.
Nothing in Army policy blocks a Phase III. It requires an Army organization that owns a requirement and already holds non-SBIR funds, and a technical point of contact willing to sign the derivation memorandum. The Army states that finding the buyer is the company's responsibility.
TB MED 577 / NAVMED P-5010-10 / AFMAN 48-138_IP, dated 1 May 2010, is the tri-service doctrine for sanitary control and surveillance of field water. It is the standard any water quality instrument is measured against in the field, and it sets three things that shape our approach.
| Total coliform | E. coli | Table 4-3 result |
|---|---|---|
| Absent | Absent | Green. Water safe for drinking. |
| Present | Absent | Amber. Drinkable with caution, repeat tests, remedial action if confirmed. |
| Present | Present | Red. Unsafe. Stop distribution, notify operators and the Surgeon or Commander. |
| Absent | Present | Gray. Testing error, retest. |
The standard is zero. Short-term potability requires 0 CFU/100 mL total coliform and 0 CFU/100 mL E. coli, and long-term potability repeats that with membrane filtration or most probable number. The bulletin states that E. coli presence "is a very strong indicator of fecal contamination and, therefore, warrants more concern."
Testing is periodic and slow. Coliform presence/absence runs weekly to monthly at production points, monthly in distribution, weekly to monthly at stand-alone storage. The fielded instrument is Colilert in the Water Quality Analysis Set-Preventive Medicine, which needs 24 hours of incubation and is held only by preventive medicine units. Between those tests, free available chlorine is the only real-time microbial safety signal: 2 mg/L after 30 minutes contact at production, 1 mg/L at delivery to secondary storage, checked daily at storage.
The bulletin concedes the gap itself: "There are no relatively simple field tests for measuring the specific concentration of any of the variety of infectious organisms." That is why doctrine tests indicator organisms by presence/absence and leans on a chemical surrogate in between.
Lume enters as a continuous operational monitoring instrument that indicates when treatment is failing and directs preventive medicine to sample. It does not certify potability, does not replace Colilert, and does not enter the preventive medicine approval chain.
Doctrine already has this slot. Where preventive medicine cannot test reverse osmosis product water in time, supervisors may distribute water on a provisional basis once documented operational monitoring, listed as pH, total dissolved solids, turbidity, color, taste, odor and chlorine residual, verifies the treatment equipment is working. Field water doctrine therefore already accepts a surrogate as its real-time microbial safety signal, with culture as the periodic check. We are offering a better surrogate for a job the doctrine already defines.
This position also keeps Lume in the sustainment lane. Presented as a preventive medicine test method, it becomes Class VIII medical materiel and inherits medical materiel approval, the DAPA and ECAT catalog process, and the WQAS-PM supply channel.
TB MED 577 permits "any EPA-approved testing method" for coliform and E. coli, which points at the drinking water method list under 40 CFR 136 and 141. That is not our route. The alternative test procedure path is retired for this method, and 40 CFR 136 attaches to permit compliance reporting rather than to ambient monitoring. Our regulatory work targets Water Quality Standards through the site-specific alternative indicator framework in EPA-820-R-14-011.
For a defense customer the useful credential is AOAC Performance Tested Methods: independent third-party certification of a proprietary device, single independent-laboratory validation, ISO 16140-2 aligned, on the order of six to twelve months. OMB Circular A-119 and the National Technology Transfer and Advancement Act direct DoD to prefer voluntary consensus-body methods over vendor-unique ones, so a PTM certificate removes the objection that Lume is not a recognized method, without touching 40 CFR 136.
Our validation does not yet speak to the bar TB MED 577 sets, and the difference is the threshold. Against the compartment bag test in East Africa, balanced accuracy was 0.93 at the WHO threshold of 10 MPN/100 mL, and 0.73 at 1 MPN/100 mL. TB MED 577 asks about presence, effectively one organism per 100 mL, which is where the evidence is thinnest.
Three conditions in field water operations are also untested for us: chlorinated water carrying 2 mg/L free available chlorine, reverse osmosis product water where organics are largely stripped and the baseline should be very low, and unit temperatures up to 42 degrees Celsius, already observed in the East Africa deployments.
Generating that record is what the AFRL cooperative research and development agreement or a DEVCOM GVSC test service agreement is for, since both provide the water, the reference testing and the government-owned results. DoD's Environmental Security Technology Certification Program is the funded vehicle for the same work at larger scale, and it issues a peer-reviewed cost and performance report that functions as validation for operations.
The Army tests field water for E. coli once a week to once a month, by a presence or absence test that takes 24 hours and is held only by preventive medicine units, and infers safety in between from a chlorine reading. Lume measures continuously, in seconds, and tells those units when and where to test. The doctrine already accepts a surrogate for exactly that purpose.
Present Lume as sustainment equipment for expeditionary water assurance, never as preventive medicine or force health protection. A medical framing routes the product into Class VIII medical materiel, which brings medical materiel approval, FDA review and the ECAT catalog process. It also triggers an explicit exclusion in the Army xTech competition rules for technologies falling within the Army medical research portfolio.
The Air Force STTR in the company's history belongs to Urban Sky as prime with CU as the research institution. It creates no rights for Virridy and should not appear in any document a contracting officer reads.
| When | Action | Outcome sought |
|---|---|---|
| This week | Reply-all to Mike Bunting and Joe Kobsar: thank them, say where the Guard conversations stand and whether the USPFO has been approached, propose a call. | Call with Joe on Phase III, consortium choice and Guard contacts |
| This week | Ask the Colorado Guard contacts who owns a water quality requirement, whether money exists this fiscal year, and for an introduction to the USPFO purchasing and contracting office. Offer a two-unit pilot under $15,000. | Card purchase direct to SweetSense Inc |
| This week | Accept Caitlin Payne's walkthrough. Send a one-paragraph Lume description, the current DoD engagements, and the questions above. | A shorter, Lume-specific vehicle list |
| This week | Ask Eric Brack for the DEVCOM SC CRADA final signature date and the status of the Army and NSF determinations for the sequential Phase II. | Signed CRADA; Phase II on track |
| This week | Support the AFRL trial run and next week's experiments. Follow up with Dr. Agans on the CRADA and ask that the next purchase go direct, citing UEI M9YULLTP4PH8 and CAGE 71HF3. | Signed AFRL CRADA; first direct sale |
| Next two weeks | Follow up with NAVFAC EXWC on the loan unit. | Unit in Navy testing |
| Next two weeks | Create a GoColosseum profile. Join CEED and NAMC ($500 per year). ERIS video submitted 10 November (11-26-4113, chemical and biological threats topic); results due by 31 December. | Vehicles ready when a sponsor wants to buy |
| By 31 December | Identify the Lume battery cell maker and pack assembler and check them against the Sec. 154 list. Ask Blues for the board fab origin and whether a non-Quectel Notecard fits Lume's power and satellite needs. | Bill of materials clear of the 2027 deadlines |
| By 31 December | Specify a no-radio, wired logging variant for installations whose cyber approval forbids cellular, as AFRL's does. | A configuration AFRL can approve and outside the PCB statute |
| Rolling | ERDC broad agency announcement W912HZ26S0001, five-page pre-proposal on CERL-14 or EL-5, response within 60 days. | Funded installation water work |
| Watch | DFARS Case 2022-D011 (PCB rule); Sec. 805 on 30 June 2027; Sec. 154 on 1 October 2027; Sec. 5949 on 23 December 2027. | No surprises in a 2027 bid |
Held: APEx until Caitlin names its sponsor; NSTIC and DIU Bridge until a sponsor points at one.
WaterPalooza, DEVCOM GVSC: Mark Bagwell, Dr. Ben Thomas, Ramsey Slim, Kim Wegner. 25th Infantry Division: MAJ Mark Sopkiw, 1LT Trent Ferguson.
AFRL 711 HPW: Dr. Richard Agans (CRADA), Monica Wolfe (program lead), Isabel Jensen and Kyle Eckhoff (testing). DEVCOM Soldier Center: Eric Brack. NAVFAC EXWC: David Thompson, Haur Su, Ken Ho.
CU Center for National Security Initiatives: Dr. Michael Bunting (Deputy Executive Director), Joe Kobsar. MITRE: Caitlin Payne (Contract Analyst, Cost Acquisition Management Solutions).
ERDC topics: Mark Ginsberg (integrated water security for DoD installations), Dr. Jared Cobb (environmental sensors). Army xTech: usarmy.xtech@army.mil. APFIT: osd.apfit@mail.mil.
DIU has no water portfolio and competes only problems a defense customer submits, so it becomes useful when a sponsor writes the problem statement. Army PIT operates through xTech, SBIR, ManTech and the G-TEAD accelerated capability events, and its published investment threads do not include water.