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.
AFRL is formally testing Lume and has purchased one unit at $5,000, bought through a support contractor rather than directly. A CRADA with AFRL is pending. 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 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.
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 |
|---|---|
| This week | Ask AFRL to make the next purchase direct, citing UEI M9YULLTP4PH8 |
| This week | Send the Phase III lineage memo to the AFRL technical point of contact |
| This week | Ask DEVCOM GVSC about a CRADA or test service agreement with its Fuel and Water Equipment Branch |
| 28 to 29 September | G-TEAD ASCC synchronization forum, virtual, open to industry, previews Pacific capability events |
| 19 October | xTech Search 10 white paper, three pages, if pursued for visibility |
| Rolling | ERDC broad agency announcement W912HZ26S0001, five-page pre-proposal, response within 60 days |
WaterPalooza, DEVCOM GVSC: Mark Bagwell, Dr. Ben Thomas, Ramsey Slim, Kim Wegner. 25th Infantry Division: MAJ Mark Sopkiw, 1LT Trent Ferguson.
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.