Small Arms Suppressor Justification and Approval.pdf
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United States Marine Corps
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UNITED STATES MARINE CORPS
MARINE CORPS SYSTEMS COMMAND
2200 LESTER STREET
QUANTICO, VIRGINIA 22134-6050
JUSTIFICATION AND APPROVAL
Code: CT-2.1 J&A Number: 20,183
FOR USE OF OTHER THAN FULL AND OPEN COMPETITION
1. Contracting Activity
Marine Corps Systems Command (MARCORSYSCOM) Portfolio Manager, Ground Combat Element Systems Program Manager, Infantry Weapons (PMM 140) 2200 Lester Street Quantico, VA 22134-6050
2. Description of Action being Approved
The use of other than full and open competition to procure the commercial 5.56mm Small Arms Suppressor to be used on the following weapon systems: M27 Infantry Automatic Rifle (IAR), M4 Carbine and M4A1 Close Quarter Battle Weapon. The proposed action is for a Firm Fixed Price, Indefinite Delivery/Indefinite Quantity (IDIQ) contract with Knights Armament Company (KAC), 701 Columbia Blvd, Titusville, FL 32780.
3. Description of Supplies/Services
Marines will attach the Small Arms Suppressors to their individual rifles to aid in inter-squad communications, reduce hearing loss, and support operational stealth by reducing detection by a threat through reduced audible and visual signatures. Marines will use these systems on the M27, M4, and M4A1 in close combat force units. Currently, there are approximately KAC 5.56mm suppressors in the United States Marine Corps (USMC) inventory.
The proposed contract action is to establish a seven-year IDIQ contract consisting of a base ordering period of five years with two twelve month options. In order to fulfill the Small Arms Suppressor AAO, the USMC plans to procure approximately suppressors on the first two orders of this contract, utilizing FY20 and FY21 Procurement, Marine Corps (PMC) funding as identified in the table below. The MCSC contract is the enterprise contract vehicle for initial procurement as well as any replacement quantities for suppressors in the USMC. As the lead Service on this suppressor, additional quantities may be procured as shown in FY21-
FY27.
Table 1: IDIQ Procurement
FY20 FY21 FY22 FY23 FY24 FY25 FY26 FY27 TOTAL
PMC $6.664M $14.914M
O&M $10.738M
TOTAL $6.664M $25.652M
4. Statutory Authority Permitting Other Than Full and Open Competition
The statutory authority permitting use of other than full and open competition for this action 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. Rationale Justifying Use of Cited Statutory Authority
Through the life of the Small Arms Suppressor program, the Marine Corps expended at least $14,960,975 on the procurement of the current USMC inventory (Qty The USMC procured Suppressors via the competitively awarded Navy contract N00164-04-D-0003.
Additionally, the Marine Corps purchased Small Arms Suppressors competitively in 2015 under contract M67004-15-P-2005. Most recently, the USMC procured Small Arms Suppressors via a competitively issued Defense Logistics Agency Tailored Logistics Support Program order.
The planned sole source procurement will allow the USMC to eliminate the need to re-train Marines on a new materiel solution. It will also enable the USMC to continue to use their existing bayonets, as well as their existing Small Arms Collimators (SAC), Laser Borelight Systems (LBS), and Blank Firing Adapters (BFA), all of which are critical to accuracy and lethality in both training and combat. These items are interoperable with the current Small Arms Suppressor.
Conversely, conducting a competitive procurement would result in significant duplication of cost to the Government. In particular, the Marine Corps would expect to spend $1.261M on various testing events during a competitive process; $6.941M on procurement of new ancillary equipment that would be interoperable with the chosen competitive solution, including items such as the SAC, LBS, BFA, bayonets and technical manuals; and $8.324M in replacing the
KAC suppressor currently in inventory. BFAs and bayonets are issued one for one per rifle. Therefore, if the USMC procured a suppressor solution other than KAC, new BFAs and bayonets would be required (one for one per suppressor). A portion of SACs would be replaced at each infantry battalion and School of Infantry, resulting in 19 SACs being replaced per battalion and 13 per School of Infantry at a unit cost of approximately each total replacements). A portion of LBS mandrels would need to be replaced at each infantry battalion, resulting in a quantity of 1 new mandrel being procured for every ten suppressors at a cost of approximately each total replacements). All duplicate costs are outlined in the table below. The testing costs were determined based on comparable analysis of similar test events by Program and Test Manager subject matter experts. The ancillary equipment costs were determined based a combination of program office analysis of current costs of those items, with under the Special-Purpose Marine Air-Ground Task Force (SPMAGTF)— Crisis Response—Central Command 16.2; Africa under the SPMAGTF—Crisis Response—AF;
Europe under the Black Sea Rotational Force, Norway Rotational Force, and South America under the SPMAGTF—SC. These deployments are concurrent with the Marine Corps’ regular force-in-readiness role requiring the infantry to deploy rotationally under Marine Expeditionary Units. Using KAC’s historical production performance, the Marine Corps can extrapolate that KAC would take approximately twenty months to fulfill the AAO increase with its suppressor. Conversely, delivering from any source other than KAC would cause at least a one year delay for initial delivery. The projected year delay timeframe is based on expected timelines associated with testing and contractual efforts for a competitive award. After award, assuming production rates of the lowest priced vendor to respond to market research, the Marine Corps can expect another eighteen months of production and delivery to fulfill the AAO. In total, if the USMC were to seek a source other than KAC, it would cause a delay of at least a year and a half to deliver the first suppressors to infantry units. This extreme delay is unacceptable as it unnecessarily decreases the warfighting capability among deploying security forces. The suppressor ensures auditory and visual concealment, which enhances communication between the Marines and avoids detection from the enemy. It is an essential device for the weapons of the deploying Marine and any delay places the Marines’ lives at risk.
No other type of currently available system will satisfy the Marine Corps requirement for a Small Arms Suppressor suitable for every Infantry Marine. By equipping close combat forces with the existing suppressor, their visible and audible signatures are significantly reduced providing concealment from the enemy. Additionally, the existing suppressor significantly increases and improves internal communications with a system that is interoperable with all fielded accessories (SAC, LBS, bayonets, etc.). Maintaining one suppressor configuration also aids in the safety of the close combat forces by eliminating the possibility of billet identification based on the suppressor configuration being utilized. Additionally, the suppressors must be common and interchangeable to allow for standardization throughout the close combat forces.
Commonality and interchangeability significantly decrease training time and enables each operator to safely function in any given system under critically high-stress situations. For example, commonality and interchangeability allow Marines to operate any weapon with the suppressor properly in lowlight conditions because the components and their dimensions are all known and the same—a lifesaving quality under the extreme stresses of combat. The known existing suppressor attachment method also allows quick attach/detach movements as needed during any particular mission, as well as provides interoperability amongst weapon systems as all muzzle devices would accept the common suppressor. Due to proprietary designs of the compensator, and the need for systems to be interchangeable, the Marine Corps would have to purchase the entire AAO from a source other than KAC, causing the Marine Corps to repurchase approximately suppressors and waste the functional systems it previously purchased from KAC.
6. Description of Efforts Made to Solicit Offers from as Many Offerors’ as Practicable
In 2017, Combat Development & Integration (CD&I), Plans, Policies and Operations (PP&O), and the Program Manager, Infantry Weapons Systems, directed market research into industry’s ability to fulfill a potential Approved Acquisition Objective (AAO) increase of Small Arms Suppressors. The purpose of the AAO increase would be to supply close combat forces with a suppressor to decrease their audible and visible signatures.
Small Arms Suppressor. MCSC will actively asses new market data in consideration for possible future competitive sourcing.
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