W15QKN-26-D-A095 REDACTED JUSTIFICATION AND APPROVAL.pdf

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FAR Part 6 Justification and Approval for Other than Full and Open Competition

1. Requiring Activity: Portfolio Acquisition Executive Maneuver Ground, Capability Program Executive Ground, Project Manager (PM) Soldier Lethality, Product Director Crew Served Weapons

2. Contracting Activity: Almy Contrncting Command- New Jersey (ACC-NJ)

3. Description of Action: Requested action consists of a new sole source, five-year, Indefinite Delive1y Indefinite Quantity (IDIQ) contract with Fi1m Fixed Price (FFP) delive1y orders. The contractor is Charles Reed Knight Jr, doing business as (DBA) Knight's Almament Company (hereinafter refened to as Knight's), CAGE: 1S002, 701 Columbia Blvd, Titusville, Florida, 32780-7902. Foreign Militaiy Sales (FMS), Other Government Agency (OGA� Procurement Funds will be utilized for all delive1y orders under this contract. -

The anticipated award date is fourth qua1ter Fiscal Year 2026 FY26 . T e most recent Ml 10 IDIQ contract with Knight's expired on 23 September 2025. Since the previous IDIQ expired, requirements have been met under Contract WISQKN- 25-C-0033, which was a one-time standalone contract to satisfy emergent requirements for a specific FMS case and cunently has the contractor at capacity. Therefore, this new sole source IDIQ is needed to ensure requirements are still met. Failure to approve this Justification and Approval (J&A) will result in unacceptable delays which will lead to an inability to satisfy FMS cases, OGA, and Almy requirements in FY26 and beyond, compromising the safety and effectiveness of militaiy operations.

4. Description of Supplies/Services: 7.62mm Semi-Automatic Sniper System (SASS)- Ml 10, Variants, Accessories, Spare Paits, Special Tools, and Training to support the United States Almy (USARMY), United States Mai·ine Corps (USMC), United States Air Force and United States Navy herein refe1Ted to as the United States Aimed Forces, as well as OGA and vai·ious FMS allied nations. The Ml IO SASS is primarily utilized by a "Designated Marksman" and provides sniper suppo1t, squad ove1watch, counter sniper operations, long-range surveillance and light vehicle/equipment disablement.

The estimated requirements (FY26- Fiscal Yeai· 2030) ai·e outlined in the table below. This estimate was derived from historical quantities and pricing, average escalation factors, and commercial info1mation sourced from Knight's.

Item ste

• /L w • sse s

I I I I I I

Quantity* Delive1y Date

Estimated / Average

Unit Price* Estimated Value*

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ELE

ASE"

Item

FAT

Rifles / S stems

Item ste

·/L w sse s

Su ressors

Bulle Ma azines TY 50

S are Patts Kits

0 tics Kits

S ecial Tool Kits

Individual S ai·e Parts

Enoineerin Services

Trainin O erator and Maintainer

Item

FAT

Rifles / S stems

U er/ Lower Assemblies

Su ressors

Bulle Ma azines TY 50

S are Pa1ts Kits

0 tics Kits

S ecial Tool Kits

Individual S ai·e Parts

Enoineerin Services

Orderi

Trainin O erator and Maintainer

Orderi

Quantity* Delive1y Date

- I

Estimated / Average

Unit Price*

- I

Estimated Value*

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Item Quantity* Delivery Date Estimated / Average

Unit Price* Estimated Value*

FAT

Rifles / Systems Upper / Lower Assemblies Suppressors Bulk Magazines (QTY 50) Spare Parts Kits Optics Kits Special Tool Kits Individual Spare Parts Engineering Services Training (Operator and Maintainer)

Orderi Total of

* Quantity total is inclusive of all M110 system variants on Contract Line Item Numbers (CLINs) including base, Army, Lightweight, USMC, K3, A2, K7 and A3, as such these unit prices are averages and Quantity X Unit Price will not equal total estimated values This is due to differing requirements and configurations to meet specific customer requirements. Full breakout of quantities with estimated unit prices for all items can be found in the Independent Government Estimate.

5. Authority Cited: Title 10 United States Code (U.S.C.) §3204(a)(1) as implemented in Federal Acquisition Regulation (FAR) 6.103-1(c)(2)(ii), Unacceptable delays in fulfilling the agency’s requirements. Failure to approve this J&A will lead to unacceptable delays estimated to be in total.

6. Reason for Authority Cited: As described at FAR 6.103-1(b), Agencies may contract without providing for full and open competition when the supplies or services required by the agency are available from only one responsible source and no other type of supplies or services will satisfy agency requirements. For Department of War, this authority extends to situations where only a limited number of responsible sources can satisfy agency requirements. FAR 6.103-1(c)(2)(ii) states supplies may be deemed as available only from the original source in the case of a follow-on contract for the continued development or production of a major system or highly specialized equipment, when award to any other source would result in unacceptable delays in fulfilling the agency’s requirements. Defense Federal Acquisition Regulation Supplement (DFARS) 206.103-170(e) further supplements this authority with application for proprietary specifications or standards.

a. Background: The M110 SASS is proprietary to Knight’s, which is a variant of the commercial SR-25 with minor deviations. Following a competitive selection process in 2005, Knight's design was chosen and formally qualified to meet the USARMY's requirements. All subsequent acquisitions of this weapon were procured from Knight’s. Due to the primary use of the M110 SASS being from FMS partners, the United States Government (USG) does not own the Technical Data Package (TDP) and Knight’s .

Knight’s continues to be the only source to have the engineering, production, quality assurance, test personnel, and facilities in place to manufacture, identify, and implement optimum solutions

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to any unforeseen problems associated with the Ml 10 SASS. Market research is ongoing and continuous to identify similar items, however due to the unique aspects of the Ml 10 SASS as stated above, there are cunently no other known rifles manufactured that satisfy the requirements. Knight's is the only source with a qualified design and the only source which possesses expertise in the intricacies of the design, manufacturing, and function of the Ml 10 SASS. First Aliicle Testing will be waived because of this continuous production line and the fact that no design changes are anticipated.

The introduction of a new semi-automatic sniper system during a period of active conflict presents an unacceptable risk. A lack of soldier familiarity with the new weapon would degrade mission effectiveness and increase the potential for loss of life. Additionall awarding to another vendor would �table delays of approximately This estimate is comprised of- to competitively solicit and aw�ro uction contrnct (based on Procurement Administrative Lead Time estimates),_ for�ucer to complete system qualification, - for operational and airdrop testing,_ to complete

N e Classification (�ull Material Release (FMR) package preparation and an additiona to begin hardware production, enter/pass First Aliicle Testing and to begin initial fiel mg reqmrements. This timeline is listed in the table below:

Activity

Initial Deliveries with FAT / Fieldin Total

b. Alternatives: In addition to the previously mentioned unacceptable d�d open �tition would result in substantial duplication of costs, estimated to be _, derived from a comparison with a similar program for the Compact Senn-Automatic Sniper System adjusted for inflation, to the USG that would not be recovered through use of the competitive procedures. The estimated duplicated costs represent- of cost compared to the dollar value of this requirement, a substantial amount almost equal to the full estimated requirement of Ordering Period 1. As previous! stated a Febrnai 2026 in un to Kni ht' s re ai·din the USG urchase of the TDP

Additionally, the USARMY has filled the Almy Acquisition Objective and has no active steady requiI·ements for these items. The contemplated IDIQ contract will facilitate requiI·ements from mainly FMS customers with occasional requirements from the United States Aimed Forces and OGA. With this

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consideration, there is not a singular customer available with a requirement large enough to fund purchasing the TDP, should it be made available once again for purchase.

In addition to these considerations, most requirements for the M110 SASS are supported by signed Letters of Offer and Acceptance (LOA), many of which require the Knight’s M110 SASS, called out either by name or by National Stock Number. As a result, any requirement supported in this manner must be awarded to Knight’s and would require completion and approval of an International Agreement Competitive Restriction (IACR) document. If a competitive acquisition led to contract award to a vendor other than Knight’s, the resulting award could not be used for any requirements supported by a LOA specifying the Knight’s M110 SASS. This would have numerous impacts beyond just the production of the weapon. Further the impact would include a potential duplicated costs and would make it difficult for the USG to establish a minimum guarantee for an IDIQ contract.

c. Impact if not approved: If this justification is not approved, no standing contract vehicle will be in place to fill requirements for the M110 SASS. If award was made to another vendor there would be unacceptable delays of approximately

. Any emerging requirements would require individually approved IACR documents and subsequent purchase orders or standalone contracts. While this would not completely prevent requirements from being fulfilled, it would result in ACC-NJ’s need to award sole source acquisition for each requirement, which would provide additional delays and duplicated costs above and beyond those outlined previously. The previous contract, W15QKN-20-D-0044, had a total of 44 requirements filled over the five 1-year Ordering Periods. For comparative purposes, this would mean 44 unique Procurement Packages and either IACR or Contracting Officer-level Sole Source Justifications would need to be developed and approved to fulfil the requirements, in lieu of this approval and resulting contract.

7. Efforts to Obtain Competition:

a. Effective competition: Since this is a sole source action, effective competition is not applicable. The notices required by FAR 5.201 shall be published and any bids or proposals received shall be considered.

b. Subcontracting competition: Subcontracting opportunities exist primarily for component manufacturing, maintenance support, and specialized services. Subcontract competition will be maximized to the fullest extent possible, as required by FAR 52.244-5, “Competition in Subcontracting” and FAR 52.219-8 “Utilization of Small Business Concerns,” which will be included in the resultant IDIQ contract.

8. Actions to Increase Competition: The TDP for the M110 SASS is the property of Knight’s.

To increase future competition, the USG inquired with Knight’s regarding acquiring the TDP

There have been several companies that have expressed an interest in qualifying their weapons and the USG has provided these companies with information on how to qualify their weapons. However, to date none of these companies have followed through on an attempt to qualify. The

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procurement of this item will remain sole source for the duration of this contract's ordering periods. Potential sources (other than Knight's) will have the opportunity to qualify their design in accordance with the approved perfonnance specification. Potential vendors will be fully responsible for all costs and coordination associated with the qualifications of their design.

Cunently, Knight's is the only qualified source for manufacturing this rifle. The Government's interest in additional sources has been and will continue to be communicated to potential sources through Sources Sought announcements on SAM.gov.

This action is a follow-on to contract Wl5QKN-20-D-0044. Under the previous Justification the paragraph "Actions to Increase Com etition" ofKni ht's.

the purchase of the TDP. Cunently, there is no funding that can be made available to negotiate the purchase of the data rights. This approa echnical data,

9. Market Research: Personal knowledge of the requiring office in procuring supplies of this type, (Non Standard Weapons, Sniper Rifles, etc), conta.ct with knowledgeable people in the USG and indust:Iy regarding the commercial nature of the requirement and standard indust:Iy practices for commercial sniper systems, internet and database searches and review of cunent / recent market surveys are among the types of Market Research perfonned for this requirement.

Additionally, in accordance with DFARS 205.205-71, DFARS 206.302-l(d), and DFARS Procedures, Guidance and Infonnation (PGI) 206.302-1 ( d), Sources Sought Notice Wl 5QKN- 26-X-1AUF was posted to SAM.gov on 29 October 2025 with a closing date of 21 November 2025 by ACC-NJ. The request focused on potential suppliers of Ml 10 SASS, Ml 10A2, Ml 10K3, and 6.5 Creedmoor weapons, as well as related accessories, upper and lower receiver assemblies, spare parts, suppressors, special tool kits, optics and ti·aining. The responses to the notice were analyzed to detennine the level of capability of each interested paiiy based on the following capability criteria:

CAP ABILITY CRITERIA:

Highly Capable- Company is capable and responsible as conoborated by the company's manufacturing capabilities and experience . The Company is a cmTent Government contract holder for the production of Ml 10 SASS and/or other weapons produced in accordance with a Militaiy Perfonnance Specification.

Likely/Somewhat Capable - Company response provided general statements and did not address/meet all requirements, may meet requirements through capital improvements or subconti·acting airnngements, or indicated the company may have a cmTent or previous Government contract for production of other weapons, spai·e paiis, and/or ancillaiy hai·dwai·e.

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Unlikely Capable - Company response minimally addressed or indicated the inability to meet all requirements. Response may have included some capability and experience needed to meet the requirements. However, serious doubts still remain either pertaining to the company's response or past perfonnance.

Incapable - Company response indicated it does not have the resources ( either in-house or subcontracted) to meet the requirements.

There were four res onses received:

An inqui1y was submitted by owever no response was ever submitted. Out of the four responses, on y one Highly Capable. The following is a detailed assessment of each submittal:

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The submission from-did not address the full requirement but focused exclusively on the ability to provide suppressors only. While this vendor could potentially meet some of the USG requirements for suppressors, they have not indicated any ability to manufacture the Ml 10 SASS or any comparable rifle to meet MIL-PRF-3 2316.

CAP ABILITY: Incapable. This company only highlighted additive manufacturing for suppressors. The size of the company, weapon perfo1mance, ex rience, and manufacturing capability are all unknown. Based on the info1mation provided, would be incapable of meeting this contract's requirements.

■ does have extensive manufacturing experience, however they have stated a desire to acquire the USG owned TDP for the Ml 10 SASS. The USG does not own the TDP for the Ml 10 SASS, which is proprieta1y to Knight's. An alternate approach proposed by■ is based around collaboration with the USG on thellll weapon platfo1m to make it confonn to MIL-PRF- 32316. It is believed that this wourcr'be' out of scope of the requirement.

CAPABILITY: Unlikely. While this company listed extensive manufacturing experience in small aims, their proposal hinges on manufacturing the Ml 10 SASS based on a government provided TDP. The government does not cunently own the TDP for the Ml 10 SASS and is unable to provide it for production.

rovided a res onse leveraging their . Although a platfo1ms ai·e not similai· in nature. The the Ml 10 SASS in US invento1y, although this has yet to occur and is now unlikely.

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__ not available for

CAPABILITY: Unlikely. While this com an small anns, their proposal hinges on compatible with the Ml 10 SASS or Ml 10A2 and is not available Knight's Annament Company (Knight's) expenence m which is not

The Knight's submission included additional infonnation regarding manufacturing capabilities and monthly production capacity. As Knight's has been in production of the Ml 10 SASS and other variants since 2005, they are a known provider and the Original Equipment Manufacturer of the Ml 10 SASS family of weapons.

CAP ABILITY: High. The company does indicate direct experience in the manufacture and servicing of small anns, small anns components and small anns maintenance. Manufacturing histo1y does indicate a strong capability in the machining of weapons related components.

Company is the cunent manufacturer of the requested system which has passed militaiy testing and received Type Classification/Materiel Release.

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

11. Other Facts:

a. Procurement histo1y.

Contract Number / Contract Procurement Amount Period of Performance

Contractor Tvue Method

Wl5QKN-25-C-0033* FFP Sole Somce $21.2 M 25 SEPT 2025 through 30 Charles Reed Knight Jr. dba. FAR6.302-7 DEC 2026 Knight's Annament Co

Wl5QKN-20-D-0044 Charles FFP Sole Somce $29M 23 SEPT 2020 through 22 Reed Knight Jr. dba. Knight's FAR6.302-l SEPT2025 Annament Co

Wl 5QKN-12-D-0029 FFP Sole Somce $24.9M 19 MAR 2012 through 19 Charles Reed Knight Jr. dba. FAR 6.302-1 MAR2019 Knight's Annament Co

Wl 5QKN-05-C-0689 FFP F&OC $30.lM 26 SEPT 2005 through 25 Charles Reed Knight Jr. dba. AUG2011 Knight's Annament Co

*Note: WJ SQKN-25-C-0033 was a one-time standalone contract to satisfy emergent requirements for a specific FMS case, and is currently at compacity as previously mentioned above.

1) Contract Number: W15QKN-25-C-0033, awarded 25 September 2025

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2) Competitive Status: Sole Source

3) Authority Previously Cited: FAR 6.302-7

4) Changed Circumstances: None

5) Unusual Patterns: None

6) Protests Received: None

1) Contract Number: W15QKN-20-D-0044, awarded 23 September 2020

2) Competitive Status: Sole Source

3) Authority Previously Cited: FAR 6.302-1(a)(2)(ii)(A)

4) Changed Circumstances: None

5) Unusual Patterns: None

6) Protests Received: None

1) Contract Number: W15QKN-12-D-0029, awarded 19 March 2012

2) Competitive Status: Sole Source

3) Authority Previously Cited: FAR 6.302-1(a)(2)(ii)(A)

4) Changed Circumstances: None

5) Unusual Patterns: None

6) Protests Received: None

1) Contract Number: W15QKN-05-C-0689, awarded 26 September 2005

2) Competitive Status: Full and Open Competition

3) Authority Previously Cited: Not Applicable

4) Changed Circumstance: None

5) Unusual Patterns: None

6) Protests Received: None

b. Other facts. Not applicable.

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12. Technical Certification: I ce1iify that the suppo1iing data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

13. Requirements Certification: I ce1iify that the suppo1iing data under my cognizance, which are included in the justification, are accurate and complete to the best of my knowledge and belief.

14. Fair and Reasonable Cost Determination: I hereby detennine that the anticipated price/cost to the Government for this contract action will be fair and reasonable. This detennination will be made using a price analysis in accordance with FAR 15. and the Independent Government Estimate. As paii of the basis, ce1iified cost or pricing data will not be required as the item is a commercial item, which is an exception noted at FAR 15 .403 .

15. Contracting Officer Certification: I ce1iify that this justification is accurate and complete to the best of my knowledge and belief.

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Approval

Based on the foregoing justification, I hereby approve the procurement of 7.62MM Semi- Automatic Sniper System (SASS) – M110, Variants, Accessories, Spare Parts, Special Tools & Training on an other than full and open competition basis pursuant to the authority of Title 10 U.S.C. §3204(a)(1) as implemented in FAR 6.103-1(c)(2)(ii), unacceptable delays in fulfilling the agency’s requirements. The estimated value of the new contract is for a five-year Indefinite Delivery Indefinite Quantity Contract with five one-year ordering periods from fourth quarter Fiscal Year 2026 to fourth quarter Fiscal Year 2031. The approval is subject to availability of funds, and provided that the supplies and/or services herein described have otherwise been authorized for this acquisition.

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CAO-26-0054 M110 SASS JA CUI REDACTING ms 3_Redacted 508

CAO-26-0054 M110 SASS JA CUI REDACTING ms 4_Redacted 508

CAO-26-0054 M110 SASS JA CUI REDACTING ms 5_Redacted 508

Binder1_Redacted