JA M134D Boat Program for release_REDACTED.pdf

June 2025

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

1. Requiring Activity: Project Manager Soldier Lethality (PM SL), Picatinny Arsenal, New Jersey

2. Contracting Activity: United States (U.S). Army Contracting Command New Jersey (ACC-NJ)

3. Description of Action: ACC-NJ, on behalf of PM SL, requests approval to award a new sole source Requirements Firm Fixed Price (FFP) contract for Philippines Case ZB- B-WFS, for the M134D-M (Marinized) Min gun system along with associated mounting systems for water platforms, parts, accessories, support equipment, installation, and training for operators and maintaine s. The contract will have a one (1) year period of performance. The Government projects award by the end of Fiscal Year (FY) 2026. The proposed contractor is Dillon Aero, Inc., CAGE: 1PN61, 21615 N 7th Ave., Phoenix, AZ 85027. Building Partner Capacity (BPC) will support this requirement.

4. Description of Supplies/Services: The requirement fo M134D-M Minigun system, along with associated mounting systems for water platf rms, parts, accessories, support equipment, installation, and training for operators and maintainers is required to support BPC, Case ZB-B-WFS. The M134D-M is a 7 62x51mm rotary machine gun. The Government has a need for M134D-M as capable of delivering precision and rapid fire on personnel and vehicle-sized (2m x 3m) materiel targets with fixed firing rates of 3,000 rounds per minute. The M134D M uti izes ceramic coatings to improve corrosion resistance for use in the marine environment. The M134D-M along with the mounting systems and support equipment, a e built to commercial, proprietary technical data packages (TDPs) owned by Dillon Aero, Inc. and are Commercial off the Shelf (COTS) items. Spare parts and accessories are also required for each configuration and will be incorporated into the c ntract using separate Contract Line Item Numbers (CLINs).

Installation and training s rvices will be included for platform installation (water platforms) and operato and maintainer training courses to support BPC case ZB-B- WFS. The U.S Government requires these weapons to facilitate BPC agreement. This includes specialized equipment that PM SL and foreign partners need to execute their mission successfully through FY 2027. Table One below depicts the forecasted requirement with a . For the duration of this document, the group of aforementioned items being acquired in support of this effort will be referred to as the M134D Minigun Systems and associated services. The Capability Program Executive (CPE) Ground has been given the responsibility for the procurement of non-standard small arms weapons, optics, and accessories for U.S. Army requirements and support for Foreign Military Sales (FMS). Additionally, CPE Ground was directed to work with all the Services, and when appropriate, based on other Services' requests, to coordinate support and execute their non-standard weapons, optics, and accessories acquisition requirements.

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The ACEIT output is top level based on actual costs of a similar acquisition with a complexity factor to account for differences. The labor represents a level of effort for five years, during which all of the following would be completed: performance specification developed, source selection plan, procurement package, solicitation and bid sample delivery, testing and proposal evaluation, source selection evaluation, contract award, support to Development and Operational Testing, Type Classification and Full Material Release documentation. The Development and Operational testing includes the cost to test and evaluate new weapon systems, mounting systems and support equipment. If another company were to compete for the M134D variant requirements, it is expected that the duplication of costs would not be r covered by cost savings through competition since the current requirement is sporadic and will primarily be used to support FMS and other agency requirements. The ACEIT model estimated for the Government to have a contractor develop a rotary machine gun weapon system. If a contractor developed this at their own expense they would spend about the same and expect a significant profit, pushing the estimated cost of obtaining the TDP to more than . The table above also does not include this estimated TDP cost, and the impact that would have on overa l duplication of cost. The table above indicates a , in comparison to the dollar value of the effort, that the Government will not be able to recoup, even if competition did exist.

Competition may yield lower prices but for a weapon syst m with a limited commercial market, which is significantly lower than the

. Additionally, since this is primarily a BPC customer funded contract, there is no feasible way to pay for any duplication of cost. Consequently, the only viable option is for a single country to bear the entire f nancial responsibly. If the in duplication costs were to be incurred by the BPC customer with the largest contract awarded to date it would r sult in a increase to their total cost.

Furthermore, maintaining two physically unique versions of a weapon, mount and support equipment with the same primary purpose would duplicate the logistical burden in terms of additional lifecycle costs. Based on subject matter expertise, it would have a detrimental impact on operator and maintenance training, an increased burden on logistics/supportability nd, in the case of other DoW Agencies, require a second, separate maintenance contract to provide repairs and refurbishment of weapons.

b. Alternatives: Dillon Aero, Inc. is not willing to sell the TDP for the M134D variants, mounting and support equipment to the Government. The Government made an inquiry with respect to the purchase of such data, to which Dillon Aero, Inc. confirmed on 10 December 2025 that the TDP is not available for purchase. Since this weapon system is not type classified by the U.S. Army, the need for the Army to purchase the TDP does not exist. There is no reason for the Army to purchase the TDP for an end item with no current or anticipated U.S. Army requirements, therefore, this alternative is not in the best interest of the Government. Current and future requirements, while still including other Government agencies, will be primarily driven by BPC. Notwithstanding the above, BPC requirements are specifically for M134D Minigun Systems and

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associated services produced and provided by Dillon Aero, Inc.

As outlined above, the development of an alternative procurement method leading to full and open competition does not exist since the Government has not been able to and the Government of Philippines specified Dillon Aero, Inc.

c. Impact if not approved:

7. Efforts to Obtain Competition: The notices r quired by FAR 5.201 shall be published and any bids or proposals received shall b considered.

a. Effective Competition: The Contracting Officer published Sources Sought Notice W15QKN-26-X-1C57 on 10 July 2026 via the Syst m for Award Management website (SAM.gov) in accordance with DFARS PGI 205 101-70. Based on the results of that notice, as well as additional Market Rese rch dated 11 August 2026, effective competition is not anticipated for thi action.

b. Subcontracting Competition: Subcontracting opportunities exist primarily for materials, components, and specialized services. Subcontract competition will be maximized to the fullest extent possible, as required by FAR 52.244-will be included in the resultant contract.

8. Actions to Increase Competition: The Government performs continuous Market Research through periodic internet searches, exchanges with industry, and Sources Sought Notices and has not yet found another system meeting the M134D system capability and Government requirements. The initial startup cost required of another contractor, with no guaranteed contract or steady demand to help offset that risk, serves as a large barrier to entry. On 10 December 2025, Dillon Aero, Inc. confirmed they are not willing to sell the TDP to the Government. With the Army Acquisition Objective having been met, the Army does not intend to fund the purchase of a TDP that the Army would not be able to utilize to realize any potential cost savings a competitive acquisition could produce. The Government will continuously conduct market research before any subsequent acquisition for these supplies and services to determine if other sources exist that may be able to provide an acceptable product to the Government.

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Previous acquisitions for M134D Minigun Systems and associated services in support of FMS cases with LOAs that required products from Dillon Aero, Inc. have been awarded as individual standalone contracts under other than full and open competition as approved within International Agreement Competitive Restriction documents under the authority of FAR 6.103-4, International agreement (formerly FAR 6.302-4).

9. Market Research: In accordance with FAR Part 10, DFARS 210.001, and DFARS PGI 206.103-170, a Sources Sought Notice, W15QKN-26-X-1C57, was posted to SAM.gov on 10 July 2026, with a closing date of 30 July 2026, to determine viable solutions to this requirement and to identify contractors capable of meeting the

. Three responses to the Notice were received: Dillon Aero, Inc., . The following is a detailed assessment of each response.

Dillon Aero, Inc. is the original equipment manufacturer (OEM) and sole source producer of the M134D. They provided a thorough response to the Sources Sought Notice. Dillon Aero, Inc. has fielded and supported mor than 6,500 weapons systems in more than 50+ countries. The Dillon M134D and M 34D-H became the standard model in U.S. and allied services in 2008. Wi h over 30 years of proven performance, Dillon Aero, Inc. has been awarded over 1,338 U S. Government contracts. Dillon Aero, Inc. is a proven OEM for the subject weapon systems, parts, mounting solutions, installation, and training. They have a well documented history of supplying U.S.

Government and international customers with proven hardware and thousands of individual units fielded. The M134D, M134D-H, and M134D-M Minigun Weapon Systems, mounting hardware, spare parts, installation, and training provided by Dillon Aero, Inc. is the lowest risk solution as they are a proven supplier for the subject requirement.

sent an email in esponse to the sources sought notice to express interest in M134 Weapons, tools parts and accessories. However, the vendor did not provide the information re uested or answers to most of the Questionnaire. It is not possible to determine the capabilit es and experience of this respondent based on the information provided. As a result, was determined to not be capable of producing or providing the required services for the subject requirement.

is not a supplier or manufacturer of the Dillon Aero M134 configuration. The response to the Sources Sought Notice indicates a number of design changes, and a limited production capability with no history of fielded units, only a completed live fire test for Limited Safety Release documentation and a next phase effort to provide 12 weapon systems. may eventually become a competitor for the Dillon M134 weapon system; however it is currently too early in the systems design lifecycle to meet the needs of this contract vehicle.

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12. Technical Certification: I certify that the supporting 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 certify that the supporting 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 determine that the anticipated price/cost to the Government for this contract action will be fair and reasonable. This determination will be made using a comparison of the proposed prices to historical prices paid, compari on with the Independent Government Estimate, and analysis of data other than certified cost or pricing in accordance with FAR 15.404-1(b)(2), (5), and (7). As part of the basis, certified cost or pricing will not be required per FAR 15. 03-2(b)(3), when a commercial product or commercial service is being acquir d.

15. Contracting Officer Certification: I certify 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 M134D-M Minigun Weapon Systems, Mounting Systems for Water Platforms, Parts, Accessories, Support Equipment, Installation, and Training for Operators and Maintainers 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)(i), Substantial duplication of cost to the Government that is not expected to be recovered through competition. The estimated value of the new contract is for a one-year Requirement contract with a one-year ordering period. The approval is subject to availability of funds, and provided that the suppli s and/or services herein described have otherwise been authorized for this acquisiti n.

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