John Walsh III

Heads Up...DoD News related to Architect - Engineering (AE) Services! (1) FINAL RULE Effective 8/26/2024 - DFARS Case 2024-D019 Architect and Engineering Service Fees. This rule changes DFARS to implement Section 2881 of the FY24 NDAA to increase the limitation of the contract price (i.e., "fee") for A-E services for the preparation and delivery of designs, plans, drawings, and specifications from 6% of the project's estimated construction cost to 10%. It is applicable to Army, Navy, and Air Force projects (references in 10 U.S.C. 7540,8612, and 9540). The new 10% limit replaces the 6% fee limitation on contract modifications for work not initially included in the contract and redesign, and applies only to that portion of the contract (or modification) price attributable to the preparation of designs, plans, drawings, and specifications. If a contract or modification also includes other services, the part of the price attributable to the other services is not subject to the fee limitation. (Personally, I've been waiting since the early 1990's for this percentage to change (and yes, I've been doing this THAT long). This makes it easier for small AE businesses to participate in the Federal space. So, YEA!) Permalink: https://lnkd.in/g7vF95R6 (2) PROPOSED RULE Comments due 9/27/2024 -- DFARS Case 2023-D007 Task Order and Delivery Order Contracting for Architectural and Engineering Services. This rules proposes a corresponding change to DFARS Subpart 216.5, Indefinite-Delivery Contracts, to require DoD Contracting Officers (KOs) to use qualification-based selections when awarding task orders and delivery orders for AE services that was previously implemented procedurally under FAR Subparts 16.500, 16.505, and 36.6 procedures in 2005 under the final rule for FAR Case 2004-001 Improvements in Contracting for Architect-Engineer Services. This proposed rule adds DoD-specific statutory guidance (10 U.S.C. 3406(h)(2)) to DFARS directing KOs not to request additional info regarding qualifications unless necessary to determine qualifications for a particular task order or delivery order under a multiple-award contract. There should be little to no impact from this proposed rule since there are no procedural changes, new clauses or provisions, and no new applicability in terms of thresholds or types of contracts. Permalink: https://lnkd.in/gwh2_38J

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DoD rule-makers have been busy with proposed rules for DFARS. Those of you with a NAICS code that begins with 5416--management, scientific, and technical consulting services NAICS--will want to pay attention to this first rule in particular... Preventing Conflicts of Interest for Certain Consulting Services (DFARS Case 2024-D007) - Proposes amending DFARS to-- ▶ implement Section 812 of the FY24 NDAA which prohibits DoD from awarding contracts assigned a North American Industry Classification System (NAICS) code beginning with 5416 to offerors who hold contracts that involve consulting services with certain covered foreign entities. ▶ add a new solicitation provision in which an offeror certifies whether the offeror, its subsidiaries, or affiliates hold a contract for consulting services with one or more covered foreign entities and whether the offeror maintains a conflict-of-interest mitigation plan that meets certain requirements. ▶ requires that if the offeror, its subsidiaries, or affiliates hold such a contract and the offeror is selected for award, the offeror may submit its existing conflict-of-interest mitigation plan, which will be incorporated into a contract resulting from the solicitation. The provision is prescribed for use in solicitations assigned a NAICS code beginning with 5416 that involve consulting services. (https://lnkd.in/gCdMD7D4) DoD Cost or Pricing Data Reporting Requirements (DFARS Case 2022-D004) - Would amend DFARS to-- ▶ require offerors to submit data other than certified cost or pricing data upon contracting officer request. ▶  establish a $2 million threshold for the Truthful Cost or Pricing Data statute requirements with respect to contract modifications, subcontracts, and modifications to subcontracts.  ▶ require that contract modifications to reflect the revised threshold be executed “as soon as practicable.” The proposed rule implements these changes via several proposed new clauses. (https://lnkd.in/gfNcW2rR) Public Access to Results of Federally Funded Research (DFARS Case 2020-D028) - Proposes two new clauses that require contractors with contracts that include fundamental research to develop and maintain a data management plan and to submit final peer-reviewed manuscripts to the Defense Technical Information Center’s publicly accessible repository. (https://lnkd.in/g7bDcij6) Comments for all proposed rules are due on 11/25/2024. Instructions to comment are found at each permalink.

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I never thought I would have a passionate opinion of DoD acquisition policies and practices - until I did. I just read Dan Ward's paper, "Buy the Way We Fight: Policies, Practices, and Partnerships" (link in post below) on why the US DoD must rethink it's acquisition thesis to fit within the context of the world in which is operates. I am sharing this paper because: 1) The information we didn't know that we needed: Always follow the money. "Buy the Way We Fight..." not only opens our eyes to new ways in which the US government can deploy precious DoD dollars to build stronger international alliances, drive efficiencies by lessening cost and time overruns significantly, and drive much needed innovation that can only come at the intersection of differing areas of expertise, experiences, and perspectives. And, all of this can be done by enhancing national security versus at the risk of it. 2) The paper was so good that the editor of the National Defense Magazine cited Dan's paper for his argument on updating antiquated acquisition policies around innovation: It's always interesting to me to see what industry experts see as game-changing - you might think that way too. Of course, this the defense industry - however, these take aways can be applied to any innovation-based culture. 3) The structure and tone of the paper to support Dan's point of view provide a master class on how to change deep seeded policies: The paper is an excellent example for my coaching clients, followers, and readers (and me) on how to craft a well-thought argument in a way that it becomes a roadmap to your vision by bringing the rest of us along and engaging us with new facts and expert insights and perspectives. Enjoy!

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So this is going to get interesting. The Department of Commerce has essentially stated that any foundational Large Language Model is a dual use defense asset and under federal regulatory control. Key sections out of this are: "To carry out its obligations under section 4.2(a) of E.O. 14110, BIS is exercising its DPA authority, which was delegated to the Department by the President in Executive Order 13603, and subsequently re-delegated within the Department to BIS, to collect information from U.S. companies that are developing, have plans to develop, or have the computing hardware necessary to develop dual-use foundation models. AI models are quickly becoming integral to numerous U.S. industries that are essential to the national defense." "The integration of AI models into the defense industrial base also requires the U.S. Government to take actions as needed to ensure that dual-use foundation models operate in a safe and reliable manner. Products integrating these models may operate in unpredictable or unreliable ways, potentially resulting in dangerous accidents, and a lack of reliability will make it difficult for the U.S. Government to use those products in contexts where the margin for error is small, including defense-related activities where accidents could result in injury or even loss of life. Thus, the U.S. Government needs information about how companies developing dual-use foundation models are training those models to respond to different kinds of inputs and information about how those companies have tested the safety and reliability of their models." The rule goes on to detail quarterly reporting requirements for the model developers. Covered entities are based on size of model and computing capability, not on use or feature. Lets see where this goes, I am sure OpenAI, Google, Microsoft, Tesla, Amazon are reading it carefully.

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📊 Critical Insights from This Week's Customer Conversations: Defense Manufacturing & Innovation The recently passed FY2025 National Defense Authorization Act (NDAA) highlights an urgent challenge in US manufacturing. Here's what's at stake: 🔹 Massive Defense Investment The Senate just passed an $886 billion defense policy bill, underscoring the critical need to rebuild our military stockpiles after supporting Ukraine. Notably, lawmakers expressed significant concerns about the Navy's approach to addressing #welder compensation and retention (link to article below) - a clear signal that the skilled labor shortage in defense manufacturing requires innovative solutions. ⚠️ The Workforce Crisis The most pressing challenge? A severe shortage of skilled labor, including welders, threatening our ability to meet these crucial production demands and critical timelines. 💡 Innovation Meeting National Security This is where cutting-edge automation becomes vital. At Path Robotics, we're seeing remarkable results: • Our autonomous welding systems are demonstrating the ability to match the output of 3-5 skilled welders with a single robotic cell • By automating the most physically demanding and hazardous welding tasks, we enable our expert welders to focus on complex work that demands their specialized knowledge and craftsmanship 🎯 Impact This technology isn't just about efficiency - it's about ensuring America's manufacturing capabilities can meet critical #defense requirements while enhancing the work environment for our skilled workforce. The intersection of national security and manufacturing innovation has never been more crucial. And solving the skilled labor shortage is absolutely key. https://lnkd.in/g83xwNi3 Path Robotics Andrew Lonsberry Joe Onderko John Paradise Alex Lonsberry US Navy #Manufacturing #Defense #Innovation #Robotics #NationalSecurity #Manufacturing40 #Welding #WeldAutomation #Automation #AI #Navy #Shipbuilding #Senate #Congress #USA #MadeInTheUSA #MadeInAmerica #OH #Midwest #RoboticWelding #LaborShortage #SkilledLabor #Onshoring

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Great article Gene Keselman and Fiona Murray. Dual-Use Is a Strategy, Not a Category (Nor a Trap) https://lnkd.in/gHUtgabr This is a critical strategy for our National sovereignty and global productivity. Many DOD innovations were dual-use and critical for defense and civil systems. But without a North Star and mission, there is NO chance of accelerating our nation's Innovation OODA loop. A key comment: "commercial customers emphasize features, benefits, user experience, and value propositions". Without a North Star, we will continue to pump out widgets, better mouse traps, and thousands of papers leading to “Death by a Thousand Cuts.” AI, NextG, Robotics, and Edge Computing are like concrete/asphalt/steel building blocks. What are we Building? Autonomy is not a feature; it will unleash the largest productivity boom & secure our national supply chains for both commercial and defense. The commercial industry has established the North Star for AUTONOMY PRIME. https://lnkd.in/gmGTE5Uk Mobilizing private infrastructure and innovation capital is critical to compete with China's Military-Civil-Fusion and Belt and Road Initiative. Industry 4.0 solutions like autonomous systems are a North Star that requires a whole-of-nation approach. The CONTINUUM of Innovation Capital aligns Innovation funds with Infrastructure Investment developed over the last 4-years with infrastructure investors, private equity, and federal agencies. In 1960, investors did not know what Venture Capital was; few know about the Continuum of Capital today. Simply put, it is the merging of Infrastructure Investors with Innovation Investors. https://lnkd.in/geVHueFz Autonomy Institute https://lnkd.in/ectbj8eA

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The DoD’s Office of Strategic Capital (OSC) Unveils FY25 Investment Strategy The U.S. Department of Defense’s OSC has released its Fiscal Year 2025 Investment Strategy, focusing on strengthening the defense industrial base through credit-based financial products and strategic private sector partnerships. The OSC Credit Program provides debt financing to eligible borrowers in critical technology areas that drive national and economic security. OSC’s loan and loan guarantee authority is utilized to attract and scale investments for national security. Key Highlights: 🎯 Targeted Investments – OSC is prioritizing critical technologies essential to national security by providing credit-based financial tools to sustain and expand defense capabilities. 🤝 Public-Private Collaboration – The strategy underscores the importance of working with private capital providers to drive innovation and enhance resource allocation within the defense sector. 🏭 Strengthening the Industrial Base – By implementing this approach, OSC aims to bolster the resilience and capacity of the defense industrial base to address evolving security challenges. Read the full strategy here: https://lnkd.in/efxzyz-X

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The debate surrounding manned fighter jets, especially in the context of the Air Force's review of the Next-Generation Air Dominance program, is gaining attention. The reassessment of requirements for 6th generation fighters is crucial amidst escalating costs and rapid technological progress. While Elon Musk has criticized the relevance of manned fighter jets like the F-35 in the era of drones, it's essential to recognize that both have unique strengths and can work in tandem. The decision to pause the NGAD program for a thorough analysis considering aspects like design, technology, and resource allocation is prudent. However, a prompt resolution is necessary, especially with the FY26 POM implications looming. (https://lnkd.in/e2NkZu3z)

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Shifting the focus to warfighter-driven needs and mission outcomes is the way forward. It’s about enabling industry to think creatively and deliver faster, solving challenges at the speed of relevance. Exciting times for #Innovation and #TechAcquisition! #WarfighterFirst #MissionOutcomes

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A Culture of Security is Vital In Aviation, Healthcare, and other sectors, you often hear about building a strong "Culture of Safety." This is one of the highest priorities for organizations which can impact human life. Building a culture of safety is seen as foundational. Without it, human lives will be lost. ​ The same goes for cybersecurity. With the great increase of threats, it is no longer adequate to educate people about the basics. There needs to be a strong culture of security. Everyone needs to feel free to speak up when they see something wrong or make a mistake. #cybersecurity #culture #resilience https://lnkd.in/edfTKAAA

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Garrett Smith would have you believe he's "a head in the clouds, visionary CEO who's not grounded in reality." But Reveal Technology's story proves otherwise. While some defense tech startups chase headlines and trade show sponsorships, Garrett and his team have quietly become the first commercial software solution certified on the Army's mobile network. Today on #CrossingtheValley, I sat down with Garrett and Dave Caudle, the company's VP of Defense, to unpack how a small team is revolutionizing tactical edge operations. This episode just might change how you think about defense tech. We cover: 🎯 The Power of Tactical Truth While others pitched PowerPoints to generals, Reveal spent time on ranges with sergeants and lieutenants, building capabilities they wished they had in combat. Result? When they finally met program leadership, the grassroots demand was undeniable. 💡 The Integration Revelation Most founders obsess over technology readiness (TRL). Reveal discovered early that integration readiness (IRL) is the real kingmaker. It's not enough to build great software – it has to seamlessly integrate into the warfighter's complex ecosystem. 🤝 The Platform Play What started as an edge mapping solution is morphing into something much bigger. With a recent acquisition and a $33.6M STRATFI award, Reveal is positioning to become the standard platform for AI-enabled operations at the tactical edge. Full episode available now at ValleyCrossers (dot) Com. Whether you're a founder, investor, or acquisition professional, you don't want to miss this. #DefenseTech #Military #Innovation #Leadership

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The formation of a tech consortium led by Palantir and Anduril is a game-changing move in the U.S. defense industry, shaking up traditional defense contracting. With heavyweights like SpaceX and OpenAI potentially on board, this consortium is poised to introduce agile methodologies and cutting-edge technologies that could redefine military capabilities. As the U.S. defense budget swells to around $850 billion, this initiative not only connects innovation with critical defense needs but also fosters healthy competition among tech giants and legacy contractors. The implications are enormous—accelerating advancements in autonomous systems and AI-driven decision-making while challenging the status quo. As we await formal announcements in January 2025, one thing is clear: the integration of Silicon Valley’s prowess with the defense sector is set to disrupt established norms and transform national security strategies. How will traditional defense players respond to this paradigm shift? The next few years will be crucial.

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After receiving many LinkedIn questions about how Dobbs Defense Solutions managed funding during our rapid growth, I wanted to share our journey. Social bias against women and minorities and our fast growth denied us access to traditional working capital and even COVID relief funds like PPP and EIDL. We relied on bootstrapping and factoring to move forward. While I’m not promoting factoring, it was our only option at the time. Thankfully, I was introduced to Parabilis - A Better Financial Partner for Government Contractors, a strategic partner that has been instrumental in helping us scale. If you’re in that awkward phase where traditional banking isn’t an option, I highly recommend Bruce Lyman and his team as a trusted resource. #SmallBusinessChallenges #FundingSolutions #Bootstrapping #Parabillis #GrowthAndResilience

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The Department of Defense (DoD) is proposing changes to the Defense Federal Acquisition Regulation Supplement (DFARS) to implement updates from the National Defense Authorization Acts (NDAAs) for FY 2018, 2021, and 2022. These changes aim to refine requirements for contractors to submit cost or pricing data. Key updates include: 1. Higher Threshold for Certified Cost or Pricing Data: The threshold is raised to $2 million, reducing paperwork for smaller contracts while maintaining certification requirements for larger ones. 2. New Requirements for Non-Certified Data: Contracting officers can request "data other than certified cost or pricing data" to verify price reasonableness, making organized and transparent pricing documentation essential. 3. Application to Commercial Products and Services: The rules now apply to commercial items, including off-the-shelf products and services, requiring the same data submissions as traditional contracts. 4. Stronger Focus on Fair Pricing: Contracting officers have increased authority to scrutinize pricing data, even when certified data isn’t mandatory, emphasizing the need for clear, well-documented pricing justifications. The public comment period for this proposed rule ends on November 25, 2024, with comments accepted at Regulations.gov.

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A few things to digest here: 1. Thank you Robert Metzger for volunteering all of your time to help make things happen. 2. A tax rebate or reduction is only available AFTER the fact, so that's not going to help much at all. Small businesses live or die on cash flow. 3. Any kind of loan - with interest - doesn't help the business, it just puts it further in debt. 4. Even if a business goes through with all of this, there is NO GUARANTEE they will ever win or renew a DiB contract. Ideas: Why not just have the government front the cost, and then deduct it from the payment? This would incentivize the government and prime contractors to use many different sub-contractors. Why not just use DIBCAC assessors to do the third party attestations? There is no training necessary.

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Heidi Shyu, the Pentagon's Chief Technology Officer, continues to emphasize the importance of the Rapid Defense Experimentation Reserve (RDER) program. Unlike traditional service-focused initiatives, RDER is designed to address the pressing needs of combatant commands through rigorous experimentation. By involving joint staff and combatant commands, RDER is strategically positioned to close capability gaps and prioritize joint warfighting needs. The program has already made significant strides, including the successful transition of projects like the Family of Integrated Targeting Cells, which notably reduced the U.S. Marine Corps' acquisition timeline. While lawmakers express concerns over RDER's progress, Shyu's commitment to developing and fielding critical military capabilities remains steadfast. At Samuel Group D.C., we recognize the critical role of such initiatives in enhancing national security. As trusted advisers to business and government, we are uniquely positioned to support our clients in navigating the complex landscape of defense and technology. Through the SamuelAdvantage™, we offer an unparalleled network and expertise to help C-suite executives, business organizations, and government leaders succeed in this evolving environment. Let’s work together to unlock new opportunities and drive progress. #Defense #NationalSecurity #Innovation #RDER #SamuelAdvantage https://lnkd.in/e64FpcPD

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Big thanks to Robert MacFarlane and Jeff Watkins for having me on the 435 Podcast to talk about transformation in Southern Utah, the perils and thrills of the aerospace industry, and a bunch of other stuff. https://lnkd.in/dG4Upysp

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DoD Weapon System Production and Sustainment at Risk: National Security Implications of Port Disruptions The recent U.S. port strike resolution may seem like a temporary reprieve, but it highlights significant vulnerabilities for the Department of Defense (DoD) supply chain—particularly in the context of weapon system production and sustainment. As labor costs rise and U.S. ports struggle with automation adoption, increased shipping fees and delays could severely impact the delivery of critical components needed for military platforms, from aircraft to precision-guided munitions. In a time of rising tensions with near-peer adversaries like China, these disruptions pose a real national security risk. The U.S. is already facing a $19 billion backlog in weapon transfers, including to key allies like Taiwan, and studies have shown that the U.S. could run out of long-range precision munitions in less than a week in the event of a major conflict. Supply chain vulnerabilities like these will only be exacerbated by rising costs and port inefficiencies. Furthermore, reliance on alternative foreign ports, particularly those in Mexico, where China has significant influence and investments, could introduce additional risks. Supply chain visibility in these ports is less robust, increasing the potential for foreign adversaries to exploit weaknesses in the defense industrial base. The DoD has already acknowledged its limited visibility into the lower tiers of its supply chain. This is a critical oversight that needs urgent attention, especially when many critical materials and electronic components are sourced from regions vulnerable to adversary control. The inability to track these vulnerabilities across the supply chain means delays and disruptions could cascade, undermining weapon system production and sustainment. To mitigate these risks, the DoD must accelerate its supply chain risk management efforts, modernize its industrial base, and reduce reliance on foreign ports by investing in domestic production capabilities. The development of “ever-warm” production lines for critical materials, as well as increased automation at U.S. ports, are key strategies that can enhance resilience and ensure the U.S. is prepared for any conflict scenario. Now more than ever, a robust, resilient, and secure supply chain is essential to maintaining military readiness and safeguarding national security. Govini #SupplyChainRisk #SupplyChainRiskManagenent #NationalSecurity #DoDLogistics #DefenseLogistics #WeaponSustainment #DefenseIndustrialBase #DefenseReadiness

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