The Defense Production Act (DPA) has long been viewed as the primary federal mechanism for managing and supporting defense production.  Since it was enacted in September 1950—just months after the Korean War began—the DPA has armed the President with wartime-style powers to prioritize contracts, allocate scarce materials, and finance surge defense production capacity.  These DPA industrial authorities are subject to periodic reauthorization, with the current sunset set for September 30, 2025.  While the reauthorization of the DPA remains pending, the Senate Armed Services Committee (SASC) has advanced a new NDAA provision that would convert the extant Industrial Base Fund (IBF) (10 U.S.C. section 4817) into a Pentagon-controlled toolkit that closely mirrors—but is not identical to—DPA’s Title III authorities.  The introduction of section 849A of the FY 2026 NDAA suggests that the SASC is no longer willing to entrust the re-armament of the Pentagon and revitalization of the Defense Industrial Base (DIB) solely to reauthorization of the DPA—a process that lives or dies in other committees’ jurisdictions. 

What Would Section 849A Actually Do?  First, section 849A broadens the IBF’s list of “eligible uses” so the Secretary of Defense can intervene anywhere along the supply chain—upstream, midstream, or downstream—as needed for:  castings and forgings; kinetic systems and platforms across the spectrum of sensing, targeting, and delivery; microelectronics; machine tools and other production equipment; critical minerals, materials, and chemicals; the DIB workforce; manned and unmanned systems; power sources; shipbuilding and submarines; defense space systems; even forward echelon advanced manufacturing nodes inside the Indo-Pacific theater.  Should the Secretary of Defense wish to invoke section 849A for a purpose not already covered by its expansive list, he need only justify the determination in a report to the Armed Services Committees at least 30 days in advance.

Second, section 849A would authorize virtually every familiar DPA Title III tool:  contracts, grants, other-transaction agreements, purchase commitments that can run for ten years, direct subsidies to “offset market manipulation” and keep higher-cost domestic production viable against cheaper imports, authority to stockpile strategic materials, and even permission for DoD to install government-owned equipment in private plants or build entirely new facilities whenever “necessary for the national security interests of the United States.”

Notably, section 849A expressly adds a pivotal new power:  funding equity stakes.  Nowhere in the DPA’s governing text—50 U.S.C. section 4533—does Congress expressly authorize the federal government to take an ownership interest in a private firm.  Section 849A flips that script.  New subsection (h)(3) would let the Secretary of Defense channel IBF dollars into “debt and equity investments” executed through third-party vehicles that support “small- and medium-sized entities working in areas of national-security interest.”  By explicitly opening the door to minority shareholdings, Congress offers the Pentagon a financing tool the traditional DPA has never expressly provided—one that can crowd in private capital, share in upside returns, and synchronize a company’s long-term growth with national security demand signals. 

How is Section 849A Different?  Although section 849A’s architecture is unmistakably DPA-like, the differences are consequential.  Chief among these is the transfer of program custodianship:  DPA authorities ultimately reside with the President and are parceled out across seventeen federal departments and agencies, whereas section 849A would lodge the whole portfolio in the Secretary of Defense.  That change matters in terms of speed and focus—no dilutive interagency clearance is required when the Secretary wants to underwrite a new solid rocket motor line or stand up a drone airframe factory.

Beyond the shift in custodianship, section 849A would also tighten the statute’s substantive reach, aiming it squarely at warfighting supply chains.  Whereas Title III defines “national defense” broadly enough to cover public health emergencies, critical infrastructure, and even commercial semiconductors, the SASC language limits spending to defense missions—especially those tied to Indo-Pacific operational needs.  It further erects a statutory bar:  no IBF money may be spent for any activity in China, Russia, Iran, or North Korea—a guardrail the DPA lacks.  Finally, it orders an annual return on investment report markedly more granular than Title III’s biennial industrial base review and a 90-day plan for coordinating IBF projects with the DPA Fund and the Pentagon’s Office of Strategic Capital. 

Funding mechanisms diverge as well.  Per 50 U.S.C. section 4534(e), the DPA Fund carries a statutory cap of $750 million in unobligated authority at each fiscal year’s close.  By contrast, section 849A would impose no ceiling; the size of the IBF would be whatever appropriations Congress supplies, as well as monies transferred from other DoD appropriations.  Congress took action to fill IBF coffers a month ago in the One Big Beautiful Bill Act (Public Law 119-21), which pours billions directly into the fund.  Among these direct appropriations:  $3.3 billion for grants and purchase commitments made from the IBF, $5 billion for IBF critical mineral projects, and $600 million for solid rocket motor expansion.  The Act also included a dizzying array of earmarked line items—$1 billion for one-way attack unmanned aerial systems, another $1 billion for artificial intelligence efforts, and nearly $15 billion for naval shipyard capacity, advanced manufacturing, and submarine procurement—some or all of which could be shifted into the IBF and further leveraged under its new authorities.  No comparable windfall has ever been routed through the government-wide DPA Fund.  In a single stroke, section 849A would transform what has been a modest pilot account into the largest single-department industrial base policy instrument in federal law. 

Why is the Senate Armed Services Committee Acting Now?  Four overlapping pressures explain the SASC’s sense of urgency.

Time pressure remains the most acute variable.  Both chambers stand adjourned until early September, leaving scant legislative days before the fiscal year’s end.  Although the Armed Services Committees can shepherd the NDAA, any DPA reauthorization must originate in the Senate Banking and House Financial Services Committees, and neither panel has yet scheduled a markup.  The stakes are amplified because the DPA’s September 30, 2025, sunset coincides with the date by which Congress must pass all 12 appropriations bills, wrap them into an omnibus, or at least adopt a continuing resolution to avert a government shutdown.  With congressional floor time already at a premium, there is some concern that DPA renewal could become collateral damage in a crowded queue. 

These headwinds are real.  If spending negotiations crowd out a standalone DPA bill, the statute could lapse—leaving only the current, comparatively modest IBF authority in force until the FY 2026 NDAA reaches the President’s desk, most likely in December 2025.  That outcome would be far from ideal, but not catastrophic:  section 849A would still arrive in time to backstop defense supply chains for the new calendar year, provided the provision survives conference intact.  The caution, then, is clear:  Congress can avoid any gap by pairing a short-term DPA extension with the looming appropriations package—or risk a brief, but very real, vacuum in surge production tools. 

Operational urgency is next.  Multiple joint exercises and think tank studies have concluded that U.S. stocks of anti-ship and air defense missiles would be depleted within weeks of a major Indo-Pacific conflict, outpacing current production capacity.  SASC wants a tool that can add machine tool capacity, forge canister casings, and certify new energetics without running a gauntlet of interagency coordination.

The certainty and security of supply chains is a third driver.  Section 849A’s explicit prohibition on work in covered countries ensures that not a dollar of the IBF will flow into Chinese-owned factories.  That blanket ban is easier to legislate in a defense-only statute than across the whole of government, where healthcare and energy requirements sometimes weigh in favor of broader sourcing flexibility under the DPA.

Finally, appropriations politics played a role.  The authors of the One Big Beautiful Bill Act were willing to send huge sums to the Pentagon, but needed an account with adequate legal authorities to obligate that money.  Expanding IBF appropriations through Public Law 119-21 and authorities through the NDAA would solve the problem in a way familiar to legislators:  create the funding and the authorities in tandem—a means to re-industrialize at scale without reinventing the DPA.

Deterrence Through Durable Production.  The real strength of any military is measured not just in brigades, squadrons, and ships, but in the factories, foundries, and fabs that build and sustain them.  By granting the Pentagon its own DPA-like authorities—and financing them at scale—Congress is attempting to ensure that the United States can out produce, not merely out fight, its rivals.  If the broader DPA is renewed, section 849A will complement it; if not, DoD will still wield a sovereign set of industrial levers.  Either outcome signals a strategic shift.  In this proposed revamping of the IBF, the SASC envisions a modern strategic production base, purpose built for the great power competitions of the twenty-first century.

Photo of Stephanie Barna Stephanie Barna

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior…

Stephanie Barna draws on over three decades of U.S. military and government service to provide advisory and advocacy support and counseling to clients facing policy and political challenges in the aerospace and defense sectors.

Prior to joining the firm, Stephanie was a senior leader on Capitol Hill and in the U.S. Department of Defense (DoD). Most recently, she was General Counsel of the Senate Armed Services Committee, where she was responsible for the annual $740 billion National Defense Authorization Act (NDAA). Additionally, she managed the Senate confirmation of three- and four-star military officers and civilians nominated by the President for appointment to senior political positions in DoD and the Department of Energy’s national security nuclear enterprise, and was the Committee’s lead for investigations.

Previously, as a senior executive in the Office of the Army General Counsel, Stephanie served as a legal advisor to three Army Secretaries. In 2014, Secretary of Defense Chuck Hagel appointed her to be the Principal Deputy Assistant Secretary of Defense for Manpower and Reserve Affairs. In that role, she was a principal advisor to the Secretary of Defense on all matters relating to civilian and military personnel, reserve integration, military community and family policy, and Total Force manpower and resources. Stephanie was later appointed by Secretary of Defense Jim Mattis to perform the duties of the Under Secretary of Defense for Personnel and Readiness, responsible for programs and funding of more than $35 billion.

Stephanie was also previously the Deputy General Counsel for Operations and Personnel in the Office of the Army General Counsel. She led a team of senior lawyers in resolving the full spectrum of issues arising from Army wartime operations and the life cycle of Army military and civilian personnel. Stephanie was also a personal advisor to the Army Secretary on his institutional reorganization and business transformation initiatives and acted for the Secretary in investigating irregularities in fielding of the Multiple Launch Rocket System and classified contracts. She also played a key role in a number of high-profile personnel investigations, including the WikiLeaks breach. Prior to her appointment as Deputy, she was Associate Deputy General Counsel (Operations and Personnel) and Acting Deputy General Counsel.

Stephanie is a retired Colonel in the U.S. Army and served in the U.S. Army Judge Advocate General’s Corps as an Assistant to the General Counsel, Office of the Army General Counsel; Deputy Staff Judge Advocate, U.S. Army Special Forces Command (Airborne); Special Assistant to the Assistant Secretary of the Army (Manpower & Reserve Affairs); and General Law Attorney, Administrative Law Division.

Stephanie was selected by the National Academy of Public Administration for inclusion in its 2022 Class of Academy Fellows, in recognition of her years of public administration service and expertise.

Photo of Scott A. Freling Scott A. Freling

Scott Freling co-chairs the firm’s Government Contracts practice and is recognized by Chambers USA as a leading practitioner. He divides his practice between representing civilian and defense contractors in traditional government contracts matters and guiding buyers and sellers—including a number of leading private…

Scott Freling co-chairs the firm’s Government Contracts practice and is recognized by Chambers USA as a leading practitioner. He divides his practice between representing civilian and defense contractors in traditional government contracts matters and guiding buyers and sellers—including a number of leading private equity firms—through the regulatory aspects of complex M&A deals involving government contractors.

Chambers USA ranks Scott as a Band 1 lawyer for Government Contracts M&A. Scott is sought after for his regulatory expertise and his ability to apply that knowledge to the transactional environment. He has extensive experience leading classified and unclassified due diligence reviews of government contractors, negotiating transaction documents, and assisting with integration and other post-closing activities. He has served as the lead government contracts lawyer in dozens of M&A deals, with a combined value of more than $80 billion. Scott’s notable transactions include Warburg Pincus and Berkshire Partners’ take-private acquisition of TRIUMPH for $3 billion, Advent International’s take-private acquisition of Maxar Technologies for $6.4 billion, Aptiv’s acquisition of Wind River for $3.5 billion, and Veritas Capital’s sale of Alion Science and Technology to Huntington Ingalls Industries for $1.65 billion.

Scott also represents contractors at all stages of the procurement process and in their dealings with federal, state, and local government customers. He handles a wide range of government contracts matters, including compliance counseling, contract terminations, claims, disputes, audits, and investigations. Scott frequently advises contractors on organizational conflicts of interest and government intellectual property rights. He also counsels clients on risk mitigation strategies, including obtaining SAFETY Act liability protection for anti-terrorism technologies.

Law360 has recognized Scott as a MVP in Government Contracts. He was a founding co-chair of the Mergers and Acquisitions Committee of the ABA’s Public Contract Law Section.

Photo of Nooree Lee Nooree Lee

Nooree Lee represents government contractors in all aspects of the procurement process and focuses his practice on the regulatory aspects of M&A activity, procurements involving emerging technologies, and international contracting matters.

Nooree advises government contractors and financial investors regarding the regulatory aspects of…

Nooree Lee represents government contractors in all aspects of the procurement process and focuses his practice on the regulatory aspects of M&A activity, procurements involving emerging technologies, and international contracting matters.

Nooree advises government contractors and financial investors regarding the regulatory aspects of corporate transactions and restructurings. His experience includes preparing businesses for sale, negotiating deal documents, coordinating large-scale diligence processes, and navigating pre- and post-closing regulatory approvals and integration. He has advised on 40+ M&A deals involving government contractors totaling over $30 billion in combined value. This includes Veritas Capital’s acquisition of Cubic Corp. for $2.8 billion; the acquisition of Perspecta Inc. by Veritas Capital portfolio company Peraton for $7.1 billion; and Cameco Corporation’s strategic partnership with Brookfield Renewable Partners to acquire Westinghouse Electric Company for $7.8+ billion.

Nooree also counsels clients focused on delivering emerging technologies to public sector customers. Over the past several years, his practice has expanded to include advising on the intersection of government procurement and artificial intelligence. Nooree counsels clients on the negotiation of AI-focused procurement and non-procurement agreements with the U.S. government and the rollout of federal and state-level regulations impacting the procurement and deployment of AI solutions on behalf of government agencies.

Nooree also counsels clients navigating the Foreign Military Sales (FMS) program and Foreign Military Financing (FMF) arrangements. Nooree has advised both U.S. and ex-U.S. companies in connection with defense sales to numerous foreign defense ministries, including those of Australia, Israel, Singapore, South Korea, and Taiwan.

Nooree maintains an active pro bono practice focusing on appeals of denied industrial security clearance applications and public housing and housing discrimination matters. In addition to his work within the firm, Nooree is an active member of the American Bar Association’s Section of Public Contract Law and has served on the Section Council and the Section’s Diversity Committee. He also served as the firm’s Fellow for the Leadership Council on Legal Diversity program in 2023.