FT-Weapon idea MDC

I have some DP9 mini spaceships, and was thinking about a weapon to 
represent the mass driver cannons (the tripple turrets mounted on the 
ships). The spinal mount laser weapons I can use K-guns for, and the 
missiles use SMLs, but I am after something different for the MDCs.

My idea for the MDCs is as follows-

Mass=3 mass for 1 arc, 4 mass for 3 arcs, 5 mass for 6 arcs.

Cost=4x mass.

Dammage=1 Die at long range (0-36 mu), 3 Die at medium range (0-24 mu),
6 
Die at close range (0-12 mu). Ranges are the maximum that the
coresponding 
dammage may fire upto. Ignores sheilds, but has no reroll for 6`s. Non 
penitrating, so all dammage taken against armour first.

Ammo=10 rounds per mass (at 4x cost). Uses 1 round for a limited (long 
range) burst, 3 rounds for a moderate burst (medium range), and 6 rounds
for 
a continus burst (close range). May elect to fire a shorter burst than 
nesasery or able to if desired (can fire a limited burst at 0-12 mu if 
wished).

PDS=May fire as PDS if not fired in anti-ship mode that turn, using same

rules as KV scatterguns (including ADFC/firing in support of anouther
ship). 
Uses 1 round for PDS fire.

Fircon=Requires use of a firecon at all times, even in PDS mode. In PDS 
mode, 1 firecon can control any amount of MDC`s against separate
targets.

This is my idea that I have actually spent some time thinking about, and

just need to know if it`s ballanced for cost/mass/dammage, and if it may

require altering.

BIF
(looking for comments and help)

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