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88rocco

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About 88rocco

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  1. So you'd probably use FAR 12 procedures where GP is under the SAT?
  2. Sunstrider, Some factors to consider since you haven't explained the type of repairs needed: where will the materials come from for the repair? Would they be FFP? Is there a risk of losing the aircraft due to poor maintenance practices by the KTR? If so, how is that mitigated? Also, there wouldn't be any disposition requirements if the aircraft is only repaired and returned to the unit.
  3. Neil, the DoDI link had nothing to do labeling an item as GFP, only prior discussion of accountability when GFP is provided and ji's incorrect assumptions. Whether some of you agree or not, go ahead. I don't care. But the OP is just trying to tap dance around from inserting 52.245-1 by trying to call an aircraft wing incidental. Yeah, lets call a wet bay an office and we can setup some computers and desks in a fuel tank. Geesh. Not sure how much more clearer the definitions need to be. BLUF is, the OP's action most likely requires 52.245-1 which is a clause for what? Ah yes, GP / GFP (or anything else you want to call it). 45.000 (a) This part prescribes policies and procedures for providing Government property to contractors, contractors’ management and use of Government property; and reporting, redistributing, and disposing of contractor inventory. FAR 45 definition: “Government-furnished property” means property in the possession of, or directly acquired by, the Government and subsequently furnished to the contractor for performance of a contract. Government-furnished property includes, but is not limited to, spares and property furnished for repair, maintenance, overhaul, or modification. Government-furnished property also includes contractor-acquired property if the contractor-acquired property is a deliverable under a cost contract when accepted by the Government for continued use under the contract. 245.107 Contract clauses. (1)(i) In lieu of the prescription at FAR 45.107(d), use the clause at FAR 52.245-1, Government Property, in all purchase orders for repair, maintenance, overhaul, or modification of Government property regardless of the unit acquisition cost of the items to be repaired. How much clearer does it have to be for some?
  4. https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodi/500064p.pdf?ver=2019-06-10-100933-460 4.4. PROPERTY FURNISHED TO OR IN THE POSSESSION OF A THIRD PARTY. a. Although the DoD may not have physical custody, in order to maintain effective property accountability and for financial reporting purposes, DoD Components must establish and maintain records and accountability for government property of any value furnished to contractors as GFP or loaned to outside entities such as federal agencies, State and local governments, and foreign governments. f. Third party property management or accountability systems, e.g. custodial systems, must not supersede or replace the APSR or the accountable property records maintained by the DoD.
  5. I know the difference between the GP and GFP. I lazily made reference to "GFP" because unless the action falls under 45.107 (d), 52.245-1 should be inserted and then the wing will be treated as such. I believe the OP was searching more towards "how can I side-step inserting 52.245-1"; not really "how to define GFP". IRT 45(b)(5), seen a few times folks trying to s-t-r-e-t-c-h the definition of "incidental" and "on a govt installation" to try and justify NOT inserting 52.245-1 "GP Clause". ji20874, you made reference to: "but it IS NOT Government-furnished property (or probably is not, as the property likely remains on the Government's property records and never transfers to the contractor's property records). " GFP remains on the Govt Property APSR even when it's in the contractors hands. We maintain fiduciary accountability, while the contractor maintains stewardship.
  6. If we contract out repairs to a wing, it's still GFP no matter where it's located. Read DFARS 245.107.
  7. An aircraft/wing isn't even remotely considered incidental property. The examples of incidental in the FAR are to preclude the -1 clause use for small amounts of govt property (GP) where risk to assets do not need that much protection. Something you need to consider is how will our aircraft be protected while the contractor performs the repair? Is it minor repairs or major? Something to think about: - GFP definition includes: Government-furnished property includes, but is not limited to, spares and property furnished for repair, maintenance, overhaul, or modification. - 245.107 Contract clauses. (1)(i) In lieu of the prescription at FAR 45.107(d), use the clause at FAR 52.245-1, Government Property, in all purchase orders for repair, maintenance, overhaul, or modification of Government property regardless of the unit acquisition cost of the items to be repaired. - DFARS 228.370 - (b)(1) Use the clause at 252.228-7001, Ground and Flight Risk, in all solicitations and contracts for the acquisition, development, production, modification, maintenance, repair, flight, or overhaul of aircraft, except those solicitations and contracts– (i) That are strictly for activities incidental to the normal operations of the aircraft (e.g., refueling operations, minor non-structural actions not requiring towing such as replacing aircraft tires due to wear and tear); (ii) That are awarded under FAR Part 12 procedures and are for the acquisition, development, production, modification, maintenance, repair, flight, or overhaul of aircraft; or otherwise involving the furnishing of aircraft
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