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DOE Solution To Underfunded Pension Plans: Don't Pay For Them

Client Alert | less than 1 min read | 05.03.06

In a "notice" issued April 27, 2006 (http://directives.doe.gov/pdfs/doe/doetext/neword/351/n3511.pdf), DOE announced that "after a date to be negotiated with each Contractor, but no later than March 1, 2007," DOE will try to incorporate provisions in its contracts that would appear to make defined-benefit pensions and retiree medical benefits for new employees unallowable and prohibit reimbursement for plan enhancements unless approved in advance by DOE. It seems unlikely that DOE would have the authority to impose these requirements on existing contracts unilaterally, and some of them, particularly restrictions on the allowability of costs required by collective bargaining agreements, would conflict with existing FAR cost allowability rules.

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Client Alert | 5 min read | 09.03.26

DOT Final Rule Narrows Airline Delay and Cancellation Reporting Obligation Under FAA Reauthorization Act of 2024

The U.S. Department of Transportation (DOT) published a final rule amending 14 CFR Part 234 that fundamentally changes how airlines report the causes of flight delays and cancellations. Effective October 19, 2026, the rule implements Section 511(b) of the FAA Reauthorization Act of 2024 by creating a new reporting category, the “Section 511(b) category,” for ten specific events that Congress determined are not attributable to airline control. The rule simultaneously narrows the existing "Air Carrier" reporting category by expressly excluding those same ten events....