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Capital Costs Must be Treated as Indirect Costs

Client Alert | 1 min read | 05.31.11

On May 12, 2011, the Armed Services Board of Contract Appeals issued yet another decision in the on-going Todd Pacific Shipyards Corporation appeal for reimbursement of costs associated with dry dock facilities. The Board's decision contained two key holdings: (1) the six-year statute of limitations for a CDA claim for cost recovery does not begin to run until the contractor has submitted an invoice for payment under the applicable contract's payment provisions (here the Allowable Cost and Payment Clause) seeking reimbursement of the amounts at issue, and the government has failed to pay the invoice, and (2) capital costs that benefit multiple cost objectives, such as those incurred by Todd for refurbishing a dry dock used for government and commercial work, must be charged as indirect costs and not direct costs.

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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....