Circular No. A-76 -- Revised
1. This Appendix
provides guidance for use in cost comparisons involving the provision
of aircraft or aviation management support services. It has been
prepared to ease completion of cost comparisons conducted in accordance
with OMB Circular A-76 and OMB Circular A-126, "Improving
the Management and Use of Government Aircraft," dated May 22, 1992.
2. In accordance
with OMB Circular A-126, agencies should conduct approved cost comparisons
before retaining, purchasing or otherwise providing Federal aircraft
or aviation services not otherwise exempt from Circular A-76 (see
Part I). In reviewing aviation programs, agencies should consider
that although an activity or mission may be inherently governmental,
the tools needed to perform the activity are not necessarily inherently
governmental. Related aviation support services should be reviewed,
in accordance with this Supplement, for possible conversion to or
from in-house, contract or interservice support aggreement (ISSA)
performance. Leases for aircraft of 90 days or more are subject to
these principles and procedures.
may estimate lease, charter, or other contract aviation support costs
through the General Services Administration's (GSA) Federal Aviation
Management Information System (FAMIS) or other pre-approved data
sources. This approach avoids the need for formal solicitations to
acquire commercial bids for comparison with an in-house Government
cost estimate. Other aspects of the process described in this Supplement
4. When an aviation
cost comparison is conducted, the agency will notify affected Federal
employees and announce the tentative cost comparison decision in
the Commerce Business Daily. The announcement will initiate the A-76
Administrative Appeal process. The Performance Requirements Summary,
the Management Plan, including the calculation of commercial costs,
and the aviation cost comparison form will be made available to the
public upon request.
5. Appeals of
tentative aviation cost comparison decisions will be directed to
the agency's A-76 Administrative Appeal Authority, who will conduct
the appeal as provided in Part I and Part II of this Supplement.
6. These instructions
incorporate the cost element definitions used elsewhere in Parts
I and II of this Supplement. In addition, there are several cost
definitions that pertain to only aircraft and aviation services as
provided by this Appendix.
will provide copies of each aircraft or aviation cost comparison
to the GSA Office of Aircraft Management Division, when completed,
and to the Office of Management and Budget (OMB) upon request or
as required by OMB Circular A-11 to justify aircraft purchases.
should rely on commercial airline or other aviation services to
meet their aviation mission and transportation support needs.
2. In general,
the operations of aircraft and aviation services are commercial in
nature and are not inherently governmental. Certain Government officials
or missions may require enhanced levels of security, both on the
ground and in the air. In most cases, however, the aviation industry
can accommodate the Government's need for services and for on-board
security devices, special flight profiles, testing equipment, etc.
3. The number
of aircraft owned or leased by an agency may not exceed the number
necessary to carry out direct mission requirements and, then, only
where commercial operations are not as cost effective or are not
available, as demonstrated by the procedures of this Supplement.
4. The size
and capacity of agency aircraft acquired or leased should not exceed
that necessary to cost-effectively meet mission requirements, including
the crew and equipment for the mission flight profiles.
C. The Aviation
1. The Management
Plan for aircraft or aviation support services should conform to
the principles and procedures in Part I of this Supplement. The
Management Plan is structured to identify the lowest overall cost
to the taxpayer and to fully consider Government Owned Contractor
Operated (GOCO) options.
2. A Performance
Work Statement (PWS) or a Performance Requirements Summary (PRS)
is a part of the Management Plan. It should define the scope of services,
workload data and performance criteria needed to meet agency mission
requirements. It may not describe a specific kind or make or model
should determine if equipment and/or personnel can be fitted to a
contract or charter/rental aircraft agreement that results in a lower
total service cost to the Government. Equipment requirements include,
but are not limited to, aircraft, unique navigation, secure communication,
and flight test devices.
4. GSA FAMIS
data assume that the contractor will provide all related equipment,
including aircraft. Agencies that wish to use these aircraft cost
comparison procedures, under a GOCO arrangement, may need to solicit
adjusted rate schedules from a variety of sources. If acceptable
information sources are not available, a formal competition with
commercial and/or ISSA sources may be necessary.
5. If the scope
of the competition includes non-aviation support (ground support
activities), the cost of such in-house, contract or ISSA support
is calculated as provided in Part II of this Supplement.
D. The cost of
material and fuel costs are estimated and escalated as provided
in Part II of this Supplement.
E. Standard aviation
operation cost elements--variable
costs of operating aircraft are those costs that vary depending
on how much the aircraft are used. The specific variable cost elements
1. Fuel and
other fluids. These are the costs of aviation gasoline, jet fuel,
and other fluids, e.g., engine oil, hydraulic fluids, and water-methanol,
consumed by aircraft. Fuel costs are the cost per gallon times gallons
per hour. Engine oil and other lubricants can be estimated using
manufacturers' estimates or on the basis of an historic percentage
of engine fuel cost per hour.
2. Crew. The
crew costs that vary according to aircraft usage consist of travel
expenses, particularly reimbursement of subsistence, i.e., per diem
and miscellaneous expenses, overtime charges, and wages plus benefits
of crew members hired on an hourly or part-time basis.
lease or rental. When aircraft are obtained under an open-ended arrangement,
such as an on-call (hourly/availability rate) basis, the associated
lease or rental costs are considered variable costs.
4. Landing and
tie down fees (if applicable). Landing and tie down fees that are
not common costs and are associated with aircraft usage are considered
variable costs. Tie down fees for storing an aircraft at its base
of operations should be considered a fixed cost. Include the historic
fees paid or assessed per landing, times landings, divided by projected
maintenance and spares.
activities and parts costs based on aircraft use are variable costs.
All non-scheduled maintenance and all non-scheduled maintenance inspections
are also variable costs. Maintenance and inspection activities scheduled
on a calendar interval basis will be considered fixed. In addition
to the costs of normal maintenance activities, variable maintenance
costs include aircraft refurbishment, such as painting and interior
restoration, and costs of or allowances for performing overhauls
and modifications required by service bulletins and airworthiness
labor. All labor expended by mechanics, exclusive of the overhaul
or major repair of components and engines.
parts. This includes materials and parts consumed in aircraft
maintenance and inspections, exclusive of materials and parts
for engine overhaul, aircraft refurbishment, and/or repair
of major components. Typical items in this category are tires,
instruments, avionics, generators, relays, pumps, brakes, filters,
airframe hardware, windows, interiors, paint, shafting, and
bearings not inside components covered under an overhaul.
contracts. This includes all contracted costs for unscheduled
maintenance and for maintenance scheduled on a flying hour
basis or based on the condition of the part or component.
- Engine overhaul,
aircraft refurbishment, and major component repairs. These
are the materials and labor costs of overhauling engines, refurbishing
aircraft, and/or repairing major aircraft components.
This is for overhauling components of engines, and other major
work including painting, refurbishment of the aircraft interior,
and expenses not recognized in other maintenance accounts.
- Add lines
5a through 5e and enter on line 5f for the total cost of direct
variable maintenance and spares.
6. Add lines
1 through 4 and 5f to find the total direct operations cost per flight
7. Enter the
annual number of flight hours from the PWS/PRS.
the total direct operating cost per flight hour (line 6) by the number
of flight hours (line 7) to find the total direct operating cost.
F. Standard aviation
operation cost elements--fixed
costs of operating aircraft are those that result from owning and
supporting the aircraft and do not vary according to aircraft usage.
9. Crew. Federal
pilots/crew are often paid whether or not the aircraft are flown.
These fixed crew costs include the salaries, benefits, and training
costs of crew members who perform minimal aircraft maintenance or
other administrative tasks that could be impacted by a conversion
to contract performance. Also included in fixed crew costs are the
costs of their charts, personal protective equipment, uniforms, and
other personal equipment when the agency is authorized to purchase
such items. Non-aviation activities performed by pilots/crew that
would continue even if operations were converted to contract should
not be included.
10. Fixed maintenance.
and inspection activities are scheduled on a calendar interval basis
and take place regardless of whether or how much the aircraft are
flown. These are fixed costs, including labor and material.
labor. This includes all projected labor expended by mechanics,
technicians, and inspectors associated with maintenance scheduled
on a calendar interval basis. This category also includes costs
associated with non-allocated maintenance labor expenses; i.e.,
associated salaries, benefits, travel expenses, and training
costs. These costs should be evenly allocated over the number
of aircraft in the fleet.
parts. This includes all parts and consumables used for maintenance
scheduled on a calendar interval basis.
contracts. This includes all contracted costs for maintenance
or inspections scheduled on a calendar interval basis.
lease. When aircraft are leased for 90 days or more, with a known
fee, utilization rate or minimum reimbursement guarantee, the associated
lease costs are considered fixed. Include the entire amount paid.
in Part II of this Supplement, aircraft and other major asset (hangar)
depreciation costs are added to each option year. Aircraft have finite
economic or useful service lives. Depreciation is the method used
to spread the acquisition cost, less residual value, over an asset's
useful life. Although these costs are not direct outlays as is the
case with most other costs, it is important to recognize them for
analysis. Subtract the residual (not market) value from the total
of the acquisition cost plus any capital improvements and, then,
divide by the remaining estimated useful life of the asset--not less
than the cost comparison period.
acquisition cost is the value initially recorded on agency
property/accounting records at the time of acquisition. If
the aircraft is acquired through an interagency transfer, the
acquisition cost is the greater of the aircraft net book value
plus the cost of returning the aircraft to an airworthy, mission
ready condition or the commercial retail value of that aircraft
in average condition, as established by the Aircraft Bluebook
Price Digest or other industry standard. If it is a military
aircraft without a direct commercial equivalent, the acquisition
cost is equal to the most comparable commercial equivalent
plus the cost of returning the aircraft to an airworthy, mission
ready condition. The following explains the relevant terms:
- Useful life.
Useful life is the estimated period during which the aircraft
will be used. If a new aircraft has an airframe with a design
life of 10,000 hours and the agency expects to fly the aircraft
500 hours per year, the useful life is twenty years.
value. Residual value reflects the historically expected condition
of the asset at the end of its useful life. It is the dollar
value below which the asset will not be depreciated. Residual
value is established at the time of acquisition. Agencies will
select the lessor of the following methods to calculate the
residual value of aircraft:
a 10 percent residual value for purposes of calculating the
depreciable value of the aircraft and annual depreciation expenses.
(2) Select the average of the historic resale value of similar
aircraft by age and type, as provided by GSA.
conversions, refurbishment, and certification of ex-military
aircraft. These maintenance efforts add value or prolong the
life of aircraft. They are capital improvements that add to
the Net Book Value of the asset (acquisition cost less accumulated
depreciation). This revised total value should then be depreciated
over the remaining or extended useful life of the asset.
- Fully depreciated
assets. If an asset has been fully depreciated or has exceeded
its expected useful life, recalculate the depreciation schedule
through the end of the cost comparison period.
13. Self insurance costs.
involves risks, potential casualty losses and liability claims. These
risks are covered in the commercial sector by purchasing insurance,
the costs for which are captured within the GSA FAMIS system. Actual
or historic agency costs are not comparable with the costs included
in the commercial bid (FAMIS) or representative of the overall cost
to the Government as a whole.
should calculate annual in-house hull aircraft casualty insurance
costs by multiplying the "Blue Book" or market value
of the aircraft by the insurance factors provided annually
by the General Services Administration's Aircraft Management
Division. Enter these cost estimates on line 13a.
should calculate annual Federal aircraft liability insurance
costs on the basis of the number of aircraft seats the agency
has or will install, including pilots, over the course of the
cost comparison period. Enter the aircraft liability cost developed
using data provided annually by the General Services Administration's
Aircraft Management Division on line 13b.
- All other
insurance costs incurred in the performance of the aviation
service under study are calculated in accordance with Part
II and entered on Line 13a or 13b, as appropriate.
- Enter the
total for all insurance (sum of lines 13a through 13c) on Line
This includes all costs associated with operational and administrative
overhead. As described in Part II of this Supplement, aviation management
overhead costs shall be calculated by applying the standard overhead
cost factor of 12 percent to the total of lines 2, 5.a, 9 and 10.a
of the Aircraft and Aviation Cost comparison Form. Enter the total
of this calculation on Line 14.
15. Cost of
capital or finance expense.
cost of capital is the annual cost to the Government of acquiring
the funds necessary for capital investments. The cost of capital
is applied to the outstanding balance of the aircraft purchase
price for each year of the performance period.
- The annual
cost of capital is included for any depreciable asset acquired
less than two years prior to or after the cost comparison that
will be used as a part of the MEO. The cost of capital is only
applicable to assets required by the MEO that will not be provided
(GOCO) to the commercial source.
- The cost
of capital is calculated by applying OMB Circular A-94
"Discount Rates to be Used in Evaluating Deferred Costs and
Benefits," plus any capital improvements.
- If the purchase
price is unknown, as in the case of a forfeited asset or interagency
transfer, the acquisition cost is the greater of the aircraft
net book value plus the cost of returning the aircraft to an
airworthy, mission ready condition or the commercial retail
value of that aircraft in average condition, as established
by the Aircraft Bluebook Price Digest or other industry standard.
If it is a military aircraft without a direct commercial equivalent,
the acquisition cost is equal to the most comparable commercial
equivalent plus the cost of returning the aircraft to an airworthy,
mission ready condition.
acquired through lease/purchase arrangements are not be burdened
with the cost of capital. The cost of capital is assumed to
exist in the lease/purchase agreement. At the transfer of title,
depreciation expenses, calculated from the then existent market
price of the aircraft, will be incurred.
16. Total fixed
operating costs. Add lines 9 through 15 and enter on line 16.
17. Total in-house
MEO performance costs. Add lines 8 and 16 and enter on line 17.
G. Standard aviation
operation cost elements--developing the cost of contract performance
18. Contract cost.
comparable cost of contract performance is to be calculated
on the Aviation CCF.
- The most
efficient commercial cost of meeting the service requirement
is to be entered if a solicitation was issued requesting formal
bids. If GSA/FAMIS data is being used to estimate contract
costs, this figure is established by reviewing existing contracts
and rental/charter flight rate information provided by FAMIS
or from other GSA approved sources.
the estimated trip costs times the number of trips/missions
or the hourly rate for that aircraft times the number of estimated
flight hours from the PWS/PRS on line 19. If FAMIS does not
reflect the aircraft services requirements, and reasonably
accurate costs cannot be constructed by extrapolation from
the FAMIS database, agencies may utilize other approved data
19. Cost construction
to meet PWS/PRS.
There may be
other adjustments necessary to estimate the cost of contract performance
using GSA/FAMIS data. The following are other costs that may be considered
and entered--to the extent that they are not common costs or costs
included in the published/developed rates. All such costs will be
fully justified and made available for public review.
Pilot and Crew Charges.
Not Provided by the Government.
Ground Service Support.
- Travel and
administration. There will be costs that the agency incurs in administering
the contract. These costs are relevant only if they differ between
in-house and contract alternatives. Agencies should refer to Part
II, Chapter 3, Table 3-1 for guidance.
conversion costs. See Part II, Chapter 3 of this Supplement.
22. Gain from
disposal/transfer of assets. See Part II Chapter 3 of this Supplement.
income tax. Multiply line 19 as provided in Appendix 5 and enter
as a savings/revenue to the Government caused by the conversion to
24. Total estimated
cost of contract performance. This element reflects the total of
lines 18 through 24.
H. Aviation cost
comparison of in-house versus contractor or ISSA performance.
performance costs. Data is taken from Line 17--for each year of
performance as established in the PRS, but not less than three
or ISSA performance. Data is taken from line 24--for each year of
differential. As provided in Part II of this Supplement, a conversion
differential equal to the lesser of; (1) 10 percent of the in- house
personnel related costs (total of Lines 2, 5.a, 9 and 10.a.) or (2)
$10 million over the performance period, is added to the total cost
of current method of performance. Enter the result of this calculation
on Line 27.
total cost of in-house performance. If the cost comparison is being
conducted to determine if an aircraft or aviation service should
be converted from contract or ISSA performance to in-house operation,
the conversion differential as calculated above (Line 27) is added
to the In-house performance cost estimate (Line 25, Total Column
only) and the sum is entered under Adjusted Total Cost of In-House
Performance (Line 28). The amount in the Total Column for Line 26
is replicated on Line 29.
total cost of contract performance. If the cost comparison is being
conducted to determine if an aircraft or aviation service should
be converted from in-house operation to contract or ISSA performance,
the conversion differential as calculated above (Line 27) is added
to the Contract performance cost estimate (Line 26, Total Column
only) and the sum is entered under Adjusted Total Cost of Contract
Performance(Line 29). The amount in the Total Column for Line 25
is replicated on Line 28.
Subtract Line 28 from Line 29 and enter the result on Line 30. A
positive amount on Line 30 supports a decision to perform the aircraft
and aviation support activity with in-house resources. A negative
amount on Line 30 supports a decision to accomplish the work with
31. Cost comparison decision.
the appropriate block on line 31 the decision supported by line 30.
- If the
result of the comparison is a decision to accomplish the work
with contract resource and that decision is affirmed after
adjustments by the public review, the agency will:
the Performance Requirements Summary developed under the aviation
methodology to meet the requirements of a Performance Work
(2) Issue a formal solicitation for bids from the
commercial sector and convert to contract.
- If the decision
of the aviation cost comparison is to accomplish the work with
in-house resources, and that decision is affirmed after adjustments
by the public review, the agency will announce the final decision
in the Commerce Business Daily. The results will be recorded
in the OMB Circular A-76 tracking system.
THE A-76 AIRCRAFT AND AVIATION COST COMPARISON FORM
DIRECT OPERATION COST PER FLIGHT HOUR (PFH)
1. Fuel and and Other Fluids $_____
2. Crew (PFH) _____
3. Aircraft Lease or Rental _____
4. Landing and Tie-Down Fees (If applicable) _____
5. Variable Maintenance and Spares
a. Maintenance Labor @ $___ per hour
multiplied by ___ man-hours PFH ____
b. Maintenance Parts ____
c. Maintenance Contracts ____
d. Engine over-haul, etc. ____
e. Reserves ____
f. Total variable maintenance cost _____
6. Total Direct Operating Cost Per Flight Hour _____
7. Flight Hours for PWS. _____
8. TOTAL DIRECT OPERATING COST (line 6 x line 7) $_____
FIXED OPERATING ANNUAL COST
9. Crew _____
10. Fixed Maintenance
a. Maintenance Labor _____
b. Maintenance Parts _____
c. Maintenance Contracts _____
11. Aircraft Lease _____
12. Depreciation _____
13. Self Insurance
a. Hull _____
b. Liability _____
c1. Casualty _____
c2. Personnel Liability _____
d. Total Self-Insurance _____
14. Overhead _____
15. Cost of Capital or Finance expense _____
16. TOTAL FIXED OPERATING ANNUAL COST (Lines 9
thru 15) $_____
17. TOTAL IN-HOUSE PERFORMANCE COST (Lines 8 + 16)$_____
CONTRACT AVIATION OPERATIONS COST WORKSHEET
18. Contract (PFH times number of hours)$_____
19. Cost construction to meet PWS
a. Daily availability/guarantee hours _____
b. Additional pilot and crew charges _____
c. Additional maintenance support _____
d. Airframe alteration/equipment
e. Equipment not provided by Government _____
f. Additional ground service support _____
g. Travel and per diem _____
h. Service equipment mileage _____
i. Airport fees _____
j. Other _____
20. Contract Administration _____
21. One-time Conversion _____
22. Gain on Disposal/Transfer of Assets
23. Federal income tax (deduct) (_____)
24. TOTAL CONTRACT PERFORMANCE COST $_____
IN-HOUSE VERSUS CONTRACT PERFORMANCE
1st 2nd 3rd Add'l TOTAL
25. In-house performance $______ $______ $______ $______ $______
26. Contract performance $______ $______ $______ $______ $______
27. Conversion Differential $______
28. Adjusted Total Cost of In-House Performance $______
29. Adjusted Total Cost of Contract Performance $______
30. Decision - Line 29 minus Line 28: $______
31. COST COMPARISON DECISION: Accomplish Work
In-house (+) $______
Contract (-) $______
32. In-House MEO Certified By:__________________________
Office and Title
"I certify that, to the best of my knowledge and
belief, the in-house organization reflected in this
cost comparison is the most efficient and cost
effective organization that is fully capable of
performing the scope of work and tasks of the PWS/PRS.
I further certify that I have obtained from the
appropriate authority concurrence that the
organizational structure, as proposed, can and will be
fully implemented - subject to this cost comparison, in
accordance with all applicable Federal regulations.
33. In-House Cost Estimate Prepared By:_________________
34. Independent Reviewer: _________________________
Office and Title
"I certify that I have reviewed the PWS/PRS, Management
Plan, In-house and GSA/FAMIS cost estimates and
supporting documentation available prior to bid opening
and to the best of my knowledge and ability have
determined that: (1) the ability of the in-house MEO to
perform the work contained in the PWS/PRS at the
estimated costs included in this cost comparison is
reasonably established, (2) that the selection and
inclusion of contract performance costs are reasonable
and, (3) that all costs entered on the cost comparison
have been prepared in accordance with the principles
and procedures of Circular A-76 and its Supplement.
35. Cost Comparison Completed By: ________________
36. Contracting Officer: ________________
37. Tentative Cost Comparison
Decision Announced By: ________________
38. Appeal Authority (if applicable):________________
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