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    If the GFRC was written for aircraft to be purchased by the DoD and generally not used for COCO aircraft, how does one get relief from 228.370 which states "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..." This seems pretty expansive and I don't see an exception for COCO, other than discussion in CMA 100. In the absence of the GFRC, should DCMA Instr 8210.10 or other DFARs be applied to COCO aircraft contracts? What should contracting officers understand about airworthiness and aircraft design changes performed under a DoD contract?


    Andrew, the GFRC (and AFI10-220 by invocation) can apply to COCO aircraft in rare occassions.  Most instances of government oversight of COCO flight and ground operations occur not thru the GFRC (protecting DoD aircraft), but thru directly referencing AFI10-220 on the contract.  The application of the flight and ground operating requirements in the Combined Instruction (AFI10-220) thru the use of attachments 15 and 16 in the Combined Instruction.  Given the varying nature of COCO operations, it most often comes down to the Service Waiver Authority's determination.

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