AFMAN 65-604 states BP13 can be used. Can we use 3010 BP10 for Production Line Shutdown cost? Is there any information in FMR and/or any other guidances WRT shutdown funding?
Thank you very much
No, there is no reference in the DoD Financial Management Regulations (FMR) regarding the budgeting or execution of Production Line Shutdown costs. Moreover, the distinction between Budget Programs (in your case, Budget Program 10 and Budget Program 13) seems to be an Air Force policy/management item (i.e., the Navy uses no such denotation for their procurement budget exhibits, and they do not appear anywhere in the DoD FMR). As such, Budget Programs do not carry any fiscal law implications, so using one versus the other will not violate the Purpose Statute (or other fiscal law).
That said, the Services (in this case, the Air Force) are authorized to implement policy that is more restrictive than either the law or DoD policy for their own management purposes. This is the case in this situation, in that the AF Manual Guidance (AFMAN 65-604) seems to be the most authoritative source on Budget Programs.
More specifically, the AFMAN 65-604 states the following:
- In the very top header of the AFMAN 65-604: “COMPLIANCE WITH THIS PUBLICATION IS MANDATORY”:
- The top of page 2 states, “The authorities to waive wing/unit level requirements in this publication are identified with a Tier (“T-0, T-1, T-2, T-3”) number following the compliance statement. See Department of the Air Force Instruction (DAFI) 33-360, Publications and Forms Management, for a description of the authorities associated with the Tier numbers. Submit requests for waivers through the chain of command to the appropriate Tier waiver approval authority, or alternately, to the requestor’s commander for non-tiered compliance items. The use of the name or mark of any specific manufacturer, commercial product, commodity, or service in this publication does not imply endorsement by the DAF. Compliance with the attachments in this publication is mandatory.
- Section 9.23.2 (on page 109). “If the last production aircraft has been delivered, BP 1300 (Post Production Support) will be used for production line closedown costs.”
Summary: Given the lack of DoD FMR guidance and fiscal law implications, this would leave the Air Force’s policy (in this case, AFMAN 65-604) as the authoritative source of guidance for an Air Force program such as yours. As such, I would recommend that you either follow the policy in the AFMAN 65-604 (which calls for budgeting for Production Line Shutdown costs as BP13), or to seek out a waiver (in accordance with page 2 of the AFMAN 65-604) to instead budget for these Production Line Shutdown costs as BP10.