[Government Liability for Unauthorized Emergency Telephone Services]

The Air Force requested permission to pay a company for emergency telephone services provided to an Air Force training range. The company took the initiative of installing an auxiliary generator to restore power after the main electrical transformer that served all the buildings on the training range had been disrupted and backup power could not be brought on line. GAO found that: (1) the services would have been a permissible procurement had formal procedures been followed; (2) the continued operation of telephone services at the range was in the interest of public safety and constituted a public necessity as established in Comptroller General decisions; and (3) the Air Force concluded that the amount of the claim was reasonable. Accordingly, payment for the emergency generator services was authorized on a quantum meruit basis.