B-165340, OCTOBER 21, 1968, 48 COMP. GEN. 226

B-165340: Oct 21, 1968

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THE COST TO A CIVILIAN EMPLOYEE TO EQUIP A HOUSETRAILER TRANSPORTED INCIDENT TO A PERMANENT CHANGE OF STATION WITH AN EXTRA AXLE IN COMPLIANCE WITH STATE LAW IS NOT A REIMBURSABLE EXPENSE. THE EXPENDITURE REPRESENTING THE COST OF A STRUCTURAL CHANGE IN THE TRAILER CONSTITUTES A CAPITAL IMPROVEMENT THAT IS NOT REIMBURSABLE AS A MISCELLANEOUS EXPENSE UNDER SECTION 3 OF BUREAU OF THE BUDGET CIRCULAR NO. REIMBURSEMENT FOR THE COST OF THE AXLE IS EXCLUDED UNDER SECTION 9.3A (3) OF THE CIRCULAR. HUFFMAN WAS AUTHORIZED TO TRAVEL FROM PHOENIX. A HOUSETRAILER TO BE USED AS A RESIDENCE WAS AUTHORIZED TO BE TRANSPORTED AT GOVERNMENT EXPENSE. HUFFMAN $324.71 TO HAVE A THIRD AXLE PUT ONTO HIS 12 FOOT X 60 FOOT HOUSETRAILER PRIOR TO THE MOVE.

B-165340, OCTOBER 21, 1968, 48 COMP. GEN. 226

TRAILER ALLOWANCES - CIVILIAN PERSONNEL - COSTS TO PREPARE TRAILER FOR SHIPMENT, ETC. THE COST TO A CIVILIAN EMPLOYEE TO EQUIP A HOUSETRAILER TRANSPORTED INCIDENT TO A PERMANENT CHANGE OF STATION WITH AN EXTRA AXLE IN COMPLIANCE WITH STATE LAW IS NOT A REIMBURSABLE EXPENSE. THE EXPENDITURE REPRESENTING THE COST OF A STRUCTURAL CHANGE IN THE TRAILER CONSTITUTES A CAPITAL IMPROVEMENT THAT IS NOT REIMBURSABLE AS A MISCELLANEOUS EXPENSE UNDER SECTION 3 OF BUREAU OF THE BUDGET CIRCULAR NO. A-56, AND THE STRUCTURAL CHANGE TO THE TRAILER HAVING BEEN INCURRED TO PREPARE THE TRAILER FOR MOVEMENT, REIMBURSEMENT FOR THE COST OF THE AXLE IS EXCLUDED UNDER SECTION 9.3A (3) OF THE CIRCULAR.

TO WILLIS H. STALEY, DEPARTMENT OF THE INTERIOR, OCTOBER 21, 1968:

THIS REFERS TO YOUR LETTER OF SEPTEMBER 23, 1968, REFERENCE 300, BY WHICH YOU FORWARDED FOR OUR ADVANCE DECISION THE RECLAIM VOUCHER OF JAMES D. HUFFMAN, AN EMPLOYEE OF THE BUREAU OF RECLAMATION, COVERING AN EXPENSE OF $324.71 INCIDENT TO THE TRANSPORATION OF A HOUSETRAILER UPON A PERMANENT CHANGE OF STATION.

BY TRAVEL AUTHORIZATION DATED APRIL 22, 1968, MR. HUFFMAN WAS AUTHORIZED TO TRAVEL FROM PHOENIX, ARIZONA, TO O-NEILL, NEBRASKA. A HOUSETRAILER TO BE USED AS A RESIDENCE WAS AUTHORIZED TO BE TRANSPORTED AT GOVERNMENT EXPENSE.

NEBRASKA LAW REQUIRES THAT ALL HOUSETRAILERS OVER 55 FEET IN LENGTH BE EQUIPPED WITH THREE (3) AXLES BEFORE A PERMIT TO TRAVEL OVER NEBRASKA HIGHWAYS CAN BE ISSUED. IT COST MR. HUFFMAN $324.71 TO HAVE A THIRD AXLE PUT ONTO HIS 12 FOOT X 60 FOOT HOUSETRAILER PRIOR TO THE MOVE.

THE COMPUTATION OF ALLOWANCES WHEN A HOUSETRAILER IS TRANSPORTED BY A COMMERCIAL CARRIER IS CONTAINED IN SECTION 9.3A OF BUREAU OF THE BUDGET CIRCULAR NO. A-56 WHICH PROVIDES AS FOLLOWS:

A. WHEN A HOUSE TRAILER IS TRANSPORTED BY A COMMERCIAL CARRIER,

(1) THE ALLOWANCE SHALL INCLUDE THE CARRIER'S CHARGES FOR ACTUAL TRANSPORTATION OF THE TRAILER IN AN AMOUNT NOT EXCEEDING THE APPLICABLE TARIFF AS APPROVED BY THE INTERSTATE COMMERCE COMMISSION (OR APPROPRIATE STATE REGULATORY BODY FOR INTRASTATE MOVEMENTS) FOR TRANSPORTATION OF A TRAILER OF THE SIZE AND TYPE INVOLVED FOR THE DISTANCE INVOLVED, COMPUTED AS PROVIDED IN SECTION 9.2.

(2) THE ALLOWANCE ALSO SHALL INCLUDE FERRY FARES AND BRIDGE, ROAD, AND TUNNEL TOLLS, TAXES, CHARGES OR FEES FIXED BY A STATE OR MUNICIPAL AUTHORITY FOR PERMITS TO TRANSPORT HOUSE TRAILERS IN OR THROUGH ITS JURISDICTION, SIMILAR CHARGES IMPOSED BY A CANADIAN JURISDICTION FOR A TRAILER BEING TRANSPORTED BETWEEN ALASKA AND THE CONTINENTAL UNITED STATES, AND CARRIERS' SERVICE CHARGES FOR OBTAINING NECESSARY PERMITS.

(3) ALLOWANCES SHALL NOT INCLUDE COSTS OF PREPARING TRAILERS FOR MOVEMENT, MAINTENANCE, REPAIRS, STORAGE, INSURANCE FOR VALUATION OF TRAILERS ABOVE CARRIERS' MAXIMUM RESPONSIBILITY, NOR CHARGES DESIGNATED IN THE TARIFFS AS "SPECIAL SERVICE.'

THE EXPENDITURE FOR WHICH REIMBURSEMENT IS CLAIMED REPRESENTS THE COST OF A STRUCTURAL CHANGE MADE IN THE TRAILER WHICH, ASIDE FROM BEING REQUIRED TO ALLOW TRANSPORTING OVER NEBRASKA ROADS, CONSTITUTED A CAPITAL IMPROVEMENT TO THE TRAILER. AN EXAMINATION OF THE NATURE OF THE EXPENSES FOR ALLOWANCES UNDER SECTIONS 9.3A (1) AND (2), ABOVE, REVEALS THAT NONE OF THE ITEMS INCLUDE THE COST OF A MAJOR MODIFICATION OF A HOUSETRAILER SUCH AS HERE INVOLVED IN ORDER TO COMPLY WITH A STATE LAW. THE COST OF SUCH MODIFICATION MORE REASONABLY MAY BE REGARDED AS BEING EXCLUDED BY SECTION 9.3A (3) AS A COST OF PREPARING THE TRAILER FOR MOVEMENT. THEREFORE, WE DO NOT BELIEVE THAT THE ALLOWANCES FOR THE TRANSPORTATION OF HOUSETRAILERS WERE INTENDED TO COVER SUCH COSTS. MOREOVER, BECAUSE THE COST WAS INCURRED FOR A STRUCTURAL MODIFICATION OF THE TRAILER, NO PART THEREOF WOULD BE REIMBURSABLE AS A MISCELLANEOUS EXPENSE UNDER SECTION 3 OF BUREAU OF THE BUDGET CIRCULAR NO. A-56. IN VIEW THEREOF, WE HOLD THAT THE COST OF MODIFYING A HOUSETRAILER--- IRRESPECTIVE OF WHETHER IT IS REQUIRED TO PERMIT ITS TRANSPORTATION OVER THE HIGHWAYS OF A PARTICULAR STATE--- DOES NOT FALL WITHIN THE PURVIEW OF THE STATUTORY REGULATIONS PERTAINING TO ALLOWANCES PAYABLE INCIDENT TO A PERMANENT CHANGE OF STATION. ACCORDINGLY, THE VOUCHER WHICH IS RETURNED HEREWITH MAY NOT BE CERTIFIED FOR PAYMENT.