B-137441, JANUARY 29, 1959, 38 COMP. GEN. 513

B-137441, JANUARY 29, 1959, 38 COMP. GEN. 513

MILITARY PERSONNEL - TRAVEL - PERMANENT CHANGE OF STATION - TRAVEL TIME COMPUTATIONS - MIXED MODES OF TRAVEL ANY TRAVEL TIME ON PERMANENT CHANGE OF STATION OF MEMBERS OF THE UNIFORMED SERVICES WHICH MAY BE CONSIDERED INCIDENT TO THE PERSONAL CONVENIENCE OF THE TRAVELER, TO THE EXTENT THAT IT EXCEEDS THE TRAVEL TIME NECESSARY TO ACCOMPLISH THE TRAVEL REQUIRED, SHOULD NOT BE CONSIDERED AS AUTHORIZED TRAVEL TIME BUT SHOULD BE CHARGED AGAINST AUTHORIZED LEAVE OF ABSENCE. ALTHOUGH THE AUTHORIZATION AND DIRECTION OF ANY PARTICULAR MODES OF TRAVEL ARE PRIMARILY MATTERS FOR ADMINISTRATIVE DETERMINATION THAT THE USE OF THAT MODE IS IN THE GOVERNMENT'S INTEREST, TIME REQUIRED TO PERFORM TRAVEL BY THE MODE SPECIFIED WILL BE COMPUTED ON SUCH BASIS UNLESS EVIDENCE CLEARLY INDICATES THAT THE MODE USED WAS AUTHORIZED PRIMARILY FOR THE CONVENIENCE OF THE TRAVELER TO PERMIT HIS ABSENCE FROM DUTIES FOR PERSONAL REASONS, SUCH AS FOR LEAVE OR CIRCUITOUS TRAVEL, IN WHICH CASE TIME SHOULD BE COMPUTED ON BASIS OF TRAVEL BY COMMERCIAL CARRIER OVER THE DIRECT ROUTE AND EXCESS TRAVEL TIME CHARGED TO LEAVE. THE COMPUTATION OF TRAVEL TIME ON A MILEAGE BASIS WHEN DIFFERENT MODES OF TRANSPORTATION ARE AUTHORIZED FOR MEMBERS OF THE UNIFORMED SERVICES ON PERMANENT CHANGE OF STATION WILL NOT BE OBJECTED TO; HOWEVER, THE USE OF A 300-MILE FIGURE AS THE MEASURE FOR ONE DAY'S TRAVEL TIME FOR TRAVEL BY PRIVATELY OWNED AUTOMOBILE, WITH AN ADDED DAY ALLOWABLE FOR FRACTIONS EXCEEDING 150 MILES, WOULD BE MORE REALISTIC THAN THE PROPOSED 250-MILE AND 125-MILE MEASURE; AND IT IS ALSO RECOMMENDED THAT DISPARITY IN COMPUTATION OF TRAVEL TIME FOR MEMBERS WHO TRAVEL BY AIR UNDER ORDERS DIRECTING AIR TRAVEL AND FOR THOSE WHO TRAVEL BY AIR UNDER ORDERS WHICH DO NOT DIRECT THAT MODE BE ELIMINATED. WHERE TRAVEL BY THE PRIVATELY OWNED AUTOMOBILE IS AUTHORIZED FOR MEMBERS OF THE UNIFORMED SERVICES ON PERMANENT CHANGE OF STATION AND THE MEMBER USES SUCH TRANSPORTATION FOR ONLY PART OF THE TRAVEL AND A COMMERCIAL CARRIER FOR THE BALANCE OF THE TRAVEL, TIME SHOULD BE COMPUTED ON THE BASIS OF TRAVEL BY COMMERCIAL CARRIER BY THE DIRECT ROUTE IN ABSENCE OF AFFIRMATIVE EVIDENCE THAT COMBINATION OF DIFFERENT MODES OF TRAVEL WAS NOT FOR THE PERSONAL CONVENIENCE OF THE TRAVELER.

TO THE SECRETARY OF DEFENSE, JANUARY 29, 1959:

REFERENCE IS MADE TO LETTER OF SEPTEMBER 18, 1958, FROM THE ACTING ASSISTANT SECRETARY OF DEFENSE ( COMPTROLLER), REQUESTING DECISION AS TO WHETHER LEGAL OBJECTION EXISTS TO THE ADOPTION BY THE DEPARTMENT OF DEFENSE OF RULES FOR THE COMPUTATION OF TRAVEL TIME INCIDENT TO PERMANENT CHANGE OF STATION OF MILITARY PERSONNEL RECOMMENDED BY THE DEPARTMENT OF DEFENSE MILITARY PAY AND ALLOWANCE COMMITTEE UNDER THE CIRCUMSTANCES OUTLINED IN COMMITTEE ACTION NO. 206, A COPY OF WHICH WAS ATTACHED.

THE STATED PURPOSE OF THE COMMITTEE ACTION IS TO SET FORTH SIMPLIFIED PROCEDURES OR RULES UNIFORMLY APPLICABLE TO MEMBERS OF THE VARIOUS ARMED FORCES TO GOVERN THE COMPUTATION OF AUTHORIZED TRAVEL TIME ON PERMANENT CHANGE OF STATION FOR TRAVEL PERFORMED ENTIRELY BY PRIVATELY OWNED VEHICLE, ENTIRELY BY COMMERCIAL CARRIERS, OR PARTLY BY EACH, TO REPLACE EXISTING REGULATIONS WHICH LACK UNIFORMITY BETWEEN THE SERVICES AND WHICH ARE CONSIDERED TO BE INADEQUATE IN OTHER RESPECTS, PARTICULARLY WITH RESPECT TO THOSE SITUATIONS WHERE BOTH PRIVATELY OWNED CONVEYANCE AND COMMERCIAL CARRIERS ARE USED FOR THE SAME CHANGE OF STATION.

IN EXPLANATION OF THE FORMULATION OF THE RULES PROPOSED, IT IS STATED THAT EASE OF UNDERSTANDING AND ADMINISTRATION AND UNIFORMITY OF APPLICATION WERE THE OBJECTIVES SOUGHT, AND ALSO THAT THERE WAS AN EFFORT TO GIVE MAXIMUM CONSIDERATION TO MEMBERS WHILE AT THE SAME TIME GIVING ADEQUATE PROTECTION TO THE INTERESTS OF THE GOVERNMENT. ON THE BASIS THAT THE USE OF MILEAGE RATES PROVIDE A GREATLY SIMPLIFIED METHOD FOR TRAVEL TIME COMPUTATION FOR TRAVEL BY COMMERCIAL CARRIERS AND PRIVATE CONVEYANCES, THE PROPOSED RULES PROVIDE AS FOLLOWS FOR SITUATIONS WHERE BUT ONE METHOD OF TRANSPORTATION IS INVOLVED:

(1) TRAVEL BY COMMERCIAL CARRIER. TRAVEL TIME FOR TRAVEL IN THE UNITED STATES BY MEANS OF ANY COMMERCIAL CARRIER, ON PERMANENT CHANGE OF STATION ORDERS WHICH DO NOT DIRECT THE USE OF COMMERCIAL OR GOVERNMENT AIR, WILL BE BASED ON THE RATE OF 720 MILES PER DAY OR FRACTION THEREOF. FOR TRANSOCEANIC TRAVEL BY VESSEL, THE ACTUAL TIME REQUIRED WILL BE USED.

(2) TRAVEL BY PRIVATELY OWNED CONVEYANCE. TRAVEL TIME FOR TRAVEL BY PRIVATELY OWNED CONVEYANCE, ON PERMANENT CHANGE OF STATION ORDERS WHICH PERMIT THIS MODE OF TRANSPORTATION, WILL BE BASED ON THE RATE OF 250 MILES PER DAY WITH AN EXTRA DAY ALLOWED FOR ANY EXCESS OF 125 MILES OR MORE OVER MULTIPLES OF 250.

THE PROCEDURE RECOMMENDED FOR COMPUTING TRAVEL TIME WHEN BOTH COMMERCIAL CARRIERS AND PRIVATE CONVEYANCES ARE USED IS STATED TO HAVE BEEN DEVELOPED ON THE BASIS OF THE FOLLOWING PRINCIPLES AND ASSUMPTIONS:

(1) ALL TRAVEL PERFORMED AFTER DETACHMENT SHOULD BE CONSIDERED AS INCIDENT TO THE CHANGE OF STATION SINCE IN THE MAJORITY OF INSTANCES IT WOULD NOT HAVE BEEN PERFORMED IF ORDERS HAD NOT BEEN ISSUED.

(2) MEMBERS SHOULD BE GIVEN MAXIMUM CONSIDERATION FOR TRAVEL BY PRIVATELY OWNED CONVEYANCE.

(3) ARITHMETICAL COMPUTATIONS AND THE NUMBER OF SMALL MILEAGES TO BE CONSIDERED SHOULD BE KEPT TO A MINIMUM. THUS ALL PERIODS OF TRAVEL BY PRIVATE CONVEYANCE SHOULD BE ADDED TOGETHER AND CONSIDERED AS A TOTAL IN DETERMINING THE APPLICABLE TRAVEL TIME. ONLY ONE CALCULATION SHOULD BE REQUIRED FOR TRAVEL BY COMMON CARRIER FOR THE REMAINING DISTANCE.

(4) THE TOTAL TRAVEL TIME AUTHORIZED WHEN MIXED MODES OF TRANSPORTATION ARE USED SHOULD NOT EXCEED THAT WHICH WOULD BE APPLICABLE IF THE TOTAL OFFICIAL DISTANCE WERE TRAVELED BY PRIVATE CONVEYANCE.

(5) WHEN TRAVEL IS PERFORMED BY GOVERNMENT CONVEYANCE OR ON GOVERNMENT TRANSPORTATION REQUESTS UNDER ORDERS WHICH DO NOT SPECIFICALLY DIRECT TRAVEL BY AIR, TRAVEL TIME SHOULD BE COMPUTED IN THE SAME MANNER AS THAT APPLICABLE TO SIMILAR TRAVEL BY COMMERCIAL CARRIER OR PRIVATELY OWNED VEHICLE. THERE APPEARS TO BE NO COGENT REASON FOR SETTING UP SEPARATE REGULATIONS FOR TRAVEL TIME IN CONNECTION WITH TRAVEL BY SIMILAR OR IDENTICAL MEANS SOLELY BECAUSE ONE CONVEYANCE IS OWNED BY THE GOVERNMENT OR THE TRANSPORTATION IS PROCURED AT GOVERNMENT INSTEAD OF PERSONAL EXPENSE.

THE PROPOSED PROCEDURE IS AS FOLLOWS:

(3) TRAVEL TIME WHEN BOTH PRIVATELY OWNED VEHICLE AND COMMERCIAL CARRIER ARE SUED.---WHEN TRAVEL IS PERFORMED BY BOTH PRIVATELY OWNED VEHICLE AND BY COMMERCIAL CARRIER/S), ON PERMANENT CHANGE OF STATION ORDERS UNDER WHICH TRAVEL BY PRIVATE VEHICLE IS ALLOWED, TRAVEL TIME WILL BE COMPUTED AS FOLLOWS. THE OFFICIAL DISTANCES BETWEEN THE STARTING POINT OF TRAVEL BY PRIVATE VEHICLE DIRECT TO THE POINT AT WHICH THE MODE OF TRANSPORTATION WAS CHANGED WILL BE DETERMINED, REGARDLESS OF THE STAGE OF THE TRAVEL WHERE THIS MODE OF TRANSPORTATION WAS USED. INTERMEDIATE STOPOVERS WILL NOT BE CONSIDERED. IF THERE IS MORE THAN ONE PERIOD OF TRAVEL BY PRIVATE VEHICLE, THE DISTANCES FOR EACH WILL BE DETERMINED AS ABOVE AND THE MILEAGES FOR ALL PERIODS OF SUCH TRAVEL WILL BE TOTALED. IF THIS TOTAL EQUALS OR EXCEEDS THE DISTANCE ALLOWED FROM THE OLD TO THE NEW STATION, TRAVEL TIME WILL BE ALLOWED FOR THE OFFICIAL DISTANCE IN ACCORDANCE WITH PAR (2). IF THE TOTAL DISTANCE TRAVELED BY PRIVATELY OWNED VEHICLE IS LESS THAN THE OFFICIAL DISTANCE BETWEEN THE DUTY STATIONS, THE DISTANCE TRAVELED BY PRIVATE VEHICLE WILL BE DEDUCTED FROM THE TOTAL OFFICIAL DISTANCE. THE TOTAL TRAVEL TIME ALLOWED WILL THEN BE THE SUM OF THAT ALLOWED FOR THE DISTANCE TRAVELED BY PRIVATE VEHICLE AS COMPUTED IN ACCORDANCE WITH PAR (2) PLUS TRAVEL TIME FOR THE REMAINDER OF THE OFFICIAL DISTANCE COMPUTED IN ACCORDANCE WITH PAR (1) FOR TRAVEL BY COMMERCIAL CARRIER. IF THE DISTANCE TRAVELED BY PRIVATE VEHICLE IS 125 MILES OR MORE IN EXCESS OF 250 MILES OR MULTIPLES THEREOF, AN EXTRA DAY'S TRAVEL TIME WILL BE ALLOWED. IF THE EXCESS IS LESS THAN 125 MILES, SUCH EXCESS WILL BE DISREGARDED. REGARDLESS OF THE NUMBER OF MODES OF TRANSPORTATION UTILIZED, ONLY ONE DAY'S TRAVEL TIME WILL BE ALLOWED WHEN THE OFFICIAL DISTANCE BETWEEN THE OLD AND THE NEW DUTY STATIONS IS LESS THAN 375 MILES. FURTHERMORE, IN NO CASE WILL MORE TRAVEL TIME BE ALLOWED THAN WOULD BE AUTHORIZED IF THE TOTAL TRAVEL TIME BE ALLOWED THAN WOULD BE AUTHORIZED IF THE TOTAL TRAVEL HAD BEEN PERFORMED BY PRIVATELY OWNED VEHICLE. WHEN TEMPORARY DUTY IS DIRECTED EN ROUTE, EACH LEG OF THE ORDERED TRAVEL WILL BE COMPUTED SEPARATELY. * * *

THE PROPOSED RULES PROVIDE AS FOLLOWS FOR CIRCUMSTANCES WHERE AIR TRAVEL IS SPECIFIED:

(4) TRAVEL TIME WHEN AIR TRAVEL SPECIFIED. WHEN ORDERS DIRECT TRAVEL BY GOVERNMENT OR COMMERCIAL AIR AND SUCH MODE IS ACTUALLY USED FOR THE ENTIRE TRAVEL, ONE DAY'S TRAVEL TIME WILL BE ALLOWED FOR TRAVEL IN THE UNITED STATES. FOR TRAVEL OUTSIDE THE UNITED STATES, ACTUAL SCHEDULES OVER THE MOST DIRECT ROUTE WILL BE USED AS THE BASIS FOR DETERMINING AUTHORIZED TRAVEL TIME. TRAVEL TIME WILL BE COMPUTED AS WHOLE DAYS. IF THE ALLOWED TRAVEL TIME COMPUTED AS ABOVE IS INSUFFICIENT, ADDITIONAL TIME, AS NECESSARY, MAY BE AUTHORIZED IF THE TRAVELER CERTIFIES THAT THE ADDITIONAL TRAVEL TIME WAS ACTUALLY REQUIRED (EXCLUSIVE OF PERSONAL PREFERENCE OR CONVENIENCE), STATING THE SPECIFIC REASONS CAUSING THE DELAY. WHEN TRAVEL IS PERFORMED PARTLY BY AIR AND PARTLY BY OTHER MEANS UNDER THE TYPE OF ORDERS REFERRED TO HEREIN, TRAVEL TIME SHALL BE COMPUTED ON A COMBINATION OF METHODS PRESCRIBED IN THIS PARAGRAPH AND IN PARAGRAPH (1) FOR APPLICABLE PORTIONS OF TRAVEL.

WHERE THE GOVERNMENT CONVEYANCE IS UTILIZED, THE RULES PROVIDE:

(5) TRAVEL TIME WHEN GOVERNMENT CONVEYANCE IS UTILIZED. WHEN ALL OR PART OF THE TRAVEL IN CONNECTION WITH A PERMANENT CHANGE OF STATION, UNDER ORDERS WHICH DO NOT SPECIFICALLY DIRECT TRAVEL BY AIR, IS PERFORMED BY GOVERNMENT CONVEYANCE, TRAVEL TIME FOR SUCH TRAVEL WILL BE COMPUTED IN THE SAME MANNER AS THAT FOR COMMERCIAL CARRIER AND/OR PRIVATELY OWNED VEHICLE (AS APPROPRIATE) IN ACCORDANCE WITH PARAGRAPHS (1), (2), AND (3).

WE KNOW OF NO SOUND OR REASONABLE BASIS UPON WHICH TO CONCLUDE THAT TRAVEL TIME ON PERMANENT CHANGE OF STATION MIGHT BE ALLOWED FOR ANY PURPOSE OTHER THAN TO ACCOMPLISH THE TRAVEL REQUIRED UNDER THE CHANGE OF STATION ORDERS. CONSEQUENTLY, UNLESS THE COLLATERAL CONSIDERATION OF CONVENIENCE TO THE TRAVELER CAN FIT WITHIN THAT FRAMEWORK, WE ARE OF THE OPINION THAT ANY TIME FOR TRAVEL ARISING FROM PERSONAL REASONS, TO THE EXTENT THAT IT EXCEEDS THE TRAVEL TIME NECESSARY TO MEET THE BASIC TRAVEL REQUIREMENTS IN A MANNER AND BY A MEANS IN WHICH IT CAN BE SAID THAT THE GOVERNMENT'S INTEREST IS INVOLVED, SHOULD NOT BE CONSIDERED AS AUTHORIZED TRAVEL TIME, BUT PROPERLY SHOULD BE A CHARGE AGAINST AUTHORIZED LEAVE OF ABSENCE.

QUESTIONS AS TO THE NEED OR DESIRABILITY, IN THE INTEREST OF THE GOVERNMENT, TO AUTHORIZE OR DIRECT ANY PARTICULAR MODES OF TRAVEL FOR USE BY MILITARY PERSONNEL ON CHANGE OF STATION ARE PRIMARILY MATTERS FOR ADMINISTRATIVE DETERMINATION. CONSEQUENTLY WE ASSUME, GENERALLY, THAT AUTHORIZATION TO TRAVEL BY ANY MODE DIRECTED OR PERMITTED BY THE TRAVEL ORDERS HAS BEEN EXTENDED ON THE BASIS OF AN ADMINISTRATIVE DETERMINATION THAT THE USE OF THAT MODE IS IN THE GOVERNMENT'S INTEREST, AND WE WILL NOT OBJECT TO THE COMPUTATION OF TRAVEL TIME REQUIRED TO PERFORM THE NECESSARY TRAVEL BY THAT MODE, UNLESS EVIDENCE IS AVAILABLE WHICH CLEARLY INDICATES THAT THE MODE USED IN A PARTICULAR CASE ACTUALLY WAS AUTHORIZED PRIMARILY FOR THE CONVENIENCE OF THE TRAVELER TO ENABLE HIM TO BE ABSENT FROM HIS ASSIGNED DUTIES FOR PERSONAL REASONS IN CONNECTION WITH MATTERS SUCH AS THE GRANTING OF LEAVE OR THE PERFORMANCE OF CIRCUITOUS TRAVEL. IN THOSE CIRCUMSTANCES, TRAVEL TIME PROPERLY SHOULD BE COMPUTED ON THE BASIS OF TRAVEL BY COMMERCIAL CARRIER OVER THE DIRECT ROUTE AND THE EXCESS TRAVEL TIME INVOLVED SHOULD BE CHARGED TO LEAVE. THE GRANTING OF LEAVE EN ROUTE ALONE WILL NOT BE REGARDED AS SUFFICIENT EVIDENCE THAT TRAVEL BY PRIVATELY OWNED CONVEYANCE WAS AUTHORIZED FOR PERSONAL REASONS.

WE FIND NO LEGAL OBJECTION TO THE COMPUTATION OF TRAVEL TIME ON A MILEAGE BASIS AS PROPOSED FOR TRAVEL BY EACH OF THE DIFFERENT MEANS OF TRANSPORTATION, IF CONSIDERED DESIRABLE, ALTHOUGH THE USE OF A 300-MILE FIGURE AS THE MEASURE FOR ALLOWING ONE DAY'S TRAVEL TIME FOR TRAVEL BY PRIVATELY OWNED CONVEYANCE WITH AN ADDED DAY ALLOWABLE FOR FRACTIONS EXCEEDING 150 MILES, CORRESPONDING TO THE RATE SET OUT IN EXECUTIVE ORDER NO. 10153, AUGUST 17, 1950, AND EXECUTIVE ORDER NO. 10649, DECEMBER 28, 1955, FOR A SIMILAR PURPOSE, IS BELIEVED TO PRESENT A MORE REALISTIC APPROACH TO THE MATTER THAN THAT PROPOSED. ALSO, IT IS NOTED THAT THE PROPOSED RULES WOULD ALLOW TRAVEL TIME OF ONE DAY TO A MEMBER WHO TRAVELS BY AIR IN THE UNITED STATES UNDER ORDERS DIRECTING AIR TRAVEL, WHILE THE MEMBER PERFORMING THE SAME TRAVEL BY AIR UNDER ORDERS THAT DO NOT DIRECT TRAVEL BY THAT MODE OF TRANSPORTATION WOULD BE ALLOWED TRAVEL TIME COMPUTED ON THE BASIS OF CREDIT FOR ONE DAY FOR EACH 720 MILES OR FRACTION THEREOF. THERE WOULD APPEAR TO BE LITTLE JUSTIFICATION FOR SUCH DISPARITY. WE FEEL, THEREFORE, THAT CONSIDERATION SHOULD BE GIVEN TO THE NEED FOR INCLUDING LANGUAGE IN THE RULES TO RESTRICT THE ALLOWANCE OF TRAVEL TIME IN CASES WHERE GOVERNMENT OR COMMERCIAL AIR IS USED FOR THE ENTIRE TRAVEL INVOLVED ON THE BASIS SET FORTH IN PARAGRAPH (4) OF THE PROPOSED PROCEDURE, QUOTED ABOVE, IRRESPECTIVE OF WHETHER OR NOT TRAVEL BY AIR IS DIRECTED.

WITH REFERENCE TO THE PROPOSED RULES COVERING SITUATIONS WHERE BOTH PRIVATELY OWNED CONVEYANCE AND COMMERCIAL CARRIER ARE USED UNDER ORDERS ALLOWING TRAVEL BY PRIVATELY OWNED VEHICLE, IT WOULD APPEAR THAT IN ALL BUT VERY EXCEPTIONAL CASES PERSONAL CONVENIENCE RATHER THAN THE GOVERNMENT'S INTEREST WOULD BE THE PRIMARY FACTOR INVOLVED. WHILE IT IS RECOGNIZED THAT A SUFFICIENT ELEMENT OF GOVERNMENT INTEREST MAY EXIST IN THE ACCOMPLISHMENT OF TRAVEL BY PRIVATELY OWNED CONVEYANCE TO AUTHORIZE THE ALLOWANCE OF MORE TRAVEL TIME THAN IS PERMITTED FOR TRAVEL BY COMMERCIAL TRANSPORTATION AND WE HAVE ASSUMED, GENERALLY, THAT IF TRAVEL BY SUCH MEANS IS AUTHORIZED THERE HAS BEEN ADMINISTRATIVE DETERMINATION THAT SUCH INTEREST WAS INVOLVED, THAT ASSUMPTION WAS BASED ON THE BELIEF THAT THE DETERMINATION AS TO THE GOVERNMENT'S INTEREST HAD AS ITS BASIS THE EXPECTATION THAT ALL TRAVEL WOULD BE BY AUTOMOBILE AND THAT SUCH INTEREST ACTUALLY WAS ASSOCIATED WITH THE USE OF PRIVATELY OWNED CONVEYANCE FOR ALL TRAVEL TO THE NEW STATION. THE NATURE OF THE GOVERNMENT'S INTEREST IN TRAVEL BY PRIVATELY OWNED CONVEYANCE IS RATHER TENUOUS SINCE SUCH INTEREST ORDINARILY IS BEST SERVED BY THE USE OF MORE EXPEDITIOUS MEANS OF TRANSPORTATION. IF, AFTER BEING AUTHORIZED TO TRAVEL BY PRIVATELY OWNED CONVEYANCE, THE TRAVELER USES SUCH TRANSPORTATION FOR ONLY A PART OF THE TRAVEL TO HIS NEW STATION, WITH THE TACIT CONSENT OF THE ADMINISTRATIVE AGENCY CONCERNED, A QUESTION ARISES AS TO WHETHER A PUBLIC INTEREST IS INVOLVED IN ANY OF THE TRAVEL BY THAT MEANS OF TRANSPORTATION. CONSEQUENTLY, IN THE ABSENCE OF AFFIRMATIVE EVIDENCE IN SUCH CASES THAT TRAVEL BY A COMBINATION OF PRIVATELY OWNED VEHICLE AND COMMERCIAL CARRIER WAS PERFORMED ONLY FOR THE PURPOSE OF ACCOMPLISHING THE TRAVEL REQUIRED BY THE ORDERS AND NOT FOR PERSONAL REASONS SUCH AS CIRCUITOUS TRAVEL OR THE TAKING OF LEAVE, TRAVEL TIME SHOULD BE COMPUTED ON THE BASIS OF TRAVEL BY COMMERCIAL CARRIER BY THE DIRECT ROUTE RATHER THAN ON THE BASIS SET FORTH IN THE PROPOSED RULES.