B-146389, AUGUST 3, 1961, 41 COMP. GEN. 82

B-146389, AUGUST 3, 1961, 41 COMP. GEN. 82

COMPENSATION - OVERTIME - TRAVEL TIME - BETWEEN RESIDENCE AND HEADQUARTERS - PERFORMANCE OF WORK STATUS - ARDUOUS CONDITIONS - CRITERIA THE TIME REQUIRED FOR TRAVEL BETWEEN THE RESIDENCE AND HEADQUARTERS OF AN EMPLOYEE WHO RESPONDS TO AN EMERGENCY CALL-BACK OUTSIDE HIS REGULARLY SCHEDULED ADMINISTRATIVE WORKWEEK TO PERFORM REPAIRS AT AN OUTLYING FACILITY--- WHICH TRAVEL DOES NOT INVOLVE THE PERFORMANCE OF ACTUAL WORK AND IS NOT CARRIED OUT UNDER ARDUOUS CONDITIONS--- MAY NOT BE CONSIDERED "TIME SPENT IN A TRAVEL STATUS AWAY FROM THE OFFICIAL DUTY STATION" WITHIN THE MEANING OF SECTION 204 OF THE FEDERAL EMPLOYEES PAY ACT OF 1945, 5 U.S.C. 912B, SO AS TO BE COMPENSABLE AS HOURS OF EMPLOYMENT. AN EMPLOYEE WHO, IN RESPONSE TO EMERGENCY CALL-BACK DUTY, WHILE TRAVELING IN A VEHICLE EQUIPPED WITH COMMUNICATIONS AND MONITORING EQUIPMENT TO THE REPAIR SITE, VISUALLY INSPECTS THE NAVIGATIONAL AIDS EN ROUTE AND COMMUNICATES WITH HEADQUARTERS IS REGARDED AS IN THE "PERFORMANCE OF WORK" AS THAT TERM IS USED IN SECTION 204 OF THE FEDERAL EMPLOYEES PAY ACT OF 1945, AS AMENDED, 5 U.S.C. 912B, FOR ENTITLEMENT TO COMPENSATION FOR SUCH WORK DURING TRAVEL, ALSO, IF NO WORK IS ACTUALLY PERFORMED DURING TRAVEL BUT THE TRAVEL BY MOTOR VEHICLE BETWEEN HEADQUARTERS AND THE FACILITY IS OVER UNUSUALLY ADVERSE TERRAIN OR DURING SEVERE WEATHER CONDITIONS--- AS DISTINGUISHED FROM TRAVEL OVER HARD SURFACED ROADS WHEN NO UNUSUALLY ADVERSE WEATHER CONDITIONS ARE ENCOUNTERED, OR TRAVEL BY RAIL OR OTHER COMMON CARRIER-- SUCH TRAVEL WOULD BE TRAVEL UNDER ARDUOUS CONDITIONS AND THEREFORE COMPENSABLE TIME. AN EMPLOYEE WHO, INCIDENT TO CALL-BACK DUTY OUTSIDE OF HIS REGULARLY SCHEDULED WORKWEEK, TRAVELS FROM HIS RESIDENCE DIRECTLY TO A FACILITY TO BE REPAIRED WITHOUT FIRST REPORTING TO HEADQUARTERS WHEN DURING THE COURSE OF SUCH TRAVEL IN A SPECIALLY EQUIPPED VEHICLE HE IS REQUIRED TO MONITOR, TO VISUALLY INSPECT NAVIGATIONAL AIDS EN ROUTE, AND TO COMMUNICATE FROM TIME TO TIME WITH HEADQUARTERS, OR WHEN THE TRAVEL IS PERFORMED UNDER ARDUOUS CONDITIONS, SUCH AS TRAVEL OVER UNUSUALLY ADVERSE TERRAIN OR DURING SEVERE WEATHER CONDITIONS, THE TRAVEL TIME IS COMPENSABLE UNDER SECTION 204 OF THE FEDERAL EMPLOYEES PAY ACT OF 1945, AS AMENDED, 5 U.S.C. 912B, PROVIDED THAT THE TIME CONSUMED IN TRAVEL FROM HIS RESIDENCE TO THE FACILITY TO BE REPAIRED IS NO GREATER THAN THE ESTIMATED TRAVEL TIME FROM HIS HEADQUARTERS TO SUCH FACILITY, WHICH ESTIMATED TRAVEL TIME MUST BE REGARDED AS THE MAXIMUM LIMITATION UPON TRAVEL TIME COMPENSABLE UNDER SECTION 204. IN THE DETERMINATION OF WHETHER WORK IS PERFORMED DURING TRAVEL AND OF WHETHER TRAVEL IS PERFORMED UNDER ARDUOUS CONDITIONS TO BE CONSIDERED COMPENSABLE AS HOURS OF EMPLOYMENT UNDER SECTION 204 OF THE FEDERAL EMPLOYEES PAY ACT OF 1945, AS AMENDED, 5 U.S.C. 912B, THE FOLLOWING PRINCIPLES ARE TO BE USED AS GUIDES: (1) THAT PREPARATION PRELIMINARY TO TRAVEL IS NOT CONSIDERED WORK (2) THE TIME OF THE TRAVEL, THAT IS, WHETHER PERFORMED DURING THE DAY OR NIGHT ORDINARILY IS NOT FOR CONSIDERATION IN DETERMINING WHETHER TRAVEL IS PERFORMED UNDER ARDUOUS CONDITIONS AND (2) A DISTINCTION MUST BE DRAWN BETWEEN ARDUOUS CONDITIONS AND HAZARDOUS CONDITIONS, HOWEVER, THE LATTER MIGHT CONTRIBUTE TO THE FORMER.

TO THE ADMINISTRATOR, FEDERAL AVIATION AGENCY, AUGUST 3, 1961:

ON JULY 11, 1961, YOU REQUESTED OUR DECISION UPON SEVERAL QUESTIONS CONCERNING TRAVEL-TIME PAY FOR TRAVEL PERFORMED BY EMPLOYEES OF YOUR AGENCY INCIDENT TO EMERGENCY CALL-BACK DUTY PERFORMED OUTSIDE THEIR REGULARLY SCHEDULED ADMINISTRATIVE WORKWEEKS. THE STATUTORY PROVISION GOVERNING THE PAYMENT OF TRAVEL-TIME COMPENSATION IS SECTION 204 OF THE FEDERAL EMPLOYEES PAY ACT OF 1945, AS ADDED BY SECTION 205 (B) OF THE ACT OF SEPTEMBER 1, 1954, 68 STAT. 1110, 5 U.S.C. 912B. THAT SECTION READS AS FOLLOWS:

SEC. 204. FOR THE PURPOSES OF THIS ACT, TIME SPENT IN A TRAVEL STATUS AWAY FROM THE OFFICIAL-DUTY STATION OF ANY OFFICER OR EMPLOYEE SHALL BE CONSIDERED AS HOURS OF EMPLOYMENT ONLY WHEN (1) WITHIN THE DAYS AND HOURS OF SUCH OFFICER'S OR EMPLOYEE'S REGULARLY SCHEDULED ADMINISTRATIVE WORKWEEK, INCLUDING REGULARLY SCHEDULED OVERTIME HOURS, OR (2) WHEN THE TRAVEL INVOLVES THE PERFORMANCE OF WORK WHILE TRAVELING OR IS CARRIED OUT UNDER ARDUOUS CONDITIONS.

YOU SAY IN YOUR LETTER THAT---

THE FAA IS RESPONSIBLE FOR, AMONG OTHER THINGS, THE OPERATION OF ELECTRONIC NAVIGATIONAL FACILITIES WHICH PROVIDE GUIDANCE TO AIRLINE, MILITARY, AND PRIVATE AIRCRAFT THROUGHOUT THE UNITED STATES AND ITS POSSESSIONS. THIS IS DIVIDED INTO SIX REGIONS WHICH IN TURN ARE SUBDIVIDED INTO AIRWAYS TECHNICAL FIELD OFFICES ( ATFO) FOR PURPOSES OF MAINTENANCE OF THESE NAVIGATIONAL AID FACILITIES.

THERE ARE PRESENTLY OVER 5600 ELECTRONIC MAINTENANCE TECHNICIANS ( EMT) IN THE AGENCY WHO ARE RESPONSIBLE FOR THE MAINTENANCE, REPAIR AND UPKEEP OF THESE NAVIGATIONAL FACILITIES. THEIR PRIMARY OBJECTIVE IS TO ASSURE CONTINUOUS AND RELIABLE SERVICE FROM ALL FACILITIES WITHIN THE AIRWAY SYSTEM. OBVIOUSLY, ACCURACY AND CONTINUITY OF SERVICE OF THESE FACILITIES ARE OF CRITICAL IMPORTANCE. EACH FACILITY MUST FUNCTION PROPERLY SO THAT AIRCRAFT WILL NOT BE ENDANGERED BY THE RECEIPT OF INCORRECT INFORMATION. AN INTERRUPTION OF THIS SERVICE MAY DEPRIVE PILOTS OF ESSENTIAL NAVIGATIONAL INFORMATION PERHAPS WHEN MOST NEEDED. IT IS OF THE UTMOST IMPORTANCE THAT THESE NAVIGATIONAL AIDS BE REPAIRED QUICKLY AND PLACED IN A SERVICEABLE CONDITION WHEN THEY FAIL TO FUNCTION PROPERLY. NAVIGATIONAL FACILITIES MUST OPERATE 24 HOURS A DAY, 7 DAYS A WEEK.

OUR EMPLOYEES ARE REQUIRED, ON A "CALL-BACK BASIS," TO MAKE EMERGENCY REPAIRS TO OUR NAVIGATIONAL AIDS OVER AND BEYOND THEIR ADMINISTRATIVE WORK -DAY AND WORK-WEEK. AN EMPLOYEE WHO IS ON CALL-BACK DUTY MUST BE AVAILABLE AT ALL TIMES TO RESPOND TO AN EMERGENCY. WITHOUT EXTRA PAY, HE IS REQUIRED TO BE READILY AVAILABLE BY TELEPHONE FOR CALL-BACK DUTY, FOR AS MANY AS 125 1/2 HOURS PER WEEK IN ADDITION TO HIS REGULARLY SCHEDULED WORK-WEEK. THIS, OF COURSE, RESTRICTS HIS USE OF NORMAL OFF-DUTY HOURS BECAUSE HE MUST REMAIN WITHIN REASONABLE REACH OF HIS HEADQUARTERS.

WITHIN THE GEOGRAPHICAL AREA OVER WHICH THE FAA HAS JURISDICTION, EVERY CONCEIVABLE TYPE OF TERRAIN AND ADVERSE WEATHER CONDITION IS ENCOUNTERED. MANY OF OUR AIDS ARE LOCATED AT REMOTE, BARELY ACCESSIBLE SITES. SOME FACILITIES ARE LOCATED ON MOUNTAIN TOPS; OTHERS ARE LOCATED IN REGIONS SUBJECT TO DUST STORMS, OR FLASH FLOODS; STILL OTHERS ARE LOCATED IN DESERTS OR SWAMP AREAS. THESE CALL-BACKS CAUSE GRAVE CONCERN TO THE EMPLOYEES' FAMILIES BECAUSE INVOLVED IN THESE CALL BACKS ARE THE HAZARDS OF WORKING WHILE FATIGUED ON HIGH VOLTAGE EQUIPMENT AND DURING ADVERSE WEATHER CONDITIONS. ALSO THESE EMPLOYEES ARE EXPOSED TO THE ADDITIONAL HAZARD OF NECESSARY TRAVEL, ALONE, BY AUTOMOBILE, OFTEN FOR GREAT DISTANCES, OVER POOR ROADS, IN DENSE TRAFFIC, AND ADVERSE WEATHER CONDITIONS, DURING THE HOURS OF DARKNESS, AND WITHOUT THE BENEFIT OF PROPER REST OR SLEEP. IN ORDER TO REACH THESE FACILITIES AN EMPLOYEE RESPONDING TO A CALL-BACK IS REQUIRED TO USE VARIED MEANS TO TRANSPORT HIMSELF, AND HIS TESTING AND REPAIR EQUIPMENT TO THE FACILITY SITE. THE MODES OF TRANSPORTATION MAY INCLUDE THE USE OF PRIVATE AUTOMOBILE, PANEL TRUCKS, 1 1/2 TON TRUCKS, FOUR WHEEL DRIVE VEHICLES, AERIAL TRAMWAY, BOAT, FERRY, AIRCRAFT, SKIS, SNOWSHOES AND TRAVEL ON FOOT.

THE GEOGRAPHICAL AREA FOR WHICH EACH ATFO IS RESPONSIBLE IS OF CONSIDERABLE SIZE. IT IS COMMON FOR AN ATFO TO BE RESPONSIBLE FOR THE MAINTENANCE, UPKEEP, AND REPAIR OF A SITE WHICH IS 200 MILES REMOVED FROM ITS HEADQUARTERS. OUR MAINTENANCE PERSONNEL AS A REGULAR PART OF THEIR DAILY WORK ASSIGNMENT SERVICE THESE OUTLYING FACILITIES. DURING THEIR REGULAR WORK DAY, THEY RESPOND IMMEDIATELY TO AN EMERGENCY CALL FROM THEIR HEADQUARTERS AND PROCEED TO THE SITE TO CORRECT THE PROBLEM, IRRESPECTIVE OF WHERE THEY MAY BE PHYSICALLY LOCATED AT THE TIME OF THE CALL. AT THAT TIME THEY MAY BE AT THEIR HEADQUARTERS OR THEY MAY BEAT SOME OTHER FACILITY WITHIN THE ATFO. OUR EMPLOYEES IN RESPONSE TO CALL-BACKS REPAIR FACILITIES WHICH LIE WITHIN THEIR NORMAL WORK AREA. THEY DO NOT TRAVEL WITHIN THE ORDINARY MEANING OF THE WORD TRAVEL. THE HEADQUARTERS OF THE ATFO IS A PLACE OUT OF WHICH OUR MAINTENANCE EMPLOYEES OPERATE ON A DAILY BASIS. IT IS A PLACE WHERE ADMINISTRATIVE CONTROLS ARE EXERCISED AND IS A FOCAL POINT FOR THE LOCATION OF TEST EQUIPMENT, REPAIR PARTS AND THE MAINTENANCE OF VEHICLES. IN SOME INSTANCES AN EMPLOYEE WHO IS ASSIGNED A VEHICLE DOES NOT EVEN REPORT TO HEADQUARTERS DURING HIS REGULAR WORK DAY. HE KNOWS WHAT HIS ASSIGNMENTS ARE AND CARRIES THEM OUT. OFTEN AN EMPLOYEE RESPONDING TO A CALL-BACK, WILL PROCEED DIRECTLY TO THE SITE EITHER IN A VEHICLE WHICH HAS BEEN ASSIGNED TO HIM OR EVEN IN HIS OWN VEHICLE. THIS GENERALLY OCCURS WHEN THE EMPLOYEE'S HOME LIES BETWEEN THE SITE TO BE REPAIRED AND HEADQUARTERS. IN SUCH INSTANCES VALUABLE TIME IS SAVED IN RESTORING THE NAVIGATIONAL AID TO SERVICE.

THE MAJORITY OF THE VEHICLES USED BY OUR EMPLOYEES WHO RESPOND TO A CALL- BACK ARE EQUIPPED WITH COMMUNICATION AND MONITORING EQUIPMENT. WHEN RESPONDING TO CALL-BACKS OUR EMPLOYEES COMMUNICATE WITH HEADQUARTERS, AND AS WELL MONITOR THE VARIOUS NAVIGATIONAL AIDS WHILE ENROUTE TO THE MALFUNCTIONING FACILITY. THEY ALSO VISUALLY INSPECT ANY NAVIGATIONAL AIDS WHICH ARE ALONG THEIR ROUTE TO THE FACILITY. IN ADDITION, THEY INSPECT PRIVATE POWER AND COMMUNICATION LINES WHICH LEAD TO THE FACILITY

BASED UPON THE FACTS AND CIRCUMSTANCES RELATED ABOVE YOU REQUEST OUR DECISION UPON THE FOLLOWING SPECIFIC QUESTIONS:

1. MAY AN EMPLOYEE WHO RESPONDS TO AN EMERGENCY CALL-BACK BE COMPENSATED FOR THE ENTIRE PERIOD OF TIME REQUIRED BY THE CALL-BACK, BEGINNING WHEN HE LEAVES HIS RESIDENCE AND ENDING WHEN HE RETURNS TO HIS RESIDENCE?

2. IF THE ANSWER TO QUESTION NO. 1 IS IN THE NEGATIVE, MAY AN EMPLOYEE WHO RESPONDS TO A CALL-BACK BE COMPENSATED FOR THE TIME SPENT ENROUTE TO THE FACILITY FROM HIS HEADQUARTERS, AND FOR HIS RETURN TRIP FROM THE FACILITY TO HIS HEADQUARTERS?

3. IF THE ANSWER TO QUESTION NO. 2 IS IN THE AFFIRMATIVE, MAY AN EMPLOYEE WHO RESPONDS TO A CALL-BACK BE COMPENSATED FOR THE TIME SPENT ENROUTE TO THE FACILITY FROM HIS RESIDENCE AND FOR HIS RETURN TRIP ON A CALL-BACK WHEN HE DOES NOT FIRST REPORT TO HEADQUARTERS?

WE ASSUME THAT YOUR FIRST QUESTION CONTEMPLATES A SITUATION IN WHICH THE EMPLOYEE TRAVELED FROM HIS RESIDENCE TO HIS HEADQUARTERS, THENCE TO THE FACILITY TO BE REPAIRED AND RETURN.

YOU WILL NOTE THAT SECTION 204 OF THE FEDERAL EMPLOYEES PAY ACT OF 1945, QUOTED ABOVE, APPLIES ONLY TO "TIME SPENT IN A TRAVEL STATUS AWAY FROM THE OFFICIAL DUTY STATION OF THE OFFICER OR EMPLOYEE.' THE TIME SPENT BY AN EMPLOYEE IN TRAVELING BETWEEN HIS RESIDENCE AND HEADQUARTERS PROPERLY MAY NOT BE REGARDED AS "TIME SPENT IN A TRAVEL STATUS AWAY FROM THE OFFICIAL DUTY STATION" WITHIN THE MEANING OF SECTION 204. MOREOVER, IT DOES NOT APPEAR FROM YOUR LETTER OR FROM THE INFORMATION TRANSMITTED THEREWITH THAT ANY ACTUAL WORK WAS PERFORMED DURING THAT PORTION OF THE TRAVEL BETWEEN THE RESIDENCE OF THE EMPLOYEE AND HIS HEADQUARTERS, OR THAT THAT PORTION OF THE TRAVEL NORMALLY WOULD BE PERFORMED UNDER ARDUOUS CONDITIONS. HENCE, QUESTION 1 IS ANSWERED IN THE NEGATIVE.

WE ARE UNABLE TO GIVE YOU A CATEGORICAL ANSWER TO QUESTION 2 THAT WOULD APPLY IN EVERY CASE. WHETHER AN EMPLOYEE'S TRAVEL IS PERFORMED UNDER "ARDUOUS CONDITIONS" MUST BE DETERMINED UPON THE FACTS IN EACH INDIVIDUAL CASE. SIMILARLY, WHETHER AN EMPLOYEE PERFORMS WORK DURING A PERIOD OF TRAVEL IS A QUESTION OF FACT TO BE DETERMINED IN EACH CASE. IN CERTAIN INSTANCES A PART OF THE TRAVEL TO THE FACILITY TO BE REPAIRED MAY BE PERFORMED UNDER ARDUOUS CONDITIONS WHEREAS OTHER PARTS OF THAT TRAVEL MAY NOT REASONABLY BE SAID TO BE UNDER ARDUOUS CONDITIONS. SIMILARLY, WORK ACTUALLY MAY BE PERFORMED DURING A PORTION OF THE TRAVEL WHEREAS NONE WOULD BE PERFORMED DURING OTHER PORTIONS OF THE TRAVEL.

YOU POINT OUT IN YOUR LETTER THAT THE MAJORITY OF THE VEHICLES USED BY YOUR EMPLOYEES ON CALL-BACK DUTY ARE EQUIPPED WITH COMMUNICATION AND MONITORING EQUIPMENT AND THAT WHEN TRAVELING TO AN EMERGENCY REPAIR SITE THE EMPLOYEES NORMALLY MONITOR AS WELL AS VISUALLY INSPECT NAVIGATIONAL AIDS EN ROUTE AND FROM TIME TO TIME COMMUNICATE WITH HEADQUARTERS. IN ANY CASE WHEN AN EMPLOYEE ACTUALLY PERFORMS THOSE DUTIES, WHILE TRAVELING IN SUCH A SPECIALLY EQUIPPED VEHICLE, THE PAYMENT OF CALL-BACK TRAVEL TIME WOULD BE AUTHORIZED AS "PERFORMANCE OF WORK WHILE TRAVELING" AS THAT TERM IS USED IN SECTION 204 OF THE FEDERAL EMPLOYEES PAY ACT OF 1945.

SIMILARLY, EVEN IF NO WORK ACTUALLY IS PERFORMED WHILE TRAVELING, TRAVEL BETWEEN HEADQUARTERS AND THE FACILITY TO BE REPAIRED WHICH ACTUALLY IS PERFORMED UNDER ARDUOUS CONDITIONS, SUCH AS TRAVEL OVER UNUSUALLY ADVERSE TERRAIN OR DURING SEVERE WEATHER CONDITIONS, ALSO WOULD CONSTITUTE A PROPER BASIS FOR PAYMENT OF CALL-BACK TRAVEL TIME. ON THE OTHER HAND, TRAVEL BY AUTOMOBILE PERFORMED ON A HARD SURFACED ROAD WHEN NO UNUSUALLY ADVERSE WEATHER CONDITIONS ARE ENCOUNTERED, OR TRAVEL BY RAIL, WOULD NOT NORMALLY CONSTITUTE TRAVEL UNDER ARDUOUS CONDITIONS. YOUR SECOND QUESTION IS ANSWERED ACCORDINGLY.

REGARDING QUESTION 3, WHEN AN EMPLOYEE TRAVELS FROM HIS RESIDENCE DIRECTLY TO THE FACILITY TO BE REPAIRED WITHOUT FIRST REPORTING TO HEADQUARTERS, HE WOULD BE ENTITLED TO CALL-BACK TRAVEL TIME UNDER THE SAME CONDITIONS AS THE EMPLOYEES COVERED BY QUESTION 2, PROVIDED THE TIME CONSUMED IN TRAVELING FROM HIS RESIDENCE TO THE FACILITY TO BE REPAIRED IS NO GREATER THAN THE ESTIMATED TRAVEL TIME FROM THE EMPLOYEE'S HEADQUARTERS TO SUCH FACILITY. IN CASES OF THAT CATEGORY THE ESTIMATED TRAVEL TIME BETWEEN HEADQUARTERS AND THE FACILITY TO BE REPAIRED MUST BE REGARDED AS A MAXIMUM LIMITATION UPON TRAVEL TIME COMPENSABLE UNDER SECTION 204 OF THE STATUTE. YOUR THIRD QUESTION IS ANSWERED ACCORDINGLY.

BECAUSE CONDITION (2) OF SECTION 204, PUBLIC LAW 763, WAS A RULE OF DECISION BEFORE IT WAS ENACTED INTO STATUTORY LAW, WE HAVE BEEN GUIDED IN OUR DECISIONS BY CERTAIN PRINCIPLES IN DETERMINING WHETHER WORK IS PERFORMED DURING THE TRAVEL AND WHETHER THE TRAVEL IS PERFORMED UNDER ARDUOUS CONDITIONS. BRIEFLY STATED THEY ARE (1) THAT PREPARATION PRELIMINARY TO TRAVEL IS NOT CONSIDERED WORK, (2) THE TIME OF THE TRAVEL, THAT IS, WHETHER PERFORMED AT DAY OR AT NIGHT ORDINARILY IS NOT FOR CONSIDERATION IN DETERMINING WHETHER THE TRAVEL IS PERFORMED UNDER ARDUOUS CONDITIONS, (3) A DISTINCTION MUST BE DRAWN BETWEEN ARDUOUS CONDITIONS AND HAZARDOUS CONDITIONS, KEEPING IN MIND THAT THE LATTER MAY CONTRIBUTE TO THE FORMER.

IN THE LIGHT OF THOSE STATED PRINCIPLES, OUR VIEW IS THAT IN SITUATIONS ILLUSTRATED BY EXAMPLE 1, TRAVEL TIME COMPENSATION WOULD NOT BE WARRANTED. IN THE OTHER EXAMPLES, WE CONCLUDE THAT PART OF THE TRAVEL IS PERFORMED UNDER ARDUOUS CONDITIONS AND THEREFORE THAT IN SIMILAR SITUATIONS ALLOWANCE OF TRAVEL TIME COMPENSATION REASONABLY WOULD BE WARRANTED.

TO ESTABLISH FURTHER GUIDELINES YOU MAY DESIRE TO HAVE YOUR CERTIFYING OFFICER REFER TO US FOR DECISION ANY VOUCHERS PROPOSING PAYMENT OF TRAVEL TIME COMPENSATION IN CASES WHERE THERE EXISTS A REASONABLE DOUBT.