B-140941, JAN. 6, 1960

B-140941, JAN. 6, 1960

TO THE SECRETARY OF THE AIR FORCE:

REFERENCE IS MADE TO A LETTER DATED OCTOBER 1, 1959, FROM THE ASSISTANT SECRETARY OF THE AIR FORCE, REQUESTING AN EXCEPTION TO PARAGRAPH (24) OF APPENDIX A TO OUR GENERAL REGULATIONS NO. 123 (CHAPTER 2000, TITLE 5 OF OUR POLICY AND PROCEDURES MANUAL), COVERING PASSENGER TRANSPORTATION SERVICES.

PARAGRAPH (24) REQUIRES THAT THE WRITTEN SIGNATURE OF THE TRAVELER BE PLACED IN THE SPACE PROVIDED THEREFOR ON THE STANDARD FORM NO. 1169, THE UNITED STATES OF AMERICA TRANSPORTATION REQUEST, BEFORE THE DOCUMENT IS VALID FOR SERVICE. IT IS STATED, IN EFFECT, THAT BECAUSE OF ,CRITICAL MANNING PROBLEMS" A LARGE NUMBER OF SMALL ISOLATED INSTALLATIONS THROUGHOUT THE WORLD MUST FUNCTION WITHOUT THE SERVICES OF PERSONNEL QUALIFIED TO HANDLE TRANSPORTATION AND OTHER ADMINISTRATIVE MATTERS. AS A RESULT, CENTRAL HEADQUARTERS GROUPS, GENERALLY LOCATED CONSIDERABLE DISTANCES AWAY, ARE RELIED UPON BY SUCH SUBORDINATE INSTALLATIONS FOR THE FURNISHING OF TRANSPORTATION REQUEST AND CARRIER TICKET SUPPORT, AND IN RENDERING THIS SUPPORT USE IS OFTEN MADE OF MAIL AND COURIER SERVICE. HOWEVER, IN MANY INSTANCES, SUCH MEANS OF COMMUNICATION OR TRANSMITTAL IS UNSATISFACTORY BECAUSE OF THE UNCERTAINTY AND INFREQUENCY OF THE MAIL AND COURIER SERVICE, DUE TO THE PHYSICAL INACCESSABILITY OF THE INSTALLATION, WEATHER CONDITIONS, ETC. UNDER THESE CONDITIONS, WHEN TIME IS OF THE ESSENCE, TRAVELERS ARE REQUIRED TO JOURNEY PERSONALLY TO THE GROUP HEADQUARTERS TO OBTAIN THEIR TRANSPORTATION REQUESTS, SIGN THEM, AND OBTAIN THEIR TICKETS. IT IS SAID THAT SUCH PERSONAL TRAVEL RESULTS IN AN UNAVOIDABLE LOSS OF MANPOWER, TIME AND MONEY, AND THAT THE PROBLEM WOULD BE OVERCOME IF THE AIR FORCE WERE PERMITTED TO APPOINT AGENTS (AT THE HEADQUARTERS GROUPS) "TO SIGN TRANSPORTATION REQUESTS FOR TRAVELERS STATIONED AT THESE ISOLATED INSTALLATIONS.' IT IS ASSERTED THAT SUCH AN ARRANGEMENT WOULD GIVE THE HEADQUARTERS GROUPS "SUFFICIENT LATITUDE IN ISSUING TRANSPORTATION REQUESTS AND IN ARRANGING * * * TICKETING * * *," AND WOULD BE EXTREMELY BENEFICIAL TO THE AIR FORCE AND IN THE BEST INTERESTS OF THE GOVERNMENT.

OUR GENERAL REGULATIONS NO. 123 WERE FORMULATED AFTER CONSIDERABLE DISCUSSION WITH THE GOVERNMENT AGENCIES AND REPRESENTATIVES OF THE TRANSPORTATION INDUSTRY, AS BEING BEST DESIGNED TO PROTECT THE INTERESTS OF THE GOVERNMENT, THE TRAVELERS, AND THE CARRIERS. THEREFORE, WE DO NOT FAVOR THE GRANTING OF BLANKET EXCEPTIONS TO THE SIGNATURE REQUIREMENTS BECAUSE WE BELIEVE THAT SUCH EXCEPTIONS TEND TO BREAK DOWN USE AND ACCOUNTABILITY CONTROLS. HOWEVER, IN INSTANCES WHERE THERE IS A CLEAR SHOWING THAT ADHERENCE TO THE SPECIFIED REQUIREMENTS OF THE REGULATIONS RESULTS IN ADVANTAGES AND UNECONOMICAL OPERATIONS, WE HAVE GIVEN FAVORABLE CONSIDERATION TO SUCH REQUESTS FOR EXCEPTIONS. EXCEPTIONS HAVE BEEN GRANTED THE DEPARTMENTS OF JUSTICE, LABOR, AGRICULTURE AND STATE, IN SPECIFIC INSTANCES. IN ALL OF THE CITED EXCEPTIONS EITHER A SPECIAL CATEGORY OF GOVERNMENT EMPLOYEES WAS INVOLVED, OR FOREIGN NATIONALS BROUGHT TO THIS COUNTRY UNDER THE INTERNATIONAL COOPERATION ADMINISTRATION TECHNICAL ASSISTANCE PROGRAM. THE VARIETY OF COMPLICATIONS WHICH AROSE IN CONNECTION WITH THE PROCUREMENT OF PASSENGER TRANSPORTATION AND ACCOMMODATIONS FOR THESE PARTICULAR TRAVELERS ILLUSTRATED CLEARLY THAT ADHERENCE TO THE SIGNATURE REQUIREMENTS WAS IMPRACTICAL AND RESULTED IN INCREASED OPERATING COSTS. HOWEVER, THE GRANTING OF THESE REQUESTS AND THE APPROVAL OF COVERING PROCEDURES, WAS GENERALLY PREDICATED UPON THE ASSURANCE THAT NECESSARY AND ADEQUATE CONTROLS OVER THE PROPER PROCUREMENT OF THE SERVICE INVOLVED WOULD BE MAINTAINED BY THE AGENCY.

THE SUBJECT REQUEST OF THE DEPARTMENT OF THE AIR FORCE FOR EXEMPTION FROM THE REQUIREMENT OF PARAGRAPH (24) OF APPENDIX A, SUPRA, IS VERY BROAD AND IS NOT PRESENTED IN SUFFICIENT DETAIL TO ENABLE THOROUGH CONSIDERATION OF THE MATTER. IT IS MERELY STATED THEREIN, IN EFFECT, THAT PERMISSION IS SOUGHT TO APPOINT AGENTS IN VARIOUS HEADQUARTERS GROUPS THROUGHOUT THE WORLD TO SIGN TRANSPORTATION REQUESTS FOR TRAVELERS STATIONED IN THEIR RESPECTIVE SUBORDINATE, ISOLATED INSTALLATIONS, WHICH ARE NOT STAFFED "WITH QUALIFIED TRANSPORTATION OFFICERS AND OTHER ADMINISTRATIVE PERSONNEL.' HOWEVER, THERE IS NO SHOWING AS TO THE NUMBER OF SUCH HEADQUARTERS GROUPS AND SUBORDINATE INSTALLATIONS INVOLVED OR THEIR RESPECTIVE LOCATIONS. MOREOVER, THERE IS NO SHOWING AS TO THE NUMBER OF SUCH HEADQUARTERS GROUPS AND SUBORDINATE INSTALLATIONS INVOLVED OR THEIR RESPECTIVE LOCATIONS. MOREOVER, NO INFORMATION HAS BEEN FURNISHED RELATIVE TO THE VOLUME OF TRAFFIC THAT WOULD NORMALLY BE INVOLVED; THE FREQUENCY WITH WHICH THE TIME ELEMENT MENTIONED WOULD PRECLUDE THE PROCUREMENT OF PASSENGER TRANSPORTATION CONSISTENT WITH THE REGULATIONS; THE BASIS FOR SELECTING AGENTS TO SIGN TRANSPORTATION REQUESTS FOR TRAVELERS; THE ESTABLISHMENT OF NECESSARY AND ADEQUATE CONTROLS TO PRECLUDE THE REQUESTED PROCEDURE FROM BEING GIVEN BLANKET APPLICATION; AND THE SPECIFIC MANNER IN WHICH SUCH TRANSPORTATION REQUESTS WOULD BE PREPARED AND SIGNED. IT SHOULD ALSO BE STATED WHETHER THE SO-CALLED "HEADQUARTERS GROUPS" ARE GENERALLY LOCATED IN OR NEAR CITIES SERVED BY THE CARRIERS WHOSE SERVICES WOULD BE INVOLVED AND WHAT IS MEANT BY THE STATEMENT, "THIS WOULD THEN GIVE THE GROUP HEADQUARTERS SUFFICIENT LATITUDE IN * * * ARRANGING CARRIER TICKETING PROCEDURES IN COOPERATION WITH LOCAL CARRIER REPRESENTATIVES MEETING THE NEEDS OF TRAVELERS.'

ACCORDINGLY, FOR THE REASONS STATED ABOVE, WE DO NOT FAVOR GRANTING THE SUBJECT REQUEST IN ITS PRESENT FORM. WE DO, HOWEVER, RECOGNIZE THAT ADHERENCE TO THE REGULATIONS WOULD NOT BE PRACTICAL IN MANY INSTANCES IN THE CIRCUMSTANCES DESCRIBED. WE WILL GIVE FURTHER CONSIDERATION TO GRANTING THE REQUESTED EXCEPTION ON AN INDIVIDUAL INSTALLATION OR HEADQUARTERS GROUP BASIS IF THE DEFINITE NEED FOR SUCH EXCEPTION IS MORE CLEARLY SHOWN, AND CONTROL PROCEDURES HAVE BEEN WORKED OUT WHICH WILL SAFEGUARD THE INTERESTS OF THE GOVERNMENT.