B-165253, OCT. 9, 1968

B-165253, OCT. 9, 1968

TO MR. CARL W. GLASS:

WE REFER TO YOUR LETTER OF SEPTEMBER 10, 1968, WITH ENCLOSURES, REFERENCE F4215-MWR/ABF), REQUESTING OUR DECISION WHETHER MR. ROBERT P. LEACH, AN EMPLOYEE OF THE NATIONAL PARK SERVICE, MAY BE REIMBURSED AN ADDITIONAL AMOUNT FOR THE TRANSPORTATION AND STORAGE OF HIS HOUSEHOLD EFFECTS INCIDENT TO A PERMANENT CHANGE OF STATION.

BY TRAVEL ORDER DATED JULY 1, 1968, MR. LEACH WAS AUTHORIZED TO TRANSPORT HIS HOUSEHOLD GOODS AND PERSONAL EFFECTS FROM EAST STROUDSBURG, PENNSYLVANIA, TO OMAHA, NEBRASKA. THE GOODS WERE PICKED UP BY THE AERO MAYFLOWER TRANSIT COMPANY ON JULY 8, 1968, AND WERE TRANSPORTED TO A WAREHOUSE IN ALLENTOWN, PENNSYLVANIA (37 MILES FROM EAST STROUDSBURG) WHERE THEY REMAINED IN STORAGE UNTIL JULY 16, 1968. THE EMPLOYEE STATES THAT SUCH STORAGE WAS NECESSARY SINCE HE WAS UNABLE TO PROCURE DIRECT CARRIER TRANSPORTATION TO OMAHA.

THE BILL OF LADING FURNISHED BY THE CARRIER SHOWS TRANSPORTATION AND STORAGE CHARGES AS OLLOWS:

RATE CHARGES

MILEAGE: STRAIGHT SHIPMENTS - 1,177 MILES $11.40 $703.95

MILEAGE: STORAGE-IN-TRANSIT SHIPMENTS:

ORIGIN TO WAREHOUSE - 37 MILES 4.45 274.79

STORAGE IN TRANSIT - 7/8 - 7/16 .70 43.23

WAREHOUSE HANDLING 1.00 61.75

YOU SAY THAT THE EMPLOYEE HAS BEEN ALLOWED THE AMOUNT OF $845.98 ON THE COMMUTED RATE BASIS FOR DIRECT SHIPMENT OF HIS HOUSEHOLD EFFECTS FROM EAST STROUDSBURG TO OMAHA -- A DISTANCE OF 1,218 MILES. ALSO, HE HAS BEEN ALLOWED THE STORAGE AND WAREHOUSE HANDLING CHARGES SHOWN ON THE BILL OF LADING ($104.98). NO AMOUNT WAS ALLOWED FOR THE DRAYAGE OF THE HOUSEHOLD GOODS FROM THE EMPLOYEE'S RESIDENCE TO THE WAREHOUSE IN ALLENTOWN. HOWEVER, YOU NOW QUESTION WHETHER SUCH ITEM MAY PROPERLY BE REGARDED AS AN EXPENSE INCIDENTAL TO TEMPORARY STORAGE RATHER THAN AS A TRANSPORTATION CHARGE.

WE HAVE HELD THAT DRAYAGE CHARGES INCURRED IN CONNECTION WITH THE TEMPORARY STORAGE OF HOUSEHOLD EFFECTS ARE ALLOWABLE AS A NECESSARY CHARGE INCIDENTAL TO SUCH TEMPORARY STORAGE IN AN AMOUNT WHICH, TOGETHER WITH THE ACTUAL STORAGE CHARGES, DOES NOT EXCEED THE SPECIFIED MAXIMUM COMMUTED RATE. 28 COMP. GEN. 41. ALSO, SEE SECTION 2 OF GSA BULLETIN FPMR NO. A- 2, ATTACHMENT A.

OUR EXAMINATION OF HOUSEHOLD GOODS CARRIERS BUREAU TARIFF NO. 126A, MFICC NO. 142, SECTION 3, REVEALS THAT THE RATE ($4.45 PER CWT.) APPLIED BY THE CARRIER ON THE TRANSPORTATION OF THE EMPLOYEE'S HOUSEHOLD GOODS FROM EAST STROUDSBURG TO THE WAREHOUSE IN ALLENTOWN IS A PICKUP OR DELIVERY RATE APPLICABLE TO STORAGE-IN-TRANSIT SHIPMENTS, RATHER THAN A LINE-HAUL TRANSPORTATION RATE. THEREFORE, THE ITEM IN QUESTION MAY PROPERLY BE CONSIDERED AS AN EXPENSE INCIDENTAL TO THE TEMPORARY STORAGE AND IS ALLOWABLE TO THE EXTENT AUTHORIZED BY THE DECISION CITED ABOVE.

IN VIEW OF THE ABOVE, HOWEVER, IT APPEARS THAT REIMBURSEMENT UNDER SECTION 1 OF GSA BULLETIN NO. A-2 FOR THE TRANSPORTATION OF THE HOUSEHOLD GOODS SHOULD HAVE BEEN BASED ON THE LINE-HAUL DISTANCE OF 1,177 MILES (ALLENTOWN TO OMAHA) AS CHARGED BY THE CARRIER RATHER THAN 1,218 MILES. THE OVERPAYMENT FOR TRANSPORTATION SHOULD BE SET OFF AGAINST THE ADDITIONAL AMOUNT DUE FOR TEMPORARY STORAGE.

IN YOUR LETTER OF SEPTEMBER 10, YOU ALSO REQUESTED OUR DECISION WHETHER YOU MAY CERTIFY A PAYMENT IN FAVOR OF ANOTHER EMPLOYEE FOR THE TRANSPORTATION OF HIS HOUSEHOLD GOODS BETWEEN TWO POINTS IN MINNESOTA. MAY NOT RENDER A DECISION ON THE MATTER AS PRESENTED BY YOU. IN THAT REGARD WE INVITE YOUR ATTENTION TO SECTION 23.5 OF TITLE 7, GENERAL ACCOUNTING OFFICE POLICY AND PROCEDURES MANUAL, WHICH PROVIDES AS FOLLOWS:

"A CERTIFYING OFFICER HAS THE RIGHT TO APPLY FOR AND OBTAIN A DECISION BY THE COMPTROLLER GENERAL ON ANY QUESTION OF LAW INVOLVED IN A PAYMENT ON ANY VOUCHER PRESENTED FOR CERTIFICATION (31 U.S.C. 82D). A REQUEST FOR SUCH A DECISION MUST BE ACCOMPANIED BY A COPY OF THE VOUCHER AND OF EACH SUPPORTING DOCUMENT INVOLVED.'

WE SHALL BE PLEASED TO CONSIDER THE MATTER FURTHER UPON YOUR COMPLIANCE WITH THE INSTRUCTIONS QUOTED ABOVE.

THE PAPERS TRANSMITTED WITH YOUR LETTER OF SEPTEMBER 10 ARE RETURNED HEREWITH.