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                            September 26, 1997
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                             GSBCA 13986-RELO


                      In the Matter of JOHN M. HORAN


     John M. Horan, Ventura, CA, Claimant.

     Angela D. Terry, Chief, Travel Branch, Accounting Operations
Center, National Park Service, Reston, VA, appearing for Department
of the Interior.

PARKER, Board Judge.

     John M. Horan, an employee of the Department of the Interior
(DOI), was transferred to Ventura, California in March 1996.  His
travel authorization contained the following statement:

          EMPLOYEE WILL TRANSPORT OWN HSHLD GOODS under
          Commuted Rate Schedule NTE [not to exceed]
          lowest gov't carrier price of $923

The dollar limitation of $923 was the price offered by the lowest
cost carrier for transporting the goods under a Government bill of
lading.  This amount did not include the administrative costs to
the Government of such things as selecting and dealing with the
carrier, preparing a bill of lading, auditing and paying the
transportation voucher, supervising the packing of the household
goods, handling employee loss and damage claims, and other
incidentals.  In addition, the figure did not include storage-in-
transit charges.  DOI issued the travel authorization with the
above-quoted statement after determining that the lowest carrier
price was cheaper than the estimate of $1442 using the General
Services Administration's (GSA's) schedule of commuted rates.

     Mr. Horan arrived in California and requested reimbursement of
$923, the maximum permitted under his travel orders.  DOI denied
his claim, informing him that it would pay only his "out of pocket"
expenses, such as the cost of renting a truck.  According to DOI,
"The Federal Regulations and National Park Service guidelines
specifically prohibit the use of the 'Commuted Rate Method' unless
a savings to the Federal Government (at least $100.00) is
determined in advance."  Mr. Horan has asked the Board to review
the DOI's decision.

                                Discussion

     The Federal Travel Regulation (FTR) authorizes agencies to use
one of two methods for transporting an employee's household goods. 
Under the "commuted rate system," the employee makes his own
arrangements for transporting the household goods and is reimbursed
by the Government in accordance with schedules of commuted rates
set by GSA.  The amount paid to the employee is computed by
multiplying the weight of the household goods (up to a maximum) by
the applicable rate.  41 CFR 302-8.3(a) (1996).  Under the second
method, the "actual expense method," the Government normally
assumes complete responsibility for shipping the goods and does so
under a Government bill of lading.  41 CFR 302-8.3(b).

     For individual transfers, the Government is to use the
commuted rate system, and may only use the actual expense method
where a cost comparison shows that the actual expense method would
be at least $100 cheaper.  41 CFR 302-8.3(c)(4)(I).  The required
cost comparison must include the additional administrative costs
connected with the actual expense method, such as selecting and
dealing with the carrier, preparing a bill of lading, auditing and
paying the transportation voucher, supervising the packing of the
household goods, handling employee loss and damage claims, and
other incidentals.  41 CFR 302-8.4(c)(1)-(2).  Contrary to DOI's
interpretation, the FTR contains a clear preference for the
commuted rate system.  See Lawrence M. Ribakoff, GSBCA 13892-RELO,
97-2 BCA  29,018.

     Here, DOI did attempt to compare the cost of transporting Mr.
Horan's household goods using the commuted rate system to the cost
using the actual expense method.  But the estimate of costs under
the actual expense method was defective because it did not include
the administrative costs required by the FTR to be included in the
cost comparison or storage-in-transit charges.  Without these
costs, which could easily total more than several hundred dollars,
DOI could not determine which method was actually less expensive. 
Because the FTR requires that transferred employees be reimbursed
under the commuted rate system unless a properly performed cost
comparison shows the actual expense method to be at least $100
cheaper, and no such comparison was accomplished, Mr. Horan is
entitled to be reimbursed under the commuted rate system. 
Moreover, his claim may not be limited to the cost which DOI would
have incurred using the actual expense method, which DOI has only
partially estimated at $923.

                                 Decision

     The claim is granted.  In addition, Mr. Horan may submit to
DOI a supplemental claim for the difference between his claimed
amount of $923, and the amount computed using the commuted rate
method.




                                   ____________________
                                   ROBERT W. PARKER
                                   Board Judge