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May 5, 1998

General Services Administration
Office of Governmentwide Policy
Office of Transportation and Personal Property
Travel and Transportation Management Policy Division (MTT)
1800 F Street, N.W.
Washington, D.C. 20405-0001

RE: Comments on Proposed Rule for 41 CFR Parts 301-3 and 301-10 Federal Travel Regulation; Use of Commercial Transportation, Fly America Act

To Whom It May Concern:

I believe the implementation of the "plain language" style for the above regulation will be beneficial to both the traveler and the person responsible for monitoring travel expenditures involving federal funds. The use of the question and answer format allows either person to quickly locate the information they require and also provides answers in a more clear and concise manner than the previous format.

I would like to comment on two particular sections of Part 301-10 Transportation Allowable.

301-10.134 What is U.S. flag air carrier service?

I strongly agree with the adoption of the language stating "when the entire ticket is issued by the U.S. flag air carrier, and payment is to the U.S. flag air carrier" as a determination of what is a U.S. flag air carrier. If the ticket is issued by a foreign carrier, it is often difficult to determine if a code-share agreement is in force with a U.S. flag carrier upon the basis of the documents submitted for reimbursement If the regulation requires that the entire ticket be issued by the U.S. flag air carrier in order to qualify, there would be no need to question whether a particular foreign carrier has a code-share agreement.

301-10.144 What is my liability if I improperly use a foreign air carrier?

Regarding the statement, "If you are authorized by your agency to use U.S. flag air carrier service for your entire trip, and you improperly use a foreign air carrier for any or all of the trip, your transporation cost on the foreign air carrier will not be payable by your agency," I believe that language may encourage the implementation of splitting the cost of a trip involving foreign travel between non-federal and federal funds to allow the use of a foreign carrier for convenience or lower rates. If I am interpretting this statement correctly, the only portion that would be disallowed due to improper use of a foreign air carrier is the foreign portion of the air carrier expense. In the past, at our institution, we have disallowed the total cost of air travel (both foreign and U.S.) if it was found that a foreign air carrier was improperly used for part of the trip. We did not allow for only a portion of the trip to be charged to the federal funds - it was the complete trip or nothing. If the intention of the regulation is to prevent loss of revenues by U.S. air carriers, the language should be more explicit in curbing the intentional splitting of costs to receive a total net lower travel rate. If there is a U.S. flag air carrier service available to the final point of destination, and the traveler cannot certify that any of the exceptions in 301-10.137 apply and/or none of the circumstances in 301-10.138 are deemed a matter of necessity, does the federal government want to enforce regulations requiring that the complete trip be made on a U.S. flag air carrier, or do they want to give the traveler the option of splitting the charges between federal and non-federal sources? According to the new language, it would be possible for a traveler to intentionally use a foreign carrier improperly in order to reduce the total cost of the trip if he/she had non-federal funds available to pay the difference, thus, defeating the purpose of encouraging U.S. flag carriers regardless of cost and/or convenience to the traveler.

Thank you for the opportunity to comment on this proposed rule.


Jackie Frederick
Grants and Contract Specialist

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