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                         ISSUED: December 6, 1996
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                             GSBCA 13833-RELO

                    In the Matter of MICHAEL D. GRAVES

     Michael D. Graves, Hubert, NC, Claimant.

     D. Lisenby, Director, Financial Policy and Systems
Directorate, Kansas City, MO, appearing for Defense Finance and
Accounting Service.

NEILL, Board Judge.

     Claimant in this case, Michael D. Graves, seeks to be
compensated for the movement of his household goods (HHG) in
conjunction with a permanent change of station (PCS).  The agency
insists that he is entitled to no more than the costs incurred. 
Mr. Graves, instead, seeks to be paid in accordance with the
Government's commuted rate schedule.  Upon review of the record for
this case, we conclude that the claim should be granted.  

     The facts of this case are as follows:  Mr. Graves, an
aerospace engineer working at the Naval Aviation Depot at Norfolk,
Virginia, was issued travel orders on October 18, 1994, directing
him to report to his new work station at the Naval Aviation Depot
at Cherry Point, North Carolina by November 28, 1994.

     Prior to issuance of his orders, Mr. Graves met with a PCS
specialist at the base travel office to discuss the selection of a
method for shipment of his household goods.  He was told that the
Government could ship these goods for him on a Government bill of
lading.  He was also told that, if he chose to make his own
arrangements to ship his household goods, he would be reimbursed in
accordance with the Government's commuted rate schedule.  He chose
to undertake the move himself.  His travel orders, therefore,
stated: "AUTHORIZED COMMUTED RATE SYSTEM FOR MOVEMENT OF HOUSEHOLD
GOODS BY U-HAUL."  

     Mr. Graves completed his self-move on January 21, 1995. 
Approximately one month after submitting his relocation claim, the
disbursing office at Cherry Point contacted him to obtain a 
comparison of the cost of a Government managed move pursuant to a
GBL and the cost of an employee managed move using the commuted
rate schedule.   No such comparison had been made prior to issuance
of Mr. Graves' travel orders authorizing a use of the commuted rate
system.  

     A cost comparison was thereafter developed.  Since the cost
comparison showed the actual expense method using a GBL to be the
more economical method, the disbursing office on March 23, 1995,
reimbursed Mr. Graves only the expenses incurred in his move.  On
March 29, 1995, the Norfolk Depot amended Mr. Graves' original
travel order to read: "Authorized shipment of HHG by GBL.  If
member makes other arrangements to move HHG, reimbursement will be
made for actual expense."

     Mr. Graves' claim for reimbursement pursuant to the commuted
rate schedule was eventually forwarded to the Defense Finance and
Accounting Service (DFAS).  DFAS does not believe that the claimant
is entitled to reimbursement of more than the expenses incurred. 
Nevertheless, by letter dated August 26, 1996, DFAS, on behalf of
Mr. Graves, has forwarded the claim to us for final resolution.  

                                Discussion

     In a separate decision issued on this same date, we have
discussed at length the basic issue raised in this case.  Jeffrey
P. Herman, GSBCA 13832-RELO (Dec. 6, 1996).  In that decision, we
describe the two methods for transporting household goods, namely,
the actual expense method and the commuted rate method.  The Herman
decision also examines the central question of whether an agency
can reimburse an employee for the movement of household goods using
the commuted rate schedule, if it determines, only after the move,
that the commuted rate schedule was not more economical than the
actual expense method.  

     The agency in this case, being an organizational component of
the Department of Defense (DOD), relies on a provision contained in
the DOD travel regulation, the Joint Travel Regulations (JTR),
which applies to all DOD civilian employees.  The provisions of 
the JTR, however, integrate and supplement the Government's primary
travel regulation, the Federal Travel Regulation (FTR).  The FTR,
except for employees of the judicial branch, applies to all
civilian employees of Government agencies, including civilian
employees of the Department of Defense.   41 CFR 301-1.2(a).  The
provision of the JTR on which the agency relies states: 

     A cost comparison will be made between the actual expense
     (GBL) and commuted rate methods of shipping HHG.  In the
     event the estimated cost under one method exceeds the
     estimated cost under the other method by more than $100,
     the more economical method will be used.  

JTR C8001-D3c.  It is the agency s position that this provision
applies equally whether the cost comparison is done before or after
the employee s move.    

     For reasons explained in detail in the Herman decision, we
have concluded that, under the FTR and the statute which it
implements, this cost comparison must be done before the method of
transporting the goods is selected.  This restriction likewise
applies to any agency supplement of the FTR such as the JTR.  In
this case, as in the Herman case, we have determined that the
agency failed to perform a cost comparison before authorizing Mr.
Graves to undertake his self-move.  This effectually renders the
JTR provision inoperative and compels the agency to look to the FTR 
for guidance on how to proceed.

     Under the FTR, in the absence of a cost comparison showing
that the actual expense method is more economical, employees are to
be reimbursed for individual moves according to the commuted rate
schedule.  Given the facts in this case, it is apparent that, at
the time of Mr. Graves' move, both he and the local base officials
at Norfolk anticipated that he would be reimbursed for the movement
of his household goods based on the commuted rate schedule. 
Accordingly, we see no reason why, under the FTR, Mr. Graves should
not be compensated in accordance with the commuted rate schedule. 
Mr. Graves's claim is, therefore, granted. 

                                   _____________________
                                   EDWIN B. NEILL
                                   Board Judge