Dear Colleagues,

It probably goes without saying, but we have an odd situation.  A company
based in another state built a demonstration prototype here several years
ago with non-federal funding it received from various sources.  The company
established an account with the local electric utility to provide power for
work under that project.  The company does not have a presence here, other
than periodically traveling for project related activities, so all charges
for electricity are directly resulting from performing work on the project,
i.e., testing the prototype.

Since then, we received a federal cooperative agreement for developing and
testing the same prototype.  A university faculty member is principal
investigator and we are subcontracting the company that originally began
the project.  The company, our subcontractor, is requesting reimbursement
for its local electric bills and the university PI confirms the charges are
solely for the project.

So, the electric utility charges are reasonable and allocable but the issue
is whether they allowable.  OMB Circular A-21 at F.4.a. includes utilities
as overhead, in the only mention of such expenses.  I am seeking practical
experience and would greatly appreciate hearing from anyone who has dealt
with a similar situation.  Thank you in advance for your assistance.

Cordially,

Ruth Smith, Executive Director
Old Dominion University Research Foundation
P.O. Box 6369; Norfolk, VA 23508
Ph 757-683-4293, ext. 600
Fax 757-683-5290
Mobile Ph 757-469-5675

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================