This is a unique situation in which the utility bills are allowable as
direct cost to the federal project, it you take care of a couple of matters.

It is a DIRECT charge because it is needed for this one (or is shared
between two or three) project and is unrelated to your normal utility
billing/distribution, including a separate billing.  You should communicate
this to your new federal sponsor so that they understand, and hopefully get
their approval (e-mail is adequate).  This is a special, unique use of the
power.

Be very sure that the bill does not get mixed in with your normal utility
bills, which are in the F&A.

If I understand correctly that this prototype thingey has its own electric
meter, so to speak, then you should have no problem charging full normal
F&A which includes all electricity for all purposes (offices, labs) except
this one special device.

At 03:24 PM 1/3/2005, Ruth B Smith wrote:
>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
>
>
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Herbert "Chuck" Chermside, CRA
Director Emeritus, VCU Sponsored Programs
Executive Director, Research Administrators Certification Council
1915 Robindale Rd.
Richmond, VA 23235-3931
804-320-5502
xxxxxx@verizon.net

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