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DECISION
FILE: B-197699
b.- ~
LER s%
~THE COMPTROLLER GENERAL
. OF THE UNITED STATES
WASHiNGTON. D.C. 20548
DATE: June 3, 1980
MATTER OF: Department of Interior- -Heritage Conservation
and Recreation Service--Pregrant Award Costs.
Project related pre-application grant costs may
be paid out of funds appropriated for Urban Park
and Recreation Recovery Program, Pub. L. No.
95-625, 16 U.S.C. 2501 et seq., where reimburse-
ment of architectural or engineering or other
grant costs is considered by Secretary of Interior
to be appropriate and in the public interest in
carrying out program.
The Assistant Secretary of Interior for Fish and Wildlife
and Parks asks whether the Heritage Conservation and Recreation
Service has (authority to pay grantees for architectural and
engineering costsincurred by grantees prior to, or in con-
junction with, the preparation of pre-applications for grants
under the Urban Park and Recreation Recovery Program.
This program is authorized by the Urban Park and
Recreation Recovery Act of 1978, Pub. L. No. 95-625, 92 Stat.
3538, approved November 10, 1978, to be codified at 16 U.S.C.
2501 et seq. All the pre-application costs that the
Assistant Secretary argues should be paid were incurred after
July 25, 1979, the date the first appropriation for the pro-
gram was approved. Pub. L. No. 96-38, 93 Stat. 106. We
conclude, as discussed below, that the Secretary or his
delegate has the authority to pay project related costs
incurred prior to grant awards under the facts presented.
In his letter, the Assistant Secretary says:
The UPARR [Urban Park and Recreation Recovery] grants
are awarded on a competitive basis without options
for increases in grant assistance necessitated
through cost overruns, The grant awards are based
upon the submission of a pre-application and grant
approval is contingent upon the completion of the
full OMB Circular A-102 application forms and require-
ments. Due to these constraints, applicants must
incur architectural and/or engineering costs
prior to, or in conjunction with the preparation of
DIGEST:
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