BOARD OF CONTRACT APPEALS
   U.S. GOVERNMENT PRINTING OFFICE
   WASHINGTON, DC  20401

In the Matter of             )
                             )
the Appeal of                )
                             )
UNIVERSAL PRINTING COMPANY   )   Docket No. GPO BCA 09-90
Jacket No. 563-541           )
Purchase Order K-0469        )

   DECISION AND ORDER

   This appeal, timely filed by Universal Printing Company,
   Southwest Sales Office, Suite 212, 115 Executive Way, Dallas,
   Texas 75115 (hereinafter the Appellant or Contractor),1 is
   from the final decision, dated January 24, 1990, of
   Contracting Officer, Mr. Richard W. Wildbrett (hereinafter
   Contracting Officer), of the U.S. Government Printing Office's
   (hereinafter Respondent or GPO or Government), Dallas Regional
   Printing Procurement Office (hereinafter DRPPO) denying the
   Appellant's claim for additional compensation in the amount of
   $16,620.89 on Jacket No. 563-541, Purchase Order K-0469 (R4
   File, Tabs I and L).2  For the reasons which follow, the
   Contracting Officer's decision is MODIFIED, and the
   Appellant's claim is ALLOWED to the fair and reasonable amount
   of $8,310.45.3

     I. BACKGROUND4

   On December 12, 1988, the DRPPO issued an Invitation for Bids
   (IFB) to procure 10,050 copies of a four (4) color saddle-
   stitched pamphlet,5 estimated at 48 pages plus cover, entitled
   "The Fifth Army Citizen Soldier" (Citizen Soldier) for the
   Department of the Army (Army) (R4 File, Tabs A).  The IFB
   specifications provided, in pertinent part:

      MATERIAL FURNISHED: 94 pieces of double spaced, typewritten
      manuscript copy and approximately 90 to 100 full color
      photoprints or 35mm color transparencies.

      COMPOSITION: It is estimated that there will be 48 pages of
      text matter set flush left and right, on a 14 pica line
      length, in 11 on 12 point type.  Heads will be set in 13
      point boldface (upper and lower case) and subheads will be
      set in 11 on 12 point boldface (upper and lower case).

      PAGE MAKE-UP: Make up into pages 44 x 61 picas, including
      folios, (contractor to provide at the time of page make-up)
      consisting generally of three 14 pica columns.  The
      Department will furnish a lay-out dummy, with the returned
      galley proofs, to be followed for exact page make-up.

      CORRECTIONS: All corrections, whether they be contractor's
      errors or author's alterations must be made prior to
      production of the final camera repro copy and must be
      cleanly mortised, spliced or stripped in.  Paste over will
      not be acceptable.

      COPY PREPARATION: All textmatter prints in black ink.
      There will be approximately 90 to 100 four-color process
      illustrations ranging in size from 2-1/4 x 3-1/4" to full
      8-1/2 x 11" page size.  See "Schedule of Prices".

   * * * * * * * * * *

      FORMAT: Covers 1 through 4 print in four-color process.
      Text prints head to head in four-color process, no blanks.

      NOTE: This order must be produced on offset press equipment
      capable of printing four colors on one side of one sheet in
      one operation (four printing units).

   * * * * * * * * * *

      BINDING: Saddle[-]stitch in two places on the 11"
      dimension.

      PROOFS AND PRESS SHEET INSPECTION: Reader's galley proofs,
      page proofs, press progressive proofs, prior-to-production
      samples and an on-line press sheet inspection are required
      for this order.

      GALLEY PROOFS: Prior to page make-up, the contractor must
      submit for approval four (4) sets of reader's galley
      proofs, along with all furnished material.  One set of the
      galley proofs must be waxed for mounting.  The [Army] will
      paste up a page dummy for exact placement of the typematter
      and the halftone illustrations.  The proofs and dummy will
      be withheld no more than fifteen (15) workdays from receipt
      in the GPO and the photoprints or transparencies for the
      illustrations will be furnished with the return of the
      proofs and dummy.

      PAGE PROOFS: After page make-up and prior to submission of
      the press proofs, the contractor must submit for approval
      four (4) sets of page proofs with all elements, text and
      illustrations in positions.  The text may be Xerox or equal
      copy and the illustrations must be PMT or equal, cropped,
      sized and pasted in position.  The page proofs will be
      withheld no more than fifteen (15) workdays after receipt
      in GPO.

      PROGRESSIVE PROOFS AND SAMPLES: Prior to printing, the
      contractor must submit for approval 4 complete sets of
      press proofs, collated in proof books and 6 prior-to-
      production samples.  The proofs and samples must be printed
      on the paper and in the inks that will be used for the
      complete production and the samples must be trimmed, folded
      and bound in exact accordance with these specifications.
      NOTE: The samples may be hand folded and trimmed.

      The proofs and samples will be checked for quality and
      compliance with these specifications, approved or
      disapproved and returned to the contractor within fifteen
      (15) working days after receipt in the Government Printing
      Office, Dallas, TX.  If, in the opinion of the GPO, the
      proofs are not a true representation of the furnished art,
      (objectionable or serious shift in hue, saturation, or
      lightness) or contain noticeable defects (misregister,
      voids, hickies, etc.) they will be rejected and returned to
      the contractor for correction and reproofing at no
      additional expense to the Government.  The schedule . . .
      CANNOT be extended to allow for such reproofing.

   * * * * * * * * * *

      PRESS SHEET INSPECTION: A Government representative will
      inspect press sheets ar the beginning of production run to
      ensure that press sheets match the approved press proof(s)
      and to approve any required corrections or changes.  The
      inspection will be at the contractor's plant and the GPO
      must be notified at least five workdays in advance of he
      commencement of production. . . .

      Delays caused by the contractor's failure to notify the GPO
      at least five workdays in advance of the production run or
      failure of the press sheets to match the approved press
      proofs will be the responsibility of the contractor and the
      schedule CANNOT be extended due to these delays.

   * * * * * * * * * *

      SCHEDULE: See "Notice of Compliance with Schedules",
      Article 12, Contract Clauses, GPO Contract Terms, dated
      December 1, 1987.

      Material will be furnished by-January 6, 1989

      Galley proofs delivered to Dallas RPPO by-January 17, 1989

      Galley proofs and dummy returned to contractor by-February
      7, 1989

      Page proofs delivered to Dallas RPPO by-February 17, 1989

      Page proofs returned to contractor by-March 13, 1989

      Progressive proofs delivered to Dallas RPPO by-March 24,
      1989

      Progressive proofs returned to contractor by-April 14, 1989

      Ship complete on or before-May 5, 1989

   * * * * * * * * * *

      DETERMINATION OF AWARD: The Government will determine the
      lowest bid by applying the prices quoted in the "Schedule
      of Prices" to the following units of production which are
      the estimated requirements to produce the products
      specified herein.  These units do not constitute, nor ar
      they to be construed as, a guarantee of the volume of work
      required.  The following item designations correspond to
      those listed in the "Schedule of Prices".

          1. a.   1   2. a.  1   3. a. 3,285   4. a. (1)   1
             b.   4      b.  4      b.     4         (2) 100
             c. 150
             d.   5                        b. (1)   1
             e.  50                           (2) 100


See, R4 File, Tab A, pp. 1-3, 6-7.6

   Since GPO Contract Terms was incorporated by reference, the
   contract also included a supplemental specification concerning
   "Author's Alterations", which states:

      Author's alterations consist of all marks made by the
      author at variance with the original manuscript as
      submitted to the contractor, but do not include corrections
      marked by the editor due to the failure of the contractor
      to follow copy literally.  Author's alterations shall be
      charged on a per-line basis.  In tabular matter, each line
      in a single column will be considered one line.  Display
      lines will be paid for at the original line setting rate.
      The charge for deleting or transposing type lines without
      setting and inserting new material will be a one-line
      charge for each group, regardless of the number of lines in
      the group.  Proofs of any deleted matter must be submitted
      with the voucher to obtain payment.  If, after the pages
      are made up, the contractor is required to transpose type
      from one column to another, or from one page to another,
      the contractor will be entitled to charge only two lines of
      author's alterations per transposition.  If the contractor
      is required to transpose within a makeup page such
      components as a table or space for an illustration, he/she
      will be entitled to charge two lines of alterations for
      each affected column.  For example, transposition of a
      table which is printed across three columns will result in
      a charge of six lines.

         (a) Minimum charge. One minimum charge will be allowed
         for author's alterations each time proofs are submitted
         by the Government for alterations.  The charge shall be
         indicated in the specifications.

         (b) Maximum charge. The maximum charge allowable for
         author's alterations on any one galley or page shall be
         an amount equal to the cost of setting that galley or
         page from manuscript copy.

         (c) Proof of charge. Charges for author's alterations
         will not be honored unless the voucher which is
         submitted to the Government Printing Office is supported
         by all marked proofs, or facsimiles thereof, showing
         author's alteration marks.  Charges will not be allowed
         for proofing operations or materials which are due to
         the fault of the contractor.

see, GPO Contract Terms, Supplemental Specifications, Art. 17
(Author's Alterations), as well as the standard GPO "Changes"
clause, which provides, in pertinent part:

      (a) The Contracting Officer may at any time, by written
      order, and without notice to the sureties, if any, make
      changes within the general scope of this contract in any
      one or more of the following:

         (1) Drawings, designs, or specifications when the
         supplies furnished are to be specially manufactured for
         the Government in accordance with the drawings, designs,
         or specifications.

   * * * * * * * * * *

      (b) If any change causes an increase or decrease in the
      cost of, or the time required for, performance of any part
      of the work, whether or not changed by the order, the
      Contracting Officer shall make an equitable adjustment in
      the contract price, the delivery schedule, or both, and
      shall modify the contract.

   * * * * * * * * * *

      (e) Failure to agree to any adjustment shall be a dispute
      under article 5 "Disputes."  However, nothing in this
      article shall excuse the contractor from proceeding with
      the contract as changed.

See, GPO Contract Terms, Contract Clauses, Art. 4 (Changes).7

   On December 22, 1988, the Appellant submitted the following
   bid for this job:

      1. Composition (including 4 sets of galley proofs)

         a. First 48 pages (8-1/2 x 11")      $ 2,886.00

            b. Each additional page (8-1/2" x 11") or
                  fraction thereof            $    57.00

            c. Head and Caption lines-18 picas or
                  fraction thereof-per page      $      N/C

            d. Additional Proofs (8-1/2 x 11")
                  if required-per page         $      .08

            e. Author's Alterations-per line      $      .94
                  (A minimum of 15 lines will be allowed)

      NOTE: Charges for Author's Alterations will not be honored
      unless the voucher submitted to GPO is supported by a copy
      of the proofs showing all changes.

      2. Page make-up (Including full page Illustration and
            4 sets of page proofs)

              a. First 48 pages (8-1/2 x 11")      $ 1,646.00

                b. Each additional page (8-1/2 x 11") or
                fraction thereof            $    38.55

      3. FILMS AND PROGRESSIVE PROOFS: Prices quoted are all-
      inclusive for the cost of all materials, opaquing and
      services including stripping of illustrations and
      positioning for compositioning.  All measurements will be
      based on the printed image size rather than the trim size
      of the finished films.

            a. Four-color process separations (per
                        square inch)               $     2.19

         b. Four-color progressive proofs
            (includes one full-color proof and
            one progressive proof book on the
            stock and in the inks to be used)
            (each set)               $   875.00

      4. PRINTING AND BINDING: Prices quoted must be all-
      inclusive for printing, binding and all paper.

                                       Makeready/        Running
                                       Per
                                                  Setup
                                                  100 copies
                                                  (1)
                                                  (2)

            a. First 48 pages plus cover   $ 3,840.00       $
            188.72

         b. Additional 4 page signatures   $ 1,224.00       $
         8.70

See, R4 File, Tab C; Complaint, p. 1.  The Contractor's total
estimated cost for the work was $40,461.75 (R4 File, Tab C).

   On January 4, 1989, the DRPPO issued Purchase Order No. K-0469
   to the Appellant, who was the low bidder,8 awarding it the
   contract to produce 10,050 copies of the Citizen Soldier, at
   an estimated contract price of $40,461.75 (R4 File, Tab E).

   Although the Purchase Order indicates that the Appellant was
   expected to complete production and delivery of the Citizen
   Soldier by May 5, 1989, as provided in the contract schedule
   (R4 File, Tabs A, p. 6 and E), the final publication was not
   shipped until January 31, 1990, nearly nine months later.
   See, Complaint, p. 3; App. Mem., p. 4,  23.  The reason for
   this delay is explained by the following undisputed chronology
   of events:

      1. On January 5, 1989, in accordance with the contract
      schedule, the Appellant picked up the Government furnished
      material, namely, the typewritten manuscript copy for a 48
      page, saddle-stitched pamphlet, with covers, as well as the
      photoprints and/or transparencies for the color
      illustrations.  Complaint, p. 1; App. Mem., p. 1.,  4, 5;
      Res. Brf., p. 2.

      2. On January 9, 1989, after completing the typesetting
      from the manuscript copy, the Appellant delivered the
      galley proofs to the DRPPO, well ahead of the contract
      schedule (January 17, 1989). Complaint, p. 1; App. Mem., p.
      1,  6; Res. Brf., p. 2.  See, R4 File, Tab A, p. 6.

      3. After the galley proofs were furnished to the DRPPO, the
      Respondent asked the Appellant to reset the type in two
      different type sizes so the Army should compare sizes with
      the original type, and decide which they wanted to use.
      The Contractor complied with these instructions, and on
      January 17, 1989, sent the DRPPO two additional galley
      proofs of the publication with the type changes.
      Complaint, p. 1; App. Mem., p. 2,  7.

      4. On February 15, 1989, nearly a week later than the date
      provided in the contract schedule (February 7, 1989), the
      DRPPO returned the two galley proofs and a dummy layout,
      and instructed the Contractor to make page proofs.
      Complaint, p. 1; App. Mem., p. 2,  8; Res. Brf., p. 2.  In
      order to comply with the DRPPO's directions, the Appellant
      had to go through the job twice, because the Army had used
      two different editors in making revisions, and set 164
      typed lines of changes.  The Contractor figures this
      additional work took eight (8) hours to accomplish, and
      none of that time was covered by its bid quote.9
      Complaint, p. 1; App. Mem., p. 2,  8.

      5. After making all of the author's alterations, the
      Appellant composed the pages, sized all illustrations, and
      then shot and stripped the entire job.  On February 23,
      1989, the Contractor furnished the required page proofs to
      the DRPPO.10  Complaint, p. 1; App. Mem., p. 2,  9.

      6. Sometime between February 23, 1989, and July 15, 1989,
      the Respondent told the Appellant that there would be major
      changes in the Citizen Soldier, and that the Contractor
      would be receiving new copy and instructions from the
      Government.  App. Mem., p. 2,  10.

      7. On July 15, 1989, more than two months after the
      original contract completion date (May 5, 1989) had lapsed,
      the DRPPO furnished the Appellant with a computer disk, and
      instructed the Contractor to use it to reset the text,
      totally replacing the existing type.11  Complaint, p. 2;
      App. Mem., p. 2,  11.  The art work, transparencies, or
      illustrations were not given to the Contractor at that
      time.  The Appellant attempted to comply with the DRPPO's
      new instructions, but because the disk contained numerous
      unrecognizable codes, the Contract was unable to use it for
      that purpose, and informed GPO that it would need hard copy
      of the new type in order to read it.  Complaint, p. 2; App.
      Mem., p. 2,  11.

      8. On July 24, 1989, the Appellant received the hard copy
      it had requested from the DRPPO, as well as the art work,
      dummy layout, and other materials which were not furnished
      on July 15, 1989.12  Complaint, p. 2; App. Mem., p. 3, 
      12; Res. Brf., p. 2.  Using this material, the Contractor
      was instructed to rest the type, make up the pages by
      pasting the new text on the existing art boards, and shoot
      progressive proofs.  Complaint, p. 2; App. Mem., p. 3, 
      12; Res. Brf., p. 2.  Pursuant to these directions, and
      following the hard copy as a guide, the Appellant began to
      reset the job from the furnished computer disk.  However,
      after setting the new type in galley format, the Appellant
      discovered that the text had been completely rewritten and
      would not fit the existing page layout.  Complaint, p. 2;
      App. Mem., p. 3, 12.  As a result, none of the original
      page layouts could be salvaged, and a major part of the
      film already produced was unusable.  Accordingly, the DRPPO
      instructed the Contractor to make new galley proofs and
      submit them along with the original pay layout.  Complaint,
      p. 2.; App. Mem., p. 3,  12.

      9. On August 1, 1989, the Appellant submitted the new
      galley proofs and the existing art boards to the DRPPO, as
      instructed.  Complaint, p. 2; App. Mem., p. 3,  13.

      10. Between August 1, 1989, and August 29, 1989, GPO and
      the Army revised the layouts and the art boards to conform
      to the new type.  App. Mem., p. 3,  14.

      11. On August 29, 1989, the Appellant received the galley
      proofs, as revised, with a new layout from the DRPPO.  The
      new layout confirmed what the Contractor had discovered a
      month earlier, namely, that the pamphlet had undergone
      major changes, and that, as redesigned, the Citizen Soldier
      consisted of 28 pages of text, not the 48 pages specified
      in the IFB.  Complaint, p. 2; App. Mem., p. 3,  15.
      Indeed, only the original outside cover was still usable.

      12. Between August 29, 1989, and September 28, 1989, the
      Appellant proceeded to carry out the DRPPO's instructions
      to prepare progressive page proofs.  In that regard, the
      Contractor unstripped all illustrations, including 48 four-
      color separations, scrapped all existing line film
      negatives, shot and stripped new line copy, restripped all
      four-color illustrations, and produced the progressive
      proofs.  Complaint, p. 2; App. Mem., p. 3,  16.
      13. On September 28, 1989, the Appellant submitted the
      progressive page proofs and six prior-to-production samples
      to the DRPPO.13  Complaint, p. 2; App. Mem., p. 3,  17;
      Res. Brf., p. 3.

      14. On October 2, 1989, the Appellant wrote to the DRPPO
      asking for a contract modification to cover its additional
      costs in making the changes to the Citizen Soldier (R4
      File, Tab F).  See, infra.  Complaint, p. 2; App. Mem., p.
      3,  18.  Subsequently, the Contractor also submitted
      separate claims for author's alterations, by letter dated
      January 9, 1990, and for film charges, by letter dated
      February 8, 1990 (R4 File, Tabs G and K).14  See, infra.
      App. Mem., pp. 3-4,  18-19.
      15. On December 6, 1989, the DRPPO returned the progressive
      page proofs, which contained additional author's
      alterations, to the Appellant.15  Complaint, p. 2; App.
      Mem., p. 4,  20; Res. Brf., p. 4.

      16. Between December 6, 1989 and December 27, 1989, the
      Contractor made the required changes, and then scheduled a
      press inspection.  Although the inspection was originally
      scheduled for December 27, 1989, at the DRPPO's request it
      was postponed until January 9, 1990 (R4 File, Tab G).16
      Complaint, p. 2; App. Mem., p. 4,  21.

      17. On January 9, 1990, the DRPPO and the Army made the
      press inspection, approved the job, and the Appellant went
      into press production.  Complaint, p. 3; App. Mem., p. 4, 
      22.

      18. On January 31, 1990, the Contractor shipped the
      completed job to the Army, in accordance with the
      contract's distribution instructions (R4 File, Tab G).
      Complaint, p. 3; App. Mem., p. 4,  23.  See, R4 File, Tab
      A, pp. 5-6 (Shipping Instructions).

   There is no dispute that the Appellant fully performed all of
   the work required under the contract in a timely manner and to
   the complete satisfaction of the Government.

   II. THE CONTRACTOR'S CLAIM

   As indicated above, this dispute began when the Appellant sent
   a letter to the DRPPO on October 2, 1989, providing the
   Respondent with information concerning its additional expenses
   and asking for a contract modification reimbursing it for the
   costs it would not otherwise have incurred but for the changes
   and delays connected with the work on the Citizen Soldier (R4
   File, Tab F).  In that letter, the Contractor itemized its
   claim, as follows:

      1. a. Typesetting initial order per contract      $
      2,886.00
         e. Author's alterations 164 @ $ .94           154.16
            Rerun two galleys @ $48.00 ea[ch]             96.00
      2. a. Page make[-]up               1,646.00
            Total first set of camera copy         $  4,782.16

      1. a. Resetting a total of 32 pages
            Base price of $2,886.00 less 16 pages
            @ $ 57.00 ea[ch] (-$912.00)         $ 1,974.00
         e. Author's alterations 4 @ $ .94              3.76
      2. a. Page make[-]up second round
            Base price of $1,646.00 less 16 pages
            @ $38.55 ea[ch] (-$616.80)           1,029.20
            Total cost to reset and remake         $ 3,006.96
            Total [c]ost for typesetting         $ 7,789.1217

      3.a. Price would obviously remain as quoted as this is to
      be charged per square inch on work actually performed, and
      up to now, we have not remade any four-color [separations].

        b. This price would also remain unchanged as we are still
        furnishing four sets of progressive proofs as originally
        specified.
      4.a. (1) and (2). These prices would obviously change due
      to the extensive alterations.  We are now running three
      [different press configuration] signatures plus cover.18
      With this in mind, our new prices for these two items are
      as follows:

         a. (1) Setup               $14,688.00
         a. (2) Running per 100 copies                92.75

      Provided the [Army] doesn't make additional alterations to
      the proofs, this should cover all of our additional costs.

See, R4 File, Tab F, pp. 2-3.

   On January 9, 1990, the Contractor submitted another claim to
   the DRPPO for making the author's alterations indicated in the
   returned progressive page proofs (R4 File, Tab G).  Noting
   that its higher costs were due to the fact that the changes
   were made to pages that had already been made up and
   photographed, the Appellant informed the Respondent that the
   new charges were:

      1. Page 5-Redo process color map to knock
            out color in highlighted area, leaving
            the bold and light state borders, and
            drop back in to print all one color red   $450.00

         Set new line copy @ 2 lines      $  15.00

         Shoot and strip new line copy      $  42.00   507.00

      2. Page 7-Set new line copy @ 2 lines   $  15.00

         Shoot and strip new line copy      $  42.00    57.00

      3. Page 14-Set new copy @ 2 lines   $  15.00

         Shoot and strip new line copy      $  42.00    57.00

      4. Page 20-Set new line copy @ 2 lines   $  15.00

         Shoot and strip new line copy      $  42.00    57.00

      5. Page 28-Set new line copy @ 3 lines   $  20.00

         Shoot and strip new line copy      $  50.00    70.00

      6. Recomposite one set of four-color
         40" flats and three black only flats
         @ $40.00 each                  280.00

      TOTAL COST FOR AUTHOR[']S ALTER-
      ATIONS MARKED ON THE PRESS
      PROGRESSIVE PROOFS                 $1,028.00

See, R4 File, Tab G, p. 1.

   In response to these claims, the Contracting Officer sent a
   letter, dated January 24, 1990, to the Contractor stating
   that, by his calculations, the changes made to the Citizen
   Soldier had reduced the contract price to $28,514.11 (R4 File,
   Tab I).19  In that regard, the Contracting Officer figured the
   allowable charges for the publication as follows:

      1. Composition from manuscript, 48 pages + cover,
            and associated author's alterations         $
            3,040.16
      2. Page makeup, 36 pages + cover           1,337.60
      3. Composition from new computer disk, 28 pages +
         cover, and associated author's alterations
         1,977.76
      4. Page makeup, 28 pages + cover           1,029.20
      5. Four-color separation, 46 photographs for a total
            of 1,066 sq.in.                     2,334.54
      6. Four-color progressive proofs, 4 sets           2,500.00
      7. Print, makeready                    3,840.00
      8. Print, running                   11,426.85
      9. Author's alterations to progressive proofs
      1,028.00
         TOTAL COST FOR THE ORDER         $28,514.11

See, R4 File, Tab I.  Attached to the Contracting Officer's
letter was Contract Modification No. K-1, dated the same day and
signed by him, decreasing the price of the pamphlet from an
estimated cost of $40,461.75 to "the agreed upon firm cost of
$28,514.11" (R4 File, Tab I).

   The Appellant disagreed with the Contracting Officer's
   calculations and refused to sign the Contract Modification.
   Instead, on January 29, 1990, the Contractor set a letter to
   the Contracting Officer, stating, in pertinent part:

      Your Contract Modification Number K-1, ... is in error.
      The total cost we agreed upon was as listed in our two
      letters, dated October 2, 1989 and January 9, 1990, to your
      office, not the $28,514.11 in the Contract Modification.

      Actual bottom line figure we computed was $38,707.00.  In a
      phone conversation with Mr. Bollinger of your office we
      expressed a willingness to compromise on one minor charge
      ($96.00 to return galleys) even though that was the amount
      charged us.  We do not agree on any other reduction.

See, R4 File, Tab J.

   The record discloses that the parties discussed their dispute
   over the telephone on February 7, 1990 (R4 File, Tab K).  The
   following day, the Appellant wrote another letter to the
   Contracting Officer which confirmed their conversation, and
   said, in pertinent part:

      Our charges for Author's Alterations were fair and
      reasonable.  We responded to the alteration in the manner
      we did for the convenience of the Government, so that
      prices would flow with the original schedule of prices, and
      your representative gave verbal approval.  The fact is we
      incurred a greater cost on the order up to the time we were
      instructed to scrap what we had done and start over than we
      estimated.  But, because your representative requested we
      reply with a cost quickly, we replied with estimated
      figures in lieu of actual figures.  These estimated figures
      were low by $6,428.00 but, since we had already furnished
      them to you, we were willing to honor them.

      Now, 114 days after your representative accepts our figure,
      you make a unilateral decision to reduce it $10,192.89.
      Since you have refused to honor the figures we submitted in
      October, we submit to you the following:

         1. Original estimated cost for forty-eight pages plus
         cover is $40,461.75.

         2. Having done all the typesetting, page make[-]up,
         camera and stripping on the original copy, we completed
         approximately 50% of the work to be done.  Total
         invested up to this point [was] $20,230.00.

         3. Starting over, we now produce 28 pages plus cover.
         If you prorate the original cost to the Government (as
         you apparently did to arrive at your figure) the cost
         for this is $24,900.00.  Add to this the cost of
         alterations done after the progressive proofs were
         returned and the cost comes to $25,928.00.

         4. In actuality, for all work performed up to the time
         we started over on this project, the total cost is
         $15,395.00.

         5. The total cost for all work performed to produce the
         28 page plus cover version is $29,740.00 bringing a
         total cost for the order to $45,135.00.

      We now request the Contract Modification be amended or a
      new one issued to reflect a total cost of $45,135.00 . . .

      We also request you make your final decision by February
      15, 1990 . . .

See, R4 File, Tab, pp. 1-2.

   By letter dated February 12, 1990, the Contracting Officer
   answered the Appellant's previous correspondence, reaffirming
   his decision concerning the allowable charges, and denying the
   Contractor's request for a new or revised Contract
   Modification (R4 File, Tab L).  The Contracting Officer's
   reasons for his determination, in pertinent part, were as
   follows:

      . . . [T]he charges allowed, as itemized in my letter to
      you on January 24, 1990, are accurate.  Each of those
      charges has been derived from your original quotation.
      Except for the charges attributable to author's alterations
      to press progress proofs, for which you are being paid in
      accordance with the list of charges in your letter of
      January 9, 1990, all of the charges allowed represent a
      proportionate value for work performed.

      With respect to the actual makeready and running of the end
      product, it is reasonable to expect that the cost of a 28-
      page product will be less than the cost of a 48-page
      product.  Again, the reduction in cost is proportionate to
      the reduction in the number of pages in the finished
      product versus the number of pages in the original
      estimate.  In every case, the charges I have allowed have
      been derived directly from your original quotation

See, R4 File, Tab L. [Emphasis added.]

   The Appellant timely appealed the Contracting Officer's
   decision to the Board by letter dated February 16, 1990 (R4
   File, Tab M).20

   III. ISSUE PRESENTED

   The sole question in this appeal is:

      Is the Appellant entitled to additional compensation as an
      equitable adjustment because of the changes made in the
      Citizen Soldier by the Government, and if so, how much?

   IV. POSITIONS OF THE PARTIES21

   The issue before the Board is essentially a question of which
   pricing mechanism-the Appellant's use of its bid estimates or
   the Respondent's proportional reduction approach-has the best
   chance of establishing a fair and reasonable price for the
   work performed under the contract for the Citizen Soldier
   before the Government decided to reduce the size of the
   pamphlet.  The positions of both parties on this question,
   each of whom relies on the Contractor's original bid estimates
   for support to some extent, can be briefly summarized.

   In its appeal letter to the Board, the Appellant succinctly
   stated the heart of its case:

      [The Contracting Officer] is basing his decision to pay us
      only $28,514.11 for the order on the fact that ". . . it is
      reasonable to expect that the cost of a 28-page product
      will be less than the cost of a 48-page product."  We agree
      wholeheartedly.  In fact we are asking payment of
      $29,740.00 for the 28-page product.  What we cannot accept
      is his decision to refuse payment on the work performed on
      the original pamphlet.  For that we request payment of
      $15,395.00.

See, R4 File, Tab M, p. 1.22  Simply stated, the Appellant wants
to be paid for all of the pre-press work it performed on the
pamphlet before the Army changed it to a smaller publication.23
See, Complaint, p. 5.

   First, the Appellant strenuously objects to the method chosen
   by the Respondent to calculate the revised contract price.
   Complaint, p. 5; App. Mem., p. 4.  In that regard, the
   Contractor argues that extrapolating the contract price for
   the 28-page final version of the Citizen Solider by the simple
   expedient of prorating the original bid estimates for a
   booklet which was to have 20 more pages, is not only illogical
   and unreasonable, but the approach is without justification as
   a matter of industry practice and unfairly penalizes the
   printer performing the work.  Complaint, p. 5; App. Mem., p.
   4; RPTC, p. 4.  Insofar as the Respondent relies on the
   language in the "Determination of Award" section of the
   contract which says that there is no guarantee of any specific
   units of production or any particular volume of work (R4 File,
   Tab A, p. 7), the Appellant believes that the contract
   provision has no relevance to this appeal.  App. Mem., p. 4.
   Thus, the Contractor does not dispute the Respondent's
   interpretation of the "Determination of Award" language, in
   principle, but contends that the real issue here concerns how
   changes to the contract are to be priced when the "Schedule of
   Prices" is silent on the matter; i.e., all line items in the
   pricing schedule contemplate in a 48 page publication.24
   Complaint p.5; App.Mem., p. 4.  In the Appellant's view it is
   not possible to simply prorate the price for a 48-page
   pamphlet in order to determine the cost of production of a
   booklet containing 20 pages less.25  App. Mem., p. 5.  Rather,
   the Contractor believes that its computation of the prices for
   the revised version of the Citizen Soldier is both fair,
   reasonable, and unimpeachable when all factors are considered.
   App. Mem., p. 5.

   Second, the Appellant contends that it is entitled to be
   reimbursed for the costs it incurred prior to the revision of
   the publication because the Contracting Officer did not manage
   the situation properly.  App. Mem., p. 5.  In that regard, the
   Contractor states that two courses were available to the
   Contracting Officer once he became aware that there would be
   extensive delays and substantial alterations in the product:
   (1) terminate the contract for the convenience of the
   Government, pay the Contractor for the work performed, and
   rebid the job; or (2) negotiate a firm fixed price for both
   the work already performed and the printing of the revised
   booklet before continuing with production under the
   contract.26  Id. (citing, PPR, Chap. VI, Sec. 3).  The
   Contracting Office took neither step in this case, but rather
   allowed the job to go to press without any meaningful price
   negotiations.  App. Mem., pp. 5-6.

   Third, the Appellant contends that the Contracting Officer was
   only interested in obtaining the Citizen Soldier for the Army
   at the lowest possible price, and was not concerned with the
   matter of fair compensation for the Contractor.  App. Mem., p.
   6.  The Appellant says this is particularly true with respect
   to its claim for $6,427.90 for the cost of unutilized film
   work on the original specifications.  Id. (citing, Complaint,
   p. 3).  Since the Respondent has not challenged the
   reasonableness of the Contractor's charges,27 it should be
   liable for the amount claimed because the Government-ordered
   changes made the previously performed work unusable.  Id.
   Furthermore, GPO's contention that the Appellant should bear
   the cost of the disputed film work because it was done
   prematurely without the approval of the Government, is not
   supported by the facts.  The Contractor says that it is
   uncontradicted that GPO did, indeed, approve the initial
   composition of the original 48 page pamphlet, subject to
   author's alterations, which were made prior to performing the
   film work.  Id.  See also, RPTC, pp. 7-8.  In the Appellant's
   view, the Respondent's claim that it had not told the
   Contractor to proceed with the camera work, merely disguises
   the real reason the films had to be scrapped; i.e., because
   the original pamphlet was completely redesigned by the
   Government.  App. Mem., p. 6.  Accordingly, for these reasons
   the Appellant asks the Board to overrule the Contracting
   Officer and sustain its claim.  App. Mem., p. 7.

   The Respondent, on the other hand, argues that the Contracting
   Officer's conclusion that the Appellant was only entitled to
   be paid $28,514.11 for the work performed producing the
   Citizen Soldier is fully justified.  Res. Brf., p. 5.  The
   Contracting Officer based his calculations for the job on the
   Contractor's own initially quoted prices.  RPTC, p. 5.
   Furthermore, the "Determination of Award" provisions of the
   contract placed the Contractor on notice that the number of
   pages could vary, more or less, from the contract estimates,
   and the Government would have to base any equitable adjustment
   on the bid figures in order to prorate the costs of the actual
   work (R4 File, Tab A, p. 7).  Id.  In this case, the
   Contracting Officer used those bid estimates to compute the
   amount due th Appellant for the author's alterations and other
   changes resulting from the Government's reduction of the size
   of the book (R4 File, Tab I, Items 1-3).  RPTC, p. 6.
   However, the Contracting Officer did not reimburse the
   Contractor for film work because, at this stage, the
   Government had not approved anything beyond typesetting.
   RPTC, pp. 6-7.  Consequently, if the Appellant produced
   negatives and film work which were later unusable, it did so
   prematurely and the Government did not have to pay for it.
   RPTC, p. 7.

   The Respondent also believes that the Appellant's equitable
   adjustment approach is illogical, undocumented, and
   insupportable.  Res. Brf., p. 6.  While the parties are in
   essential agreement with respect to the amount claimed for
   composition and page make-up, they disagree on the charges for
   progressive proofs and printing the pamphlet.  Res. Brf., p.
   5.  As GPO sees it, the Contractor's figures for progressive
   proofs and setup make no sense, because it asks for the
   original contract price for fewer pages than estimated, on the
   one hand, while it says that 32 pages of setup work cost
   nearly four times more than the original 48 pages, on the
   other.  Id.  In any event, the Respondent contends that the
   Appellant has failed to provide sufficient documentation to
   support its claim.  Id.

   Finally, the Respondent contends the law holds that when the
   Government deletes a separately priced item of work from a
   contract, the stated contract item price, rather than the
   amount the work would have cost, is the proper measure of the
   contract price adjustment.  Res. Brf., pp. 5-6 (citing,
   Gregory & Reilly Associates, Inc., FAACAP No. 65-30, 65-2 BCA
    4,918; Groesbeck-Durbin, Inc., DOT CAB No. 70-24, 72-1 BCA 
   9,251; Holtzen Construction Company, AGBCA No. 413, 75-2 BCA 
   11,378).  Even though a contractor may suffer a loss of profit
   from application of this rule, the parties should be held to
   the bargained for item price in computing equitable
   adjustments.  Res. Brf., p. 6.  Moreover, a reduction in the
   amount of work does not authorize a repricing of the entire
   contract.  Accordingly, the Respondent urges the Board to deny
   the appeal, and affirm the Contracting Officer's decision.
   Id.

   V. DECISION28

   When this appeal was filed with the Board on February 16,
   1990, no one expected that more than four years would pass
   before the Contractor received a decision.  Consequently, the
   appeals process itself has probably compounded the frustration
   felt by the Appellant with this procurement.29  Some of the
   delay experienced in processing this case, of course, occurred
   because the Board, instead of directing an audit of the claim,
   allowed the parties to fritter away time discussing possible
   audit schemes.30  On two occasions recently, the Board has
   expressed its preference for audited claims.  See, Banta
   Company, GPO BCA No. 03-91 (November 15, 1993), Sl. op. at 57;
   R.C. Swanson Printing and Typesetting Company, GPO BCA 15-90,
   Decision on Motion for Reconsideration and Order (December 20,
   1993), Sl. op. at 14 (hereinafter R.C. Swanson II).  The state
   of this record, which is nothing short of awful, only confirms
   the Board in that opinion.31  The Board's time is too
   precious, considering its small staff and the demands of its
   heavy caseload, to spend doing the work of the parties by
   sorting out the various aspects of their respective claims.
   Accordingly, in the future, if in the judgment of the Board
   the clarification of a claim on appeal is necessary in order
   to resolve a dispute, it will remand the matter to the
   Contracting Officer, through Government Counsel, with
   instructions to have the claim audited, and will dismiss the
   appeal without prejudice until the audit is complete.32  Board
   Rules, Rule 13(c).  See, National Council of Negro Women, LBCA
   No. 84-BCA-18, 84-2 BCA  17,436, at 86,827.  The Board is
   confident that, in the long run, this new policy will buttress
   a major purpose of the Board's preliminary procedures, namely,
   obtaining fully disclosure of relevant and material facts.
   Board Rules, Preface to Rules,  VI.D.

   The Board admits that it could done a better job policing the
   time it had allowed the parties to find a path out of the
   wilderness which is this record.  However, the Respondent and
   the Appellant should also recognize that they are not
   blameless either.  From the Government's standpoint, this
   procurement was not only plagued by a customer-agency which
   could not make up its mind, but the DRPPO mishandled the
   project in the face of the Army's uncertainty, and only made a
   bad situation worse.  Generally, deletions of major portions
   of work are not authorized by the "Changes" clause.  See,
   Nager Electric Company, Inc. and Keystone Engineering
   Corporation v. United States [16 CCF  80,367], 194 Ct.Cl.
   835, 851-53, 442 F.2d 936, 945-46 (1971) (hereinafter Nager
   Electric Company); Capital Electric Company, GSBCA No., 5122,
   81-2 BCA  15,281; Burroughs Corporation, GSBCA No. 5019, 79-2
   BCA  14,083, mot. for reconsid. denied, 80-2 BCA  14,487;
   Celesco Industries, Inc., ASBCA No. 22251, 79-1 BCA  13,604;
   Toke Cleaners, IBCA 1008-10-73, 74-1 BCA  10,633.  See
   generally, John Cibinic, Jr. and Ralph C. Nash, Jr.,
   Administration of Government Contracts 2d ed., (The George
   Washington University, 1986), pp. 292-93 (hereinafter Cibinic
   and Nash).  Instead, where, as here, the Government deletes
   significant portions of the work by contract modification, or
   otherwise, the matter is usually treated as a partial
   termination for convenience.  See, J. W. Bateson Company v.
   United States [8 CCF  71,867], 308 F.2d 510 (5th Cir. 1962);
   H. L. Yoh Company, Inc. v. United States [8 CCF  71,469], 153
   Ct.Cl. 104 (1961); Manis Drilling, IBCA No. 2658, 93-3 BCA 
   25,931; Celesco Industries, Inc., supra, 79-1 BCA  13,604;
   Frederick Construction Company, ASBCA No. 12108, 68-1 BCA 
   6,832; Doughboy Industries, Inc., FAACAP No. 67-3, 66-2 BCA 
   5,712.  As explained by the Department of Interior Board of
   Contract Appeals:

      Both the Changes and the Termination for Convenience
      clauses provide a mechanism for the deletion of contract
      work.  However, when major portions of the contract work
      are deleted, the Termination for Convenience clause is more
      appropriate where no additional work is substituted in its
      place.  Similarly, deletion of a minor item of work is
      considered to be within the ordinary coverage of the
      Changes clause.  Industrial Consultants, Inc., VABCA No.
      3249, 91-3 BCA  24,326 at 121,551.  The use of the
      Termination for Convenience clause is more appropriate for
      a reduction of the number of units or supplies to be
      delivered; elimination of identifiable items of work;
      reduction in the quantity of work required under the
      contract; or similar reductions in contract tasks.  Celesco
      Industries, Inc., ASBCA No. 22251, 79-1 BCA  13,604 at
      66,682-83.
Manis Drilling, supra, 93-3 BCA  25,931, at 128,980.  [Emphasis
added.]  See also, Skidmore, Owings & Merrill, ASBCA No. 5115,
60-1 BCA  2,570; Nolan Brothers, Inc., ASBCA No. 43778, 58-2 BCA
 1,910.  In this case, the Board finds itself in agreement with
the Appellant's argument that rather than proceeding as if this
was a normal contract modification situation, the Contracting
Officer should have exercised the Government's rights under the
contract's "Termination for the Convenience of the Government"
clause, GPO Contract Terms, Contract Clauses, Art. 19, once he
saw that the extensive author's alterations being made by the
Army were causing major disruptions in the contract performance
schedule, substantially reducing the product for which bids had
been solicited, and increasing the Contractor's costs.33
Compare, e.g., R.C. Swanson Printing and Typesetting Company, GPO
BCA 15-90, Decision and Order (March 6, 1992) (a Department of
Justice contract for typesetting legal briefs from manuscript
copy was terminated for the convenience of the Government by GPO
when the customer-agency decided it also wanted to transmit brief
copy in an electronic format); Graphic Litho Company, Inc., GPO
BCA 17-85 (September 30, 1988) (after extensive delays, a
Department of Agriculture contract for the production of maps was
terminated for convenience by GPO because the customer-agency
still had not indicated when it would have the corrected
Government-furnished material ready for the contractor).
Certainly, there was ample opportunity for the Contracting
Officer to do so, especially between February 23, 1989, and July
15, 1989, a period of nearly five months, when the job was in
limbo.  The Contracting Officer's failure to exercise his
convenience termination authority directly contributed to the
subsequent problems experienced by both parties in trying to
assess the impact of the changes on the Appellant's costs, and
helps to explain why their results are so wildly different.34
Celesco Industries, Inc., supra, 79-1 BCA  13,640, at 66,682.

   On the other hand, even though the Board believes that matters
   would have been cleaner if the Contracting Officer had
   terminated the contract for convenience at the beginning,
   instead of trying to fit all of the Army's alterations under
   the umbrella of the "Changes" clause, it is also aware that in
   most cases agency boards of contract appeals will not disturb
   a contracting officer's choice of procedure, particularly
   where the contractor has not challenged the exercise of that
   discretion.  See, Condor Reliability Services, Inc., ASBCA No.
   40538, 90-3 BCA  23,254; Goetz Demolition Company, ASBCA No.
   39129, 90-3 BCA  23,241; Kinetic Engineering & Construction,
   Inc., ASBCA No. 30726, 89-1 BCA  21,397; Celesco Industries,
   Inc., supra, 79-1 BCA  13,604.  Thus, the ASBCA has said:

      The question of whether work should be deleted under the
      Changes clause or the Termination clause is best left to
      the circumstances of each case and where the parties
      proceeded by means of a deductive change we will not alter
      that treatment absent a compelling reason.  [Citation
      omitted.]  Here, we see no reason whatever, and none is
      provided to us by the parties, to disturb the parties'
      treatment of the termination of identifiable items of work
      through a deductive change.

Goetz Demolition Company, supra, 90-3 BCA  23,241, at 116,618.
See also, Condor Reliability Services, Inc., supra, 90-3 BCA 
23,254, at 116,675; Kinetic Engineering & Construction, Inc.,
supra, 89-1 BCA  21,397, at 107,871-72; Celesco Industries,
Inc., supra, 79-1 BCA  13,604, at 66,683.  From the outset, this
dispute has been treated by the parties as one involving a
deductive change under the "Changes" clause, and their respective
monetary claims have been crafted with an eye toward traditional
equitable adjustment rules.  Since the parties have presented
this appeal in its "Changes" clause form, and the Board can find
no "compelling reason" to take a different approach, consistent
with established Board policy it will leave their judgement
undisturbed.  See, Shepard Printing (1993), supra, Sl. op. at
14-15, fn. 20; Stephenson, Inc., supra, Sl. op. at 19-20, fn. 22;
Stabbe Senter Press, GPO BCA 13-85 and 19-85 (May 12, 1989), Sl.
op. at 53.

   The Appellant also made a significant contribution to the
   confused state of this record.  No doubt is was too much to
   expect the Contractor to submit a pristine claim given the
   turmoil of the actual procurement.  However, the history of
   this claim shows that the Appellant, both in substance and
   approach, fell far short of providing the sort of cooperation
   and assistance that is normally expected from someone asking
   for money from the Government.  In that regard, the claim was
   deficient in at least three respects.
   First, the piecemeal fashion in which the Contractor submitted
   its claim to the Contracting Officer-i.e., the total claim was
   submitted in three parts over a five month period, on October
   2, 1989, January 9, 1990, and February 8, 1990, respectively
   (R4 File, Tabs F, G, and K)-was hardly conducive to orderly
   processing.  Since GPO's Contracting Officers are required by
   the agency's procurement rules to attempt to negotiate claim
   settlements before issuing final decisions, the casual manner
   in which the Appellant delivered the separate pieces of its
   total claim only frustrated the regulatory purpose.  PPR,
   Chap. X, Sec. 1,  4.

   Second, and perhaps more importantly, the regulations describe
   a properly filed claim as possessing certain essential
   characteristics, namely: (1) it must be made in good faith;
   (2) it must honestly and accurately reflect of the
   contractor's belief of the contract liability of the
   Government; (3) it must be prepared from the contractor's
   books of account in accordance with Government recognized cost
   principles and accounting practices; (4) it must be accurate,
   complete, and current as of the date of submission; and (5) it
   must be prepared for the purpose of furnishing a basis for
   settlement.  PPR, Chap. X, Sec. 1,  3.  These requirements
   are somewhat mirrored in the Board Rules regarding Complaints.
   Board Rules, Rule 6(a).  However, in this case the Appellant
   has submitted a claim which, to be charitable, may be
   described as practically indecipherable.  For example, 65
   percent of the Contractor's claim is in a single line item-
   makeready/setup charges (item 4.a(1)).35  Originally, the
   Appellant estimated that makeready/setup would cost $3,840.00
   (R4 File, Tab C).  By the time the Appellant had completed
   making all of the Army's alterations, that figure had
   ballooned to $14,688.00.  To be blunt, the adjusted amount
   does not inspire much trust or confidence as a proper claim
   under the regulations because simple arithmetic shows that
   $14,688.00 is exactly 3.825 times $3,840.00.  On the surface,
   therefore, rather than being an accurate and complete
   statement of the Appellant's costs as reflected in its
   accounting ledgers, or at least a rational and honest estimate
   of them, the revised makeready/setup charge looks suspiciously
   like the result of some arbitrary formula.  Claims prepared on
   such a basis are uniformly rejected by agency boards of
   contract appeals.36  See, e.g., Ordnance Materials, Inc.,
   ASBCA No. 32371, 88-3 BCA  20,910 (a contractor's appeal for
   an equitable adjustment was denied because his claim was based
   on the arbitrary formula he used in preparing his bid rather
   than on the actual increase in his costs stemming from the
   Government's change order).

   Lastly, the Appellant has not supported its claim with any
   relevant or material documentation showing how it arrived at
   its statement of costs.37  Apart from the material in the R4
   File, only two pieces of documentary evidence were submitted
   by the Appellant in the context of this appeal-the price
   quotation from Colortek and its preliminary bid estimate for
   another GPO contract (Program C598-S)-and the Board had
   rejected both of them.38  See, Appellant's Letter of April 3,
   1990, Exhibits A and B.  As a consequence, despite the Board's
   requests from the outset of the appeal for information which
   would clarify the record either by means of a stipulation of
   facts or an audit of the Appellant's claim, and the
   opportunity afforded the parties to provide such evidence, the
   record in this case is in no better shape than it was when it
   crossed the Board's threshold four years ago.

   In the end, the Board is left to puzzle its way through an
   appeal record which is murky at best.  Unfortunately, the
   Board's analytical powers do not include clairvoyance.
   However, the Board has a responsibility to put an end to this
   controversy.  See, Banta Company, supra, Sl. op. at 24.  See
   also, Lawrence D. Krause, AGBCA No. 76-118-4, 82-2 BCA 
   16,129, at 80,073; Johnson, Drake & Piper, Inc., ASBCA No.
   9824, 65-2 BCA  4868, at 23,073.  Accordingly, when the board
   considers the appeal record in light of traditional equitable
   adjustment principles, it believes, for the following reasons,
   that the Appellant is entitled to an additional reimbursement
   of $8,310.45 from the Government.


      A. Neither the Respondent's proportional approach nor the
      Appellant's unsupported estimates furnish an adequate basis
      for calculating the appropriate equitable adjustment in
      this case.  Instead, the Board Believes that a fair and
      reasonable equitable adjustment is best determined by use
      of the "jury verdict" technique.

   Clearly, when the Government reduced the number of pages in
   the Citizen Soldier, it expected there would be a concomitant
   shrinkage in the contract price.  See, Plaza Maya Limited
   Partnership, GSBCA No. 9086, 91-1 BCA  23,425; Goetz
   Demolition Company, supra, 90-3 BCA  23,241; Art Cap Company,
   Inc., ASBCA No. 3793, 58-1 BCA  1,623.  Therefore, the
   central issue in this dispute concerns the quantum of relief;
   i.e., how much of equitable adjustment should the Appellant
   receive or, in the alternative, how much of a credit was due
   the Respondent because of the page reduction.  Banta Company,
   supra, Sl. op. at 49.  The answer to that question really
   depends on the scope of the reduction in the Appellant's
   contract performance which was brought about by the
   Government's change in the size of the publication.
   Consequently, when the Board looks at the record in this case,
   it finds itself in agreement with the ASBCA which remarked, in
   a similar situation:

      It is unfortunate that the parties never concentrated on
      the actual reduction of appellant's specific contractual
      obligations . . . thereby contributing to their fruitless
      efforts over a period of four years to reach an amicable
      resolution.

Celesco Industries, Inc., supra, 79-1 BCA  13,604, at 66,682.

   At the outset, perhaps it is best to restate certain elemental
   principles concerning equitable adjustments so that the
   parties may have a clear understanding of the guideposts
   followed by the Board in resolving this dispute.

   First, an equitable adjustment is basically a corrective
   measure designed to keep a contractor whole when the
   Government modifies a contract.  J.F. Shea Company, Inc. v.
   United States, 10 Cl.Ct. 620, 627 (1986) (citing, Bruce
   Construction Corporation v. United States, supra, 163 Cl.Ct.
   at 100, 324 F.2d at 518); Dick & Kirkman, Inc., VABCA Nos.
   1545, 1581, 84-3 BCA  17,662, at 88,082; CRF, A Joint Venture
   of CEMCO, Inc. and R.R. Communications, Inc., ASBCA No. 17340,
   76-1 BCA  11,857, at 56,805 (hereinafter CRF, A Joint
   Venture).

   Second, the purpose of an equitable adjustment is to place a
   contractor in the position it would have been in had the
   change not occurred; i.e., the adjustment also should not
   alter the contractor's profit or loss position from what it
   was before the change occurred.39  J.F. Shea Company, Inc. v.
   United States, supra 10 Cl.Ct. at 627;  Pacific Architects &
   Engineers, Inc. v. United States, 203 Ct.Cl. 499, 508, 491
   F.2d 734, 739 (Ct.Cl. 1974);  Nager Electric Company, supra,
   194 Ct.Cl. at 851-53, 442 F.2d at 945-46; Keco Industries,
   Inc. v. United States, 176 Ct.Cl. 983, 999-1002, 364 F.2d 838,
   849-850 (1966),  cert. denied, 386 U.S. 958
(1967); CRF, A Joint Venture, supra, 76-1 BCA  11,857, at
56,804; Hensel Phelphs Construction Company, ASBCA No. 15142,
71-1 BCA  8,796.  See also, Cibinic and Nash, pp. 544-45.

   Third, the burden of proof in establishing the total amount of
   an equitable adjustment falls on the party who is claiming the
   benefit of the adjustment.  See, Cibinic and Nash, p. 504.
   Thus, a contractor has the affirmative burden of proving the
   amount of money to which it is entitled.  Michael-Mark, Ltd.,
   IBCA Nos. 2697, 2890, 2891, 2892, 2893, 2894, 2895, 94-1
BCA  26,453; Lemar Construction Company, ASBCA Nos. 31161,
31719, 88-1 BCA  20,429; Lawrence D. Krause, supra, 82-2 BCA 
16,129; Onetta Boat Works, Inc., ENGBCA No. 3733, 81-2 BCA 
15,279; Globe Construction Co., ASBCA No. 21069, 78-2 BCA 
13,337.  Meanwhile, the Government must establish the amount of
the credit it took.  Michael-Mark Ltd., supra, 94-1 BCA  26,453;
Zurfluh Enterprises, Inc., VABCA No. 1941, 85-1 BCA  17, 789;
CRF A Joint Venture, supra, 76-1 BCA  11,857; Hudson Garment
Company, Inc., ASBCA No. 4645, 60-1 BCA  2,628.  Whether that
burden has been met is determined by the "preponderance of the
evidence" test.  Teledyne McCormick-Selph v. United States, 214
Ct.Cl. 672, 558 F.2d 1000 (1977); Wilbur Smith & Associates,
Inc., ASBCA No. 35301, 89-3 BCA  22,025.  See, Cibinic and Nash,
p. 504.

   Fourth, the preferred method for establishing the amount of an
   equitable adjustment is through the introduction of actual
   cost data.40  See., e.g., Dawco Construction, Inc. v. United
   States, supra, 930 F.2d at 882; Cen-Vi-Ro of Texas v. United
   States, 210 Ct.Cl. 684 (1976); Buck Brown Contracting Co.,
   IBCA No. 1119-7-76, 78-2 BCA  13,360; Engineered Systems,
   Inc., DOTCAB No. 75-5, 76-2 BCA  12,211; Bregman Construction
   Corporation, ASBCA No. 15020, 72-1 BCA  9,411.  As a rule,
   actual costs are proved through the introduction of the
   contractor's accounting records, which will be accepted if
   they have been audited by the Government and are unrebutted.
   Celesco Industries, supra, 79-1 BCA  13,604.  However, if the
   accounting records are not available due to no fault of the
   contractor, the costs may be established on the basis of
   estimates, if they are supported by detailed, substantiating
   data.41  See, e.g., R. G. Robbins & Company, ASBCA No. 27516,
   83-1 BCA  16,420; Leopold Construction Company, ASBCA No.
   23705, 81-2 BCA  15,277; Bailey Specialized Buildings, Inc.,
   ASBCA No. 10576, 71-1 BCA  8,699.

   Finally, the touchstone for determining the amount of an
   equitable adjustment is the difference between what it
   reasonably would have cost to perform the work as originally
   required and what it reasonably cost to perform the work as
   changed.42  General Builders Supply Co. v. United States, 187
   Ct.Cl. 477 (1969); Michael-Mark Ltd., supra, 94-1 BCA 
   26,453; Zurfluh Enterprises, Inc., supra, 85-1 BCA  17,789;
   Dick & Kirkman, Inc., supra, 84-3 BCA  17,662; Lawrence D.
   Krause, supra, 82-2 BCA  16,129; Celesco Industries, supra,
   79-1 BCA  13,604; Jack Picoult, VABCA No. 1221, 78-1 BCA 
   13,024.  Whether a contractor's costs are reasonable is a
   question of fact depending on the circumstances.43  Nager
   Electric Company, supra, 194 Ct.Cl. at 851-53, 442 F.2d at
   945-46.

   The principle claim in this case is a Government claim; i.e.,
   the Respondent issued a contract modification which took a
   credit for the deleted work (R4 File, Tab I).  Goetz
   Demolition Company, ASBCA No. 39129; 90-2 BCA  22,756; P.X.
   Engineering Company, supra, 89-2 BCA  21,859; ACS
   Construction Company, Inc. of Mississippi, supra, 87-1 BCA 
   19,660; Zurfluh Enterprises, Inc., supra, 85-1 BCA  17,789.
   Consequently, the Respondent was obligated to prove how much
   downward adjustment should be made.44  Nager Electric Company,
   supra, 194 Ct.Cl. at 853, 442 F.2d at 946; Griffin Services,
   Inc. v. General Services Administration, GSBCA Nos. 11022,
   11178, 92-3 BCA  25,181; Jackson Engineering Company, Inc.,
   supra, 85-3 BCA  18,418; R & E Electronics, Inc., VABCA Nos.
   2227, 2299, 2300, 85-3 BCA  18,316; Globe Construction Co.,
   supra, 78-2 BCA  13,337; G.L. Cory, Inc., GSBCA No. 4383,
   77-2 BCA  12,824.  In order to sustain its burden of proof,
   the Respondent had to show: (1) the extent to which the
   contract requirements were reduced; (2) the savings which
   resulted therefrom; (3) the Contractor's effort was, in fact,
   reduced by the contract change; and (4) the amount of downward
   price adjustment it took was reasonable.45  R & E Electronics,
   Inc., supra, 85-3 BCA  18,316; Zurfluh Enterprises, Inc.,
   supra, 85-1 BCA  17,789; Celesco Industries, supra, 79-1 BCA
    13,604; Southeastern Services, Inc., ASBCA No. 21278, 78-2
   BCA  13,239; Industrial Textile Mills, Inc., ASBCA No. 18163,
   73-2 BCA  10,232.

   From its analysis of the record, the Board concludes that the
   Respondent has not sustained its burden of proof.
   Specifically, the Government has failed to show that the
   Appellant's effort was, in fact, reduced by the contract
   change.  See, Banta Company, supra, Sl. op. at 51 (citing, ACS
   Construction Company, Inc. of Mississippi, supra, 87-1 BCA 
   19,660).  In that regard, the method chosen by the Respondent
   to revalue the contract price in this case is similar to the
   technique used by GPO in Banta Company, an appeal which also
   stemmed from the Government taking a credit for a reduced
   number of pages based on a manipulation of the original bid
   estimates, and the result is equally distorted.  See, Banta
   Company, supra, Sl. op. at 21, fn. 31.  The Board rejected the
   Respondent's theory in that case, reasoning, in pertinent
   part:

      . . . [T]he key to the Respondent's argument is its
      assumption that the changes which reduced the number of
      printed pages under each contract "undoubtedly" lowered the
      level of production effort, meant that less raw materials
      would be needed to perform the contracts, and were the
      cause of the "dramatic" reduction in the Appellant's
      potential losses under the contracts.  [Citation to
      Respondent's brief omitted.]  However, GPO has offered no
      evidence to support this premise beyond these mere
      allegations and self-serving and conclusory statements,
      which are insufficient to carry its burden of proof on the
      "level of effort" issue.  Cf., Fry Communications,
      Inc./InfoConversion Joint Venture, GPO BCA 9-85, Decision
      on Remand (August 5, 1991), Sl. op. 32-33, fn. 31 (citing,
      Fry Communications, Inc./InfoConversion Joint Venture v.
      United States, 22 Ct.Cl. 497, 510 (1991); Tri-State
      Services of Texas, Inc., ASBCA No. 38010, 89-3 BCA 
      22,064; Gemini Services, Inc., ASBCA No. 30247, 86-1 BCA 
      18,736). . . .

See, Banta Company, supra, Sl. op. 51-52.  [Original emphasis.]
Accord, Griffin Service, Inc. v. General Services Administration,
supra, 92-3 BCA  25,181.

   Here, as in Banta Company, the fatal flaw in GPO's logic is
   its assumption that a significant reduction in the number of
   printed pages also substantially lowered the Appellant's
   production costs.  Such reasoning ignores a basic tenet of the
   printing trade, namely, the most expensive copy of any book is
   the first one off the press.  Consequently, press time, make-
   ready, labor, collating and binding costs would not have been
   significantly affected simply by reducing the number of pages.
   As the Board sees the pricing structure of the contract, each
   line item describes an integral part of a production process
   in which each step had to be accomplished before the next one
   could begin, whether the final product was 48 pages or 28
   pages.  Therefore, consistent with its approach in Banta
   Company, the Board rejects the Respondent's pricing stratagem
   by which the Government calculates its credit for a reduced
   number of pages by the simple expedient of prorating the
   original bid estimates, without making a realistic assessment
   of the impact of the changes on the contract work.46  Banta
   Company, supra, Sl. op. at 51-52.

   The Board recognizes that unlike Banta Company, where GPO
   solicited single fixed-price bids for the overall contract,
   here the Respondent asked for prices on a line item basis.
   However, that fact alone does not militate in favor of a
   different result.  In the Board's view, GPO's use of different
   bidding schemes in the two contracts merely creates a
   distinction without a difference.  The Respondent cites
   several cases for the proposition that the item price rather
   than the cost of the work is the proper measure of an
   equitable price adjustment when the Government deletes a
   separately priced item of work from a contract.  Res.Brf., p.
   6 (citing, Holtzen Construction Company, supra, 75-2 BCA 
   11,378; Groesbeck-Durbin, Inc., supra, 72-1 BCA  9,251;
   Gregory & Reilly Associates, Inc., supra, 65-2 BCA  4,918).
   These cases merely demonstrate the analytical pitfalls which
   can occur when too much reliance is place on construction
   contracts where supply or services contracts are involved.  In
   construction contracts, the deleted items are usually complete
   in and of themselves and severable from the remainder of the
   contract work.47  See, Holtzen Construction Company, supra,
   75-2 BCA  11,378, at 54,160.

   Rather, the Board believes that the better analogy to the
   present circumstances involves the service contract confronted
   by the General Services Board of Contract Appeals (GSBCA) in
   Griffin Services, Inc., supra.  In that case, a building
   maintenance contractor was warded a cleaning contract for four
   Federal buildings.  The contract price was an aggregate of
   monthly prices for the provision of services at all locations
   involved.  At the same time, the contract also contained
   breakdowns of the monthly maintenance costs applicable to each
   building.  When the Government closed one of the covered
   buildings, it partially terminated the contract and reduced
   the total contract price by he amount listed in the offer for
   that building.  The GSBCA rejected the Government's pricing
   theory because it was inequitable for the following reason:

      The Government's premise for reducing the appellant's
      payment by the amount of appellant's offer in its bid for
      the individual building is that the contract consisted of
      line items rather than monthly prices.  Thus, it maintains,
      the deletion of one building required the deletion of that
      line item in its entirety from the contract payment.  We
      have previously held, however, that in contracts containing
      similar pricing schemes, the price per month must be take
      as an aggregate offer and not merely as the sum of
      severable line items.  Griffin Services, Inc., GSBCA [No.]
      10841, 92-2 BCA  24,945.

   Griffin Services, Inc. v. General Services Administration,
   supra, 92-3 BCA  25,181, at 125,486.  [Emphasis added.]  As
   the Board has already indicated, it believes that because of
   the integrated nature of the production process under the
   disputed contract, it is unreasonable to treat each line item
   task as if it were a severable item within the pricing
   structure of the disputed contract.  Accordingly, for all of
   these reasons, the Board finds and concludes that the
   Government has failed to prove its claimed entitlement to a
   price reduction on the basis taken.

   As for the Appellant's equitable adjustment claim, that matter
   is easily disposed of.  The Contractor also had a burden of
   proof in this case.  First, it had to show the total amount of
   money to which it is entitled.  See, Lawrence D. Krause,
   supra, 82-2 BCA  16,129; Onetta Boat Works, Inc., supra, 81-2
   BCA  15,279; Globe Construction Co., supra, 78-2 BCA 
   13,337; Click Company, Inc., GSBCA No. 3007, 70-1 BCA  8,335;
   Campbell Company, General Contractor, Inc., IBCA No. 722, 69-1
   BCA  7,574.  Second, the Appellant had to demonstrate the
   causal connection between its increased costs and the changes
   ordered by the Government.  Banta Company, supra, Sl. op. at
   55, fn. 69.  See also, S.W. Electronics & Manufacturing
   Corporation v. United States, 228 Ct.Cl. 333, 655 F.2d 1078
   (1981), aff'g, ASBCA No. 20698, 77-2 BCA  12,631; Jan-Beck
   Associates, supra, 87-2 BCA  19,831, at 100,322 (citing,
   Schoenfeld Associates, supra,  87-2 BCA  19,648).  Third, the
   Contractor had to prove that its costs were reasonable.  See,
   Celesco Industries, supra, 79-1 BCA  13,604; Triple "A"
   Machine Shop, Inc., ASBCA No. 21561, 78-1 BCA  13,065; Cal
   Constructors, ASBCA No. 21179, 78-1 BCA  12,992.  See
   generally, Cibinic and Nash, pp. 504-05.  The Contractor has
   shown none of these elements in this case.

   The Board does not need to repeat its detailed criticisms of
   the Appellant's claim.
Suffice it to say, while the Contractor elected to establish its
equitable adjustment costs on the basis of estimates, they are
not supported by the detailed, substantiating information which
is required.  See, e.g., R.G. Robbins & Company, supra, 83-1 BCA
 16,420; Leopold Construction Company, supra, 81-2 BCA  15,277;
Bailey Specialized Buildings, Inc., supra, 71-1 BCA  8,699.
Furthermore, the Board has already expressed its strong suspicion
that the Appellant's revised makeready/setup charge is the
product of some arbitrary formula, rather than an honest attempt
to approximate its actual increase in costs resulting from the
Government's change order, and hence is unacceptable on that
basis.  See, Ordnance Materials, Inc., supra, 88-3 BCA  20,910.
Consequently, the Board has no benchmark by which to determine
the reasonableness of the Contractor's costs for performing the
work as originally required and as subsequently changed by the
Government.  Zurfluh Enterprises, Inc., supra, 85-1 BCA  17,789;
Dick & Kirkman, Inc., supra, 84-3 BCA  17,662; Lawrence D.
Krause, supra, 82-2 BCA  16,129; Jack Picoult, supra, 78-1 BCA 
13,024.  Since the Board is unable to determine the
reasonableness of the Appellant's costs on the basis of this
record, it must also conclude that the Appellant has failed to
sustain its burden of showing that its costs were reasonable
under the circumstances of this case.  Banta Company, supra, Sl.
op. at 45 (citing, Michael, Inc., ASBCA No. 35653, 92-1 BCA 
24,412, at 121,863).

      B. Applying the "jury verdict" method, the Board concludes
      that the Respondent took too large a reduction in the
      contract price because of the page deletions, and the
      Appellant is entitled to additional compensation of
      $8,310.45 as a fair and reasonable equitable adjustment in
      this case.

   Having rejected the cost computation methods advanced by both
   parties, the Board now finds itself on the horns of a dilemma.
   On the one hand, the Board cannot ignore the undisputed fact
   that the Government directed the Appellant to make numerous
   author's alterations to the Citizen Soldier on at least three
   separate occasions, caused the Contractor to produce multiple
   sets of varying galley and progressive page proofs, and
   otherwise delayed completion of the contract of the contract
   for nearly nine months.  On the other hand, the Board knows
   that while there is no standard by which to measure the
   reasonableness of the Contractor's costs, it is nonetheless
   inescapable that the contract changes ordered by the
   Respondent had some cost impact.  The law, however, provides a
   way out of this conundrum.

   In Banta Company, which also arose out of a contractor's claim
   that the Government took too large a credit for page
   deletions, the Board, as here, rejected the cost computations
   of both parties, and applied the so-called "jury verdict"
   method to establish a fair and reasonable equitable
   adjustment.48  Banta Company, supra, Sl. op. at 46-47.  See
   also, Maryland Composition, supra, Sl. op. at 6 (Claim I,
   Group I-Jacket Nos. 356-532, 397-529, 424-224, 470-631,
   476-450, 732-414, 461-096-citing, Johnson, Drake & Piper,
   Inc., supra, 65-2 BCA  4,868).  Under the "jury verdict"
   technique, where a board or court finds an entitlement to an
   equitable adjustment but the evidence is incomplete, or the
   amount cannot be determined with any degree of mathematical
   precision, it may exercise its discretion to resolve
   conflicting evidence concerning the claim and arrive at a fair
   amount of compensation.49  Assurance Company v. United States,
   813 F.2d 1202, 1205 (Fed. Cir. 1987); S.W. Electronics &
   Manufacturing Corporation v. United States, supra, 228 Ct.Cl.
   at 333, 655 F.2d at 1078; Electronic & Missile Facilities,
   Inc. v. United States, 189 Ct.Cl. 237, 416 F.2d 1345, 1358
   (1969).  See also, Dawco Construction, Inc., ASBCA No. 42120,
   92-2 BCA  24,915; Gricoski Detective Agency, GSBCA Nos.
   8901(7823), 8922(7824), 8923(7825), 8924(7826), 8925(7827),
   8926(7828), 90-3 BCA  23,131; E.W. Eldridge, Inc., ENGBCA No.
   5269, 90-3 BCA   23,080; Harvey C. Jones, Inc., IBCA Nos.
   2070, 2150, 2151, 2152, 2153, 2467, 90-2 BCA  22,762.  The
   key to the use of the "jury verdict" method is the presence of
   sufficient evidence to permit the determination of a fair and
   reasonable approximation of damages.50  J.E.T.S. Incorporated,
   ASBCA No. 28083, 88-2 BCA  20,540, at 103,859 (citing,
   Schuster Engineering, Inc. ASBCA Nos. 28760, 29306, 30683,
   87-3 BCA  20,105).  Thus, a trier of fact may allow recovery
   if it determines that: (1) clear proof of injury exists; (2)
   there is no more reliable method for computing damages; and
   (3) there is sufficient evidence to make a fair and reasonable
   approximation of damages.51  See, Dawco Construction, Inc. v.
   United States, supra, 930 F.2d at 880 (citing, WRB Corporation
   v. United States, 183 Ct.Cl. 409, 425 (1968)); Gricoski
   Detective Agency, supra, 90-3 BCA  23,131; Harvey C. Jones,
   Inc., supra, 90-2 BCA  22,762; J.E.T.S. Incorporated, supra,
   88-2 BCA  20,540; Lawrence D. Krause, supra, 82-2 BCA 
   16,129.  In the Board's judgment, all of the elements
   necessary for a "jury verdict" award are present in this case.
   Consequently, that approach is the appropriate method for
   resolving this dispute.52  Banta Company, supra, Sl. op. at
   49.  Accord, Gricoski Detective Agency, supra, 90-3 BCA 
   23,131.

   In Banta Company, unlike here, the contractor's claim had been
   audited by the Respondent's OIG, and the Board was able to use
   the audit report, which was part of the record, as a basis for
   its recalculation of the amount of the Government's
   deduction.53  Banta Company, Inc., supra, Sl. op. at 57
   (citing, S.W. Electronics & Manufacturing Corporation v.
   United States, supra, 228 Ct.Cl. 333, 655 F.2d at 1078; E.W.
   Eldridge, Inc., supra, 90-3 BCA  23,080, at 115,901; Schuster
   Engineering, Inc., supra, 87-3 BCA  20,105; Celesco
   Industries, supra, 79-1 BCA  13,604; Pavement Specialists,
   Inc., ASBCA No. 17410, 73-2 BCA  10,082).  Obviously, that is
   not possible in this case.  However, while an audit of the
   disputed claim would certainly have been helpful, the Board's
   research discloses that even without an audit report there are
   other ways to recompute a fair and reasonable equitable
   adjustment using the "jury verdict" method.  One well-accepted
   device is simply to "split the difference" between the amount
   claimed by each party.  See, Sentry Insurance, A Mutual
   Company, VABCA No. 2617, 91-3 BCA  24,094 (50 percent of the
   contractor's invoiced costs, plus 15 percent for markup);
   Gricoski Detective Agency, supra, 90-3 BCA  23,131 (amount
   which was midway between the contractor's original demand and
   the final bargaining position of the agency); Parkdale
   Building Maintenance, ENGBCA No. 5232, 90-1 BCA  22,319
   (average of the contractor's and Government's estimates);
   Second Growth Forest Management, Inc., AGBCA No. 88-153-3,
   89-1 BCA  21,569 (average of the contractor's and
   Government's production rates); The Morrison Company, ASBCA
   Nos. 26746, 26920, 26921, 83-1 BCA  16,417 (equitable
   adjustment was midway between the amounts which the parties
   claimed).  See also, Delfour, Inc., VABCA Nos. 2049, 2215,
   2539, 2540, 89-1 BCA  21,394 (50 percent of the amount
   claimed by the contractor).  Given the record the Board has to
   deal with in this case, a "jury verdict" which sets the
   Appellant's recovery midway between its claim and the amount
   offered by the Respondent is the best way to break the
   deadlock between the parties and resolve the conflicting
   evidence concerning the amount that would be most reasonable
   and fair in light of the Government's changes.  See, Gricoski
   Detective Agency, supra, 90-3 BCA  23,131, at 116,138-39;
   Parkdale Building Maintenance, supra, 90-1 BCA  22,319, at
   112,094; Delfour, Inc., supra, 89-1 BCA  21,394, at 107,862;
   The Morrison Company, supra, 83-1 BCA  16,417, at 81,675.
   Accordingly, the Board will allow the Appellant's claim to the
   extent of $8,310.45, calculated as follows:

      Appellant's claim         $45,135.00
      Government's offer          28,514.11
      Difference between
        claim and offer          16,620.89
      50 percent of difference      $ 8,310.45

   The Board doubts that either party will be satisfied with this
   compromise verdict.  However, since they both contributed to
   the shortcomings with this record, any dissatisfaction with
   the Board's decision should also be shared equally.

   VI. CONCLUSION

   In summary, the Board concludes that while the Respondent was
   entitled to some credit for the page deletions, it
   underestimated the impact of the deductive changes and took
   too much of a reduction in the price of the contract.  Banta
   Company, supra, Sl. op. at 59 (citing, R & E Electronics,
   Inc., supra, 85-3 BCA  18,316; Zurfluh Enterprises, Inc.,
   supra, 85-1 BCA  17,789; Celesco Industries, supra, 79-1 BCA
    13,604).  Consequently, while this decision allows the
   Government less of a credit for the deleted work, the Board
   believes that its "jury verdict" award represents a fair and
   reasonable proximation of the Contractor's costs resulting
   from the Government's page reductions.  Id. (citing, E.W.
   Eldridge, Inc., supra, 90-3 BCA  23,080; Arctic Corner,
   supra, 86-3 BCA  19,304).  Accord, Gricoski Detective Agency,
   supra, 90-3 BCA  23,131; Parkdale Building Maintenance,
   supra, 90-1 BCA  22,319; Delfour, Inc., supra, 89-1 BCA 
   21,394; The Morrison Company, supra, 83-1 BCA 16,417.

   Therefore, when the Board considers the quantum of relief
   issue in light of the evidence, cases, authorities, and
   applicable regulations, it ALLOWS the Appellant's claim to the
   fair and reasonable amount of $8,310.45.54  The Contracting
   Officer's decision is MODIFIED, accordingly.

   ORDER

   From the foregoing analysis, the Board finds and concludes
   that: (1) both the Appellant and the Respondent have
   miscalculated the appropriate equitable adjustment in this
   case; (2) the "jury verdict" technique is the best method for
   determining a fair and reasonable proximation of the
   Contractor's costs resulting from the Government's page
   reductions; and (3) applying the "jury verdict" method to this
   case, the Appellant is entitled to additional compensation of
   $8,310.45 as a fair and reasonable equitable adjustment.
   THEREFORE, the Board MODIFIES the Contracting Officer's
   decision and REMANDS the case with instructions that
   appropriate arrangements be made to pay the Contractor in
   accordance with this opinion.  Banta Company, supra, Sl. op.
   at 62; R.C. Swanson II, supra, Sl. op. at 15.

It is so Ordered.

June 22, 1994               STUART M. FOSS
                     Administrative Judge
_______________

    1 The contract in dispute was awarded to the Appellant's
    central office located at 1701 Macklind Avenue, St. Louis,
    Missouri 63110.  However, this appeal was filed by the
    Contractor's Southwest Sales Office in Dallas, Texas.
    2 The Contracting Officer's appeal file, assembled pursuant
    to Rule 4 of the Board's Rules of Practice and Procedure, was
    delivered to the Board on March 22, 1990.  GPO Instruction
    110.12, Subject: Board of Contract Appeals Rules of Practice
    and Procedure (GPO Instruction 110.12), dated September 17,
    1984 (Board Rules), Rule 4.  It will be referred to hereafter
    as R4 File, with an appropriate tab letter(s) also indicated.
    The R4 File consists of 13 documents identified as Tabs A
    through M.
    3 By letter dated April 3, 1990, the Appellant advised the
    Board that it had selected the optional Accelerated
    Procedure.  Board Rules, Rules 12.1(b) and 12.3.  However,
    numerous delays have characterized this case from the
    beginning.  For example, although the Board docketed the
    Contractor's appeal letter on February 22, 1990, an agency
    reorganization soon afterward resulted in the reassignment of
    the Board's only Administrative Judge to another senior
    position within GPO.  Consequently, it was not until March
    11, 1991, more than a year after the appeal had been filed,
    that the Board's new Administrative Judge was able to conduct
    a prehearing telephone conference in the matter.  See, Report
    of Prehearing Telephone Conference, dated May 23, 1991, p. 1
    (RPTC).  As a result of that conference, the Board asked the
    parties to formulate a stipulation of facts and verify the
    Appellant's claim (which was unaudited) by September 3, 1991,
    so that the Board could settle the record.  Board Rules, Rule
    13.  See, Universal Printing Company, GPO BCA 9-90, Order
    (August 16, 1991), p. 2.  For the next 30 months the Board
    had intermittent contact with the parties concerning their
    progress, and was assured that they were actively discussing
    the terms of an agreement which would establish a method for
    clarifying the record and assist the Board in resolving the
    dispute.  Specifically, the Board was told that the parties
    were exploring the possibility of creating a joint panel to
    audit the Appellant's claim, and to make recommendations to
    the Board regarding an appropriate equitable adjustment.
    Based on this understanding, the Board, in effect, suspended
    further proceedings in the appeal.  On March 25, 1994, the
    parties sent the Board a proposed stipulation which would
    have, inter alia, withdrawn the appeal and submitted the
    issues to binding arbitration.  The Board appreciates that
    the idea of using alternate dispute resolution procedures is
    currently in vogue, see, 140 CONG. REC. No. 70, S6593-94
    (daily ed. June 8, 1994) (statement of Sen. Wellstone); 24
    Agencies Sign OFPP Pledge to Use ADR, 61 FED. CONT. REP.
    (BNA) No. 20, pp. 670-72 (May 23, 1994), although the concept
    is not without its critics, see, Richard C. Reuben, The Dark
    Side of ADR, 14 CAL. LAWYER No. 2, pp. 53-58 (February 1994).
    However, the simple fact is that the Board has no authority
    to divest itself of its jurisdiction over appeals from final
    decisions of GPO contracting officers.  Board Rules, Preface
    to Rules,  I.  The Board's jurisdiction is not statutory,
    but rather is derivative and contractual, and flows from the
    Public Printer's right, as the agency officer authorized by
    law to contract on behalf of the United States, see, 44
    U.S.C.  502, to delegate his appeal authority to the Board
    by regulation and the provisions of the contract.  See, GPO
    Instruction 110.10C, Subject: Establishment of the Board of
    Contract Appeals, dated September 17, 1984,  3; GPO Contract
    Terms, Solicitation Provisions, Supplemental Specifications,
    and Contract Clauses, GPO Publication 310.2, Effective
    December 1, 1987 (Rev. 9-88), Art. 5(b) (Disputes) (GPO
    Contract Terms).  See also, The Wessel Company, Inc., GPO BCA
    8-90 (February 28, 1992), Sl. op. at 32-33; Automated
    Datatron, Inc., GPO BCA 20-87 (March 31, 1989), Sl. op. at
    4-5; Bay Printing, Inc., GPO BCA 16-85 (January 30, 1987);
    Peak Printers, Inc., GPO BCA 12-85 (November 16, 1986), Sl.
    op. at 6.  Indeed, as an arm of the Legislative branch of
    Federal Government, GPO is not an "agency" covered by either
    the Contract Disputes Act of 1978 (CDA), 41 U.S.C.  601 et
    seq., or the Administrative Procedure Act (APA), 5 U.S.C. 
    551 et seq., including the 1990 and 1992 amendments to the
    APA concerning alternative means of dispute resolution in the
    administrative process, 5 U.S.C.  571 et seq.  See,
    Tatelbaum v. United States, 749 F.2d 729, 730 (Fed. Cir.
    1984) (CDA does not apply to GPO contract disputes).
    Therefore, no legal basis exists for the Board to voluntarily
    waive its appellate authority over contract disputes
    involving GPO and the contractors who do business with the
    agency, and allow the parties to name their own final
    arbiters from the private sector.  Thus, the Board would not
    approve the proposed stipulation.  See, Universal Printing
    Company, supra, Order Settling the Record (April 15, 1994),
    p. 3 (citing, GPO Instruction 110.10C, Subject: Establishment
    of the Board of Contract Appeals, dated September 17, 1984,
     4, 5).  See also, Board Rules, Preface to Rules,  I
    (Jurisdiction for Considering Appeals).  Since nearly three
    years had elapsed without any meaningful progress on a
    stipulation of facts or a method to verify the Appellant's
    claim, the Board settled the record.  See, Universal Printing
    Company, supra, Order Settling the Record, p. 4.
    Accordingly, notwithstanding the Appellant's election of the
    optional Accelerated Procedure, this matter, for all
    practical purposes, has been processed under the Board's
    regular procedure for handling cases submitted on the record
    without a hearing.  Board Rules, Rule 11.  See, McDonald &
    Eudy Printers, Inc., GPO BCA 06-91 (May 6, 1994), Sl. op. at
    1, fn. 2.
    4 Since the parties were unsuccessful in providing the Board
    with a stipulation of facts, see, note 3 supra, the factual
    description of this case is based on the R4 File, the
    Appellant's Complaint, dated March 1, 1990, the Respondent's
    Informal Brief, dated July 1, 1991 (Res. Brf.), and the
    Appellant's Post Conference Memorandum, dated July 29, 1991
    (App. Mem.).  The facts, which are essentially undisputed,
    are recited here only to the extent necessary for this
    decision.
    5 In pamphlet binding, there are basically two methods of
    stitching the signatures together after they have been
    collated; i.e., saddle-stitching and side-stitching.  In
    saddle-stitching, the booklet is placed on a saddle beneath a
    mechanical stitching head, and staples are forced through the
    backbone or spine of the booklet.  This type of binding it
    the simplest and least expensive.  See, Pocket Pal,
    International Paper Company, Memphis, Tennessee (14th ed.,
    1989), pp. 149-50.
    6 In addition to being subject to all the terms and
    conditions of GPO Contract Terms, see, note 3 supra, the
    contract was also covered by the Respondent's Quality
    Assurance Through Attributes Program (R4 File, Tab A, p. 1).
    See, GPO Contract Terms, Quality Assurance Through Attributes
    Program for Printing and Binding, GPO Publication 310.1,
    dated September 2, 1986.
    7 An examination of the "Changes" clause in GPO Contract
    Terms discloses that the wording is identical to the standard
    Government "Changes" clause for fixed-price contracts.  See,
    FAR  52.243-1 (Changes-Fixed-Price).
    8 The bid abstract shows that three other printers competed
    for the work-Monarch Litho (bid of $151,637,85); Gulf
    Printing (bid of $85,539,75); and Hart Graphics (bid of
    $50,647.85) (R4 File, Tab D).
    9 At first blush, the Appellant's statement that it did not
    include the labor and time necessary to accomplish the
    additional work in its original bid price would tend to
    discredit its own job estimates.  See, KRW, Incorporated,
    DOTBCA No. 2572, 94-1 BCA  26,435, at 131,538.  However, for
    at least the past 20 years, in order to avoid the subjective
    judgments inherent in charging for author's alterations on a
    time basis, such changes under GPO contracts have been paid
    for on a "per line" basis.  GPO Contract Terms, Supplemental
    Specifications, Art. 17 (Author's Alterations).  See,
    Maryland Composition, No GPOCAB Docket Number (December 30,
    1974), Sl. op. at 7 (Claim II-Jacket No. 465-238).
    Consequently, the time taken by the Appellant to perform the
    additional work is not relevant.  (It should be noted that
    Maryland Composition was decided by one of the ad hoc
    contract appeals panels which considered appeals from final
    decisions of GPO Contracting Officers prior to the
    establishment of the Board in 1984.  GPO Instruction 110.10C,
    Subject: Establishment of the Board of Contract Appeals,
    dated September 17, 1984.  Decisions of these ad hoc panels
    are cited by the Board in its decisions as GPOCAB.  While the
    Board is not bound by the decisions of the ad hoc panels, its
    policy is to follow their rulings where applicable and
    appropriate.  See, Shepard Printing, GPO BCA 23-92 (April 29,
    1993), Sl. op. at 14, fn. 19 (hereinafter Shepard (1993));
    R.C. Swanson Printing and Typesetting Company, GPO BCA 15-90
    (march 6, 1992), Sl. op. at 28, fn. 30; Stephenson, Inc., GPO
    BCA 02-88 (December 20, 1991), Sl. op. at 18, fn. 20; Chavis
    and Chavis Printing, GPO BCA 20-90 (February 6, 1991), Sl.
    op. at 9, fn. 9.).
    10 Under the contract schedule, this task should have been
    accomplished by February 17, 1989 (R4 File, Tab A, p. 6).
    However, because the Respondent had returned the galley
    proofs and dummy layout on February 15, 1989, instead of
    February 7, 1989, the schedule was automatically extended a
    like amount of time by operation of the contract, so the
    Appellant actually set the page proofs to the DRPPO a day or
    two early.  See, GPO Contract Terms, Contract Clauses, Art.
    12.(c) (Extension of Schedules).
    11 The Contractor notes that the original specifications only
    called for composition from "typewritten manuscript copy",
    not from a "floppy disk"; i.e., from hard copy and not by
    electronic means.  Complaint, p. 2; App. Mem., p. 2,  11.
    See, R4 File, Tab A, p. 1 (Material Furnished).
    12 The Respondent recalls this as occurring on July 21, 1989.
    Res. Brf., p. 2.
    13 The Respondent recalls this as occurring on September 27,
    1989.  Res. Brf., p. 3.
    14 According to the Appellant, all of these charges were
    either approved by the Contract Administrator or are
    undisputed.  App. Mem., pp. 3-4,  18, 19.  See, R4 File,
    Tab K.  In that regard, the record indicates that the DRPPO's
    Contractor Administrator for the contract in dispute was Bill
    Bollinger (R4 File, Tabs G and J).  See also, Complaint, p.
    3.
    15 Accompanying the proofs was a letter from the Contracting
    Officer to the Appellant telling it to proceed with the
    production run once it made the two necessary corrections;
    i.e., (1) the author's alterations on pages 5, 7, 14, 20 and
    28, as marked on the proofs; and (2) deleting the brown
    screen from the red screened Fifth Army area of the
    illustration on page 5.  See, Letter from R. W. Wildbrett,
    Contract Officer to Morey Mast, Universal Printing Company,
    dated December 6, 1989.  The Contracting Officer's letter was
    not in the R4 File, but rather was furnished to the Board by
    the Appellant, as an attachment to its letter of June 11,
    1991, in which it commented on the RPTC and restated its
    position in this appeal.  See, Letter from Morey Mast, Sales
    Manager, Southwest Region, Universal Printing Company, to the
    Board of Contract Appeals, dated June 11, 1991.  Although the
    Board is willing to believe that the Contracting Officer's
    failure to make this letter part of the R4 File was
    unintentional, there is also no doubt that this document was
    pertinent to appeal and should have been included.  In that
    regard, the Government's obligation in preparing the appeal
    file is to search its records diligently so that it submits
    to the Board as complete a file as may be assembled under the
    circumstances.  It goes without saying that the Government
    may not, with respect to those documents actually reviewed
    during compilation of the appeal file, limit inclusion only
    to those documents which support its position.  It should be
    emphasized that selective omission of pertinent documents is
    contrary to the requirements of Rule 4 of the Board Rules.
    See, P.J. Dick Contracting, Inc., VABCA No. 3177R-82R, 93-1
    BCA  25,263, at 125,838.  See also, Bethlehem Steel
    Corporation, ASBCA No. 29459, 86-3 BCA  19,159.
    16 The Board assumes that the postponement was due to the
    Christmas-New Year's holiday season.  As the Board has
    remarked in the past, customarily little work is accomplished
    at that time of year in the typical Government agency or
    business firm.  See, Graphics Image, Inc., GPO BCA 13-92
    (August 31, 1992), Sl. op. at 15, fn. 17.
    17 On January 11, 1990, the Contractor revised its claim by
    deleting the $96.00 charge for rerunning two galleys, thus
    changing the total cost for typesetting to $7,693.12 (R4
    File, Tabs F, p. 2, and J).
    18 The bracketed words were inserted in place of the word
    "mixed", which was crossed out (R4 File, Tab F, p. 3).
    19 The appeal file contains a handwritten document entitled
    "Recap-Charges for J 563-541" which shows the computations
    made by the Contract Compliance Officer in arriving at the
    revised contract price (R4 File, Tab H).  RPTC, pp. 2, 7;
    Res. Brf., p. 2.  Essentially, the Contract Compliance
    Officer accepted the Appellant's figures for: (a) typesetting
    the pamphlet as initially ordered and making 164 line of
    author's alterations ($2,886.00 + 154.16 = $3,040.16); (b)
    resetting the Citizen Soldier as a 32 page publication and
    making 4 lines of author's alterations ($2,886.00 - 912.00 +
    3.76 = $1,997.76); (c) the page make-up for the revised
    pamphlet ($1,646.00 - $616.80 = $1,029.20); and (d) the
    entire claim for making the author's alterations on the
    progressive page proofs ($1,028.00).  On the other hand, the
    Contract Compliance Officer rejected the Contractor's
    calculations for: (a) the page make-up on the original order
    ($1,646.00 for 48 pages); (b) the makeready/setup charges for
    the revised publication ($14,688.00); and (c) the new running
    rate of $92.75 (which would have made the cost for printing
    1,050 copies of the Citizen Soldier $13,912.50).  Instead,
    the Contract Compliance Officer recomputed these costs.
    First, he reduced the page make-up cost on the original order
    by $308.40 (40 pages at the additional page rate in the
    Appellant's bid of $38.55 per page) to $1,337.60.  Then for
    printing and binding costs, the Contract Compliance Officer:
    (a) retained the makeready/setup charges in the original bid
    estimate ($3,840.00); (b) established a new running rate of
    $180.02 by subtracting the additional rate for four page
    signatures ($8.70) from the bid estimate for running 100
    copies ($188.72); (c) calculated a signature rate of $60.00
    (based on a 16 page signature) by dividing the new running
    rate ($180.02) by the number of signatures in the originally
    ordered booklet (48 ( 16 = 3); and (d) used the signature
    rate to compute the cost of running 1,050 copies of the
    Citizen Soldier in three different configurations
    ($10,552.50) and the additional rate to calculate the cost of
    running the covers ($874.35), for a total printing, binding,
    and distributing cost of $11,426.85.  Finally, for the film
    and proof work, the Contracting Officer: (a) calculated a
    price for four-color process separations of $2,334.54 by
    determining that the 46 photographs in the Citizen Soldier
    totaled 1,066 square inches and then multiplying that figure
    by the bid estimate price ($2.19); and (b) computed a cost of
    $2,500.00 for the progressive proofs by applying the bid
    estimate rate to the four sets of proofs produced (4 sets x
    $875.00 each set = $3,500.00) and then subtracting the cost
    of two press forms (there were 7 press forms in each set of
    proofs, so the cost of each press form was $125.00; i.e.,
    $875.00 ( 7 = $125.00) from each of the four sets ($125.00 x
    2 press forms = $250.00 x 4 sets = $1,000.00).  See
    generally, Res. Brf., pp. 2-5.
    20 A question arose during the processing of this appeal
    about whether or not the Contracting Officer's letter of
    January 24, 1990, was a "final decision" within the meaning
    of GPO's regulations-a condition precedent to the Board's
    assertion of jurisdiction in this appeal (R4 File, Tab I).
    See, Printing Procurement regulation, GPO Publication 305.3
    (September 1, 1988), Chap. X, Sec. 1,  4.d (PPR).  See also,
    Board Rules, Preface to Rules,  I (Jurisdiction for
    Considering Appeals).  The parties, from the outset, have
    construed this letter to be a final decision, and the
    Contracting Officer's subsequent letters of February 12, 1990
    and April 8, 1994, only reaffirmed that view.  See, R4 File,
    Tab L; Letter from R.W. Wildbrett, Contract Officer to Board
    of Contract Appeals, dated April 8, 1994.  In any event,
    attached to the Contracting Officer's letter of January 24,
    1990, was Contract Modification K-1, dated the same day,
    decreasing the price of the Appellant's contract from
    $40,461.75 to the "firm cost" of $28,514.11 (R4 File, Tab I).
    It is well-settled that a unilateral contract modification by
    the Government reducing the price of a contract constitutes a
    formal and final action equivalent to a final decision by the
    Contracting Officer from which a contractor can appeal.  See,
    Goetz Demotion Company, ASBCA No. 39129, 90-2 BCA  22,756;
    P.X. Engineering Company, ASBCA No. 38215, 89-2 BCA  21,859;
    Systron Donner, Inertial Division, ASBCA No. 31148, 87-3 BCA
     20,066.  Like section 8(e) of the CDA, 41 U.S.C.  607(e),
    the Board Rules contemplate the just and inexpensive
    resolution of disputes without unnecessary delay.  Board
    Rules, Preface to Rules,  VI.C. (Administration and
    Interpretation of Rules).  Consequently, the Board agrees
    with the Armed Services Board of Contract Appeals (ASBCA)
    that, as a rule, a contractor is not required to go through
    the "charade" of filing a claim and requesting a decision
    from the Contracting Officer where, as here, the Government
    has issued a unilateral modification reducing the contract
    price, because that would be an unnecessary, delaying and
    expensive formality.  See, P.X. Engineering Company, supra,
    89-2 BCA  21,859, at 109,952.
    21 As indicated previously, both parties submitted written
    briefs setting forth their respective positions on the issues
    in this appeal.  See, note 4 supra.  The Board's
    understanding of the parties is based on the Appellant's
    Complaint, the formal briefs filed by the parties, and the
    discussions at the prehearing conference on March 11, 1991.
    22 Although it would appear from the appeal letter that the
    gap between the parties with respect to the contract price
    for the 28-page pamphlet is only $1,225.89-a modest
    difference of opinion in the context of this case-in reality,
    their disagreement is much larger.  In that regard, it is
    clear that the Contractor is willing to accept $29,740.00
    only for the 28-page Citizen Soldier, while the Contracting
    Officer tendered $28,514.11 in payment for the whole job.
    23 At the conclusion of the prehearing telephone conference
    on March 1, 1991, there was no disagreement about the fact
    that the Government owed the Appellant at least $28,514.11,
    which had not yet been paid to the Contractor.  RPTC, p. 9,
    fn. 1.  GPO's Printing Procurement Regulation provides: "In
    the event of an appeal, the amount, if any, determined to be
    payable in the decision of the Contracting Officer, less any
    portion previously paid, should be paid in advance of any
    decision by the board without prejudice to the rights of
    either party or the appeal."  See, PPR, Chap. X, Sec. 1, 
    5.g.  The Board has been advised that since the conference
    the Contractor has submitted a proper invoice for the
    undisputed amount of $28,514.00, and has been paid.
    Therefore, the amount of the original claim still in
    controversy is $16,620.89 ($15,395.00 + 1,225.89).
    24 The crux of the Appellant's argument is that the
    Government's changes to the publication were so extensive
    that the apart from the separation of the front and outside
    covers and restripping, all of the work it had done on the
    48-page pamphlet was lost and it had to start the pre-press
    work afresh.  RPTC, p. 4.  Thus, the Appellant believes that
    it is justified in asking the Government to reimburse it for
    the preparatory work it did on the 48-page pamphlet which
    could not be salvaged for the final product.  RPTC, pp. 4-5,
    8.  Insofar as the Contractor also contends that the gap
    between the original order for a 48-page Citizen Soldier and
    the final 28-page product was so large as to be
    unconscionable, see, RPTC, p. 8, its argument is tantamount
    to an allegation that the Respondent was acting in bad faith.
    However, the Board has held on numerous occasions that
    because of the strong presumption that Government officials
    properly and honestly carry out their functions, an
    allegation of bad faith must be established by "well-nigh
    irrefragable" proof.  See, e.g., Sterling Printing, Inc., GPO
    BCA 20-89 (March 28, 1994), Sl. op. at 23, fn. 35; Hurt's
    Printing Company, Inc., GPO BCA 27-92 (January 21, 1994), Sl.
    op. at 11, fn. 15; Shepard Printing (1993), supra, Sl. op. at
    7-8, fn. 11; B. P. Printing and Office Supplies, GPO BCA
    14-91 (August 10, 1992), Sl. op. at 16; The Standard Register
    Company, GPO BCA 4-86 (October 28, 1987); Sl. op. at 12-13.
    Accord, Karpak Data and Design, IBCA No. 2944 et al., 93-1
    BCA  25,360; Local Contractors, Inc., ASBCA No. 37108, 92-1
    BCA  24,491.  The key to such evidence is that there must be
    a showing of a specific intent on the part of the Government
    to injure the contractor.  Kalvar Corporation v. United
    States, 543 F.2d 1298, 1302 (Ct.Cl. 1976), cert. denied, 434
    U.S. 830 (1977).  See, Stephenson, Inc., supra, Sl. op. at
    54.  In the Board's view, no such "irrefragable" proof of the
    Respondent's bad faith exists in this record.  Certainly,
    there is absolutely nothing to show that the employees of two
    separate Government entities-GPO and the Army-set out to harm
    the Appellant or that they acted in concert to achieve that
    specific result.  See, e.g., Sterling Printing, Inc., supra,
    Sl. op. at 23, fn. 35; Stephenson, Inc., supra, Sl. op. at
    57.
    25 Among other things mentioned by the Appellant, the
    "Schedule of Prices" only asks for makeready/setup and
    running prices based on "four page signatures" (R4 File, Tab
    A, p. 9), and not on any other basis.  App. Mem., p. 5.
    Furthermore, the Contractor says that the Contracting Officer
    ignored the most basic fact in the printing trade; i.e., that
    on the type of press used for the job, it costs more per page
    to produce the smaller size book (28 pages) than the larger
    one (48 pages).  RPTC, p. 4.  Consequently, reducing the size
    of the Citizen Soldier from 48 pages to 28 pages would
    produce savings only in the use of paper and ink, which would
    be minimal at best, and would not affected the costs for
    press time, make-ready, labor, collating and binding.  App.
    Mem., p. 5.
    26 Indeed, the Appellant says that if the Contracting Officer
    had informed it earlier in the production process of his
    intention to reprice the contract for the smaller version of
    the Citizen Soldier on the basis of prorating the original
    bid estimates, the Contract itself would most likely have
    refused to proceed, and demanded a termination for
    convenience.  App. Mem., p. 6.
    27 The Appellant enclosed two documents with its letter of
    April 3, 1990, to the Board, identified as Exhibits A and B,
    respectively.  The first document was a price quotation from
    Colortek, Inc. (Colortek), a film shop located in Dallas,
    Texas, showing charges of $6,336.00 for separations and
    $6,469.00 for stripping work on a 40-page sample, plus cover,
    of the Citizen Solider.  See, Letter from Morey Mast, Sales
    Manager, Southwest Region, Universal Printing Company to
    Board of Contract Appeals, dated April 3, 1990 (hereinafter
    Appellant's Letter of April 3, 1990), Exhibit A.  Since
    Colortek's quote is dated March 27, 1990, it was obviously
    solicited by the Contractor solely for the purpose of this
    appeal.  The Board assumes that Colortek's quotation is
    intended to show that the Appellant's charges for the same
    work are in accord with prices in the industry, and hence its
    claim for film work is reasonable.  The Board would be
    willing to accept Colortek's price quotation as evidence if
    the Appellant had subcontracted the work to that firm, see,
    Fireman's Fund Insurance Company, ASBCA No. 39666, 91-1 BCA 
    23,372 (citing, Delco Electronics Corporation v. United
    States [35 CCF  75,679], 17 Cl.Ct. 302 (1989)), or there was
    some other proof of privity of contract between them; e.g.,
    producer-supplier.  See, Sterling Printing, Inc., supra, Sl.
    op. at 8 and 35, fns. 13 and 47 (report on quality of paper
    from contractor's paper supplier).  Accord, Atlantic Electric
    Company, GSBCA No. 6016, 83-1 BCA  16,484.  In the absence
    of such proof, Colortek's price quotation is entitled to
    little evidentiary weight beyond that of argument.  Board
    Rules, Rule 13(c).  See, RD Printing Associates, Inc., GPO
    BCA 02-92 (December 16, 1992), Sl. op. 10 and 13, fns. 11 and
    15 (memorandum from customer-agency employee supporting
    contractor's interpretation of the contract, and revised
    pricing specification from the succeeding contract).  See
    also, Merchant's Service Company, No GPOCAB Docket Number
    [GPO Contract Nos. 373 and 374] (February 11, 1980), Sl. op.
    at 18-20.  Accord, Hildebrand and Day, AGBCA No. 82-183-1,
    82-188-1, 83-1 BCA  16,321 (affidavit attached to brief).
    The second document, a preliminary estimate prepared by the
    Appellant on March 29, 1990, for bid purposes on another GPO
    contract-Program C598-S-covering the production of a saddle-
    stitched pamphlet with a page count of between 24 to 48
    pages, is also of no help to the Contractor in proving its
    claim.  See, Appellant's Letter of April 3, 1990, Exhibit B.
    The Contractor contends that its estimate for Program C598-S,
    which does not include film work, will demonstrate the
    unreasonableness of the Contracting Officer's decision to
    calculate the revised contract price by prorating the
    original bid estimates.  Apart from the "bootstrap" nature of
    this argument, the Board has already indicated that its
    narrow jurisdictional mandate prevents it from considering
    matters pertaining to other contracts unrelated to the one
    involved in this case.  See, note 3 supra (and cases cited
    therein).  Consequently, except for default termination cases
    where a reprocurement contract is under review because the
    contractor is contesting the assessment of excess
    reprocurement costs, see, e.g., Sterling Printing, Inc.,
    supra, Sl. op. at 55-63, the Board has consistently refused
    to consider matters outside the scope of the disputed
    contract.  See, Shepard Printing (1993), supra, Sl. op. at 7,
    fn. 11; B. P. Printing and Office Supplies, supra, Sl. op. at
    14-15.  Accordingly, the Board will not consider the
    Appellant's estimates for Program C598-S in the context of
    this case.
    28 The record on which the Board's decision is based consists
    of: (a) the Appellant's Complaint; (b) the R4 File, Tabs A-M;
    (c) the Report of Prehearing Telephone Conference; (d) the
    Respondent's Informal Brief; and (e) the Appellant's Post
    Conference Memorandum.
    29 The extent of the Contractor's palpable frustration can be
    seen in its letter of October 2, 1989, when it told the
    DRPPO: ". . . [B]oy are we going to be happy to see this job
    come to an end."  See, R4 File, Tab F, p. 3.
    30 See, note 3 supra.
    31 The appeal was submitted to the Board for resolution on
    the record.  Board Rules, Rule 11.  See, RPTC, p. 2;
    Appellant's Letter of April 3, 1990.  It is well-settled that
    even though an appellant selects a Rule 11 proceeding for its
    appeal, it is still responsible for providing adequate
    evidence to allow a contract appeals board to make a finding
    in its favor.  Shumate Constructors, Inc., VABCA No. 2772,
    90-3 BCA  22,946, at 115,192 (citing, Jan-Beck Associates,
    VABCA Nos. 2107 et al., 87-2 BCA  19,831; Shoenfeld
    Associates, VABCA Nos. 2104, 2510-2517, 87-2 BCA  19,648).
    Although there is enough undisputed evidence here to decide
    the issues, the record contains certain evidentiary conflicts
    which perhaps could have resolved if the parties had agreed
    to a stipulation of facts, on the one hand, or a method for
    auditing the Appellant's claim, on the other, as requested by
    the Board.  See, note 3 supra.  However, the Board cannot
    avoid its responsibility, and we make our decision on the
    record as we find it.  Shumate Constructors, Inc., supra,
    90-3 BCA  22,946, at 115,192.
    32 Under GPO Contract Terms, where, as here, the pricing of
    any contract modification is in dispute, the Contracting
    Officer has the right to audit the contractor's books,
    records, documents and other data related to negotiating,
    pricing or performing the modification.  See, GPO Contract
    Terms, Contract Clauses, Art. 40 (Audit-Sealed Bidding).  The
    same right is accorded to GPO's Office of the Inspector
    General (OIG).  Id.  However, by its terms, this clause only
    applies when the contract amount exceeds $100,000.00.
    Consequently, the Board's policy, announced in this decision,
    merely extends the Government's auditing rights to sealed bid
    contracts of lesser value.  The comparable contract clause
    for other types of contracts (e.g., cost-reimbursement,
    incentive, time-and-materials, labor-hour, or price
    redeterminable contracts, etc.) is GPO Contract Terms,
    Contract Clauses, Art. 42 (Audit-Negotiation).
    33 Indeed, the observations made by the authors of the book
    "Getting It Printed: How to Work with Printers and Graphic
    Arts Services to Assure Quality, Stay on Schedule, and
    Control Costs", seem particularly apropos.  In that regard,
    they say, in pertinent part: "Final costs almost always
    exceed quotes because of changes from the original
    specifications. . . . Most alterations take place during film
    preparation, not press or bindery work.  Printers usually
    base estimates and quotes on specifications, not final copy.
    . . . Alterations also occur when customers change their
    minds between writing specifications and producing camera
    ready copy. . . . The cost of alterations varies from almost
    free to very expensive, depending on the nature of the
    changes and at what stage they occur.  We use the rule of
    thumb that a change that costs $5 at the pasteup stage will
    cost $50 at the negative stage and $500 on press [in other
    words, at multiples of 1, 10 and 100]. . . . After negatives
    are stripped, any change in format such as a revised page
    count, a new trim size, or a different number of colors means
    major alteration costs.  New formats require at least partial
    restripping and may require refiguring the entire job."  Mark
    Beach, Steve Shepro, and Ken Russon, Getting It Printed: How
    to Work with Printers and Graphic Arts Services to Assure
    Quality, Stay on Schedule, and Control Costs, (Coast to Coast
    Books, Portland, Oregon, 1986), pp. 90-91 (hereinafter Beach,
    Shepro, and Russon).  [Emphasis added.]
    34 The regulations and case law make it clear that
    adjustments to the contract price on account of Government-
    ordered changes are on a cost basis.  GPO Contract Terms,
    Contract Clauses, Art. 4.(b).  See, Bruce Construction
    Corporation v. United States [9 CCF  72,325], 163 Ct.Cl. 97,
    324 F.2d 516 (1963); ACS Construction Company, Inc. of
    Mississippi, ASBCA No. 33550, 87-1 BCA  19,660.
    35 The unpaid cost of film work ($6,427.97), which was
    submitted to the Contracting Office on February 8, 1990,
    represents 39 percent of the claim.
    36 The Board cannot tell whether the Contractor's adjusted
    running rate for 10,050 copies of the Citizen Soldier is also
    derived from some arbitrary formula.  (Although there was a
    58 percent reduction in the number of pages in the pamphlet-
    from 48 to 28-the downward revision in the running rate was
    only 49 percent-from $188.75 to $92.75.)  Indeed, the Board
    has no idea how the Appellant computed the new figure since
    it has not supplied any supporting documentation.  However,
    it is unnecessary for the Board to answer that question.
    Suffice it to say, that when the Board compares the
    Contracting Officer's calculation for running the pamphlet
    ($11,426.85) with the Appellant's approximately 18 percent
    lower figure ($9,321.38) for the same work, it wonders if the
    parties are even dealing with the same contract.
    37 In that regard, a basic custom of the printing trade is to
    charge for author's alterations, which represents work
    performed in addition to the original specifications, at
    current rates and support the charges with documentation upon
    request.  Beach, Shepro, and Russon, p. 176.  However, for
    author's alterations performed under GPO contracts such
    documentation is required.  GPO Contract Terms, Supplemental
    Specifications, Art. 17.(c) (Author's Alterations-Proof of
    charge).
    38 See, note 27 supra.
    39 The reason for this approach was stated in Bruce
    Construction Corporation: "Since the purpose underlying such
    adjustments is to safeguard the contractor against increased
    costs engendered by the modification, it appears patent that
    the measure of damages cannot be the value received by the
    Government, but must be more closely related to and
    contingent upon the altered position in which the contractor
    finds himself by reason of the modification."  Bruce
    Construction Corporation v. United States, supra, 163 Ct.Cl.
    at 100, 324 F.2d at 518.
    40 The reason for this bias was clearly stated by the Federal
    Circuit in Dawco Construction, Inc. v. United States, when it
    said:  ". . . the `actual cost method' is preferred because
    it provides the court, or contracting officer, with
    documented underlying expenses, ensuring that the final
    amount of the equitable adjustment will be just that-
    equitable-and not a windfall for either the [G]overnment or
    the contractor."  Dawco Construction, Inc. v. United  States,
    930 F.2d 872, 882 (Fed. Cir. 1991), rev'g, 18 Cl.Ct. 682
    (1990).
    41 While the contractor's original or bid estimate can be
    used to determine the cost of the work, later evidence, such
    as purchase order prices or vendor quotations, are normally
    better evidence of the costs that the contractor would have
    incurred.  See, e.g., Atlantic Electric Company, supra, 83-1
    BCA  16,484.  If there is no such evidence, the bid estimate
    may be considered the best available proof of this amount.
    Select Contractors, Inc., ENGBCA No. 3919, 82-2 BCA  15,869;
    Dawson Construction Company, Inc., GSBCA No. 5672(5308)-Rein,
    81-2 BCA  15,387, aff'd on reconsid., 82-2 BCA  15,914;
    Onetta Boat Works, Inc., supra, 81-2 BCA  15,279; Pruitt,
    Inc., ASBCA No. 18344, 73-2 BCA  10,213.  But see, Ordnance
    Materials, Inc., supra, 88-3 BCA  29,910.  However, the use
    of estimates does not change the burden of proof.  Cf.,
    Lagarelli Brothers Construction Company, Inc., ASBCA No.
    34793, 88-1 BCA  20,363; Clary Corporation, ASBCA No. 19274,
    74-2 BCA  10,927.
    42 In Condor Reliability Services, Inc., the ASBCA stated:
    "The rule applicable to the price is . . . `the difference
    between the reasonable cost of performing without the change
    or deletion and the reasonable cost of performing with the
    change or deletion.'  [Citation omitted.]  The result should
    not change the contractor's loss or profit position before
    the change occurred.  In other words, there should be no
    repricing of the contract as a whole."  Condor Reliability
    Services, Inc., supra, 90-3 BCA  23,254, at 116,675-76.
    [Emphasis added.]
    43 As explained by the Claims Court: "The search for
    `reasonability,' . . . , is not limited to inquiry of such
    factors as `fair market value' or `historical cost.' . . .
    The reasonable cost concept includes both `objective' and
    `subjective' elements . . . The objective focus is on the
    costs that would have been incurred by a prudent businessman
    placed in a similar overall competitive situation . . .
    However, unless it also takes into account the subjective
    situation of the contractor, a test of `reasonable cost' is
    incomplete. . . .".  Nager Electric Company, supra, 194
    Ct.Cl. at 851-53, 442 F.2d at 945-46.
    44 Generally, the Government's credit for deleted work is
    measured by the net cost savings to the contractor.  S.N.
    Nielsen Company v. United States, 141 Ct.Cl. 793 (1958);
    Jackson Engineering Company, Inc., ASBCA No. 27104, 85-3 BCA
     18,418; Unicom Systems, Inc., ASBCA No. 29468, 84-3 BCA 
    17,675; N.G. Adair, Inc., ASBCA No. 25961, 83-2 BCA  16,887;
    Fordel Films West, ASBCA No. 23071, 79-2 BCA  13,913;
    Celesco Industries, supra, 79-1 BCA  13,604.  See also,
    Cibinic and Nash, pp. 483, 496.  As explained by the ASBCA:
    "When a change deletes work, the Government is entitled to an
    amount equal to what it would have reasonably cost the
    contractor to have performed the work.  In other words, the
    price reduction for the deletion should leave the contractor
    in the same financial condition as it would have been if the
    change order had not been issued.  [Citation omitted.]  While
    the proper measure of the price reduction is what it would
    have cost [the contractor] to perform the deleted work, the
    ascertainment of this figure is not always easy since by
    definition the `actual costs' of deleted work are not
    available."  ACS Construction Company, Inc. of Mississippi,
    supra, 87-1 BCA  19,660, at 99,550.  See also, Condor
    Reliability Services, Inc., supra, 90-3 BCA  23,254, at
    116,675-76.  Obviously, if the contractor realized no savings
    from a change, the Government will not be awarded a price
    reduction.  See, e.g., L.G. Lefler, Inc. v. United States, 6
    Ct.Cl. 514 (1984).
    45 Sustaining this evidentiary burden may not be an easy task
    for the Government because deleted work is not actually
    performed.  ACS Construction Company, Inc. of Mississippi,
    supra, 87-1 BCA  19,660, at 99,550.  Consequently, a board
    may have to find the requisite proof in the "comparative
    reasonableness" of the estimates presented by the respective
    parties.  Jackson Engineering Company, Inc., supra., 85-3 BCA
     18,418, at 92,492.  Indeed, it has been noted that
    estimates are used almost exclusively to establish the cost
    of deleted work.  Cibinic and Nash, p. 510.  See, Arctic
    Corner, ASBCA No. 29545, 86-3  19,304.
    46 This is not to say that the Government's changes had no
    affect on the Contractor's performance under the contact
    whatsoever.  That there was some reduction in the contract
    here is beyond cavil.  However, what the record demonstrates
    is a reduction in the number of pages per copy, not the
    number of copies which had to be produced under each
    contract.  See, Banta Company, supra, Sl. op. at 53-54, fn.
    66.  Thus, while the Appellant had to print 201,000 less
    pages (20 pages x 10,050 copies), it nonetheless still had to
    produce 10,050 copies of the Citizen Soldier.  The Respondent
    assumes that because the Government required less pages,
    ergo, less effort was required by the Contractor.  To the
    contrary, in the Board's view, the reduction in the amount of
    paper and ink required to perform the contract is offset by
    the increased activity on the part of the Contractor which
    was necessary to make all of the author's alterations and
    produce a pamphlet which was satisfactory to the Army.  Id.
    Accord, Celesco Industries, supra, 79-1 BCA  13,604.  See
    also, Beach, Shepro, and Russon, note 34 supra.
    47 Even so, a contractor is still entitled to recover
    reasonable and necessary expenses incurred exclusively for
    the deleted item prior to its deletion.  Groesbeck-Durbin,
    Inc., supra, 72-1 BCA  9,251, at 42,899.
    48 Unlike this appeal, Banta Company involved the application
    of the "loss bid" rule, which forbids the use of an equitable
    adjustment to either reduce or increase a contractor's profit
    or loss, or convert a loss to a profit or vice versa.  See,
    Pacific Architects & Engineers, Inc. v. United States, supra,
    203 Ct.Cl. at 508, 491 F.2d at 739; Nager Electric Company,
    supra, 194 Ct.Cl. at 853, 442 F.2d at 946.  Contrary to the
    position asserted by the contractor, who had bid the
    contracts in question at a loss and argued that the doctrine
    should only apply to the original work but not the additional
    work caused by the author's alterations, the Board held that
    the "loss bid" rule applied to the entire contract; i.e.,
    both the changed and unchanged work.  Banta Company, supra,
    Sl. op. at 28-30.  Accord, BH Services, Inc., ASBCA No.
    39460, 93-3 BCA  26,086.
    49 The reason the "jury verdict" technique is usually viewed
    as an evidentiary tool, rather than as a method of proof of
    the amount itself, is simple enough.  As explained by the
    ASBCA: "There is neither a single nor a precise method of
    arriving at the dollar amount of an equitable adjustment.  In
    general we seek to reach a figure as an equitable adjustment
    which represents the cost to a reasonably efficient
    contract[or] of performing the changed work under his
    contract.  Evidence of this amount may be found in the actual
    costs of the particular contract, to the extent that those
    costs are not shown to be other than reasonable, and in
    engineering estimates of reasonable cost made by experts who
    bring into play their experience and knowledge to attempt to
    visualize the price at which that reasonably efficient
    contractor could perform.  Neither estimating nor accounting
    are such exact arts that either can produce figures which
    will be agreed to by all parties without legitimate argument.
    We recognize that often, despite protestations to the
    contrary, extreme positions on monetary entitlement are taken
    during litigation. . . . [We must determine] . . . a figure
    as the amount of an equitable adjustment . . . [which] . . .
    ordinarily is . . . some place between the amount contended
    for by each party to the litigation. . . . This is a figure
    which in the view of the trier of the facts is fair in light
    of all the facts of the case, or, put another way, is
    supported by consideration of the entire record."  Johnson,
    Drake & Piper, Inc., supra, 65-2 BCA  4,868, at 23,073.
    Similarly, the Department of Agriculture Board of Contract
    Appeals has observed that: "It is not essential that the
    amount be ascertainable with absolute exactness or
    mathematical precision.  [Citations omitted.]  It is enough
    if the testimony and evidence adduced is sufficient to enable
    the court or board (acting as the jury) to make a fair and
    reasonable approximation of the amount recoverable.
    [Citations omitted.]"  Lawrence D. Krause, supra, 82-2 BCA 
    16,129, at 80,073.  See also, Greenwood Construction
    Corporation, Inc., AGBCA No. 75-127, 78-1 BCA  12,893.  See
    generally, Cibinic and Nash, pp. 519-22.
    50 In essence, notwithstanding the requirement for proof of
    costs, the cases disclose a hesitancy to completely deny
    recovery in cases where it is reasonably certain that an
    injury did, in fact, occur.  See, e.g., Meva Corp. v. United
    States, 206 Ct.Cl. 203, 220-21, 511 F.2d 548 (1975) (where
    the court allowed a "jury verdict" recovery because it was
    "equally clear" that the contractor suffered substantial
    monetary damage in direct consequence of the Government's
    breach of contract).  See also, e.g., Harold Benson, AGBCA
    No. 384, 77-1 BCA  12,490 (where the evidence did not
    support the amount claimed by the contractor but did indicate
    that the amount allowed by the contracting officer was too
    low); Custom Roofing Company, ASBCA No. 19164, 74-2 BCA 
    10,925 (where the board granted a "jury verdict" recovery
    based on "rough estimates"); and Rocky Mountain Construction
    Company, IBCA No. 1091-12-75, 77-2 BCA  12,692 (where the
    board applied the "jury verdict" method to an item whose cost
    was "totally unclear").  Indeed, under the "jury verdict"
    technique, a board may even go so far as to make its own
    calculations of an equitable adjustment if it is not
    satisfied with the computations of either the contractor or
    the Government.  See, e.g., Steve P. Rados, Inc., AGBCA No.
    77-130-4, 82-1 BCA  15.624; Varo, Inc., ASBCA No. 15000,
    72-2 BCA  9,717.  In short, the teaching of these cases is
    that it is error for a trier of fact to totally deny a
    contractor's claim when entitlement is clear and there is
    some evidence upon which to base a "jury verdict" recovery.
    See, e.g., Assurance Company v. United States, supra, 813
    F.2d at 1205; S.W. Electronics & Manufacturing Corporation v.
    United States, supra, 228 Ct.Cl. 333, 655 F.2d at 1088;
    Electronic & Missile Facilities, Inc. v. United States,
    supra, 189 Ct.Cl. 237, 416 F.2d at 1358; Eagle Paving, AGBCA
    No. 75-156, 78-1 BCA  13,107.  Thus, the "jury verdict"
    method works in harmony with two purposes of the equitable
    adjustment procedure in general, namely to recognize and give
    appropriate consideration to the special circumstances of
    each case, and to avoid blind computations of additional
    costs or cost savings.  G.M. Company Manufacturing Inc.,
    ASBCA No. 2883, 57-2 BCA  1,505, at 5,234.
    51 Even when proof of causation is not fully demonstrated, a
    board may use the "jury verdict" approach to reduce the
    amount claimed.  See, e.g., Steve P. Rados, Inc., supra, 82-1
    BCA  15,624, where the contractor had provided detailed
    evidence of the events that had occurred and of the costs
    which had been incurred, the board made its own computations
    of the amount of claimed costs that were attributable to
    Government action.  Compare, Joseph Pickard's Sons Company v.
    United States, 209 Ct.Cl. 643, 532 F.2d 739, 742 (1976)
    (where the Claims Court refused to use the "jury verdict"
    method to prove causation).
    52 It is well-settled that a board of contract appeals has
    the authority to recalculate the amount of a deduction taken
    by the Government.  Banta Company, Inc., supra, Sl. op. at 58
    (citing, Mit-Con, Inc., ASBCA No. 43021, 92-1 BCA  24,632;
    Arctic Corner, supra, 86-3  19,304; R & E Electronics, Inc.,
    supra, 85-3 BCA  18,316; Steve P. Rados, Inc. supra, 82-1
    BCA  15,624; Varo, Inc., supra, 72-2 BCA  9,717).
    53 The total amount of the contractor's claims in Banta
    Company exceeded $100,000.00, and an audit was authorized
    under GPO Contract Terms, Contract Clauses, Art. 40 (Audit-
    Sealed Bidding).  See, note 32 supra.
    54 As indicated previously, although the original claim was
    for $45,135.00, the unpaid portion which is still in dispute
    amounts to only $16,620.89.  See, note 23 supra.  In
    addition, the Appellant also asks the Board to award it
    interest and/or the cost of funds in the amount of $5,796.00.
    App. Mem., pp. 7-8.  Apart from the fact that the Appellant's
    claim for interest would have to be presented to the
    Contracting Officer for a decision before the Board could
    consider it, see, e.g., Shepard Printing, GPO BCA 37-92
    (January 24, 1994), Sl. op. at 31-32; P.X. Engineering
    Company, supra, 89-2 BCA  21,859, at 109,952, the simple
    fact is that the Board has no authority to award interest.
    It is well- settled that a contractor cannot recover interest
    on a claim against the United States unless there is an
    express provision in the contract or a relevant statute
    permitting such payment.  See, Maitland Brothers Company,
    ASBCA No. 40388, 93-3 BCA  26,007 (citing, Fidelity
    Construction Company v. United States [30 CCF  70,827], 700
    F.2d 1379 (Fed. Cir. 1983)), motion for reconsid. denied,
    94-1 BCA  26,285; Reese Industries, ASBCA No. 36077, 89-1
    BCA  21,255.  The contract in dispute here is subject to the
    contract cost principles set forth in GPO Procurement
    Directive 306.2, Contract Cost Principles and Procedures,
    dated April 1, 1988 (CCPP).  See, GPO Contract Terms,
    Contract Clauses, Art. 45 (Contract Cost Principles and
    Procedures).  Those cost principles expressly disallow
    interest on borrowings (however represented) and directly
    associated costs.  CCPP,  28.  Since the Board takes its
    authority from the contract itself, see, note 3 supra, it
    cannot award a contractor compensation which is specifically
    prohibited by its terms.  Furthermore, the Board has already
    ruled that GPO is not subject to the interest requirements of
    the Prompt Payment Act of 1982, as amended (PPA), 31 U.S.C. 
    3901 et seq., because the PPA uses the APA definition of
    "agency" to define its coverage in terms of the Executive
    branch, and GPO is a Legislative branch agency.  See, Chavis
    and Chavis Printing, supra, Sl. op. at 7, fn. 7.  Similarly,
    GPO is not an "executive agency" within the meaning of the
    CDA.  See, Tatelbaum v. United States, supra, 749 F.2d at
    730.  As a consequence, GPO is not subject to the interest
    and prompt payment provisions of the CDA either.  See, 41
    U.S.C.  611, 612(a),(b).  Accordingly, the Appellant's
    request for payment of interest in the amount of $5,796.00 is
    hereby DENIED.