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

In the Matter of           )
                           )
The Appeal of              )
                           )
NEW SOUTH PRESS            )      Docket No. GPO BCA 45-92
Jacket No. 635-994         )
Purchase Order F-1491      )

   DECISION AND ORDER

   By letter dated November 16, 1992, New South Press (Appellant
   or Contractor), 3885 North Palafox Street, Pensacola, Florida
   32505, filed a timely appeal from the November 12, 1992, final
   decision of Contracting Officer Douglas M. Faour, of the U.S.
   Government Printing Office's (Respondent or GPO or Government)
   Atlanta Regional Printing Procurement Office (ARPPO), 1888
   Emery Street NW., Suite 110, Atlanta, Georgia 30318-2536,
   rejecting the Appellant's equitable adjustment claim in the
   amount of $2,000.00,1 under its contract identified as Jacket
   No. 635-994, Purchase Order F-1491, because of the
   Respondent's delay in supplying Government-furnished materials
   (GFM) (R4 File, Tabs D, L and M).2  For the reasons which
   follow, the decision of the Contracting Officer is hereby
   AFFIRMED, and the appeal is DISMISSED.3

   I. FINDINGS OF FACT4

   1.  On July 10, 1992, the Respondent awarded the Appellant a
   contract for the production of 12 pamphlets of various case
   studies for the Centers for Disease Control (CDC) (R4 File,
   Tab A, pp. 6, 8).  Insofar as is pertinent to this appeal, the
   contract terms provided:

      Any contract which results from this Invitation for Bid
      will be subject to the applicable articles of [GPO Contract
      Terms] . . .

      PRODUCT: 11 pamphlets at 7,017 copies and 1 pamphlet at
      50,017 copies.  All pamphlets are saddle stitched and range
      from 20 to 28 pages each.

   * * * * * * * * * *

      GOVERNMENT TO FURNISH: Camera copy, 8-1/2 x 11" copy black
      on white.

      One reproduction proof (image size 7-7/8 c 6-1/8") for
      shipping container labels.

      Identification markings such as register marks, ring
      folios, rubber stamped jacket numbers, commercial
      identification marks of any kind, etc., except GPO imprint,
      form number, and revision date, carried on copy or film,
      must not print on finished product.

   * * * * * * * * * *

      PRINTING: Covers 1 thru 4 with text pages as follows:

   JUNE

         Pamphlets    Pages    Copies    ID Number

                 7      20     7,017      0093503
                 8      24        7,017      0993504
                 9      24        7,017      0992505
                10      24        7,017      0993506
                12      20        7,017      0993508
                13      20        7,017      0993509
                 4      24        7,017      0993400
                17      28        7,017      0993673

   JULY

                18      28        7,017      0993669
                19      28        7,017      0993668
                20      28        7,017      0993672
                 1      28       50,017     0993678

   * * * * * * * * * *

      SCHEDULE: Government furnished materials for the first
      eight (8) pamphlets will be available for pickup July 9,
      1992.  Pick up at the Atlanta RPPO, 1888 Emery St., NW., 2
      Park Place, Suite 110, Atlanta, GA 30318.  The Government
      furnished materials for the next four (4) pamphlets will be
      available for pickup at the same location in July 1992.

      Deliver the first 8 pamphlets July 24, 1992 with the
      balance of pamphlets being delivered at destination 10 days
      after pickup of copy.

See, R4 File, Tab A, pp. 1, 6, 8.  [Emphasis added.]

   2.  Contrary to the terms of the contract, the GFM for the
   first eight pamphlets was not available for pickup July 9,
   1992.  Instead the Appellant received the GFM for those
   pamphlets on or about July 13, 1992, and the delivery date was
   extended to July 27, 1992, to accommodate for the delay (R4
   File, Tab B).5  Thereafter, the Contractor completed the job
   on the first eight pamphlets and made a timely delivery to the
   CDC.

   3.  Under the contract's terms, the GFM for the remaining four
   pamphlets-Pamphlet Nos. 1, 18, 19, and 20-was to be available
   for pickup sometime in July 1992 (R4 File, Tabs A, p. 8, and
   D).  However, when the GFM was not ready for the Appellant by
   the end of that month, the Contractor sent the following
   facsimile message to the Contracting Officer on or about
   August 13, 1992:

      We received the first 8 pamphlets on July 13th, and have
      completed and delivered them.  The balance of the pamphlets
      were to be ready for pick up before 7/31/92/  As of 8/13/92
      the above jobs will be 8 days late.  Since all four books
      have a critical delivery we had left press and bindery
      windows open in our schedule, of which 4 days could not be
      filled.  At a rate of 500.00 per day, the charge would be
      2,000.00 for the four days.

      Please contact me and let know when the pamphlets will be
      ready to be picked up.

      Please check the appropriate line and fax back a signed
      copy of this form.6  Our number is (904) 434-8471.

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

   4.  After conferring with Douglas M. Faour, the ARPPO Manager,
   Gary Bush, the Contracting Officer for this contract, refused
   to authorize the Appellant's request to be paid for idle press
   time on the ground that the matter was covered by GPO Contract
   Terms, and besides the Government had not given its permission
   for the Contractor to hold its press open (R4 File, Tab D).

   5.  Thereafter, on August 27, 1992, the Contracting Officer
   sent the Appellant the GFM for two of the four remaining
   pamphlets-Pamphlet Nos. 19 and 20-and established a delivery
   date for those jobs of September 14, 1992 (R4 File, Tab E).
   The Contractor was also advised that the GFM for the last two
   pamphlets would be made available when received from the CDC
   (R4 File, Tab E).  The following day, the Appellant telephoned
   the Contracting Officer and asked for additional time, and by
   Contract Modification No. 1, dated September 1, 1992, the
   delivery date for Pamphlet Nos. 19 and 20 was extended to
   September 18, 1992 (R4 File, Tabs F and G).7  As noted in
   Contract Modification No. 1, the adjustment in the delivery
   date was made ". . . due to scheduling problems that resulted
   from Government delay in providing camera copy to the
   contractor."  See, R4 File, Tab G.

   6.  On September 29, 1992, the Appellant was notified that the
   GFM for the last two pamphlets-Pamphlet Nos. 1 and 18-was
   available for pick up (R4 File, Tab E).  The parties initially
   agreed to a delivery date of October 26, 1992 for these
   pamphlets, which was confirmed by Contract Modification No. 2
   (R4 File, Tabs E and H).  However, the delivery date was
   subsequently revised to November 9, 1992 (R4 File, Tab K).

   7.  One reason for the Appellant's need for additional time
   was the CDC had made certain author's alterations in three of
   the pamphlets, i.e., Pamphlet Nos. 1, 19 and 20.
   Specifically, the number of pages in Pamphlet No. 1 was
   increased from 28 to 32, while the number of pages in Pamphlet
   Nos. 19 and 20 was reduced by eight and four pages,
   respectively.  As a result of these alterations, the
   Respondent issued Contract Modification No. 3 which increased
   the contract price of Pamphlet No. 1 by $1,790.00, and
   decreased the contract price of Pamphlet Nos. 19 and 20 by a
   total of $639.95 (R4 File, Tabs F, J and K).8

   8.  It is undisputed that the Contractor completed the job on
   the remaining four pamphlets and delivered them to the CDC in
   accordance with the revised schedule.

   9.  On November 10, 1992, after the contract was completed,
   the Appellant sent the following facsimile message to the
   Contract Officer:

      We bid the above jacket on 7/7/92 for which we were to
      receive books on 7/9/92.  We finnaly [sic] received the
      first of the 8 books on 7/14/92.  These books were printed
      and delivered on 7/27/92.  The balance of the 4 books,
      according to the contract were to be received July 1992,
      and in order to comply with the contract we left the window
      open to receive and produce the books.

      On 8/14/92 we sent a fax to your office in reference to the
      balance of the books and the fact that we held a window
      open for the same (I am enclosing a copy of this fax).
      Your reply was also received the same day and is also
      attached.

      When the jobs were finally received, two on 8/28/92 and two
      on 10/1/92 we turned them around in a timely fashion.
      However, one full shift in our pressroom was initially
      lost, which could not be filled quickly enough when it was
      evident that the balance of the books would not be on time.
      That shift loss cost our plant $2000.00 in lost production.

      New South hereby requests the agent [sic] to pay for the
      above losses.  If additional information is necessary
      kindly advise.

      Please check the appropriate line and fax back a signed
      copy of this form.9  Our number is (904) 434-8471.



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

   10.  By letter dated November 12, 1992, the ARPPO
   Manager/Contracting Officer denied the Appellant's request to
   be paid for idle press time (R4 File, Tab M).  The reason
   given for his decision was succinctly stated in his letter,
   namely:

      Please refer to Contract Terms, Contract Clauses, page 15,
      (c) Extension of schedules.  The schedule was adjusted as
      requested by you.  Therefore, no payment due to Government
      delay will be paid for Purchase Order F 1491, Jacket
      635-994.

See, R4 File, Tab M.

   11.  On November 16, 1992, the Appellant timely appealed the
   Contracting Officer's decision to the Board.

   II. ISSUES PRESENTED

   At the prehearing telephone conference, the following issue
   was identified for resolution in this threshold proceeding:

      Where the Government does not have the GFM ready for the
      Appellant by the date specified in the contract, does the
      "Extension of Schedules" clause in GPO Contract Terms
      provide the exclusive remedy, or is the Contractor also
      entitled to compensation for the delay under some other
      clause?

See, RPTC, p. 3.10

   III. POSITIONS OF THE PARTIES11

   The crux of the Appellant's position at this stage of the case
   is that because the late delivery of the GFM for Pamphlet Nos.
   1, 18, 19, and 20 was caused by the Government's changes to
   those publications, GPO's standard "Changes" clause entitles
   it to reimbursement for unabsorbed overhead resulting from the
   delay.12  App. Brf., pp. 3, 4.  The Appellant contends that
   where a contractor's costs under a fixed-price contract are
   increased by the Government's dilatory conduct, the
   authorities hold that it may be compensated for any financial
   inconvenience caused by the delay,  App. Brf., p. 3 (citing,
   Cibinic and Nash, Chap. 6 (Delays), provided that it proves,
   by credible evidence, that it was impossible or impractical to
   obtain new work to absorb overhead or pay facilities costs
   during the period of delay, id. (citing, Capital Electric
   Company v. United States, 729 F.2d 743 (Fed.Cir. 1984); J.W.
   Cook & Sons, Inc., ASBCA No. 39691, 92-3 BCA  25,053, at
   124,863).

   The Contractor relies heavily on the Board's decision in Banta
   Company to support its position on the entitlement issue.  Id.
   (citing, Banta Company, GPO BCA 03-91 (November 15, 1993), Sl.
   op. at 30-32).  In that regard, the Appellant sees Banta
   Company as standing for the proposition that, contrary to the
   Respondent's belief, the contract's "Extension of Schedules"
   clause is not the exclusive remedy available to contractors
   adversely affected by Government delays.  Id.  See, GPO
   Contract Terms, Contract Clauses,  12(c).  The Contractor
   argues that Banta Company is factually similar to this appeal
   in most respects, and thus the Board's holding in that case is
   dispositive of the legal issue here.  App. Brf., pp. 3-4.
   Accordingly, the Appellant urges the Board to find, as a
   threshold matter, that the Contractor is entitled to
   compensation under the "Changes" clause for the press downtime
   caused by the Government's delayed delivery of the GFM, and it
   also asks the Board to direct the parties to proceed with
   discovery on the question of recoverable costs.  App. Brf., p.
   4.

   The Respondent, on the other hand, while admitting that the
   Government was responsible for the delay in delivering the GFM
   to the Contractor, contends that the Appellant's reimbursement
   demand is really a breach of contract claim which cannot be
   considered under the "Changes" clause.  R. Brf., p. 1.
   Furthermore, the Respondent reminds the Board that it is
   without jurisdiction to hear claims for breach of contract
   because GPO is a Legislative branch agency, and hence is not
   covered by the Contract Disputes Act (CDA), Pub. L. 95-563
   (November 1, 1978), 92 Stat. 2383, 41 U.S.C.  601, 606.  R.
   Brf., pp. 1-2 (citing, The Wessel Company, supra; United
   States v. Utah Construction and Mining Company, 384 U.S. 394
   (1966); Harbor Printing & Copy Service, Inc., GPOCAB No. 77-5
   (1977); Cloverleaf Enterprises, Inc., GPOCAB No. 79-12 (1980);
   and Information Systems, Inc., GPOCAB No. 78-11 (1979)).13
   Thus, the Respondent contends that the Appellant's sole remedy
   is to be found within the contract itself, namely, in the
   clause which provides for an automatic extension of the
   delivery schedule in the event of a delay caused by "any
   action" of the Government.  RPTC, p. 2; R. Brf., p. 2 (citing,
   United States v. Rice, 317 U.S. 61 (1942)).  See, GPO Contract
   Terms, Contract Clauses,  12(c).  Since such an extension was
   granted to the Appellant in this case-indeed, the Contractor
   received additional time, at its request-it has received the
   full relief allowed by the contract.14  RPTC, p. 2; R. Brf.,
   p. 3; Res. R. Brf., p. 4.  See, R4 File, Tabs G and H.

   As for the Appellant's reliance on the Board's decision in
   Banta Company, the Respondent believes that it is misplaced.
   Res. R. Brf., p. 1.  In the Respondent's view, this case is
   distinguishable from Banta Company because the Contractor here
   has not shown any nexus between the alterations to the number
   of text pages ordered by the Government and the delay
   experienced by the contractor.15  Res. R. Brf., p. 2 (citing,
   Banta Company, supra, Sl. op. at 33).  Instead, the record
   discloses simple tardiness by the Government in furnishing the
   GFM, or the sort of "naked delay" not compensable under the
   "Changes" clause.  Id. (citing, Banta Company, supra, Sl. op.
   at 31-32).  For the same reason, the Respondent believes that
   the Contractor's reliance on J.W. Cook & Sons, Inc., supra,
   and Capital Electric Company v. United States, supra, is
   equally unavailing; i.e., both decisions are anchored in two
   contract clauses-the "Suspension of Work" clause (FAR 
   52.212-12) and the "Protest After Award" clause  (FAR 
   52.233-3)-which explicitly allow a contracting officer to
   equitably adjust the contract price to compensate for the
   costs associated with a Government-caused delay, but which are
   not present in this appeal.  Res. R. Brf., pp. 2-3 (citing,
   Capital Electric Company v. United States, supra, 758 F.2d at
   744 ("Suspension of Work" clause); J.W. Cook & Sons, Inc.,
   supra, 92-3 BCA  25,053 at 124,863 ("Protest After Award"
   clause)).  Here, instead, the applicable GPO contract clause
   only provides for an automatic extension of the delivery
   schedule when the contractor experiences a delay in the
   Government's making the GFM available for contract
   performance.  Res. R. Brf., p. 3.  Accordingly, as the
   requisite schedule adjustment was received by the Appellant,
   the Respondent believes argues that no further relief is
   authorized and the appeal should be denied in its entirety.
   RPTC, p. 2; Res. R. Brf., p. 4.

   IV. DECISION16

   As a rule, absent facts or a clause allowing otherwise, a
   contractor bears the risk of performance costs in a firm
   fixed-price contract.  See, Web Business Forms, Inc., GPO BCA
   16-89 (September 30, 1994), Sl. op. at 23 (citing, D.K.'s
   Precision and Manufacturing, ASBCA No. 39616, 90-2 BCA 
   22,830; Chevron U.S.A., Inc., ASBCA No. 32323, 90-1 BCA 
   22,602; Nedlog Company, ASBCA No. 26034, 82-1 BCA  15,519).
   In this threshold proceeding, the Board is asked to decide
   whether, as a matter of law, the Appellant can recover its
   downtime costs under GPO's standard "Changes" clause for the
   delay caused by the Government's late delivery of the GFM for
   Pamphlet Nos. 1, 18, 19, and 20, if it can prove its claim.17
   GPO Contract Terms, Contract Clauses,  4.  On one side of
   this question is the Appellant, who claims an entitlement to
   compensation based on the standard GPO  "Changes" clause.
   See, GPO Contract Terms, Contract Clauses,  4.  On the other
   side is the Respondent, who argues that the automatic
   extension of the delivery schedule received by the Contractor
   by virtue of the "Extension of Schedules" clause, is the
   exclusive remedy for the delay.18  See, GPO Contract Terms,
   Contract Clauses,  12(c)(1).  Although both sides cite the
   Board's decision in Banta Company, they disagree on whether
   that opinion answers the issue in this proceeding; i.e., the
   Appellant sees that decision as controlling, while the
   Respondent thinks Banta Company has no application whatsoever.
   Therefore, this dispute provides the Board with a convenient
   vehicle to clarify its holding in Banta Company and describe
   the circumstances in which it applies.

   The controversy in Banta Company arose out of two contracts
   awarded by GPO for the production of separate tax booklets for
   the Internal Revenue Service.  Apart from being covered by GPO
   Contract Terms, both contracts contained a clause which
   instructed the Government to negotiate supplemental agreements
   with the contractor for contract changes.  Banta Company,
   supra, Sl. op. at 4-5, 20.  As originally ordered by the
   Government, the contractor was to print 4,701,000 copies of
   one tax booklet consisting of 88 pages, and 911,000 copies of
   the other one, a 120 page IRS publication.19  After the
   contractor had submitted the pre-production samples of both
   tax booklets to GPO, and the agency had approved them, the
   Government issued change orders reducing the number of pages
   in each booklet from 88 to 80 and from 120 to 112,
   respectively.  The parties stipulated that the change orders
   required the contractor to revise its production plans,
   reconfigure its presses, "slit" the already manufactured paper
   stock to fit those new press and forms configurations, and
   employ extra press crews to handle the additional roll changes
   required by the use of smaller paper rolls, all of which
   substantially increased the contractor's manufacturing
   costs.20  Id., Sl. op. at 5-7.  Furthermore, the parties
   agreed that the Government's late delivery of the revised
   camera copy for the 80 page tax booklet also resulted in
   increased costs because, among other things, it disrupted the
   contractor's printing operations.21  Id., Sl. op. 7, 10, fn.
   11.  Following completion of both printing jobs, the
   contractor submitted two equitable adjustment claims to the
   contracting officer, including one which asked for
   compensation for the late arrival of the GFM for the 80 page
   tax booklet.  Id., Sl. op. at 8.  On the recommendation of
   GPO's Office of the Inspector General (OIG), which audited the
   claims and found that the contractor had bid both contracts at
   a loss, the contracting officer employed the "total cost"
   method of cost accounting to recover money from the contractor
   instead of awarding it an equitable adjustment.22  Id., Sl.
   op. at 12-13.  Before the Board the contractor contended,
   inter alia, that: (1) the Government's use of the "total cost"
   approach to determine the contractor's equitable adjustment
   was inappropriate; and (2) under express language in the
   contract specifications, the Government's late delivery of the
   GFM was a "change" within the meaning of the "Changes" clause
   in GPO Contract Terms, thus, entitling the contractor to
   compensation for the delay.  Banta Company, supra, Sl. op. at
   16.  In the process of defending its choice of the "total
   cost" technique, GPO also contested its liability for late
   delivery of the revised camera copy with essentially the same
   arguments it makes in this case, namely, the Board has no
   authority to decide breach of contract claims, and the only
   remedy available to the contractor was an extension of the
   delivery schedule under the relevant clause in GPO Contract
   Terms.  Banta Company, supra, Sl. op. at 20-21.

   On these facts, the Board held, for the first time, that the
   "Changes" clause in GPO Contract Terms provided a basis for
   compensating a contractor whose production costs were
   increased by the delay resulting from the Government's late
   delivery of the GFM, and that an automatic adjustment of the
   delivery schedule pursuant to the "Extension of Schedules"
   clause was not an exclusive remedy for such dilatory
   conduct.23  Banta Company, supra, Sl. op. at 35.  In
   explaining its decision, the Board reasoned, in pertinent
   part, as follows:

      The Board's examination of cases involving contractor
      claims for the recovery of delay and impact costs, teaches
      it that a vital consideration is the timing of the delay
      with respect to the Government-ordered change.  In the
      simplest situation, extra costs stemming from a "naked"
      delay, that is, a disruption of work resulting from some
      Government action which does not physically change the work
      under the contract, are usually not recoverable under the
      standard "Changes" clause.  [Footnote omitted.]  See, Model
      Engineering & Manufacturing Corporation, ASBCA No. 7490,
      1962 BCA  3,363; Weldfab, Inc., IBCA No. 268, 61-2 BCA 
      3,121.  Also cf., Editors Press Incorporated, GPO BCA 03-90
      (September 4, 1991), Sl. op. at 18-19. . . .  On the other
      hand, the cases hold that if a delay occurs from some
      Government action after a change order is issued, the
      contractor may recover delay and impact costs for both
      changed and unchanged work.  Thus, the ASBCA has ruled
      that:

         Where costs in a work item are increased as a direct
         result of a change in that item, the increased costs are
         compensable, including costs of delays in performance in
         the change order.  [Emphasis added.]

      Power Equipment Corporation, ASBCA No. 5904, 1964 BCA 
      4,025, at 19,815, mot. for reconsid. denied, 1964 BCA 
      4,228.  See also, Coastal Drydock and Repair Corporation,
      ASBCA No. 36754, 91-1 BCA  23,324, at 117, 002 (increased
      cost of disrupted unchanged work flowing directly from the
      change is compensable under the "Changes" clause); Merritt-
      Chapman and Scott v. United States, 192 Ct.Cl. 851, 429
      F.2d 431 (1970); Paul Hardeman, Inc. v. United States, 186
      Ct.Cl. 743, 752, 406 F.2d 1357 (1969) (concurring opinion
      of Judge Davis).  [Footnote omitted.]  See generally,
      Cibinic and Nash, pp. 525-26.  In other words, recovery is
      allowed if there is a clear nexus between the change
      ordered by the Government and the delay experienced by the
      contractor.

      The reason why recovery is allowed for the contractor's
      delay and disruption costs which are the direct and
      necessary result of the Government's change order, can be
      found in the language of the "Changes" clause itself.  See,
      Cibinic and Nash, p. 524.  In that regard, the standard
      "Changes" clause for fixed-priced contracts provides, in
      pertinent part:

         (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.

      See, FAR  52.243-1 (Changes-Fixed-Price).  The drafters of
      the clause, which first appeared in the 1967 revision to
      the FAR, stated that under this language:

         [A]n equitable adjustment clearly encompasses the effect
         of a change order upon any part of the work, including
         delay expense, provided, of course, that such effect was
         the necessary, reasonable, and foreseeable result of the
         change.   [Emphasis added.]

      See, 32 Fed. Reg. 16269 (1967).

      Even a cursory examination of GPO's "Changes" clause, which
      was incorporated by reference in both contracts here,
      discloses that the language is identical to the wording of
      the FAR "Changes" clause.  GPO Contract Terms, Contract
      Clauses,  4(b).  Under settled rules of construction, the
      Board must presume that when the drafters of GPO's
      "Changes" clause adopted the FAR language verbatim, they
      also accepted the uniform interpretation given to those
      words by the 1967 revision committee, Executive branch
      contract appeals boards, and the courts.  Cf., United
      States v. Aguon, 851 F.2d 1158 (9th Cir. 1988); Van Cleef
      v. Aeroflex Corporation, 657 F.2d 1094 (9th Cir. 1981);
      L.B. Foster v. Railroad Service, Inc., 734 F.Supp. 818
      (N.D. Ill. 1990).  Furthermore, the cost accounting
      principles governing GPO contracts reenforce the Board's
      belief that GPO's "Changes" clause is intended to apply to
      a contractor's delay and disruption costs flowing from
      Government changes to the contract.  In that regard, the
      applicable accounting rules provide that payment for
      equipment downtime is allowable if, inter alia, the
      machinery was necessary when acquired and is now idle
      because of changes in requirements, production economies,
      reorganization, termination, or other causes which could
      not have been foreseen.  [Footnote omitted.] [Citing, GPO
      Contract Cost Principles, p. 22,  25(b)(2) (Idle
      facilities and idle capacity costs).] Therefore, the Board
      concludes that GPO's standard "Changes" clause, like the
      parallel provision in the FAR, allows a contractor to
      recover compensation for delay expenses stemming from a
      change order upon any part of the work as part of an
      equitable adjustment.  [Footnote omitted.]

See, Banta Company, supra, Sl. op. at 31-35.

   In this case, there is no doubt that the Government altered
   the number of pages in Pamphlet Nos. 1, 19 and 20, and that
   the time it took to do so resulted in late delivery of the GFM
   for those publications to the Appellant.24  Therefore, the
   issue in this case boils down to a question of whether that is
   enough, standing alone, to give rise to an obligation on the
   part of the Respondent to compensate the Contractor for its
   downtime costs stemming from that delay.  The Board believes
   not.  When the Board measures the facts here against the
   principles set forth above, it is compelled to conclude that
   this is simply not a Banta Company situation.
   Thus, the record shows that under the terms of the Appellant's
   contract the GFM for Pamphlet Nos. 1, 18, 19, and 20 was to be
   ready for pickup sometime in late July 1992 (Factual Finding
   No. 2).  However, the camera copy for the last four booklets
   was not available then (Factual Finding No. 3), but instead
   the GFM for Pamphlet Nos. 19 and 20 was delivered to the
   Appellant on August 27, 1992, and the camera copy for Pamphlet
   Nos. 1 and 18 was made available on September 29, 1992
   (Factual Finding Nos. 5 and 6).  While the Government changed
   the number of text pages in three of the publications
   (Pamphlet Nos. 1, 19 and 20) and it was solely to blame for
   the delayed delivery of the revised camera copy (Factual
   Finding No. 5), it is also clear that until that time the
   Appellant had performed no work whatsoever toward producing
   those booklets.  In that regard, the single most important
   distinction between Banta Company and the Appellant's
   situation here is that in Banta Company the contractor had
   already performed substantial work on the publications ordered
   by the Government.  See, KRW, Incorporated, DOT BCA No. 2572,
   94-1 BCA  26,435; Diversified Marine Tech, Inc., DOT BCA Nos.
   2455, 2482, 93-2 BCA  25,720; Industrial Controls, GSBCA No.
   5391, 79-2 BCA  14,171.  Stated otherwise, the changes in
   Banta Company, which occurred after the GPO had already
   approved the contractor's pre-production samples of both tax
   booklets, had a substantial impact on the contractor's
   production plans and operations, increased its press, paper
   and labor costs, and did more than just disrupt the
   contractor's manufacturing schedule.25  Under those
   circumstances, traditional "Changes" clause concepts clearly
   entitled the contractor to an equitable adjustment in the
   contract price to compensate for its increased costs,
   including downtime expenses-a fact which even the OIG auditors
   recognized when measuring the contractor's claim by the
   "actual cost" method.26  See, Southwest Marine, Inc., ASBCA
   No. 39472, 93-2 BCA  25,682; Bryant & Bryant, ASBCA No.
   27910, 88-3 BCA  20,923; Kolar, Inc., ASBA No. 23252, 28482,
   86-2 BCA  18,9929.

   Apart from the delay in the delivery of the GFM for the
   remaining four pamphlets, this case bears absolutely no
   resemblance to Banta Company.  That is, even though the
   Respondent altered the number of pages in three of the
   pamphlets, those changes had no affect on contract performance
   because the Appellant had done nothing as yet to produce the
   remaining booklets-indeed, it could not do so because it did
   not have the necessary GFM.  Consequently, for all practical
   purposes, the impact on the Appellant's manufacturing posture
   here is no different than if the Government had not made any
   alterations all; i.e., we would be looking at a simple delay
   situation.  Accordingly, the Board holds that the Appellant's
   claim in this case is not a matter appropriate for resolution
   under the "Changes" clause, as described in Banta Company.

   Since the "Changes" clause is not applicable in this dispute,
   the Board's authority to equitably adjust the contract price
   must be found in some other clause of the contract.  Nello L.
   Teer, supra, 86-3 BCA  19,326.  The Board's research
   indicates that if this case had arisen under the CDA, an
   Executive Branch board of contract appeals would be able to
   allow recovery under the "Government-Furnished Property"
   clause of the FAR because it expressly provides for the sort
   of relief sought by the Appellant.  See, Dave Hakala, AGBCA
   No. 85-219-3, 85-3 BCA  18,382; LogiMetrics, Inc., ASBCA No.
   28516, 84-3 BCA  17,593; Swinging Hoedads, AGBCA No.
   82-278-3, 83-2 BCA  16,707.  In that regard, the relevant FAR
   provision states, in pertinent part:

      (a) The Government shall deliver to the Contractor, at the
      time and locations stated in this contract, the Government-
      furnished property described in the Schedule or
      specifications.  If that property, suitable for its
      intended use, is not delivered to the Contractor, the
      Contracting Officer shall equitably adjust affected
      provisions of this contract in accordance with the
      "Changes" clause . . .

FAR  52.245-4 (Government-Furnished Property (Short Form)).
[Emphasis added.]

   However, the "Government Furnished Property" clause in GPO
   Contract Terms, which is incorporated by reference in the
   Appellant's contract, is more limited in scope.  It states, in
   pertinent part:

      The contractor is required to examine the furnished
      property immediately upon receipt.  If at that time there
      is disagreement with the description or requirements as
      presented in the specification . . ., and prior to the
      performance of any work, the contractor shall contact
      [GPO], . . . and contest the description. . . .  The
      Contracting Officer will then investigate and make a
      determination which will be final.  If the decision is
      reached that the original description is proper, the
      contractor will be required to proceed with the work. . . .
      If the decision is reached that the description is
      erroneous, the Contracting Officer will proceed in one of
      the following manners:

        (a) In the case of sealed bids, either an equitable
        adjustment will be negotiated with the contractor or the
        order will be terminated.

        (b) In the case of a print order placed through a term
        contract, an equitable adjustment will be negotiated and
        a supplemental agreement issued.

GPO Contract Terms, Contract Clauses,  7 (Government Furnished
Property (GFP)).  [Emphasis added.]  By its terms, the GPO clause
only authorizes an equitable adjustment in cases where there is a
difference between the GFM, as described in the specifications
and as actually delivered to the Contractor.  Although the word
"description" is not defined in the clause, or elsewhere in GPO
Contract Terms, it usually refers to a statement that paints a
word picture of what a particular item or thing should look like.
See, WEBSTER'S NEW WORLD DICTIONARY 372 (3d ed. 1988).  Thus, for
the pamphlets involved in this dispute, the "description" would
include such things as the type of paper stock for both the text
and cover, the number of pages, the identification number, the
margin dimensions, the type of binding, the location of drill
holes, and the quality level of the product; i.e., the printing
specifications.  When the GFM for Pamphlet Nos. 1, 19 and 20 was
delivered to the Appellant, the only "description" change
concerned a variation in the number of pages for each booklet,
for which the Contractor received an equitable adjustment
(Factual Finding No. 7).27  See, R4 File, Tabs F, J and K.

   There is nothing in GPO's "Government Furnished Property"
   clause comparable to the Government promise in the FAR to
   deliver the GFM to the Contractor, "at the time and locations
   stated in this contract," which is necessary to support an
   equitable adjustment for any downtime costs associated with a
   delay in the GFM.  Instead, as the Respondent contends, such
   matters are addressed and controlled by the "Extension of
   Schedules" provisions of the "Notice of Compliance with
   Schedules" clause.  GPO Contract Terms, Contract Clauses, 
   12(c).  See, Graphics Image, Inc., GPO BCA 13-92 (August 31,
   1992) Sl. op.  at 23.  Since it is uncontroverted in the
   record that the GFM delay was accommodated by revising the
   delivery schedule for the last four pamphlets, the Contractor
   received only remedy authorized by its contract with the
   Respondent.  See, R4 File, Tabs G, H and K.

   As a final observation, it seems to the Board that the only
   other theory of recovery available to Appellant is that
   somehow the Respondent breached its implied duty to cooperate
   with the Contractor in performance of the contract.  See,
   Stephenson, Inc., supra, Sl. op. at 38-39.  Accord, Finesilver
   Manufacturing Company, ASBCA No 28955, 86-3 BCA  19,243
   (Government continually failed over the term of the contract
   to timely furnish the fabric needed by the contractor to make
   the number of trousers ordered by the government, and its
   failure to do so constituted a breach of its implied
   obligation under the contract to deliver fabric in sufficient
   time and quantity to enable the contractor to manufacture the
   specified pairs of trousers by the contract completion date);
   Oxwell, Inc., ASBCA Nos. 27523, 27524, 86-2 BCA  18,967
   (Government failed to provide proper GFP support); Robert J.
   DiDomenico, GSBCA No. 5539, 82-2 BCA  16,093 (Government
   breached its lease contract by delivering the plans for
   building alterations four months late and causing the
   contractor to incur additional costs resulting from
   performance in winter weather and from inability to schedule
   work in the most efficient sequence).  Although the Board has
   ruled that it is without jurisdiction to entertain "pure"
   breach of contract claims, see, The Wessel Company, Inc.,
   supra, Sl. op. at 46, R.C. Swanson Printing and Typesetting
   Company, supra, Sl. op. at 41, it has never expressly held
   that claims relying on the Government's alleged breach of its
   implied duty to cooperate with the Contractor in performance
   of the contract are barred from this forum as well, cf.,
   Stephenson, Inc., supra, Sl. op. at 46-47 (contractor's breach
   of duty allegation considered and rejected by the Board).
   However, it is unnecessary to reach that question in this
   case.  As already mentioned, settled law holds that breach of
   contract damages are not recoverable if the contract itself
   provides a remedy.28  See, Banta Company, supra, Sl. op. at
   31, fn. 40 (citing, Triax-Pacific, A Joint Venture, supra,
   91-2 BCA  23,724).  See also, R.C. Swanson Printing and
   Typesetting Company, GPO BCA 31-90 (February 6, 1992), Sl. op.
   at 46, aff'd Civil Action No. 92-128C (Cl.Ct. October 2,
   1992).  Accord, Dave Hakala, supra, 85-3 BCA  18,382.  In
   this case, the automatic extension of the shipping schedule
   authorized by the "Extension of Schedules" clause, GPO
   Contract Terms, Contract Clauses,  12(c), is the contractual
   remedy so provided for the late delivery of the GFM to the
   Appellant.  Therefore, even if the Board, as a theoretical
   matter, had breach jurisdiction over a failure by the
   Respondent to cooperate with the Appellant in the performance
   of the contract, damages would not lie in this case, in any
   event.  Accordingly, for all of these reasons, the Board
   AFFIRMS the decision of the Contracting Officer and DISMISSES
   the appeal.

   ORDER

   From the foregoing analysis, the Board finds and concludes
   that: (1) the Appellant is not entitled to an equitable
   adjustment for the late delivery of the revised GFM on
   Pamphlet Nos. 1, 19 and 20 under the "Changes" clause of GPO
   Contract Terms; (2) no other provision of the contract
   authorizes such an equitable adjustment; and (3) the automatic
   extension of the shipping schedule allowed by the "Extension
   of Schedules" clause, GPO Contract Terms, which the Appellant
   received, is the exclusive contractual remedy for the delayed
   delivery of the GFM which occurred in this case.  THEREFORE,
   the Contracting Officer's decision rejecting the Appellant's
   claim for reimbursement in the amount of $2,000.00, for the
   Government's delay in the supplying the GFM, is AFFIRMED and
   the appeal is DISMISSED.

It is so Ordered.

November 4, 1994                  STUART M. FOSS
                        Administrative Judge

_______________

    1 During the prehearing telephone conference held on June 14,
    1994, Counsel for the Appellant stated that although the
    Appellant had initially claimed $2,000.00 , it did so only to
    settle the matter.  Since the Contractor's actual loss due to
    the Government delay was $4,020.92, Counsel for the Appellant
    said that the Contractor was now seeking full reimbursement
    for its costs.  See, Report of Prehearing Telephone
    Conference, dated September 2, 1994, p. 3 (RPTC).  In the
    Board's view, the Appellant's assertion of a new legal theory
    of recovery on appeal (compensation for actual delay costs,
    in contrast to the "bottom line" settlement figure given the
    Contracting Officer) does not constitute a new claim
    requiring a final decision from the Contracting Officer
    before the Board can exercise its jurisdiction, see, Shepard
    Printing, GPO BCA 37-92 (January 28, 1994), Sl. op. at 28;
    Epco Associates, GPO BCA 26-93 (November 18, 1993), Decision
    and Order Granting Appellant's Motion Under Rule 1(c) and
    Staying Proceedings Under Rule 1(d), Sl. op. at 3, because it
    is based upon the same operative facts underlying the
    original claim, see, Blaze Construction Company, Inc., IBCA
    No. 2863, 91-3 BCA  24,071, at 120,503 (citing, Placeway
    Construction Corporation v. United States, 910 F.2d 835, 840
    (Fed. Cir. 1990); Trepte Construction Company, ASBCA No.
    38555, 90-1 BCA  22,595, at 113,385-86; Flores Drilling &
    Pump Company, AGBCA No. 82-204-3, 83-1 BCA  16,200, at
    80,484).  Furthermore, despite the different approach taken
    by the Appellant before the Board, the Contracting Officer
    certainly had no misapprehension about the basic factual
    allegations in reaching his decision to deny the claim.  See,
    Contract Cleaning Maintenance, Inc. v. United States, 811
    F.2d 586, 592 (Fed. Cir. 1987); Paragon Energy Corporation v.
    United States, 645 F.2d 966, 976 (Ct.Cl. 1981); Cerberonics,
    Inc. v. United States, 13 Cl.Ct. 415, 418 (1987); Holk
    Development, Inc., ASBCA Nos. 40579, 40609, 90-3 BCA  23,086
    at 115,938 ("Adequate notice" requires a sufficient statement
    "to enable the contracting officer to undertake a meaningful
    review of the claim.").  Moreover, no useful purpose would be
    served by requiring resubmission of the claim to the
    Contracting Officer and asking for his final decision, since
    Counsel for GPO neither objected to the amendment at the
    prehearing conference nor in his brief, the parties have
    already briefed the threshold issue, and besides it is clear
    from the record that whether the Appellant's claim had been
    for $2,000.00, $4,020.92, or 100 times those amounts for that
    matter, the Contracting Officer would still have denied it
    because he was acting on his understanding that the
    "Extension of Schedules" clause in the contract only
    authorized an adjustment of the delivery schedule for a
    Government delay.  See, GPO Contract Terms, Solicitation
    Provisions, Supplemental Specifications, and Contract
    Clauses, GPO Pub. 310.2, Effective December 1, 1987 (Rev.
    9-88), Contract Clauses,  12(c) (Extension of schedules)
    (GPO Contract Terms).  See also, So-Pak-Company, Inc., ASBCA
    No. 38906, 93-3 BCA  26,215, at 130,469 (citing, ACS
    Construction Company, ASBCA No. 365535, 89-1 BCA  21,406;
    Emerson Electric Company, ASBCA No. 31184, 86-2 BCA  18,979;
    cf., Continental Products, Inc., ASBCA No. 45293, 93-2 BCA 
    25,879).  Thus, under the circumstances of this case, which
    shows that the same or related evidence is involved in
    connection with the original claim and the claim as amended
    at the prehearing conference, that there is no prejudice to
    the contracting officer from the Board's consideration of the
    revised claim, and that no useful purpose would be served by
    requiring resubmission of the claim to the Contracting
    Officer, the Board concludes that it has jurisdiction to
    decide the issue presented by the parties.
    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 December 29, 1992.  GPO Instruction
    110.12, Subject: Board of Contract Appeals Rules of Practice
    and Procedure, dated September 17, 1984, Rule 4(a) (Board
    Rules).  It will be referred to hereinafter as the R4 File,
    with an appropriate Tab letter indicated thereafter.  The R4
    File consists of 13 documents identified as Tabs A through M.
    3 By facsimile transmission dated June 3, 1994, the Appellant
    advised the Board that it had elected to have a hearing on
    its appeal.  Board Rules, Rules 8 and 17 through 25.
    However, during the prehearing telephone conference, the
    parties agreed that the Board's decision on the threshold
    issue-whether or not the contract's "Extension of Schedules"
    clause, see, GPO Contract Terms, Contract Clauses,  12(c),
    provided the exclusive remedy available to the Appellant in
    this case?-could be dispositive of the appeal.  See, RPTC,
    pp. 2-3.  Therefore, the Board said that it would reserve
    judgment on whether a hearing was necessary until it had
    decided the threshold question, and directed them to file
    briefs on the question of remedy.  Id., p. 4.
    4 The factual description of this case is based: (a) the
    Appellant's Notice of Appeal, dated November 16, 1992; (b)
    the Appellant's Letter, dated December 14, 1992, stating that
    the Government's delay was the direct cause of its loss of
    $2,000.00 in lost press time; (c) the R4 File; (d) the
    Appellant's Letter, dated January 8, 1993, submitting
    additional information in accordance with Rule 4(b); (e) the
    Respondent's Answer, dated April 28, 1994; and (f) the Report
    of Prehearing Telephone Conference, dated September 2, 1994
    (RPTC).  The facts, which are essentially undisputed, are
    recited here only to the extent necessary for this decision.
    5 Subsequently, the Contractor asked for an additional
    extension to July 29, 1992, because of a delay in the
    delivery of its cover stock, but its request was denied by
    the Contracting Officer (R4 File, Tab C).
    6 The facsimile message contained two blank lines-"Confirm
    Above" and "Not Confirmed"-for the Contracting Officer to
    indicate his approval or disapproval of the requested payment
    (R4 File, Tab D).
    7 As indicated previously, see note 4 supra, the Appellant's
    Letter, dated January 8, 1993, submitted certain additional
    information, namely copies of three facsimile messages it
    sent to the Contracting Officer concerning this contract.
    Specifically, the three messages related to: (a) the
    Appellant's request for an additional day's extension of the
    delivery date on the first eight pamphlets, see note 5 supra;
    (b) the Contractor's request that the shipping date on
    Pamphlet Nos. 19 and 20 be scheduled for September 18, 1992
    (which the Contracting Officer approved); and (c) the
    Appellant's message, dated November 2, 1992, confirming the
    delivery date of November 2, 1992, for the last two
    pamphlets, and informing the Contracting Officer of
    additional costs for extra pages on one of the pamphlets, see
    note 8 infra.  These messages, which were relevant to this
    appeal, were not in the Contracting Officer's R4 File,
    although clearly they should have been included.  (Indeed,
    also missing from the R4 File are copies of the Appellant's
    bid and Purchase Order F-1491.)  While the Board believes
    that their omission was unintentional, it must reaffirm its
    view that: ". . . 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, Universal Printing Company, GPO
    BCA 9-90 (June 22, 1994), Sl. op. at 14, fn. 15 (citing, P.J.
    Dick Contracting, Inc., VABCA No. 3177R-82R, 93-1 BCA 
    25,263; Bethlehem Steel Corporation, ASBCA No. 29459, 86-3
    BCA  19,159).
    8 There is nothing in the record to show on what basis the
    Contracting Officer calculated these contract price
    adjustments.  However, the Board assumes for the purposes of
    this decision, especially insofar as Pamphlet No. 1 is
    concerned, that the Contractor's bid contained a rate for
    additional pages.  See, R4 File, Tab A, p. 8 (Offers).
    9 As in its facsimile message of August 13, 1992, the
    Appellant provided "Confirm Above" and "Not Confirmed" lines
    for the Contracting Officer to indicate his approval or
    disapproval of the requested payment.  See, note 6 supra.
    10 Because the parties agreed to limit this proceeding to the
    "entitlement" question, the Appellant has made no effort to
    prove the merits of its claim, reserving that matter for
    discovery procedures and a hearing if the Board agrees with
    its reading of GPO Contract Terms.  RPTC, p. 3.  See, Board
    Rules, Rules 14, 15 and 17 through 25.
    11 Both parties submitted written briefs setting forth their
    respective positions on the threshold issue in this appeal.
    On July 14, 1994, the Board received the Appellant's Brief
    (App. Brf.)  Similarly, on July 15, 1994, the Board received
    the Respondent's Brief on Entitlement (Res. Brf.).
    Thereafter, on July 29, 1994, the Board received the
    Respondent's Reply Brief on Entitlement (Res. R. Brf.).  The
    Appellant did not file a reply brief.  The Board's
    understanding of the positions of the parties is based on the
    Appellant's Notice of Appeal, the Appellant's letter of
    December 14, 1992, the Respondent's Answer, the formal briefs
    filed by the parties, and the discussions at the prehearing
    telephone conference on June 14, 1994.
    12 The Appellant distinguishes this situation from one where
    there is merely a delay, unaccompanied by any changes in the
    work, in which case the Courts and boards of contract appeals
    leave the contractor to pursue a breach of contract claim
    under the contract.  App. Brf., p. 3 (citing, John Cibinic,
    Jr. and Ralph C. Nash, Jr., Administration of Government
    Contracts, 2d ed. (The George Washington University, 1985),
    pp. 522-24) (hereinafter Cibinic and Nash).
    13 The Board was established by the Public Printer in 1984.
    GPO Instruction 110.10C, Subject: Establishment of the Board
    of Contract Appeals, dated September 17, 1984.  Prior to the
    Board's creation, appeals from decisions of GPO Contracting
    Officers were considered by ad hoc contract appeals boards.
    R.C. Swanson Printing and Typesetting Company, GPO BCA 15-90
    (March 6, 1992), Sl. op. at 28, fn. 30.  While it is the
    Board's policy to follow the holdings of these ad hoc panels
    where applicable and appropriate, it does not regard those
    decisions as legally binding precedent; indeed, the Board
    differentiates between its decisions and the opinions of the
    ad hoc panels by citing the latter as GPOCAB.  See, The
    Wessel Company, Inc., supra, Sl. op. at 25, fn. 25.  See
    also, Sterling Printing, Inc., GPO BCA 20-89 (July 5, 1994)
    (Decision on Motion for Reconsideration), Sl. op. at 10, fn.
    6; Chavis and Chavis Printing, GPO BCA 20-90 (February 6,
    1991), Sl. op. at 9, fn. 9; Stephenson, Inc., GPO BCA 02-88
    (December 20, 1991), Sl. op. at 18, fn. 20.
    14 The Respondent also notes that the Appellant asked for and
    received additional compensation for the changes in the
    number of pages of the publications.  Res. Brf., p. 3, fn. 1
    (citing, R4 File, Tab K).  See, Factual Finding No. 7.
    15 Of course, whether or not such a nexus exists is a
    question of fact which is beyond the scope of this
    proceeding.  However, establishing a causal connection
    between such a delay and any increased costs would be part of
    a claimant's burden of proof on the merits.  See, Banta
    Company, supra, Sl. op. at 35, fn. 44 (citing, Cooper
    Mechanical Contractors and Continental Engineering, IBCA Nos.
    2744-2749, 2692, 2706-2713, 2714, 92-2 BCA  24,821; Gerald
    Miller Construction Company, IBCA No. 2292, 91-2 BCA 
    23,829).
    16 The record on which the Board's decision is based consists
    of: (a) the Appellant's Notice of Appeal, dated November 16,
    1992; (b) the Appellant's Letter, dated December 14, 1992;
    (c) the R4 File; (d) the Appellant's Letter, dated January 8,
    1993, and the additional information enclosed; (e) the
    Respondent's Answer, dated April 28, 1994; (f) the Report of
    Prehearing Telephone Conference, dated September 2, 1994; (g)
    the Appellant's Brief, dated July 14, 1994; (h) the
    Respondent's Brief on Entitlement , dated July 15, 1994; and
    (i) the Respondent's Reply Brief on Entitlement, dated July
    29, 1994.  See, Board Rules, Rule 13(a).
    17 GPO's "Changes" clause provides: "(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.  (2) Method of shipment or packing.  (3)
    Place of delivery.  (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.  (c) The contractor must
    submit any "proposal for adjustment" (hereinafter referred to
    as proposal) under this article within 30 days from the date
    of receipt of the written order.  However, if the Contracting
    Officer decides that the facts justify it, the Contracting
    Officer may receive and act upon a proposal submitted anytime
    before final payment.  (d) If the contractor's proposal
    includes the cost of property made obsolete or excess by the
    change, the Contracting Officer shall have the right to
    prescribe the manner or the disposition of the property.  (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,  4.
    18 To the extent that the Respondent also contends that the
    Appellant's demand for reimbursement is really a disguised
    breach of contract claim which cannot be considered under the
    "Changes" clause, see, R. Brf., p. 1, that argument was
    rejected by the Board in Banta Company.  See, Banta Company,
    supra, Sl. op. at 31, fn. 40, where the Board said: "As a
    rule, breach of contract damages are not recoverable if the
    contract itself provides a remedy.  See, Triax-Pacific, A
    Joint Venture, ASBCA No. 36353, 91-2 BCA  23,724.  However,
    even though the Board has no jurisdiction to hear breach of
    contract claims, it has stated that breach of contract
    damages and contract provisions for extensions of time are
    not mutually exclusive; i.e., in the appropriate forum, the
    fact that the contract includes a provision for extension of
    time to perform does not exclude the possibility that
    recovery may also be had in the form of damages for breach of
    contract.  See, The Wessel Company, Inc., supra, Sl. op. at
    27, fn. 29 (citing, The Kehm Corporation v. United States, 93
    F.Supp. 620, 624-25 (Ct.Cl. 1950)).  The simple holding of
    Wessel Company, another case involving the impact of
    Government delays, is that the Board is not an appropriate
    forum to resolve "pure" breach of contract claims; i.e.,
    breach claims not redressable under a specific contract
    provision.  See, The Wessel Company, Inc., supra, Sl. op. at
    46.]"  See also, R.C. Swanson Printing and Typesetting
    Company, GPO BCA 15-90 (March 6, 1992), Sl. op. at 41.
    19 The total contract price for this work was $950,808.00.
    See, Banta Company, supra, Sl. op. at 2-3.
    20 These steps were found to be reasonable by GPO's Plant
    Planning Division (PPD); indeed, the PPD staff could not
    suggest anything better.  Banta Company, supra, Sl. op. at
    8-9.
    21 The record showed that the revised GFM was two days late,
    for which the contractor claimed combined downtime costs and
    lost paper profits on two presses totalling $51,281.00.  See,
    Banta Company, supra, Sl. op. 7-8, fn. 8.
    22 The OIG had looked at the contractor's claim two ways;
    i.e., under the so-called "specific cost" or "actual cost"
    approach, and under the "total cost" method.  Banta Company,
    supra, Sl. op. at 10.  The OIG auditors preferred the use of
    the "total cost" technique because they thought it best
    preserved the contractor's loss position under the contracts.
    Id., Sl. op. at 11-12, fn. 15.  The contracting officer
    agreed.  Id., Sl. op. at 12, fn. 16.
    23 The key to the Board's opinion on this issue was its
    rejection of the contracting officer's use of the "total
    cost" method to decide the contractor's equitable adjustment
    claim.  The record Banta Company showed that the OIG auditors
    had allowed the claim for downtime expenses resulting from
    the late delivery of the GFM when they examined the
    contractor's evidence under the "actual cost" method.  OIG
    Audit Report, dated October 23, 1990, Jacket No. 245-004,
    Summary of Contractor's Claim and Results of Audit, Specific
    Cost Method, pp. 5 (Idle Resources,  II.A, B), 8
    (Explanatory Notes,   9, 11).  See, GPO Procurement
    Directive 306.2, Subject: Contract Cost Principles and
    Procedures, dated April 1, 1988, p. 22,  25(b)(2) (Idle
    facilities and idle capacity costs) (hereinafter GPO Contract
    Cost Principles).  However, the contractor's separate delay
    claim was completely submerged by the Government's use of the
    "total cost" approach.  Banta Company, supra, Sl. op. at
    41-43.  When the Board rejected the "total cost" technique,
    the contractor's request for an equitable adjustment because
    of the Government's late delivery of the revised camera copy
    resurfaced as an independent item within the overall claim.
    24 The record establishes that the number of text pages in
    Pamphlet No. 18 remained unchanged.  Consequently, the late
    delivery of the GFM for this booklet by the Government was a
    delay, pure and simple.  Under the principles enunciated by
    the Board in Banta Company, any additional costs experienced
    by the Appellant regarding Pamphlet No. 18 would not be
    recoverable under the "Changes" clause, in any case.  Banta
    Company, supra, Sl. op. at 31-32.  Accord, Nello L. Teer, ENG
    BCA No. 4376, 86-3 BCA  19,326.
    25 The core concept in the Government's argument was its
    assumption that reducing the number of printed pages for each
    tax booklet "undoubtedly" lowered the level of production
    effort, because less raw materials would be needed to perform
    the contracts, and thus there was a "dramatic" reduction in
    the Appellant's potential losses.  However, GPO not only
    offered no evidence to support this premise, but to the
    contrary, it  stipulated to facts which tended to show that
    the contractor's level of effort was increased because of the
    changes, and the record failed to disclose any evidence which
    would contradict that stipulation. Banta Company, supra, Sl.
    op. at 52-53.  See also, Universal Printing Company, GPO BCA
    09-90 (June 22, 1994), Sl. op. at 45.  Accord, Celesco
    Industries, ASBCA No. 22251, 79-1 BCA  13,604.  In that
    regard, 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", have observed
    that: "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.  [Emphasis added.]
    26 See, footnote 23 supra.
    27 In the absence of a challenge by the Appellant, or any
    evidence in the record whatsoever to the contrary, the Board
    accepts the Contracting Officer's determination that
    increasing the contract price of Pamphlet No. 1 by $1,790.00,
    and decreasing the contract price for Pamphlet Nos. 19 and 20
    by a total $639.95, for Pamphlet Nos. 19 and 20 (R4 File, Tab
    K), was a reasonable equitable adjustment in this case.
    McDonald & Eudy Printers, Inc., GPO BCA 25-92 (April 11,
    1994), Sl. op. at 24, fn. 20.
    28 See, note 18 supra.