Voting members present: Marlys Amundson, Lindsay Andrews, Lety Cavazos, Tess Collins, Grace Doleshel, Jillian Gregg, Kimberly Hannigan-Downs, Keith Jayawickrama, Cinamon Moffet, Jacob Putney, Shelly Signs, Brandon Trelstad, Beth Filar Williams
Voting members absent: Leela Magdaleno
Guests present: Nahuel Guiata, Maddie Moyano
C3 Membership Update – looking for recommendations for representatives from ROTC and Engineering
Update on transition to Standing Committee, proposed standing rules – work continues.
Report on charging carbon offsets to grants – Ed Dever
(From Ed Dever),
The guidance I got was that carbon offsets for air travel were not permissible under a couple sections of the Electronic Code of Federal Regulations (e-CFR) as described below.
As noted on the call, I found the UCLA carbon offset program also noted that it was not possible to charge offsets to federal grants and contracts. They state in their FAQ:
Are there any exemptions to the fee?
Yes, grant funded travel is currently exempt from the fee due to prohibitions against using certain grant funds for administrative taxes or fees. Air travel related to study abroad programs is also not included, nor are charter flights for UCLA Athletics teams.
Having said this, I think the National Science Foundation is beginning to think about allowability of carbon offsets. I'll keep my ear to the ground on this. I found my program manager broadly sympathetic, but change is slow.
You can find the e-CFR at:
The specific accounting issues as described to me follow. The numbers 200.475 and 200.403 refer to sections in the e-CFR. As mentioned on the call, I tried to argue that the costs are reasonable and necessary for the performance of the federal award, but didn't get anywhere.
If the offset is a voluntary charge that increases the overall cost to the award, it is unallowable as a direct cost. It would be similar to voluntary travel insurance or upgrades for comfort. If you are specifically talking about air travel, the Uniform Guidance is pretty straight-forward: 200.475(e) Commercial air travel. (1) Airfare costs in excess of the basic least expensive unrestricted accommodations class offered by commercial airlines are unallowable except when such accommodations would:
(i) Require circuitous routing;
(ii) Require travel during unreasonable hours;
(iii) Excessively prolong travel;
(iv) Result in additional costs that would offset the transportation savings; or
(v) Offer accommodations not reasonably adequate for the traveler's medical needs. The non-Federal entity must justify and document these conditions on a case-by-case basis in order for the use of first-class or business-class airfare to be allowable in such cases.
In addition to the UG section on travel, I don’t think they fit even the most basic qualifiers of allowable costs, mainly parts a and b below §200.403
Factors affecting allowability of costs.
Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards:
(a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
(b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
(c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
(d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
(e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
(f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also §200.306(b).
(g) Be adequately documented. See also §§200.300 through 200.309 of this part.
(h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to §200.308(e)(3).
Path to Carbon Neutrality (February 25) presentation