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    How should the addition of a natural gas line be considered - renovation or new construction?


    10 USC 2801, Scope of chapter; definitions, defines military construction as “any construction, development, conversion, or extension of any kind carried out with respect to a military installation.”


    10 USC 2802 – Military construction projects, state that military construction projects include “… (3) acquisition and installation of equipment and appurtenances integral to the project; (4) acquisition and installation of supporting facilities (including utilities) and appurtenances incident to the project.”


    10 USC 2811, Repair of Facilities, defines a repair project as a “project to restore a real property facility, system, or component to such a condition that it may effectively be used for its designated functional purpose.”


    Per DA Pam 420-11, Project Definition and Work Classification, para 1.6 a (1) states “When repairing a facility, the components of the facility may be repaired by replacement, and the replacement can be up to current standards or codes. For example, heating, ventilation, and air conditioning (HVAC) equipment can be repaired by replacement, can be state-of-the-art, and provide for more capacity than the original unit due to increased demand/standards. Interior rearrangements (except for load-bearing walls) and restoration of an existing facility to allow for effective use of existing space or to meet current building code requirements (for example, accessibility, health, safety, or environmental) may be included as repair” and para 1.6 a (5) states “Repair. Repair does not include increases in quantities of components nor extension of utilities or protective systems to areas not previously served for functional reasons or to meet codes or standards, when the condition of the systems and components do not support calling a facility as failed or failing.”


    The question leads me to believe that the work classification of the project is repair.  If that is the case, replacement of the existing systems with the natural gas water heater and boiler would be considered repair.  My opinion however based on the statutes and DA Pam 420-22 para 1.6 a (5) extension of a natural gas line that does not currently exist would be construction.  It is the Garrison’s DPW assisted by the Garrison Legal office to determine the work classification.


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