We specifically requested comment on whether other costs of a particular transaction should be included as allowable costs and what criteria should be used to determine the costs to be included. As I mentioned earlier, the statute directs us to consider the incremental cost of a particular transaction.
There is no single, generally accepted definition of the term “incremental cost,” as it applies to a particular transaction, so arriving at a definition was challenging. The incremental cost of a particular transaction could be interpreted to be the same as the marginal cost of that transaction.