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projects and transmission facilities, the Secretary of Interior issued 5.0. 2929. Guidelines for the implementation of 5.0. 2929 pertained to replacements and additions, are as follows: "Replacements and additions. The interest rates for all new investment in replacements and additions, as shown in the capital plant accounts of the constructing agency, in reservoir projects or units, or separable power features thereof, or in system transmission facilities shall be determined in accordance with these uidelines reoardless of when construction of the original project or facility was started." Underscoring supplied. Notwithstanding the above, the Commissioner of Reclamation issued a directive stating that CRSP was exempt from the requirements of 5.0. 2929. Accordingly, the region computes interest on replacements and additions on CRSP, based on authorized project rates rather than on the rate formula set forth by 5.0. 2929. In discussing this issue with regional officials, we were advised that the Com mis- sioner's directive has not been reviewed by the Departmental Office of the Solicitor. In view of the objective of 5.0. 2929 to more closely reflect current interest rates and the significant dollar impact involved, it is our opinion that the Commissioner's directive should be subjected to the Solicitor's review to ensure conformity with 5.0. 2929. Our analysis of the PRS also disclosed that approximately $185 million of reimburs- able participating project costs were not included in the base used to establish the proposed power rates. Reimbursable participating project costs used in the PRS were those published in the 21st annual report on CRSP covering the period ending September 30, 1977. Updated data containing the increased $185 million for the year ending September 30, 1978, was available in January 1979, which was still several months before the power rate increase brochure was released for customer comment. 23