Federal Courthouses
Rent Increases Due to New Space and Growing Energy and Security Costs Require Better Tracking and Management Gao ID: GAO-06-892T June 22, 2006The judiciary pays over $900 million in rent annually to GSA for court-related space, representing a growing proportion of the judiciary's budget. The judiciary's rent payments are deposited into GSA's Federal Buildings Fund (FBF), a revolving fund used to finance GSA's real property services, including the construction and repair of federal facilities under GSA control. In December 2004, the judiciary requested a $483 million dollar permanent, annual rent exemption which GSA denied, saying that it undermined the intent of FBF and that GSA was unlikely to obtain appropriations to replace lost FBF income. GAO reviewed (1) recent trends in the judiciary's rent and space occupied and (2) challenges that the judiciary faces in managing its rent costs.
The federal judiciary's rental obligations to GSA for courthouses have increased from $780 million to $990 million or 27 percent from fiscal years 2000 through 2005, after controlling for inflation--primarily due to a simultaneous net increase in space from 33.6 million to 39.8 million rentable square feet, a 19 percent increase nationwide. Much of the net increase in space was the result of new courthouses that the judiciary has taken occupancy of since 2000. According to the Administrative Office of the U.S. Courts (AOUSC), the judiciary's workload has grown substantially and the number of court staff has doubled since 1985. Shell rent (the building with basic infrastructure) increased proportionately with square footage growth, but operational (utilities and general maintenance) and security costs grew disproportionately higher than square footage due to external factors, such as increasing energy costs and security requirements. Neither GSA nor the judiciary had routinely and comprehensively analyzed the factors causing rent increases, making it more difficult for the judiciary to manage increases. The federal judiciary faces several challenges to managing its rental obligations, including costly new construction requirements, a lack of incentives for efficient space use, and a lack of space allocation criteria for appeals and senior judges. First, building enhancements, such as three separate circulation patterns for judges, prisoners, and the public, and structural and architectural elements make courthouses among the most expensive federal facilities to construct in GSA's inventory, often leading to higher rent payments. Second, the judiciary has begun a rent validation effort intended to monitor GSA rent charges, but it does not address the lack of incentives for efficient space management at the circuit and district levels. An example of the inefficiencies that may result is in the Eastern District of Virginia, where the judiciary paid about $272,000 in 2005 to rent space for an appeals judge in McLean, Virginia, in addition to paying for space designated for that judge in a nearby federal courthouse that the judiciary later used for alternative purposes. Finally, the lack of criteria for assigning courtrooms for appeals and senior judges can contribute to inefficiencies in the amount of space provided, which can result in higher rent payments.
GAO-06-892T, Federal Courthouses: Rent Increases Due to New Space and Growing Energy and Security Costs Require Better Tracking and Management
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Testimony:
Before the Subcommittee on Economic Development, Public Buildings and
Emergency Management, Committee on Transportation and Infrastructure,
House of Representatives:
United States Government Accountability Office:
GAO:
For Release on Delivery Expected at 11:00 a.m. EDT:
Thursday, June 22, 2006:
Federal Courthouses:
Rent Increases Due to New Space and Growing Energy and Security Costs
Require Better Tracking and Management:
Statement of Mark L. Goldstein, Director Physical Infrastructure
Issues:
GAO-06-892T:
GAO Highlights:
Highlights of GAO-06-892T, a testimony before the Subcommittee on
Economic Development, Public Buildings and Emergency Management,
Committee on Transportation and Infrastructure, House of
Representatives.
Why GAO Did This Study:
The judiciary pays over $900 million in rent annually to GSA for court-
related space, representing a growing proportion of the judiciary‘s
budget. The judiciary‘s rent payments are deposited into GSA‘s Federal
Buildings Fund (FBF), a revolving fund used to finance GSA‘s real
property services, including the construction and repair of federal
facilities under GSA control. In December 2004, the judiciary requested
a $483 million dollar permanent, annual rent exemption which GSA
denied, saying that it undermined the intent of FBF and that GSA was
unlikely to obtain appropriations to replace lost FBF income. GAO
reviewed (1) recent trends in the judiciary‘s rent and space occupied
and (2) challenges that the judiciary faces in managing its rent costs.
What GAO Found:
The federal judiciary‘s rental obligations to GSA for courthouses have
increased from $780 million to $990 million or 27 percent from fiscal
years 2000 through 2005, after controlling for inflation”primarily due
to a simultaneous net increase in space from 33.6 million to 39.8
million rentable square feet, a 19 percent increase nationwide. Much of
the net increase in space was the result of new courthouses that the
judiciary has taken occupancy of since 2000. According to the
Administrative Office of the U.S. Courts (AOUSC), the judiciary‘s
workload has grown substantially and the number of court staff has
doubled since 1985. Shell rent (the building with basic infrastructure)
increased proportionately with square footage growth, but operational
(utilities and general maintenance) and security costs grew
disproportionately higher than square footage due to external factors,
such as increasing energy costs and security requirements. Neither GSA
nor the judiciary had routinely and comprehensively analyzed the
factors causing rent increases, making it more difficult for the
judiciary to manage increases.
Figure: The Approximate Share of Judiciary Rent Increases Attributable
to Growth in the Net Square Footage and Other Factors (Fiscal Years
2000 through 2005):
[See PDF for Image]
[End of Figure]
The federal judiciary faces several challenges to managing its rental
obligations, including costly new construction requirements, a lack of
incentives for efficient space use, and a lack of space allocation
criteria for appeals and senior judges. First, building enhancements,
such as three separate circulation patterns for judges, prisoners, and
the public, and structural and architectural elements make courthouses
among the most expensive federal facilities to construct in GSA‘s
inventory, often leading to higher rent payments. Second, the judiciary
has begun a rent validation effort intended to monitor GSA rent
charges, but it does not address the lack of incentives for efficient
space management at the circuit and district levels. An example of the
inefficiencies that may result is in the Eastern District of Virginia,
where the judiciary paid about $272,000 in 2005 to rent space for an
appeals judge in McLean, Virginia, in addition to paying for space
designated for that judge in a nearby federal courthouse that the
judiciary later used for alternative purposes. Finally, the lack of
criteria for assigning courtrooms for appeals and senior judges can
contribute to inefficiencies in the amount of space provided, which can
result in higher rent payments.
What GAO Recommends:
In an associated report, GAO recommended that the judiciary (1) track
rent trends and (2) improve its management of space and associated
costs by providing incentives for efficient use and updating its space
allocation criteria. AOUSC strongly disagreed with our report and said
that it does not believe tracking data recommended by GAO would be
useful. We believe otherwise. AOUSC also said it is already
implementing incentives and updating its criteria, however, the actions
it identified do not fully address our recommendations. GSA generally
agreed with the report.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-892T].
To view the full product, including the scope and methodology, click on
the link above. For more information, contact Mark Goldstein at (202)
512-2834 or goldsteinm@gao.gov.
[End of Section]
Mr. Chairman, Ranking Democratic Member, and Members of the
Subcommittee:
Thank you for the opportunity to testify before you today on our work
related to federal courthouse rents. Since the early 1990s, the General
Services Administration (GSA) and the federal judiciary[Footnote 1]
have undertaken a multibillion dollar courthouse construction
initiative to address what the judiciary has identified as growing
needs. According to the Administrative Office of the U.S. Courts
(AOUSC), the judiciary's workload has grown substantially and the
number of court staff has doubled since 1985. The judiciary pays over
$900 million in rent annually to GSA to occupy court-related space, and
this amount represents a growing proportion of the judiciary's budget.
The rent payments, which by law approximate commercial rates, are
deposited into GSA's Federal Buildings Fund (FBF). With slightly over
20 percent of its budget allocated for rent payments, in December 2004,
the judiciary requested a $483 million permanent, annual exemption from
rent payments to GSA so that according to judiciary officials, the
judiciary would not have to cut personnel to pay the rent. In denying
the judiciary's requested rent exemption, GSA noted that FBF was
designed to encourage efficient space utilization by making agencies
accountable for the space they occupy, and that it is unlikely GSA
could obtain direct appropriations to replace lost FBF income. In June
2005, we testified[Footnote 2] that federal agencies' rent payments
provided a relatively stable, predictable source of revenue for FBF,
but that this revenue has not been sufficient to finance both growing
capital investment needs and the cost of leased space. In fact there
have been several direct appropriations to FBF to cover this funding
gap. We also found that previous rent exemptions, such as the one
requested by the judiciary, hampered GSA's ability to generate
sufficient revenue for needed capital investment. You asked us to
review the judiciary's courthouse rent costs.
Today my testimony will discuss (1) recent trends in the judiciary's
rent payments and square footage occupied; and (2) challenges that the
judiciary faces in managing its rent costs. My statement is based on
our report that will also be released today.[Footnote 3] In summary, we
found the following:
* About two-thirds of the judiciary's $210 million rent increase from
fiscal years 2000 through 2005 is attributable to a 19 percent increase
in net square footage. The remaining increase is attributable to
disproportionately high increases in security and operating costs. We
also found that neither the judiciary nor GSA had routinely and
comprehensively analyzed the factors influencing the rent increases. In
the report released with this testimony, we recommended that the
judiciary begin tracking and analyzing rent trends in order to improve
its understanding and ability to manage its rent costs. The judiciary
agreed that tracking trends is necessary, but said that the specific
types of data we recommended would not be particularly useful for
program planning, management, or budgeting purposes.
* The judiciary faces several challenges to managing its rent costs
including costly architectural and structural requirements for modern
courthouses, a lack of incentives for efficient space use, and a lack
of space allocation criteria for appeals and senior district judges.
AOUSC also identified several challenges in addition to the ones we
identified, including statutorily designated places of holding court,
the benefits to GSA and the Federal Buildings Fund of backfilling
courthouses with other courts, and inconsistencies in the funding
stream for courthouse construction projects. In our report released
with this testimony, we recommended that the judiciary establish
incentives to encourage local decision makers to use space efficiently
and improve its space allocation criteria in a number of ways. The
judiciary disagreed that additional space allocation criteria are
needed for appeals courts and senior judges, and said that it has
already started updating its space allocation criteria related to
technological advancements and plans to consider other changes in the
future.
Background:
Federal agencies, including the judiciary, that operate in facilities
under the control and custody of GSA are required to pay rent for the
space they occupy. Rent payments, which by law must approximate
commercial rates, are deposited into the FBF, which is a revolving fund
that GSA uses to provide a range of real property services, including
maintenance, repairs, and alterations, to space occupied by federal
agencies. GSA, through FBF, encourages federal agencies to be
accountable for the space they use by requiring them to budget and pay
for their own space requirements. A committee report accompanying the
enactment of FBF noted that because each agency would have to budget
for its space needs, doing so would promote more efficient and
economical use of space by government agencies.[Footnote 4] The
judiciary's rent payments represent roughly 15 percent of all rent
payments made into FBF, making it one of the two largest
contributors.[Footnote 5]
On the basis of a rent pricing policy introduced in the late 1990s, the
rent GSA charges is composed principally of shell rent, operating
expenses, tenant improvements, and security costs. These components
account for over 96 percent of the judiciary's rent bill payments in
fiscal year 2005.
* The shell rent represents the cost of using the structure, base
building systems, concrete floor, and basic wall and ceiling finishes
and is the largest rent component, representing 60 percent of the
judiciary's annual rent bill payments in fiscal year 2005.[Footnote 6]
For most government-owned properties, shell rent does not represent the
actual costs, but is based instead on comparable private sector
commercial rents in the local commercial market.
* Tenant improvements reflect customizing space for that tenant and can
include private offices, special type spaces, floor covering, doors,
and wood finishes. The tenant is responsible for deciding how to finish
the space beyond some basic minimum standards and thus has control over
much of the cost. GSA officials have said that the judiciary has the
highest costs for tenant improvements in its inventory because of the
level of finishes needed in federal courthouses. Unlike the other rent
components, tenant improvement costs are removed from the rent bill
once the tenant has completely paid for them.
* Operating costs--which cover cleaning; general maintenance; and
heating, air conditioning, and other utilities--are set as part of the
market appraisal for the shell rent in owned space. But unlike the
shell rent, operating costs are adjusted annually for inflation in
between appraisals.
* Until fiscal year 2005, the judiciary paid Federal Protective Service
(FPS) security costs to GSA as part of its rent payment. Starting in
fiscal year 2005, however, the judiciary began paying these security
costs directly to the Department of Homeland Security (DHS) after FPS
was transferred to that department. However, since FPS security costs
still exist, and they were an important part of rent for all of the
other years we analyzed, we included these costs as if they were still
part of annual rent bill payments for fiscal year 2005.
* Rent is also composed of several other components, including fees for
parking, building joint use, antennas, and GSA's Public Buildings
Service. These other components comprised about 4 percent of the
judiciary's entire rent bill in fiscal year 2005.
The Judicial Conference of the United States (Judicial Conference) is
the judiciary's principal policy making body. The Judicial Conference
works in coordination with AOUSC, which is responsible for
administering the federal judiciary's budget as well as performing
other programmatic and administrative functions, such as paying the
judiciary's rent bill from its annual appropriations from Congress.
Each circuit has a judicial council, which is composed of federal
judges in that circuit, and the council has the authority to determine
the need for all space accommodation within its circuit. As such, the
district, bankruptcy, and appeals courts occupy space in courthouses or
lease space in other federal or private office buildings. The district
courts are the trial courts of the federal court system, housing both
district and magistrate judges. They occupy the most space within the
federal judiciary. The district courts have jurisdiction to hear nearly
all categories of federal cases, including both civil and criminal
matters. The federal judiciary has exclusive jurisdiction over
bankruptcy cases, which are overseen by bankruptcy judges. The court of
appeals from each circuit hears appeals from the district courts
located within its boundaries, as well as appeals from decisions of
federal administrative agencies. Figure 1 illustrates the rentable
square feet distribution within the federal judiciary.
Figure 1: Space Distribution within the Federal Judiciary in Fiscal
Year 2005:
[See PDF for image]
Note: The remaining space is composed of AOUSC, the Federal Public
Defender's Office, and other specialized federal courts.
[End of figure]
Increases in Square Footage and Operating and Security Costs have
Driven Increases in the Judiciary's Rent Bill from Fiscal Years 2000
through 2005:
The federal judiciary's rental obligations for federally owned and
leased space have steadily risen from $780 million to $990 million, or
27 percent from fiscal years 2000 through 2005, after controlling for
inflation using the Gross Domestic Product price index. During this
period, the judiciary had a net increase in the amount of space it
occupies, from 33.6 million to 39.8 million rentable square feet, which
is a 19 percent increase nationwide. About two-thirds of the rent
increase is attributable to this increase in square footage. Among the
components of rent, shell (the building with basic infrastructure) grew
proportionately with the amount of net space added--about 19 percent.
However, increases in operating costs (driven by increases in energy
costs) and security costs grew disproportionately higher than the
percentage of net space added, thus contributing to the overall
increase in rent (see figure 2). The costs of tenant improvements
(finishes such as carpeting) increased at a slower rate than the amount
of net space added. AOUSC disagreed with our methods for attributing
costs to the judiciary's net growth in square footage. We continue to
believe that our methods are sound.
Figure 2: The Approximate Share of Judiciary Rent Increases
Attributable to the Net Growth in Square Footage and Other Factors
(Fiscal Years 2000 through 2005):
[See PDF for image]
[End of figure]
Square footage and total rent growth occurred in all years, circuits,
and courts (see figure 3). The judiciary's rent increases have outpaced
those of other agencies located in GSA space, largely because the
federal judiciary's square footage is growing faster than that of other
agencies. However, the rate of operating cost growth was similar to
that experienced by other agencies.[Footnote 7]
Figure 3: Percentage Net Change in Square Footage and Major Rent Bill
Components, by Judicial Circuit, Fiscal Years 2000 through 2005:
[See PDF for image]
Note: The Federal and District of Columbia circuits were included in
the aggregate statistics but are not listed in the map.
[End of figure]
Much of the judiciary's recent growth in net square footage was caused
by the construction of new courthouses. New courthouses represent about
8.8 million rentable square feet of new space that the judiciary has
taken occupancy of since fiscal year 1998 (a larger timeframe than our
rent trend data). According to judiciary officials, much of the
judiciary's growth and accompanying space-related needs have been the
result of elevating workloads, such as increases experienced in civil
case filings. The judiciary's courthouse construction effort may
continue. Before it imposed a moratorium in 2005, postponing new
courthouse construction projects for two years, the judiciary indicated
that it had 35 additional courthouse construction projects planned for
fiscal years 2005 through 2009, estimated to cost billions of dollars.
According to AOUSC, these projects will be subject to the judiciary's
new asset management planning process that will consider renovation and
other ways to limit new construction. As of May 2006, no final
decisions had been made.
We found that neither the judiciary nor GSA had routinely and
comprehensively analyzed the factors influencing the rent increases.
This information could help the judiciary better understand the reasons
behind its rent increases, make more informed space allocation
decisions in the future, and identify errors in GSA's billing.
Furthermore, the lack of a full understanding of the reasons for
increases in the judiciary rent, in our view, contributed to growing
hostility between the judiciary and GSA. Conversely, GSA's lack of full
understanding of the reasons for the rent increases left it unable to
justify them to the judiciary and other stakeholders, such as Congress.
Judiciary Faces a Number of Challenges but Could Take Actions to Better
Manage Its Future Rent Payments:
The federal judiciary faces several challenges to managing its rent
costs including costly new construction requirements, a lack of
incentives for efficient space use, and a lack of space allocation
criteria for appeals and senior district judges. First, modern
courthouses require structural and architectural elements that make
them among the most costly types of federal space to construct. Chief
among these elements are the three separate circulation patterns for
judges, prisoners, and the public that the U.S. Marshals Service
requires for security (see figure 4). These construction costs
necessitate rental rates under GSA's pricing policy that are more
expensive than the highest-quality office space in some markets,
including Denver, Colorado; Phoenix, Arizona; and Seattle, Washington.
This necessitates GSA using an approach for calculating rent charges
that is based on the costs to construct the building--known as return
on investment pricing--instead of an appraisal. The judiciary's policy
of providing one courtroom per district judge sets the number of
courtrooms needed in new federal courthouses and adds space
requirements, consequently increasing rent payments.
Figure 4: Sample Courtroom and Associated Support Spaces That Were
Based on Design Guide Criteria:
[See PDF for image]
[End of figure]
The judiciary has initiated a rent validation effort, but it does not
address the lack of incentives for efficient space use at the circuit
and district levels. Because rent is paid centrally by AOUSC, circuits
and districts have few incentives to efficiently manage their space. An
example of the inefficiencies that may result is in the Eastern
District of Virginia, where the judiciary paid about $272,000 in 2005
to rent 4,600 square feet of office space for an appeals judge in
McLean, Virginia, in addition to paying for 4,300 square feet of
chamber space originally designated for that judge in the Albert V.
Bryan U.S. Courthouse in nearby Alexandria, Virginia. According to
AOUSC, the judiciary has subsequently pursued alternative uses for this
chamber space. During site visits, we observed multiple instances of
unused or unassigned courtrooms, chambers, and support spaces. Although
planning and building for future needs may limit alternative uses of
space until it is occupied, some of this underutilization is the result
of outdated criteria, which stipulated the existence of support areas,
such as libraries, that in some cases are now rarely used. In most
cases, this was because judicial officers are increasingly turning to
electronic sources and research and keeping the limited number of books
they need in their chambers. However, since the Design Guide provides
space for law libraries, the districts we visited all had them (see
figure 5).
Figure 5: Law Library in the Evo A. Deconcini Courthouse in Tucson,
Arizona:
[See PDF for image]
[End of figure]
Assigning space to appeals courts and senior district judges poses
challenges due to a lack of criteria, which can lead to variation and
inefficiencies and, thus, higher rent. Although the appeals court is
required by law to hold court in specific locations, the statute does
not indicate how much space it should occupy. For example, the
judiciary plans to increase the space the appeals courts occupy by
taking over former district courthouses in Richmond, Virginia, and
Seattle, Washington, for appeals court use, even though the appeals
courts conduct court there once a month or less. Circuit and district
officials said that national criteria for managing the space allocated
to the appeals courts and senior district judges could help limit the
space assigned to them. In commenting on the report associated with
this testimony, AOUSC also identified several challenges in addition to
the ones we identified that we subsequently incorporated into the
report but did not evaluate. These included statutorily designated
places of holding court, the benefits to GSA and the Federal Buildings
Fund in backfilling courthouses with other courts, and inconsistencies
in the funding stream for courthouse construction projects.
Recommendations:
We made the following five recommendations to the judiciary in our
report associated with this testimony[Footnote 8] in order to help the
federal judiciary better understand and manage rent costs:
1. Work with GSA to track rent and square footage trend data on an
annual basis for the following factors:
* rent component (shell rent, operations, tenant improvements, and
other costs) and security (paid to the Department of Homeland
Security);
* judicial function (district, appeals, and bankruptcy);
* rentable square footage; and:
* geographic location (circuit and district levels).
This data will allow the judiciary to create a better national
understanding of the effect that local space management decisions have
on rent and to identify any mistakes in GSA data.
2. Work with the Judicial Conference of the United States to improve
the way it manages its space and associated rent costs.
* Create incentives for districts/circuits to manage space more
efficiently. These incentives could take several forms, such as a pilot
project that that charges rent to circuits and/or districts to
encourage more efficient space usage.
* Revise the Design Guide to establish criteria for the number of
appeals courtrooms and chambers and the space allocated for senior
district judges and make additional improvements to space allocation
standards related to technological advancements (e.g., libraries, court
reporter space, and staff efficiency due to technology) and decrease
requirements where appropriate.
Agency Comments:
We provided a draft of the report that is being released today[Footnote
9] to GSA and AOUSC for official review and comment and received
written comments from both. GSA agreed with the thrust of the report
and concurred with our recommendations, but expressed one concern. GSA
felt it was more aware of the reasons for rent increases than our draft
portrayed. In commenting on the report associated with this testimony,
AOUSC said that it does not believe tracking the data recommended by
GAO would be useful--we disagree with this assessment. AOUSC also said
it is already implementing incentives and updating its criteria,
however the actions it identified do not fully address our
recommendations. For a more thorough discussion of the agency comments,
see the report associated with this testimony.[Footnote 10]
Scope and Methodology:
We conducted our work from May 2005 to May 2006 in accordance with
generally accepted government auditing standards. During our work, we
analyzed nationwide judiciary rent data generated from GSA's billing
data, reviewed laws and the regulation related to FBF and GSA's rent
pricing process and policies, and reviewed the U.S. Courts Design Guide
and other judiciary rent planning documents. Additionally, we conducted
site visits at federal courthouses in the following districts: Arizona,
Eastern Virginia, Maryland, Nebraska, Rhode Island, and Western
Washington. We selected Arizona, Nebraska, Rhode Island, and Western
Washington because they were in districts that experienced large
overall rent increases from fiscal years 2000 through 2005 and were
geographically dispersed. We also visited Maryland and Eastern Virginia
court facilities while we were designing this audit and included them
in the review because they contained a new courthouse, a renovated
courthouse, and a courthouse that was targeted for replacement. The
findings from these courthouse visits can not be generalized to the
population of federal courthouses nationwide. We interviewed district,
magistrate, and bankruptcy judges; officials from the AOUSC, which is
the judiciary's administrative agency; clerks, circuit executives, and
other representatives from U.S. circuit and district courts with
authority over space and facilities; GSA officials in headquarters and
the regions; and other real property management experts. We determined
that the rent data were sufficiently reliable for the purposes of our
review.
Mr. Chairman and members of the Subcommittee, this concludes my
prepared statement, I would be pleased to respond to any questions that
you or the other Members of the Subcommittee may have.
GAO Contacts and Staff Acknowledgements:
For further information about this testimony, please contact me at
(202) 512-2834 or goldsteinm@gao.gov. Keith Cunningham, Randy DeLeon,
Bess Eisenstadt, Brandon Haller, Grant Mallie, Susan Michal-Smith,
Joshua Ormond, Elizabeth Repko, David Sausville, and Gary Stofko made
key contributions to this statement.
FOOTNOTES
[1] The federal judiciary is comprised of 94 judicial districts
organized around state boundaries and grouped into 12 regional
circuits, each of which has a United States Court of Appeals. There is
also a 13th Circuit, the Court of Appeals for the Federal Circuit,
which has nationwide jurisdiction to hear appeals in specialized cases,
such as those involving patent laws and cases decided by the Court of
International Trade and the Court of Federal Claims.
[2] GAO, Courthouse Construction: Overview of Previous and Ongoing
Work, GAO-05-838T (Washington, D.C.: June 21, 2005).
[3] GAO, Federal Courthouses: Rent Increases Due to New Space and
Growing Energy and Security Costs Require Better Tracking and
Management , GAO-06-613 (Washington, D.C.: June 22, 2006).
[4] H.R. Rep. No. 92-989, at 3 & 4 (1972).
[5] The other is the Department of Justice.
[6] According to GSA, it uses shell rent proceeds to finance the cost
of acquiring, repairing, altering, and operating buildings under the
custody and control of GSA.
[7] Interagency comparisons regarding security costs are not possible
since the methods used to secure federal courthouses differ from other
agencies.
[8] GAO-06-613.
[9] GAO-06-613.
[10] GAO-06-613.
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