Federal Real Property
DHS Has Made Progress, but Additional Actions Are Needed to Address Real Property Management and Security Challenges Gao ID: GAO-07-658 June 22, 2007The Department of Homeland Security (DHS) has a large, diverse portfolio of property it uses to carry out its mission. GAO's objectives were to (1) describe DHS's real property portfolio; (2) determine what challenges, if any, DHS faces in managing real property and what actions it has taken in response to the administration's real property initiative; (3) determine what challenges DHS and the General Services Administration (GSA) face in consolidating DHS's Washington, D.C. headquarters; and (4) describe actions DHS has taken to help ensure the security of its facilities. GAO reviewed documents and interviewed officials from DHS, GSA, and other stakeholders, including the National Capital Planning Commission (NCPC) and the District of Columbia (D.C.).
DHS's 10 major organizational components have a portfolio that includes more than 27,000 owned or leased buildings and structures totaling about 78 million square feet. About 72 percent of DHS real property is federally owned, while about 28 percent of DHS real property is federally leased. The U.S. Coast Guard has the majority of DHS real property, accounting for 69 percent of its buildings and about 41 percent of its square footage. DHS faces challenges but has made progress toward addressing them in response to the administration's real property management initiative. One major challenge relates to DHS being a new federal department that combined 22 existing agencies, which has made the development of a cohesive approach to real property management a significant undertaking. On the administration's scorecard for real property management, DHS has achieved a "yellow" status, which indicates progress in strategically managing real property by, for example, designating a senior real property officer and developing an OMB-approved asset management plan. However, DHS could do more to link its capital decision-making practices to its real property initiatives. Consolidating DHS's Washington, D.C., area locations will be challenging because of the costs involved, estimated to be at least $3.26 billion, and stakeholders' concerns about the redevelopment of the West Campus of St. Elizabeths Hospital-- DHS's preferred location--which is under the control of GSA and is a National Historic Landmark District. DHS believes that by consolidating most of its headquarters operations, greater efficiencies would result, its mission would be better integrated, and security of the facilities could be better managed. DHS has testified that an estimated $1 billion would be saved over 30 years through the consolidation, although a revised analysis estimates cost savings at $743 million. However, this savings analysis does not (1) use actual and projected leasing costs for locations where DHS is currently housed, (2) include DHS costs of $1.32 billion to develop the site, and (3) examine a range of square footage alternatives. A more comprehensive analysis would improve transparency and help key stakeholders, including Congress, make more informed decisions about the consolidation. Also, several key stakeholders are concerned about compliance with historic preservation and environmental laws and the effect the project will have on the local community, although some community leaders support it. In July 2007, GSA plans to issue a draft Master Plan for stakeholder review that, according to GSA, will address these concerns. In recent years, DHS has taken actions intended to improve the security of its facilities, but its efforts fall short in certain key areas. DHS has designated a Chief Security Officer for the department and has established a Chief Security Officer Council to evaluate security issues. However, most DHS components have not fully implemented risk management for facility protection, which DHS has advocated for other agencies, nor has DHS developed a physical security plan, as required by Homeland Security Presidential Directive Number 7 (HSPD-7).
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-07-658, Federal Real Property: DHS Has Made Progress, but Additional Actions Are Needed to Address Real Property Management and Security Challenges
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Report to the Ranking Member, Committee on Homeland Security and
Governmental Affairs, U.S. Senate:
United States Government Accountability Office:
GAO:
June 2007:
Federal Real Property:
DHS Has Made Progress, but Additional Actions Are Needed to Address
Real Property Management and Security Challenges:
GAO-07-658:
GAO Highlights:
Highlights of GAO-07-658, a report to the Ranking Member, Committee on
Homeland Security and Governmental Affairs, U.S. Senate
Why GAO Did This Study:
The Department of Homeland Security (DHS) has a large, diverse
portfolio of property it uses to carry out its mission. GAO‘s
objectives were to (1) describe DHS‘s real property portfolio; (2)
determine what challenges, if any, DHS faces in managing real property
and what actions it has taken in response to the administration‘s real
property initiative; (3) determine what challenges DHS and the General
Services Administration (GSA) face in consolidating DHS‘s Washington,
D.C. headquarters; and (4) describe actions DHS has taken to help
ensure the security of its facilities. GAO reviewed documents and
interviewed officials from DHS, GSA, and other stakeholders, including
the National Capital Planning Commission (NCPC) and the District of
Columbia (D.C.)
What GAO Found:
DHS‘s 10 major organizational components have a portfolio that includes
more than 27,000 owned or leased buildings and structures totaling
about 78 million square feet. About 72 percent of DHS real property is
federally owned, while about 28 percent of DHS real property is
federally leased. The U.S. Coast Guard has the majority of DHS real
property, accounting for 69 percent of its buildings and about 41
percent of its square footage. DHS faces challenges but has made
progress toward addressing them in response to the administration‘s
real property management initiative. One major challenge relates to DHS
being a new federal department that combined 22 existing agencies,
which has made the development of a cohesive approach to real property
management a significant undertaking. On the administration‘s scorecard
for real property management, DHS has achieved a ’yellow“ status, which
indicates progress in strategically managing real property by, for
example, designating a senior real property officer and developing an
OMB-approved asset management plan. However, DHS could do more to link
its capital decision-making practices to its real property initiatives.
Consolidating DHS‘s Washington, D.C., area locations will be
challenging because of the costs involved, estimated to be at least
$3.26 billion, and stakeholders‘ concerns about the redevelopment of
the West Campus of St. Elizabeths Hospital” DHS‘s preferred
location”which is under the control of GSA and is a National Historic
Landmark District. DHS believes that by consolidating most of its
headquarters operations, greater efficiencies would result, its mission
would be better integrated, and security of the facilities could be
better managed. DHS has testified that an estimated $1 billion would be
saved over 30 years through the consolidation, although a revised
analysis estimates cost savings at $743 million. However, this savings
analysis does not (1) use actual and projected leasing costs for
locations where DHS is currently housed, (2) include DHS costs of $1.32
billion to develop the site, and (3) examine a range of square footage
alternatives. A more comprehensive analysis would improve transparency
and help key stakeholders, including Congress, make more informed
decisions about the consolidation. Also, several key stakeholders are
concerned about compliance with historic preservation and environmental
laws and the effect the project will have on the local community,
although some community leaders support it. In July 2007, GSA plans to
issue a draft Master Plan for stakeholder review that, according to
GSA, will address these concerns.
In recent years, DHS has taken actions intended to improve the security
of its facilities, but its efforts fall short in certain key areas. DHS
has designated a Chief Security Officer for the department and has
established a Chief Security Officer Council to evaluate security
issues. However, most DHS components have not fully implemented risk
management for facility protection, which DHS has advocated for other
agencies, nor has DHS developed a physical security plan, as required
by HSPD-7.
What GAO Recommends:
GAO recommends that DHS (1) use capital planning principles to link its
capital needs with its asset management plan and (2) develop a physical
security plan. GAO also recommends that DHS and GSA (3) develop a more
comprehensive analysis of the costs to the government as a whole for
DHS‘s headquarters consolidation. DHS agreed with the first two
recommendations. GSA did not agree with the third recommendation, while
DHS partially agreed. GAO maintains that such an analysis is needed.
GAO also obtained comments from other stakeholders.
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-658].
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]
Contents:
Letter:
Results in Brief:
Background:
DHS Has a Large and Diverse Real Property Portfolio:
DHS Faces Several Challenges Managing Real Property but Has Made
Progress Addressing Them:
DHS Headquarters Consolidation Faces Challenges Related to Its Cost and
Stakeholder Concerns:
DHS Has Taken Actions Intended to Improve the Security of Its
Facilities, but Its Efforts Are Lacking in Certain Key Areas:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Evaluation of DHS and GSA Comments:
Evaluation of the D.C. Office of Planning Comments:
Evaluation of NCPC Comments:
Evaluation of the Advisory Council on Historic Preservation Comments:
Evaluation of U. S. Commission of Fine Arts Comments:
Appendix I: Scope and Methodology:
Appendix II: FRPC Inventory Data Elements and Descriptions:
Appendix III: Comments from the Department of Homeland Security:
GAO comments:
Appendix IV: Comments from the General Services Administration:
GAO Comments:
Appendix V: Comments from the District of Columbia Office of Planning:
Appendix VI: Comments from the National Capital Planning Commission:
Appendix VII: Comments from the Advisory Council on Historic
Preservation:
Appendix VIII: Comments from the U.S. Commission of Fine Arts:
Appendix IX: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: DHS Real Property Profile by Component:
Table 2: DHS's Implementation of OMB's Real Property Initiative:
Table 3: DHS Real Property Housing Scenarios for the Washington, D.C.,
Area:
Table 4: Preliminary Estimate of the Cost to Develop the St. Elizabeths
Site:
Figures:
Figure 1: Profile of DHS's Real Property Portfolio:
Figure 2: Percentage of Square Footage across DHS Components (Owned and
Leased):
Figure 3: Building-Usage Types across DHS:
Figure 4: DHS Real Property Square Footage by State:
Figure 5: DHS's Real Property Organization:
Figure 6: The Administration Building on the West Campus of St.
Elizabeths:
Figure 7: View from St. Elizabeths West Campus Looking North:
Figure 8: GSA's Proposed St. Elizabeths Standard Development Schedule:
Abbreviations:
AMP: asset management plan:
CAO: Chief Administrative Officer:
CIS: Citizenship and Immigration Service:
CBP: Customs and Border Protection:
DDOT: District Department of Transportation:
DO: Departmental Offices:
DHS: Department of Homeland Security:
FEMA: Federal Emergency Management Agency:
FLETC: Federal Law Enforcement Training Center:
FPS: Federal Protective Service:
FRPC: Federal Real Property Council:
GSA: General Services Administration:
HSPD-7: Homeland Security Presidential Directive Number 7:
INS: Immigration and Naturalization Service:
ICE: Immigration and Customs Enforcement:
ISC: Interagency Security Committee:
NCPC: National Capital Planning Commission:
NEPA: National Environmental Policy Act:
NHPA: National Historic Preservation Act:
NTHP: National Trust for Historic Preservation:
OMB: Office of Management and Budget:
RPMC: Real Property Management Committee:
S&T: Directorate for Science and Technology:
SRPO: Senior Real Property Officer:
TAPS: The Automated Prospectus System:
TSA: Transportation Security Administration:
USSS: U.S. Secret Service:
United States Government Accountability Office:
Washington, DC 20548:
June 22, 2007:
The Honorable Susan Collins:
Ranking Member:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
Dear Senator Collins:
The Homeland Security Act of 2002 combined 22 federal agencies
specializing in various disciplines--such as law enforcement, border
security, biological research, computer security, and disaster
mitigation--into the Department of Homeland Security (DHS) to bring a
central focus to the government's efforts to prevent and respond to
terrorist threats. DHS is now the third largest federal agency, with an
estimated 180,000 employees and a budget authority of $42.8 billion for
fiscal year 2007. Much of DHS is housed in facilities managed by the
General Services Administration (GSA), including both government-owned
property and space GSA leases from the private sector. The Federal
Protective Service (FPS), which is located within DHS, protects GSA
buildings where DHS is a tenant, while DHS components are responsible
for protecting federal buildings under DHS's control that FPS does not
protect.
We have found over the years that many federal agencies face long-
standing challenges involving excess and underutilized property,
deteriorating facilities, unreliable property data, a heavy reliance on
costly leasing, and facility protection in the post-September 11
environment. These findings led to our designation, in January 2003, of
real property management as a high-risk area.[Footnote 1] In response
to our high-risk designation, the administration added a real property
initiative to the President's Management Agenda; and the President
issued Executive Order 13327, which implements the real property
initiative by outlining several requirements intended to have agencies
accurately account for, maintain, and manage their real property
assets. As such, in reviewing real property management activities at
DHS, we addressed the following questions:
1. What is the profile of DHS's real property portfolio?
2. What challenges, if any, does DHS face in managing its real property
portfolio and what actions has it taken in response to the
administration's real property initiative?
3. What challenges do DHS and GSA face in consolidating DHS's
headquarters in Washington, D.C.?
4. What actions has DHS taken to help ensure the physical security of
the facilities where it is located?
To answer our first question, we obtained and analyzed DHS and GSA real
property data. We also interviewed DHS and GSA real property officials
and a contractor that is helping DHS develop its real property
inventory. Although we identified challenges that DHS faces with
collecting some real property data elements, we determined that other
data elements--such as total number of buildings and structures--that
we are presenting later in the report were sufficiently reliable for
the purposes of our review. To answer our second question, we
interviewed DHS real property officials about challenges and considered
the extent to which DHS has implemented Executive Order 13327 as the
basis for measuring DHS's progress in real property management. For the
first and second questions, we also interviewed Office of Management
and Budget (OMB) staff because OMB oversees real property management
governmentwide. To answer our third question, we reviewed and analyzed
key documents and interviewed DHS real property officials from
headquarters and GSA officials responsible for assisting DHS with its
headquarters consolidation efforts. This included reviewing planning
documents related to a proposed consolidation of DHS headquarters on
the West Campus of St. Elizabeths Hospital in the District of Columbia.
We also interviewed additional stakeholders, including officials from
the National Capital Planning Commission (NCPC) and the District of
Columbia Office of Planning. The stakeholders we contacted are
discussed in more detail in appendix 1. To answer the fourth question,
we interviewed DHS physical security headquarters officials and
security officials from DHS's various components. We also interviewed
FPS officials and GSA officials responsible for security at locations
where GSA houses DHS. We analyzed pertinent physical security documents
and policies from DHS and GSA. We conducted our work between March 2006
and April 2007 in accordance with generally accepted government
auditing standards.
Results in Brief:
DHS's 10 major organizational components have a large and diverse real
property portfolio that consists largely of properties where DHS's
legacy agencies were housed before the department's creation. According
to DHS and GSA data, this portfolio includes more than 27,000 owned or
leased buildings and structures, totaling almost 78 million square
feet. Property in this portfolio generally falls into four categories:
(1) federally owned property that DHS controls; (2) federally owned
property that GSA controls and DHS rents from GSA as a tenant agency;
(3) property that is not federally owned that DHS leases through GSA,
which acts as a leasing agent for DHS and charges DHS rent to occupy
the space; and (4) property that is not federally owned that DHS leases
directly without GSA involvement. About 72 percent of DHS real property
is federally owned, either controlled by DHS or GSA, while about 28
percent of DHS real property is federally leased, either directly from
a nonfederal entity by DHS or through GSA. These percentages are
similar to governmentwide percentages for these property categories.
Seventy nine percent of federal real property is federally owned, while
21 percent is leased or otherwise managed. The U.S. Coast Guard (Coast
Guard) occupies the bulk of DHS real property, accounting for 69
percent of its buildings, 90 percent of its structures, such as docks,
piers, bridges, monuments, and statues, and about 41 percent of its
square footage. DHS's real property portfolio reflects the diversity of
its components' various missions and thus includes office buildings,
law enforcement training centers, laboratories, border control sites,
and detention facilities.
DHS faces challenges in the real property area, but has made progress
toward addressing them in response to the administration's real
property management initiative. One major challenge relates to DHS's
creation as a new federal department that combined 22 existing
agencies, which has made the development of a cohesive approach to real
property management a significant undertaking. For example, some
components, most notably the Coast Guard, arrived intact with stable
real property portfolios as well as strategies, an organization, and
processes for managing assets. Others, such as Customs and Border
Protection and Immigration and Customs Enforcement, were formed from
multiple legacy agencies, each with different real property portfolios
and asset management strategies. Other challenges DHS faces--including
making better use of underutilized property and ensuring data are
reliable--are typical of those we have found at other agencies in
recent years. For example, DHS reported that about 9.7 percent of its
inventory was underutilized, and DHS has yet to fully assess the
reliability of its real property data. DHS also faces other challenges
common to many federal agencies, including various legal and budget-
related limitations that often do not lead to businesslike outcomes and
a need for improved capital planning. To address the challenges, DHS
has clearly benefited from the administration's focus on improving real
property management across government. On the administration's agency
scorecard for real property management--established in fiscal year 2004
to measure each agency's progress in implementing Executive Order
13327--DHS has achieved a "yellow" status, which indicates progress in
strategically managing real property by, for example, designating a
senior real property officer and developing an OMB-approved asset
management plan. However, we found that DHS could do more to improve
its capital decision-making practices by embracing OMB's capital
planning principles, such as developing a departmentwide capital plan.
We are recommending that DHS's Secretary use OMB's capital planning
principles to link DHS's long-term capital needs with the asset
management planning activities required under the President's real
property initiative.
Consolidating its Washington, D.C., area locations will be challenging
for DHS because of the costs involved, currently estimated to be at
least $3.26 billion, and key stakeholders' concerns about the
redevelopment of the West Campus of St. Elizabeths Hospital, DHS's
preferred location. DHS believes that by consolidating most of its
headquarters operations, greater efficiencies would result, its mission
would be better integrated, and the security of its facilities could be
better managed. In the Washington, D.C., area, DHS has seven core
operating components from 22 legacy agencies in 53 locations,
accounting for approximately 7 million square feet of federally owned
and leased office space with most leases due to expire in the next 10
years. DHS is pursuing St. Elizabeths for its consolidation, based on
analyses conducted by GSA, and ultimately wants 4.5 million square feet
of space at this location. The St. Elizabeths West Campus has 61
buildings on 176 acres and is a National Historic Landmark District. As
the government's real property disposal agency, GSA gained custody and
control of the site after it was transferred in December 2004 from the
Department of Health and Human Services. According to GSA and DHS, the
St. Elizabeths site is able to accommodate DHS's preferred amount of
development and is advantageous from a security perspective because of
its security setbacks, the space between a property's perimeter barrier
and a building's exterior.
GSA and DHS estimate that the overall consolidation would cost at least
$3.26 billion if 4.5 million square feet of office space, plus parking,
is developed at the St. Elizabeths West Campus. Using an analysis
prepared by GSA, DHS has also testified that a consolidation
alternative of 4.5 million gross square feet would save an estimated $1
billion over 30 years in current dollars over an alternative involving
renewing leases, although a revised GSA analysis--that assumes a lower
rental rate for parking space than office space--currently estimates
cost savings at $743 million. However, it is important to note that
this cost-savings analysis does not (1) use DHS's actual and projected
leasing costs for locations where it is currently housed; (2) include
DHS costs to develop the site, which include costs such as tenant
building improvements and currently stand at $1.32 billion, or how
those costs would vary depending on the alternative chosen; and (3)
examine a range of possible alternatives to house DHS and their
associated costs for the St. Elizabeths site. Additionally, GSA and DHS
could better support their case for consolidation at St. Elizabeths
West Campus with a thorough analysis of the savings they expect from
reducing the costs of physical security investment and hardening at
downtown leased locations. While GSA's analysis is useful to determine
whether a construction and leasing alternative is more cost effective,
a more comprehensive analysis that considers the additional factors
above would improve transparency and allow for more informed decision
making. We are recommending that DHS and GSA develop a more
comprehensive cost analysis to better justify the St. Elizabeths
consolidation from the perspective of the government, as a whole. In
addition to the challenge of obtaining funding for a series of projects
of this magnitude, DHS and GSA face objections from several key
stakeholders that are concerned about whether the project would comply
with current historic preservation and environmental laws. These
stakeholders generally support federal use and development of the
property, up to 2.5 million square feet of office space, but have
concerns about the magnitude of the current alternatives under
consideration, given the designation of St. Elizabeths as a National
Historic Landmark District. There is also concern about the project's
effect on the local community, including the project's traffic impacts
and the availability of contracting and retail opportunities. However,
some community leaders have stated that they support locating federal
development at St. Elizabeths as an economic driver and magnet for
additional development and revitalization. Critical to the outcome of
the proposed consolidation is GSA's development of a Master Plan,
currently scheduled to be released in July 2007 for review and public
comment with a final Master Plan scheduled to be submitted by December
2007.
In recent years, DHS has taken actions intended to improve the security
of its facilities, but its efforts fall short in certain key areas,
such as fully implementing risk management across its components. Like
other federal agencies, DHS has made physical security improvements to
its facilities, such as adding pop-up bollards and installing bullet-
resistant glass. DHS has also designated a Chief Security Officer for
the department and established a Chief Security Officer Council to
assist the Chief Security Officer in evaluating security issues. DHS
also plays an important role in developing guidance for agencies to
follow in protecting federal facilities against the threat of terrorism
through the Interagency Security Committee (ISC), which DHS chairs.
However, despite the actions DHS has taken and its prominent role in
facility protection governmentwide, most DHS components have not fully
implemented risk management for facility protection, which we have
recommended and DHS has advocated for federal agencies. Risk management
is useful for ensuring that security resources are directed where they
are needed most and yield the greatest improvements in facility
protection. Furthermore, despite DHS's role in developing guidance for
federal, state, and local officials in performance measurement, no DHS
components currently have a fully developed set of agency-and facility-
specific physical security performance measures. And, FPS has not
finalized a transformation strategy, which we recommended almost 3
years ago, to address several challenges FPS faced, including its
expanding mission and issues related to funding. We also found that DHS
has not developed a physical security plan, as all executive agencies
are required to develop under Homeland Security Presidential Directive
7 (HSPD-7). It is critical that DHS lead by example in the physical
security area, and we are therefore recommending that DHS develop a
physical security plan that addresses DHS's plans to fully implement
risk management and develop performance measures for facility
protection.
DHS concurred with our recommendations to link DHS's long-term capital
needs with its asset management planning activities and to develop a
physical security plan, but it only partially agreed with our
recommendation to develop a comprehensive cost analysis for the St.
Elizabeths site. GSA did not concur with our recommendation to develop
a comprehensive cost analysis for the St. Elizabeths site. We maintain
that such an analysis would lead to more informed decision making. See
appendixes III and IV for DHS's and GSA's letters and our comments.
DHS's and GSA's comments are also discussed at the end of the report.
Other stakeholders--the D.C. Office of Planning, NCPC, the Advisory
Council on Historic Preservation, and the U.S. Commission of Fine Arts-
-provided comments and additional information which we have
incorporated in this report, as appropriate.
Background:
The Homeland Security Act of 2002 combined 22 federal agencies
specializing in various disciplines into the Department of Homeland
Security. DHS is organized into directorates, components and agencies,
collectively referred to as components. Responsibility for real
property asset management resides in the Office of the Under Secretary
for Management, which is also responsible for the DHS's budgets,
expenditure of funds, accounting and finance, procurement, human
resources, information technology systems, facilities and equipment,
and the identification and tracking of performance measurements.
The 10 major components with real property requirements and portfolios
are as follows:
* The Federal Emergency Management Agency (FEMA) prepares the nation
for hazards, manages federal response and recovery efforts following
any national incident, and administers the National Flood Insurance
Program.
* The Transportation Security Administration (TSA) protects the
nation's transportation systems to ensure freedom of movement for
people and commerce.
* Customs and Border Protection (CBP) protects the nation's borders to
prevent terrorists and terrorist weapons from entering the United
States, while facilitating the flow of legitimate trade and travel.
* Immigration and Customs Enforcement (ICE) the largest investigative
arm of DHS, identifies and mitigates vulnerabilities in the nation's
border, economic, transportation, and infrastructure security.
* The Federal Law Enforcement Training Center (FLETC) provides career-
long training to law enforcement professionals to help them fulfill
their responsibilities safely and proficiently.
* Citizenship and Immigration Services (CIS) administers immigration
and naturalization adjudication functions and establishes immigration
services policies and priorities.
* The Directorate for Science and Technology (S&T) is the primary
research and development arm of DHS. It provides federal, state, and
local officials with the technology and capabilities to protect the
homeland.
* The U.S. Coast Guard (Coast Guard) protects the public, the
environment, and U.S. economic interests--in the nation's ports and
waterways, along the coast, on international waters, or in any maritime
region as required to support national security.
* The U.S. Secret Service (USSS) protects the President and other high-
level officials and investigates counterfeiting and other financial
crimes, including financial institution fraud, identity theft, computer
fraud, and computer-based attacks on the nation's financial, banking,
and telecommunications infrastructure.
* Departmental Offices (DO) provide vision, strategic planning,
organizational structure, policy guidance, and executive leadership.
Since January 2003, we have identified federal real property as a high-
risk area because of long-standing problems with excess and
underutilized property, deteriorating facilities, unreliable property
data, and a heavy reliance on costly leasing. Federal agencies were
also facing many challenges in protecting their facilities against the
threat of terrorism. In addition, we found that these problems have
been exacerbated by competing stakeholder interests in real property
decisions, various legal and budget-related disincentives to
businesslike outcomes, and the need for better capital planning among
agencies.
DHS must meet key real property management requirements established in:
* Executive Order 13327,
* Federal Real Property Asset Management Initiative (real property
initiative),
* Federal Real Property Council guidance, and:
* OMB guidance for the real property initiative.
In response to our high-risk designation, the President signed
Executive Order 13327 in February 2004, Federal Real Property Asset
Management, which directs each executive agency such as DHS to (1)
appoint a Senior Real Property Officer (SRPO), (2) develop and
implement an asset management plan, (3) develop and use a real property
data inventory, and (4) develop and use performance measures. The
executive order also called for the establishment of the interagency
Federal Real Property Council (FRPC) to develop guidance to implement
the executive order, serve as a clearinghouse for best practices, and
facilitate the efforts of the SRPOs. FRPC initially identified and
defined 23 data elements that must be captured and reported by the 15
largest federal landholding agencies, including DHS (see app. II for a
description of these 23 data elements).[Footnote 2] Four of the 23 data
elements established by FRPC are performance measures--utilization,
condition index, mission dependency, and annual operating and
maintenance costs. OMB is responsibile for overseeing the
implementation of these real property requirements through its real
property initiative, the goal of which is to ensure that agencies
maintain their property inventories at the right size, cost, and
condition to support agency missions and objectives.
The National Capital Planning Act of 1952, as amended, requires federal
agencies to prepare master plans for proposed development using federal
funds in consultation with NCPC, which provides overall planning
guidance for federal land and buildings in the Washington, D.C.,
metropolitan area. A master plan should include the present composition
of a site and the plan for its orderly and comprehensive long-range
development, generally over a period of 20 years. NCPC has determined
that a master plan is a required preliminary stage of planning prior to
agency preparation and submission to NCPC of site and building plans
for individual projects. Master plans are necessary for sites on which
more than one principal building, structure, or activity is located or
is proposed to be located. A master plan also serves as the basic
planning document for intergovernmental coordination on developments
and projects within a site. GSA is preparing a Master Plan for the St.
Elizabeths site in conjunction with the environmental impact statement
that it must prepare for the site under the National Environmental
Policy Act (NEPA).
After the 1995 bombing of the Alfred P. Murrah Federal Building in
Oklahoma City, the Department of Justice created minimum security
standards for federal facilities. In October 1995, the President signed
Executive Order 12977, which established ISC. ISC was expected to
enhance the quality and effectiveness of security in, and protection
of, facilities in the United States that are occupied by federal
employees for nonmilitary activities and to provide a permanent body to
address continuing governmentwide security issues for federal
facilities. ISC is expected to have representation from all the major
federal departments and agencies, as well as a number of key offices.
ISC's specific responsibilities under the executive order generally
relate to three areas: developing policies and standards, ensuring
compliance and overseeing implementation, and sharing and maintaining
information.
In November 2004, we identified key practices that collectively could
provide a framework to guide agencies' facility protection efforts,
including allocating resources using risk management, leveraging
security technology, and measuring program performance. We also
identified obstacles to implementing these key practices, including
challenges in developing quality data to form the basis for risk
management, ensuring that technology performs as expected, and
determining how to measure the impact of various facility protection
approaches on improving facility protection. In July 2004, we
identified challenges facing FPS as it moved from GSA to DHS.
Since September 11, 2001, the focus on protecting the nation's critical
infrastructure has grown considerably. The Homeland Security Act of
2002 and other administration policies assigned DHS specific duties
associated with coordinating the nation's efforts to protect critical
infrastructure, and HSPD-7 stated that Secretary of Homeland Security
was responsible for coordinating the overall national effort to
identify, prioritize, and protect critical infrastructure and key
resources. Under the Homeland Security Act of 2002, the FPS was
transferred from GSA to DHS and, as a result of this transfer, DHS
assumed responsibility for coordinating ISC in March 2003.
DHS Has a Large and Diverse Real Property Portfolio:
DHS's 10 major organizational components have a large and diverse real
property portfolio that largely consists of the property where DHS's
legacy agencies were housed before the department's creation. According
to DHS and GSA data, this portfolio includes more than 27,000 owned or
leased buildings and structures totaling about 78 million square feet,
accounting for 2 percent of the federal real property portfolio. As
shown in figure 1, property in this portfolio generally falls into four
categories: (1) federally owned property that DHS controls; (2)
federally owned property that GSA controls and leases to DHS as a
tenant agency; (3) property that is not federally owned that DHS leases
through GSA, which acts as a leasing agent for DHS and charges DHS rent
to occupy the space; and (4) property that is not federally owned that
DHS leases directly without GSA involvement.
As the federal government's real property manager, GSA provides office
space for most federal agencies, including DHS, and also provides other
types of space, such as laboratories and border stations. The Federal
Buildings Fund, which is administered by GSA, is an intergovernmental
revolving fund that GSA uses as a means to finance the operating and
capital costs associated with federal space under its control or
custody. GSA charges agencies--including DHS--rent, and the receipts
are deposited into this fund. Congress exercises control over the fund
through appropriations that set annual limits--called obligational
authority--on how much of the fund can be expended for various
activities. In fiscal year 2006, DHS paid GSA approximately $828
million in rent for the lease of federally owned property held by GSA
and for property leased from a third party through GSA, depicted in
figure 1 as 16.5 percent and 24.9 percent, respectively. Although DHS
obtains 42.0 percent of its space through GSA (fig. 1) more than one-
half of DHS property does not involve GSA. This property is either
federally owned property held directly by DHS or property DHS leased
from a third party, depicted as 55.2 percent and 3.5 percent,
respectively, (fig. 1). Overall, the percentages of DHS-occupied space
that are federally owned versus leased generally fall in line with
trends for the government, as a whole. About 72 percent of DHS real
property is federally owned, either controlled by DHS or GSA, while
about 28 percent of DHS real property is federally leased, either
directly from a nonfederal entity by DHS or indirectly through GSA. By
comparison, 79 percent of federal property is federally owned, while 21
percent is leased or otherwise managed.[Footnote 3]
Figure 1: Profile of DHS's Real Property Portfolio:
[See PDF for image]
Source: GAO analysis of DHS and GSA real property data.
[End of figure]
U.S. Coast Guard Has the Majority of DHS Property:
At the component level, the Coast Guard occupies the majority of DHS
real property, accounting for 69 percent of its buildings, 90 percent
of its structures, and about 41 percent of its square footage. As shown
in table 1 and figure 2, CBP and ICE have the second and third highest
real property square footage, 19 percent and 10 percent, respectively.
CBP and ICE also lease the most property, about 12 million square feet
and 6 million square feet, respectively. Fifty-five percent of DHS's
square footage is federally owned and under the control of DHS, while
41 percent is leased through GSA. If Coast Guard real property is
excluded from the analysis of DHS real property, DHS components lease
about 71 percent of the remaining real property, a higher rate of
reliance on leases than is found governmentwide. Some components, like
ICE and CIS, said that they preferred to lease much of their property
so that they would have the flexibility to move offices to wherever
immigration populations increase or clusters of activity develop. For
changing and short-term needs such as these, it may make economic sense
to lease. However, DHS is trying to reduce its reliance on leasing for
long-term needs. For example, in January 2007, CBP purchased the 10
acre Nogales Border Patrol Station in Arizona for $5.4 million with 30
months remaining on a $90,000 per month lease. This purchase saved CBP
$2.7 million in future lease payments through 2008 plus the cost of
subsequent leases. In another example, DHS hopes to consolidate its
Washington, D.C., headquarters at the St. Elizabeths site to reduce its
reliance on leasing in the Washington, D.C., metropolitan area. As we
have reported, building ownership--rather than ordinary operating
leases--is often a less expensive way to meet agencies' long-term space
requirements.[Footnote 4]
Table 1: DHS Real Property Profile by Component:
Component: Coast Guard;
Occupied square footage (OF): 32,158,182;
Percent of total OF: 41.3 %;
Leased OF: 2,466,826;
Percent leased OF: 7.1 %;
Owned OF: 29,691356;
Percent owned OF: 69.1 %.
Component: CBP;
Occupied square footage (OF): 15,077,506;
Percent of total OF: 19.4;
Leased OF: 11,764,095;
Percent leased OF: 33.7;
Owned OF: 3,313,411;
Percent owned OF: 7.7.
Component: ICE;
Occupied square footage (OF): 7,866,571;
Percent of total OF: 10.1;
Leased OF: 6,463,027;
Percent leased OF: 18.5;
Owned OF: 1,403,544;
Percent owned OF: 3.3.
Component: FLETC;
Occupied square footage (OF): 5,550,505;
Percent of total OF: 7.1;
Leased OF: 4,079;
Percent leased OF: 0.0;
Owned OF: 5,546,426;
Percent owned OF: 12.9.
Component: CIS;
Occupied square footage (OF): 5,373,280;
Percent of total OF: 6.9;
Leased OF: 5,373,280;
Percent leased OF: 15.4;
Owned OF: 0;
Percent owned OF: 0.
Component: FEMA;
Occupied square footage (OF): 2,922,833;
Percent of total OF: 3.8;
Leased OF: 1,918,223;
Percent leased OF: 5.5;
Owned OF: 1,004,610;
Percent owned OF: 2.3.
Component: USSS;
Occupied square footage (OF): 2,459,577;
Percent of total OF: 3.2;
Leased OF: 2,184,049;
Percent leased OF: 6.3;
Owned OF: 275,528;
Percent owned OF: 0.6.
Component: TSA;
Occupied square footage (OF): 3,397,519;
Percent of total OF: 4.4;
Leased OF: 3,397,519;
Percent leased OF: 9.7;
Owned OF: 0;
Percent owned OF: 0.
Component: DO;
Occupied square footage (OF): 1,038,313;
Percent of total OF: 1.3;
Leased OF: 1,038,313;
Percent leased OF: 3.0;
Owned OF: 0;
Percent owned OF: 0.
Component: S&T;
Occupied square footage (OF): 659,701;
Percent of total OF: 0.8;
Leased OF: 101,062;
Percent leased OF: 0.3;
Owned OF: 558,639;
Percent owned OF: 1.3.
Component: Other;
Occupied square footage (OF): 1,331,850;
Percent of total OF: 1.7;
Leased OF: 146,370;
Percent leased OF: 0.4;
Owned OF: 1,185,480;
Percent owned OF: 2.8.
Component: Total;
Occupied square footage (OF): 77,835,837;
Percent of total OF: 100;
Leased OF: 34,856,843;
Percent leased OF: 100;
Owned OF: 42,978,994;
Percent owned OF: 100.
Source: GAO analysis of DHS and GSA real property data.
[End of table]
Figure 2: Percentage of Square Footage across DHS Components (Owned and
Leased):
[See PDF for image]
Source: GAO analysis of DHS and GSA real property data.
[End of figure]
Types and Locations of DHS Property:
Not surprisingly, DHS's real property portfolio reflects the diversity
of its components' various missions and thus includes office buildings,
law enforcement training centers, laboratories, border control sites,
and detention facilities. Of over 11,700 buildings in its portfolio,
three building-usage types were most common: family housing,
warehouses, and offices (see fig. 3). Family housing, most of which is
associated with the Coast Guard, is the most common building type,
accounting for about 2,900 buildings or 25 percent of DHS's building
inventory. Offices and warehouses account for about 2,400 and 2,350
buildings, respectively, or 21 percent and 20 percent of DHS's building
inventory. In terms of square footage, offices account for 44 percent
of DHS's inventory, while family housing and warehouses account for 17
and 6 percent, respectively. Examples of other relatively common
building usage types include service buildings and institutional
buildings.[Footnote 5] By comparison, in 2005, offices were the most
common building type across the federal government, accounting for 20
percent of the federal government's square footage, while family
housing and warehouses were second and third, accounting for 18 and 13
percent of the federal government's square footage, respectively (fig.
3).
Figure 3: Building-Usage Types across DHS:
[See PDF for image]
source: GAO analysis of DHS and GSA real property data.
[End of figure]
As shown in figure 4, California has the most DHS real property square
footage. DHS also has a significant presence in Texas, Alaska, Florida,
Georgia, Virginia, Maryland, the District of Columbia, New York, and
Massachusetts. This is generally consistent with federal space
governmentwide, which is concentrated heavily in California, Texas,
Virginia, Maryland, and Florida.
Figure 4: DHS Real Property Square Footage by State:
[See PDF for image]
Source: GAO analysis of DHS and GSA real property data.
[End of figure]
DHS Faces Several Challenges Managing Real Property but Has Made
Progress Addressing Them:
In addition to the challenge associated with being a new federal
department, DHS faces other challenges that, in some key areas, are
typical of those we have found at other agencies in recent years. Since
we designated federal real property as a high-risk area in 2003, we
have reported on long-standing problems across several agencies that
include unneeded and deteriorating property, unreliable real property
data, and heavy reliance on costly leasing. In addition, deep-rooted
obstacles, including competing stakeholder interests, legal and
budgetary limitations, and a need for improved capital planning,
continue to hamper reform. DHS has taken steps to address the
challenges, largely in response to the administration's real property
initiative.
DHS Faces the Challenge of Integrating the Real Property Management
Activities of 22 Legacy Agencies:
DHS faces the major challenge of being a new federal department that
combined 22 existing agencies, making the development of a cohesive
approach to real property management a significant undertaking. Some
components, most notably the Coast Guard, arrived intact with stable
real property portfolios as well as established strategies,
organization, and processes for asset management. Others, such as CBP
and ICE, were formed from multiple legacy agencies, each with distinct
real property portfolios and asset management strategies that needed to
be integrated to function as one. Components such as TSA and S&T are
relatively new federal functions with growing portfolios and newly
established real property asset management organizations. DHS and OMB
officials cited the integration of DHS's 22 legacy agencies, whose
primary missions are not real property management, as one of the
biggest challenges facing managers of DHS real property. Examples of
the challenge of integration at the component level include the
following:
* CBP, which was created through the consolidation of Customs, the
Border Patrol, and the inspective functions of the Immigration and
Naturalization Service (INS) and of the Agriculture and Plant Health
Inspection Service into a new parent organization, was challenged with
inventorying unique types of property (roads, walls, and technical
infrastructure) within the Border Patrol that have not been inventoried
in the past. CBP recently completed its real property inventory of
assets, including its border patrol stations.
* ICE, formed in 2003 by combining the law enforcement arms of INS and
the former U.S. Customs Service, is facing the challenge of increasing
its real property staff to do all the needed real property work. A
senior ICE real property official said that very few real property
staff transitioned with ICE in 2003, so ICE's real property program is
behind the programs of most other DHS components. This official said
that ICE plans to have a complete real property staff by the end of
fiscal year 2007.
* CIS, which transitioned into DHS with the service and benefit
functions of INS, also faces transition challenges. According to DHS
officials, it did not receive any administrative staff and not enough
security staff, so CIS had to set up its own management processes in
these areas and start over.
DHS officials recognize the significant challenge they face developing
a cohesive approach to real property management at DHS. To address this
challenge and respond to the administration's real property initiative,
DHS created the Chief Administrative Officer Council and the DHS Real
Property Management Committee (RPMC) in fiscal year 2004. Both were
established to review and coordinate DHS real property issues. The
activities and makeup of these councils will be discussed later as they
relate to DHS's actions in response to the real property initiative.
Percentage of Underutilized Property Is Higher for DHS than for Some
Other Large Agencies:
In our update of the high-risk series for real property in 2007, we
reported that according to DHS, approximately 9.7 percent of its
inventory is underutilized.[Footnote 6] DHS reported more combined
underutilized and excess property than some federal departments that we
surveyed.[Footnote 7] For example, some departments, including the
Department of the Interior, the Department of State, and the Department
of Veterans Affairs report levels of underutilized or excess property
at or below 2 percent. Other agencies--including the Department of
Energy, the National Aeronautics and Space Administration, and large
real property holding agencies like DHS--have similar or higher levels
of underutilized property and report that over 10 percent of the
facilities in their inventories were underutilized. Retaining excess
and underutilized properties is not the best use of federal dollars
because properties are costly to maintain and results in lost
opportunities when they are not put to more beneficial uses. In
addition, continuing to hold real property that may no longer be needed
or that could be better used does not present a positive image of the
federal government in local communities.
At the time of our review, DHS was developing a Vacant Space Report
that its components will use to report on their underutilized and
excess real property. As new space requirements arise, they will be
evaluated against this Vacant Space Report to determine if the new
requirement can be accommodated in the underutilized or excess space
before DHS seeks new space. If no suitable candidate can be found for
excess real property, the disposal process will be initiated. At the
moment, a Vacant Space Report is being developed for use only for the
Washington, D.C., area. Underutilized space is tracked via DHS's Real
Property Information System. DHS currently follows the Coast Guard's
policies, procedures, and authorities for real property disposal. This
is in accordance with established DHS policy to continue using legacy
authorities, policies, and procedures under Management Directive 560.
DHS also follows Coast Guard policy because the Coast Guard has about
69 percent of the federally owned real property in the DHS portfolio.
DHS Real Property Data Are Improving, but Some Components Struggle to
Collect Complete Information on Some Data Elements:
Overall, DHS real property data are mostly complete because DHS has
compiled an initial set of data on its real property consistent with
FRPC definitions.[Footnote 8] DHS components provide data for all data
elements required under FRPC guidance, although some data elements are
temporary proxies. Some DHS components, such as the Coast Guard and
TSA, said that they have a robust real property data inventory that
they use daily in their decision making. For example, a TSA real
property official noted that TSA's real property database is able to
generate daily reports about TSA real property needs. DHS as a whole is
working toward providing evidence to OMB that all its components use an
accurate and current inventory in their daily management decision
making.
Although DHS components' data are mostly complete, some components,
such as CBP and ICE, are using data proxies for some data elements
until these components can develop more robust data measures. The
condition index, a measure of an asset's condition at a particular
point in time, is an example of a problematic performance measure. A
common problem for some components, particularly the larger ones that
were formed from multiple legacy agencies, is finding the resources to
fully develop certain data elements, so components are developing
proxies in the interim. For example, as a proxy for a building's
condition index--which, according to a DHS official, would be expensive
to perform--CBP hired a consultant to do a mini-assessment of its
properties. The consultant rated each of CBP's properties on a scale of
1 to 5 (with 1 being in excellent condition and 5 being unusable.) CBP
will use these ratings to prioritize decisions about how best to
maintain its real property assets.
CBP and ICE have not developed a true condition index for each of their
real property holdings because, according to DHS officials, these
components lack the funding to conduct full facility condition
assessments. These assessments are important because they establish an
ongoing process for monitoring facility conditions and enable an agency
to develop a comprehensive plan for facility maintenance and building
renewal. Data from the assessments enable the agency to prioritize
projects for budget requests and increase the agency's accountability
since the assessments enable the agency to show a direct correlation
between its facility needs and budget plans. Full facility condition
assessments would also allow DHS to accurately estimate its deferred
maintenance backlog, which it is currently unable to do.[Footnote 9]
DHS officials say there are disparities in how components track
deferred maintenance across the department and acknowledge that this is
a problem. DHS said it had to take a sample of deferred maintenance in
the department to estimate that its deferred maintenance costs in
fiscal year 2005 were between $497 million and $619 million.
Components such as the Coast Guard, CBP, and ICE use data proxies to
report annual operating and maintenance costs. These components are
having difficulty tracking costs for recurring maintenance and repairs,
utilities, cleaning and janitorial services, and landscaping at the
building level. For example, the Coast Guard noted that tracking annual
operating costs was difficult because, although the Coast Guard can
easily calculate the costs of managing a facility (which consists of
multiple buildings), the agency does not have the systems in place to
account for cost streams at the building level. For example, the Coast
Guard cannot capture the costs of janitorial services and landscaping
at the building level. Without building-level cost information, it
becomes more difficult for the Coast Guard to identify how its costs
may be increasing over time, which could help the Coast Guard take
action to reduce costs. DHS is working to correct this challenge within
each of these components.[Footnote 10]
The Coast Guard, CBP, FEMA, and ICE have also struggled to report on
various property restrictions, such as whether property has historical,
endangered species, developmental, or environmental restrictions. Some
components use a data proxy as a substitute for fully researched data
on restrictions. For example, since the Coast Guard and CBP do not have
data on which buildings have lead-based paint and collecting these data
for thousands of buildings would take considerable time and resources,
the agencies are using each building's construction date as a proxy for
environmental restrictions. Buildings constructed after 1977, when lead-
based paint was banned from housing, are not restricted. Without
information on buildings' potential health hazards, such as lead-based
paint or asbestos, DHS real property managers cannot make fully
informed real property management decisions. DHS officials noted that
it was difficult for components with hundreds or thousands of buildings
and structures, such as the Coast Guard and CBP, to review the
thousands of documents associated with all the buildings in their
portfolios that would need to be reviewed to accurately identify all
restrictions.
Lastly, some components are not reporting all real property assets to
DHS's Real Property Information System. For example, the Coast Guard's
reported inventory did not include approximately 2.3 million square
feet of GSA-leased space and 1.0 million square feet of directly leased
space. FEMA's real property inventory is missing some disaster leases
and structures. Having a real property database with complete data on
an agency's real property assets is important for effective real
property management decision making. DHS's components are working to
fully update this information before their next submission to DHS's
Real Property Information System.
DHS Officials Believe That Better Tools Would Help Address Legal and
Budgetary Limitations:
As at other federal agencies, we found that the complex legal and
budgetary environment in which real property managers operate has a
significant impact on real property decision making and often does not
lead to businesslike outcomes at DHS. For example, many agencies,
including DHS, are not authorized to retain any of the proceeds from
the sale of surplus property. We have reported that this legal
limitation can lead agencies to retain unneeded assets that create
maintenance and upkeep costs for the government. Coast Guard officials
said that having the authority to retain some reasonable percentage of
proceeds from disposal of surplus real property would help offset the
amount of time and cost it takes to complete a sale.
To facilitate the disposal of federally owned historic lighthouses, the
National Historic Preservation Act (NHPA) was amended to provide a
mechanism for their disposal.[Footnote 11] Under this program, a senior
Coast Guard official noted the agency works with GSA to sell Coast
Guard lighthouses to a responsible party. The act authorizes the
crediting of net proceeds from the public sale of historic lighthouses
under Coast Guard control to the Coast Guard appropriation account that
is used to maintain lighthouses remaining under the Coast Guard's
control.[Footnote 12] According to this official, a similar arrangement
between DHS and a third party for real property other than lighthouses
would help DHS make better use of its underutilized assets.
In addition to the authority to retain proceeds, Coast Guard officials
identified enhanced-use leasing as a real property management tool that
they do not have but that would enable them to better manage their real
property portfolio.[Footnote 13] The Departments of Defense and
Veterans Affairs have been authorized to enter into enhanced-use
leasing agreements. Enhanced-use leasing encourages innovative public-
private partnerships that leverage underutilized properties to generate
revenues and reduce operating costs.
Capital Planning Functions across DHS Are Relatively New:
Over the years, we have reported that prudent capital planning can help
agencies to make the most of limited resources and that failure to make
timely and effective capital acquisitions can result in increased long-
term costs.[Footnote 14] Real property is one of the major types of
capital assets that agencies acquire. Other capital assets include
information technology, major equipment, and intellectual property.
GAO, Congress, and OMB have identified a need to improve federal
decisions about capital investment. Our Executive Guide,[Footnote 15]
OMB's Capital Programming Guide, and OMB's revisions to Circular A-11
have been designed to provide guidance to agencies for making capital
investment decisions. However, agencies are not required to use this
guidance. Furthermore, agencies have not always developed overall goals
and strategies for implementing capital investment decisions, nor has
the federal government planned or budgeted for capital assets over the
long term.
Our prior work assessing agencies' implementation of the planning phase
principles in OMB's Capital Programming Guide and our Executive Guide
found that some agencies' practices did not fully conform to OMB's
principles and that the agencies' implementation of capital planning
principles was mixed. Specifically, for the agencies we reviewed, their
capital planning processes were generally linked to their strategic
goals and objectives, and most of them had formal processes for ranking
and selecting proposed capital investments; however, the agencies had
limited success using agencywide asset inventory systems and data on
asset condition to identify performance gaps. In addition, we found
that none of the agencies had developed a comprehensive, agencywide,
long-term capital investment plan.[Footnote 16]
During this review, we found that DHS's long-term capital planning is
relatively new and generally needs improvement. DHS does not yet have a
departmentwide capital plan but is working toward developing one. DHS's
Investment Review Process is designed to promote sound capital asset
decisions across the department. However, we have reported that this
process has problems, such as reliance on interim guidance that has
changed frequently over the last 2 years, making it difficult for staff
to know if they are using the latest version. The Coast Guard has a
well-established capital planning function, but other DHS components
have capital planning functions that have just been formed. For
example, CBP established its capital planning process in November 2004,
but has not developed a comprehensive long-term capital plan, although
it does have documents that contain some elements of such a
plan.[Footnote 17] CIS's capital planning process, also established in
2004 after the formation of DHS, uses a long-term strategic plan to
assess the current state of its real property assets and to work toward
developing a longer-term capital plan. Other DHS components, such as
ICE and FEMA, have long-term capital planning functions that are in
early stages or lack real property programs with long-term capital
plans. In February 2007, ICE developed a draft 20-year leasing plan
that charts real property inventory, lease acquisition, and other key
metrics. According to ICE officials, the 20-year plan allows ICE the
ability to forecast capital needs and align staff and resources to
execute projects. However, although ICE has made progress, additional
work is needed.
Without capital plans for each of its components, DHS will have
difficulty making the most of limited resources and making timely and
effective capital acquisitions that will reduce long-term real property
costs and free funding for mission-related activities. Having capital
plans for its components would be particularly beneficial, given that
DHS is a relatively new federal department that inherited the real
property portfolio held by its components' former agencies and is now
responsible for aligning its real property assets with its current and
future mission. Once plans are developed and aggregated, linking the
agencywide capital plan with DHS's asset management plan, which we have
recommended that OMB require for other agencies, would be beneficial.
Without a clear linkage or crosswalk between these two plans, the
relationship between the real property goals specified in the asset
management plan and the agency's longer-term capital plans could be
uncertain.
DHS Is Making Progress Meeting the Requirements of the Administration's
Real Property Initiative:
DHS has taken several actions to implement key real property management
initiatives set forth in Executive Order 13327 and other guidance
documents.[Footnote 18] First, DHS has designated its Chief
Administrative Officer (CAO) as DHS's Senior Real Property Officer
(SRPO). According to DHS officials, this official's functions as SRPO
and CAO are evenly split. As SRPO, this official serves on the FRPC and
coordinates the formulation and implementation of real property
management planning and policy for DHS. As CAO, the official manages
and directs the department's administrative service functional areas,
including asset management, occupational safety and health,
environmental planning and management, historic preservation, and
energy management. The CAO supervises a Senior Executive Service-level
Director of Asset Management who in turn supervises an Assistant
Director for Real Property. The CAO reports to the Under Secretary for
Management (see fig. 5).
Figure 5: DHS's Real Property Organization:
[See PDF for image]
Source: DHS.
[End of figure]
A key step in implementing these real property management initiatives
and in formulating a DHS-wide real property strategy was the creation
of the Chief Administrative Officer Council and the DHS Real Property
Management Committee in fiscal year 2004. Both were established to
review and coordinate DHS real property issues. The Council is chaired
by the DHS Chief Administrative Officer and includes all the senior
real property officers of the components. The Committee is chaired by
the DHS Headquarters Assistant Director of Asset Management for Real
Property, and the remaining members are real property chiefs
representing the components. The Committee plays a lead role in
developing and implementing DHS real property policies and processes,
including DHS's asset management plan.
The administration's Executive Order 13327 required DHS to develop and
implement an asset management plan (AMP),[Footnote 19] develop a real
property inventory that tracks DHS's assets, and develop and use
performance measures. OMB approved DHS's AMP in June 2006. The
objective of the AMP is to foster an environment within DHS that will
promote better asset management and the disposal of unneeded federal
properties. The plan is also designed to implement the Real Property
Initiative, the goal of which is to ensure that real property
inventories are maintained at the right size, cost, and condition to
support agency missions and objectives. DHS says that the goals of the
asset management plan are to help DHS provide appropriate facilities
and infrastructure, in an expert, cost-effective, and timely manner to
achieve the right mix of facilities for specified and implied missions,
professional working environments, and responsible stewardship of
public and private resources.
OMB Has Upgraded DHS's Real Property Management Score:
In June 2006, OMB upgraded DHS' Real Property Asset Management Score
from red to yellow after DHS (1) designated a SRPO, (2) developed an
approved asset management plan, (3) developed a generally complete real
property data inventory, (4) submitted this inventory for inclusion
into the governmentwide real property inventory database, and (5)
established performance measures consistent with FRPC standards. In
order to receive a green designation, DHS developed an OMB-approved 3-
year timeline (approved in the 2nd quarter of fiscal year 2007) for
implementing its asset management plan, and is now implementing the
plan and must now take steps to demonstrate daily decision-making using
real property data and performance measures, and show that its
strategic plans, asset management plan, and performance measures are
consistent (see table 2).
Table 2: DHS's Implementation of OMB's Real Property Initiative:
Real property management action: Agency has an SRPO who actively serves
on the FRPC;
Implementation: Yes.
Real property management action: Agency has completed and maintained a
comprehensive inventory and profile of agency real property;
Implementation: Yes.
Real property management action: Agency has established asset
management performance measures;
Implementation: Yes.
Real property management action: Agency has provided timely and
accurate information for inclusion into the governmentwide real
property inventory database;
Implementation: Yes.
Real property management action: Agency has developed an OMB-approved
asset management plan;
Implementation: Yes.
Real property management action: Agency has established an OMB-approved
3-year rolling timeline with date-certain deadlines by which agency
will address opportunities and determine its priorities as identified
in the asset management plan;
Implementation: Yes.
Real property management action: Agency has demonstrated steps taken
towards implementation of the asset management plan;
Implementation: No.
Real property management action: Agency routinely uses accurate and
current asset inventory information and asset maximization performance
measures in management decision making;
Implementation: No.
Real property management action: Agency's management of its property
assets is consistent with the agency's overall strategic plan, asset
management plan, and performance measures;
Implementation: No.
Source: OMB.
[End of table]
DHS has developed an OMB-approved 3-year timeline to implement the
goals and objectives of its asset management plan. Consistent with the
goals and objectives of the asset management plan, DHS has developed
the following goals to be fulfilled through a series of initiatives
over the next 3 years:
* Instill a culture of informed, results-based decision making;
* Achieve greater uniformity in real property policies and approaches;
* Leverage human capital to maximize value added to real property
decisions;
* Deploy acquisition tools that promote effective asset management;
* Identify requirements for long-term data management and begin
investment selection steps;
* Develop a measure to track customer satisfaction and use results to
continuously improve real property service delivery;
* Accelerate disposal of unneeded assets;
* Colocate appropriate facilities.
For example, DHS's Asset Management Real Property Division has started
to identify requirements for long-term data management and to begin the
investment review steps required by DHS to plan the acquisition of a
new system. In doing so, DHS has begun to define a program of
requirements for a real property asset management data system. In
addition, to develop a measure to track customer satisfaction and use
the results to improve real property service delivery, RPMC will lead a
task force to develop a customer satisfaction survey applicable to all
components. Also, with the goal of instilling a culture of informed,
results-based decision making, DHS plans to implement and
institutionalize the appropriate use of key performance measures as the
basis for real property management decisions. Core performance measures
will include a mission dependency index, facility utilization rate,
facility condition index, and operating costs. DHS is currently
addressing comments by OMB to include additional milestones that will
lead to measurable results for the identified initiatives. Furthermore,
since DHS initially set a very aggressive goal of meeting OMB's green
standard by the end of 2007, DHS and OMB agreed to the rebaselining of
achieving the green standard to the 3rd quarter of 2008 to establish a
more realistic implementation schedule.
However, as discussed earlier, DHS has struggled with some elements of
assembling a complete real property data inventory, including
collecting data for some performance measures such as facility
condition. And, for DHS as for many other federal agencies, it is too
early to tell whether the implementation of its asset management plan
will be successful, although DHS appears headed in the right direction.
DHS officials have indicated that among its next steps is to prioritize
funding to fully assess the condition of its facilities. Without
complete facility condition data, active and efficient stewardship of
government real property assets is difficult. DHS must also link its
asset management plan with its yet-to-be-developed capital plan.
DHS Headquarters Consolidation Faces Challenges Related to Its Cost and
Stakeholder Concerns:
DHS components are currently dispersed throughout the Washington, D.C.,
area, and DHS wants to better align its real property portfolio in the
area with its mission by consolidating its headquarters facilities. GSA
and DHS estimate that the total cost of a DHS consolidation that
involves 4.5 million square feet space, plus parking--the amount of
office space DHS says it needs--will be at least $3.26 billion.
According to GSA, this estimate is a preliminary, planning-level
estimate based on alternatives currently under study. DHS believes that
lessons learned from Hurricane Katrina and the department's Second
Stage Review[Footnote 20] have reinforced its need to be better
integrated to prepare for and respond to natural disasters or terrorist
attacks and to meet its mission of leading a unified national effort to
secure America. GSA has identified the West Campus of St. Elizabeths
site as the best candidate for the consolidation in the Washington,
D.C., area, but the cost of the planned consolidation and stakeholders'
concerns pose challenges for DHS. GSA is currently preparing a Master
Plan for the redevelopment of the site as it incorporates stakeholder
input. An official draft that incorporates all stakeholders' input has
not yet been presented to stakeholders. A draft is due to be submitted
to NCPC for review and public comment in July 2007.
DHS states that consolidation of the core of its operations at St.
Elizabeths will better integrate the department. In the Washington,
D.C., area, DHS has seven core components in 85 buildings and 53
locations, accounting for approximately 7 million gross square feet of
government owned and leased office space. We agree that DHS's current
housing configuration is too dispersed and needs to be better
integrated. DHS anticipates that the end state of the consolidation
effort will result in DHS being down to six to eight locations. DHS
expects its need for office space to grow to about 8 million square
feet over the next 5 years. About 70 percent of DHS's space in
Washington, D.C., is privately held and is leased directly by DHS or
through GSA.
According to DHS, its components' dispersion across multiple locations
creates less than ideal facility protection capabilities and adversely
affects communication, coordination, and cooperation across components.
In October 2006, DHS developed a plan for consolidation called National
Capital Region Housing Master Plan for the Washington, D.C., area,
which presents DHS's strategy for consolidating its headquarters and
operating components in the Washington, D.C., area.[Footnote 21] Under
this plan, DHS would consolidate its mission execution functions on the
West Campus of St. Elizabeths site in Washington, D.C., and it would
also consolidate its support services, such as procurement, but at a
location other than St. Elizabeths. In addition, DHS maintains that
consolidation will reduce the department's costs to manage its real
property portfolio by enabling the department to avoid the costs of
renewing leases for 4.7 million square feet of office space in the
Washington, D.C., metro area that expire over the next 10 years.
According to DHS, since its plan for consolidation at St. Elizabeths
uses a campus with security setbacks--the space between a property's
perimeter barrier and a building's exterior--it would also save costs
by reducing the need for extensive blast protection hardenings
throughout the campus.
The plan states that increased colocation and consolidation will be
necessary to achieve the following five objectives:
* improve mission effectiveness,
* create a unified DHS organization,
* increase organizational efficiency,
* size DHS's real property portfolio accurately to fit its mission,
* reduce real property occupancy costs.
DHS considered a baseline scenario (existing conditions) and three
alternative housing scenarios to determine which scenario would best
accomplish these five objectives (see table 3).
Table 3: DHS Real Property Housing Scenarios for the Washington, D.C.,
Area:
Scenario: Baseline;
Description: Existing conditions, 85 buildings in 53 locations.
Scenario: Dispersed;
Description: Multiple buildings averaging between 185,000 and 300,000
rentable square feet that consolidate components or similar purpose
facilities.
Scenario: Mid-sized building;
Description: Multiple buildings averaging between 300,000 and 850,000
rentable square feet, supported by several smaller buildings, including
unique facilities.
Scenario: Campus;
Description: Consolidation resulting in several campuses, including one
large campus, in addition to unique facilities that require strategic
locations.
Source: DHS.
[End of table]
DHS found that the colocation and consolidation benefits of the campus
scenario are more favorable than those of the other scenarios and the
estimated annual costs of the campus scenario are 10 to 15 percent
lower than for the baseline scenario. Although the campus scenario
involves higher short-term transition costs than the alternative
scenarios, DHS concluded that the life-cycle and organizational
benefits to DHS outweigh these costs.
Consolidation at St. Elizabeths Could Cost over $3.26 Billion:
The West Campus of St. Elizabeths has 61 buildings containing 1.1
million square feet of space on 176 acres located in the Anacostia
neighborhood of Southeast Washington, D.C. It is a National Historic
Landmark District. This designation recognizes the exceptional national
significance of the property and is the same designation given to the
White House and the Capitol. In commenting on this report, the U.S.
Commission of Fine Arts and the Advisory Council on Historic
Preservation noted other values of the property, including the site's
historic and cultural value related to the history of the treatment of
mental illness and serving as a hospital site during the Civil War, and
the architectural value of many buildings that display the Gothic-
Revival architectural style. Figure 6 shows the Administration Building
on the campus. In addition to the buildings on the West Campus, the
National Historic Landmark designation covers the landscaping and
grounds, the scenic vistas of the river and city, and the Civil War
cemetery (see fig. 7). GSA took custody and control of the site after
it was transferred in December 2004 from the Department of Health and
Human Services, which no longer needed the site. According to GSA,
there was extensive deterioration of all the buildings and the campus
due to lack of maintenance and preservation by Health and Human
Services prior to GSA taking custody and control. The buildings are in
such poor condition, restoration is needed, according to GSA and other
stakeholders.
Figure 6: The Administration Building on the West Campus of St.
Elizabeths:
[See PDF for image]
Source: GAO.
[End of figure]
Figure 7: View from St. Elizabeths West Campus Looking North:
[See PDF for image]
Source: GAO.
[End of figure]
The West Campus of St. Elizabeths is GSA's preferred site for
consolidation because, according to GSA, it (1) can accommodate the 4.5
million square feet of office space, plus parking, DHS maintains it
needs and (2) is available immediately, which are two key requirements
for DHS. According to DHS, the occupancy plan is based on the guiding
principle that the campus must serve as the central hub for leadership,
operations coordination, policy, and program management in support of
the DHS's strategic goals. According to DHS, a campus setting promotes
those critical mission execution functions that facilitate integrated
decision making, effective communications, cooperation, and
coordination. GSA analyzed available properties within the Washington
metropolitan area and determined that the West Campus of St. Elizabeths
is the only site capable of meeting these two core
requirements.[Footnote 22] No single site under the federal
government's control and custody can accommodate DHS's need of 7
million square feet. Because the St. Elizabeths West Campus is already
owned by the federal government, acquisition costs for the
consolidation as a whole would be low.[Footnote 23] DHS also cites St.
Elizabeths' location and capacity for high-security features as
additional reasons for selecting the site. St. Elizabeths is located
within 2.5 miles of the U.S. Capitol and 3 miles from downtown D.C. In
addition, St. Elizabeths' terrain provides some natural buffer zones,
while if DHS is to remain in locations downtown, costly hardening of
buildings for security purposes would be required.
GSA and DHS estimate that the total cost of a DHS consolidation at St.
Elizabeths that involves 4.5 million square feet of office space, plus
parking, will be at least $3.26 billion, based on alternatives
currently under study.[Footnote 24] According to GSA, $150 to $200
million of this cost estimate includes the costs of infrastructure
improvements and design. Infrastructure costs include the costs of
installing utilities, fiber-optic lines, and telephone lines, and also
the costs of GSA's transportation improvements on or adjacent to the
site. According to GSA, the total scope of transportation improvements
will be determined when the Record of Decision is signed by the GSA
Regional Administrator.[Footnote 25] Other expenses included in the
$3.26 billion total include construction, renovation, information
technology, furniture, fixtures and equipment, and moving costs. (See
table 4 for a summary of estimated costs to develop the St. Elizabeths
site.)[Footnote 26] GSA's estimate includes the cost of transportation
improvements to streets, roads, and highways in the vicinity of St.
Elizabeths to support the federal redevelopment project. The
transportation improvement estimate ranges from $27 million to $40
million, of which the District Department of Transportation's (DDOT)
costs range between $4 million and $14 million, according to GSA. GSA's
estimate does not include all the mitigations--such as dioxin
remediation and landscaping--that may be required to meet the concerns
of stakeholders.[Footnote 27] In addition, access to the campus is
dependent on transportation projects estimated to cost over $1 billion
to be borne by the D.C. government--costs that are not part of the
total estimate. These projects were planned by DDOT before GSA
formulated its plans to redevelop the St. Elizabeths West Campus. The
D.C. government has only approved partial funding for these
transportation improvements thus far. DDOT is a cooperating agency for
the Environmental Impact Statement currently under development by GSA.
According to GSA, it is coordinating with the Federal Highway
Administration and DDOT to help ensure that regional projects planned
for the area are funded consistent with the St. Elizabeths West Campus
development schedule.
Table 4: Preliminary Estimate of the Cost to Develop the St. Elizabeths
Site:
Type of cost: Build out, design, moving and furnishings (DHS cost);
Amount: $1.32 billion.
Type of cost: Construction and infrastructure (GSA cost);
Amount: $1.94 billion.
Type of cost: Additional development costs;
Amount: (1) $4 to 14 million in off-site improvements at the Malcolm X
Interchange funded by DDOT; (2) Unknown mitigation costs such as dioxin
remediation funded by the Department of Health and Human Services and
other mitigations funded by GSA.
Type of cost: Total;
Amount: $3.26 billion (plus additional development costs such as
mitigation costs).
Source: GSA and DHS.
[End of table]
Based on a GSA cost analysis, DHS has testified that without federal
construction at St. Elizabeths, the department will continue to be
housed in leased space resulting in an estimated $1 billion more in
cost over a 30-year period compared with the consolidation.[Footnote
28] A revised GSA cost analysis received on June 13--that assumes a
lower rental rate for parking space than office space--estimates
savings at $743 million. We did not assess the assumptions that form
the basis of either analysis, as they were provided right before this
report was published. Furthermore, it is important to note that the
analysis is not designed to assess costs to the federal government as a
whole and does not include actual costs where DHS is currently housed.
According to GSA, this analysis is based on average rental rates for
Washington, D.C. While GSA's cost analysis is useful in determining
whether construction or leasing is more cost-effective, a more
comprehensive analysis that includes additional factors is necessary to
determine the cost of the St. Elizabeths development to the government
as a whole. For example, a more comprehensive analysis could take into
account (1) DHS's actual and projected leasing costs for locations
where it is currently housed;[Footnote 29] (2) DHS costs to develop the
site--including costs such as tenant building improvements, which stand
at $1.32 billion--and how those costs would vary depending on the
alternative ultimately selected, and (3) a range of leasing and
construction alternatives and their associated costs for the St.
Elizabeths site, depending on the square footage that actually goes to
the St. Elizabeths West Campus. A comprehensive cost analysis would
improve transparency and allow for more informed decision making.
Actual and projected leasing costs for the locations where DHS is
currently housed would provide a more accurate estimate of costs if a
consolidation at St. Elizabeths does not occur and serve as a baseline
against other consolidation alternatives. Accounting for all of DHS's
current locations in an analysis and identifying which leases could
potentially be replaced by space at St. Elizabeths would also be
helpful to decision makers in understanding the consolidation.
Furthermore, incorporating DHS costs such as tenant building
improvements and moving and furnishing costs--which stand at an
estimated $1.32 billion--and how those costs would vary depending on
the alternative ultimately selected, would be important in order to
evaluate St. Elizabeths costs from the perspective of the federal
government as a whole, not simply from GSA's perspective. And,
examining the costs of a range of varying amounts of development at the
site would be useful should funding for the preferred option become
difficult to obtain. Finally, GSA and DHS could better support their
case for consolidation at St. Elizabeths West Campus with a thorough
analysis of the savings they expect from reducing the costs of physical
security investment and hardening at downtown leased
locations.[Footnote 30] A more comprehensive St. Elizabeths cost
analysis such as this would improve transparency and help GSA, DHS, and
key stakeholders, including Congress, better assess the merits of the
consolidation from a cost perspective for the government as a whole.
GSA and DHS are moving forward with requesting funding for the first
phase of the consolidation, and therefore a more comprehensive analysis
would better inform decision making. GSA has tentatively developed a
three-phased approach for managing the consolidation, with construction
funding originally requested for the Coast Guard's new headquarters
building in fiscal year 2007 and ending with final occupancy of the
third phase in fiscal year 2015 (see fig. 8). According to GSA, the
Coast Guard requires fiscal year 2011 or earlier occupancy for their
new headquarters space, and timely Coast Guard occupancy is critical.
Due to the lack of funding for the St. Elizabeths project in the fiscal
year 2007 Continuing Resolution, GSA is concerned that the overall
schedule may be delayed with corresponding adverse impacts on DHS
operations and integration. GSA and DHS are working together to update
the schedule and will work with Congress on options to recover from any
schedule slippage that results from not receiving funding in fiscal
year 2007. GSA and DHS have requested funds for the project for fiscal
year 2008.[Footnote 31] DHS headquarters and remaining components would
relocate in the second and third phases. During phase 1-a and 1-b,
which extends from the end of 2007 to 2011, DHS anticipates bringing
3,860 employees to the site. During phase 2, which ends in 2013 if
construction begins in 2009, and Phase 3, which ends in 2015 if
construction begins in 2011, DHS will add another 5,000 employees each,
for a total of up to 14,000 employees. While this three-phase approach
distributes costs across a number of years, according to DHS, it
prolongs the current fragmented DHS housing structure and could thus
affect mission performance. DHS intends to evaluate options to
accelerate construction and combine phases with GSA to the extent that
funding is available to do so. The Coast Guard would be the first DHS
component to move its headquarters under current plans. Because of
recent hiring, the Coast Guard has outgrown its current primary
headquarters location; the lease expires in May 2008.[Footnote 32]
Other Coast Guard offices in the Washington, D.C., area will also be
incorporated in the consolidation.
Figure 8: GSA's Proposed St. Elizabeths Standard Development Schedule:
[See PDF for image]
Source: GSA.
[End of figure]
GSA and DHS officials said that GSA would fund about $1.94 billion and
DHS would fund about $1.32 billion of the current estimated $3.26
billion dollar total. Under the current GSA development schedule, the
Coast Guard is scheduled to be fully moved in by fiscal year 2011, if
GSA receives appropriations as requested. DHS stated that most of the
DHS-specific costs will be incurred, regardless of whether the St.
Elizabeths West Campus is developed because of the need to renew
expiring leases over the coming years. More specifically, funding
activity and related planning thus far have been as follows:
* To begin funding the consolidation, GSA was provided $24.9 million in
fiscal year 2006 for the design phase of the Coast Guard headquarters
construction project. GSA also received $13 million for, according to
GSA, identification of fire code deficiencies, renovation cost
estimates, a buildings demolition study, master planning, NEPA studies,
site exit analysis, a Campus Design (infrastructure only), restoration
of landscaping, cleaning of storm water systems and underground pipe
replacement, upgrades to selected fire protection systems, repair of
the wastewater system, deferred maintenance, and repair and
stabilization of selected structures at the St. Elizabeths West Campus
site in fiscal year 2006.
* GSA and DHS did not receive any funding for DHS headquarters
consolidation for fiscal year 2007.[Footnote 33] The Coast Guard and
Maritime Transportation Act of 2006 provided that the Coast Guard
cannot move any personnel, property, or other assets to St. Elizabeths
until the GSA Administrator submits a plan for the site to certain
congressional committees.[Footnote 34] As required by law, the plan
should include, among other things, the design of facilities for at
least one federal agency other than the Coast Guard, which houses no
fewer than 2,000 employees. GSA is now developing a plan in response to
the act. GSA is also developing a Master Plan for the St. Elizabeths
site, which will be discussed in more detail later.
* GSA's fiscal year 2008 request was about $347 million, the bulk of
which was for phase 1-a and phase 1-b of the proposed project. Phase 1-
a is proposed to provide 1.135 million square feet of space and 650
parking spaces for the Coast Guard headquarters facility, which will
house 3,860 Coast Guard employees. Phase 1-b is proposed to provide
203,000 square feet of shared support and other space and 350 parking
spaces. Phase 1-a and phase 1-b, according to GSA, are required to
fully support the Coast Guard's operations, and therefore are scheduled
to be completed together. This request also includes $26 million for
the design of phase 2.
* After not receiving any funding in fiscal year 2007, DHS has
requested $120 million for fiscal year 2008 to continue with its
consolidation plans for the St. Elizabeths site. According to DHS; DHS,
GSA, and OMB have developed a balanced funding stream that takes into
account the lack of fiscal year 2007 appropriations. In commenting on a
draft of this report, GSA expressed concern about its ability to meet
the U.S. Coast Guard requirements within its fiscal year 2008 St.
Elizabeths budget of approximately $347 million. This funding will be
used for Coast Guard headquarters construction costs over and above
what GSA is paying, tenant-specific phase 2 and phase 3 design costs,
and staffing costs. This is a portion of the $1.32 billion that DHS
estimates is needed for all costs associated with the development of
and move to St. Elizabeths.
* The balance of project funding for phase 2 ($491 million) was to be
requested in a future fiscal year. The goal of phase 2 is to provide
1.6 million square feet of highly secure housing plus parking garages
containing 2,000 spaces to consolidate other DHS components.
* Phase 3 would add another 1.6 million square feet of space to
accommodate what DHS hopes will be the bulk of its remaining
components.
According to GSA, the final cost of the St. Elizabeths West Campus
development will depend, initially, on the final Master Plan layout and
density selected and then by the final design and construction
contracts awarded by the federal government. GSA is currently preparing
the Master Plan for the redevelopment of the site and was originally
exploring seven development scenarios that ranged from 1.4 million to
4.5 million square feet of modern office space (plus parking) that
would reuse most of the historic structures on the site. However,
because the Coast Guard and Maritime Transportation Act of 2006
stipulated that the Coast Guard may not move to the site until, among
other things, a plan for the site includes a facility for at least one
federal agency other than the Coast Guard that houses no fewer than
2,000 employees, GSA said that it is no longer considering the two
alternatives that looked at developing only 1.4 million square feet of
space. Only the five alternatives that develop 3.0 million and 4.5
million square feet of space (plus parking) will now be
considered.[Footnote 35] DHS maintains that it currently plans to reuse
77 to 81 percent of the existing square footage that contributes to the
site's status as a National Historic Landmark, even in the most
intensely developed alternatives.
GSA plans to issue a draft Master Plan for public comment in July 2007
and to submit the final Master Plan by December 2007. According to GSA,
GSA and NCPC have agreed to a 60 day review for the preliminary and
final St. Elizabeths West Campus Master Plan submissions. As the
central planning agency for the federal government in the National
Capital Region, NCPC is charged with planning for the appropriate and
orderly development of the national capital and for the conservation of
important natural and historic features. To this end, NCPC is charged
with preparing a comprehensive plan for federal activities in
Washington, D.C., and reviewing the development plans for federal
agencies for consistency with the comprehensive plan. Under 40 U.S.C. §
8722, NCPC has approval authority over site and building designs and
uses NCPC-approved Master Plans as the basis for subsequent reviews and
approvals. The U.S. Commission of Fine Arts was established by Congress
in 1910 as an independent agency to advise the federal and District of
Columbia governments on matters of design and aesthetics that affect
the appearance of the nation's capital. One of the roles of the U.S.
Commission of Fine Arts is to provide advice on proposed building
projects.
Key Stakeholders Are Concerned about Historic Preservation,
Environmental Issues, and Impact on the Local Community:
In redeveloping St. Elizabeths, GSA must comply with the NHPA and the
NEPA. Under NHPA, federal agencies are required to consider the effects
of their activities on historic properties and to undertake planning
and actions necessary to minimize harm to the historic
property.[Footnote 36] As part of the NHPA process, GSA is consulting
with the D.C. State Historic Preservation Officer, the Advisory Council
on Historic Preservation, NCPC, the U.S. Commission of Fine Arts, and
many other groups. NEPA provides for the consideration of environmental
issues in federal agency planning and decisionmaking. NEPA requires
federal agencies, such as GSA, to prepare an environmental impact
statement for actions that may significantly affect the quality of the
human environment. GSA is conducting both reviews concurrently to avoid
duplication, since both are public processes and NEPA addresses
preservation issues as well as environmental concerns.
As part of its consultations with various organizations in developing
the Master Plan, DHS and GSA have encountered objections from several
key stakeholders that are concerned about whether the project would
comply with current historic preservation and environmental laws. Views
expressed are generally the views of senior staff and do not represent
the final positions of the organizations themselves, which will
officially provide comment as consulting parties once GSA submits its
draft Master Plan in July 2007. According to January 19 and September
21, 2006, letters submitted to GSA by NCPC's Executive Director, NCPC
is concerned that GSA's alternatives for the St. Elizabeths West Campus
thus far do not sufficiently protect the historic and natural settings
of the site. According to NCPC and other stakeholders, including the
U.S. Commission of Fine Arts, the Advisory Council on Historic
Preservation, the National Trust for Historic Preservation, and the
D.C. Office of Planning's Historic Preservation Office, DHS's
programmatic requirements are taking precedence over the preservation
and planning interests of the campus itself. NCPC and other
stakeholders are concerned that developing 4.5 million square feet of
office space, plus parking, for DHS at St. Elizabeths will not protect
the site's status as a National Historic Landmark District. Some
stakeholders maintain that developing this much space, as well as other
alternatives that have been discussed involving 3.0 million square
feet, will have significant, adverse effects on the historic setting
and character of the site and make mitigation and minimization under
NEPA and NHPA difficult if not impossible to achieve. Stakeholders
generally support federal use and maintain that the site can hold about
2.0 to 2.5 million square feet of development (plus parking) without
compromising the site's status as a National Historic Landmark
District.[Footnote 37]
In addition, according to the National Trust for Historic Preservation
(NTHP), each alternative requires a more thorough exploration of
options for off-site and underground parking, in order to minimize harm
to the maximum extent possible by reducing the additional mass and bulk
of aboveground structures in the National Historic Landmark District.
During our review DHS maintained that it currently plans to reuse 77 to
81 percent of the existing square footage that contributes to the
site's status as a National Historic Landmark District, even in the
most intensely developed alternatives.
GSA does not concur with stakeholders views on historic preservation
issues. According to GSA, it will, to the maximum extent possible,
undertake planning and actions necessary to minimize harm to the
landmark as is required by the National Historic Preservation Act. GSA
acknowledged that it had not yet developed an alternative that
reflected the views of many of the stakeholders, but stated that a
draft Master Plan would be available for review in July 2007 and that
certainly this was possible.
Furthermore, according to the NCPC Executive Director in a September
2006 letter, the proposed St. Elizabeths development does not address a
number of significant policies in the Comprehensive Plan for the
National Capital: Federal Elements, including policies to sustain
exemplary standards of historic property stewardship and to preserve
open space at St. Elizabeths for public use and enjoyment of views from
the site.[Footnote 38] GSA noted that although it may not address the
policies discussed above because sometimes there are trade-offs that
must be made in the process of developing a site, it does address the
vast majority of the Comprehensive Plan.
In addition, some stakeholders assert that GSA has not adequately
considered other DHS headquarters alternatives. For example, in a
letter dated January 26, 2007, the NTHP suggested that GSA could
explore financing the acquisition of an alternative site by disposing
of the St. Elizabeths campus for preservation-sensitive development.
GSA responded by stating that it is statutorily obligated to first
consider land that it owns to meet government housing needs. In
addition, GSA argues that it does not make financial sense to pay for a
lease or the costs of a land swap when the St. Elizabeths site can meet
DHS's needs if National Historic Landmark issues can be resolved
satisfactorily. Moreover, according to GSA, it will be able to preserve
the site's historic and natural character while developing 4.5 million
gross square feet of office space, plus parking. Overall, the debate
centers on how much development the site can accommodate while
protecting the site's status as a National Historic Landmark District.
In addition to concerns about the historic preservation and
environmental issues related to DHS's consolidation at St. Elizabeths,
D.C. planning officials and residents of the community have concerns
about how the proposed development will affect those living in the
area. The residents of Ward 8, the community that would be most
affected by the St. Elizabeths development, are primarily concerned
about increased traffic and whether the potential economic benefit of
job availability, contracting opportunities, and retail possibilities
will materialize. A D.C. planning official also expressed concern that
a federal presence there will offer no taxable infrastructure, require
increased public service response (fire, ambulance, hospital), and
expose the community to the risk of a terrorist attack. However, some
community leaders have stated in various public forums that they
support locating federal development at St. Elizabeths as an economic
driver and magnet for additional development and revitalization.
Master Plan Is Critical to the Consolidation's Outcome:
Critical to the outcome of the proposed consolidation is GSA's
development of the Master Plan, currently scheduled to be released for
comment by July 2007 and submitted by December 2007 to NCPC for review
and public comment. A completed plan should allow a better estimation
of the overall costs of this consolidation and should incorporate
stakeholders' concerns. Most stakeholders we contacted--including NCPC,
the Advisory Council on Historic Preservation, and the D.C. Planning
Office--acknowledge that GSA's outreach to the local community, review
agencies, and interested consulting parties has been extensive, even
though many stakeholders believe that GSA has not sufficiently
incorporated stakeholders' concerns into the five current Master Plan
alternatives by adding an additional alternative that accommodates
their concerns. GSA has not developed an additional alternative, but
says it has made modifications to the existing alternatives, including
moving development away from vistas and sight lines, preserving a
majority of the historic buildings, and limiting the height of new
buildings on the site.
Federal agencies are required to consult with NCPC prior to the
preparation of construction plans originated by the agency for proposed
developments and projects within the National Capital Region. According
to NCPC, once GSA's draft Master Plan is completed, NCPC will review it
for compliance with federal environmental and historic preservation
laws. NCPC will prepare a report with recommendations to the agency,
which GSA must consider. GSA hopes its efforts to reach out to
stakeholders and resolve their concerns will conclude with an agreement
with the D.C. State Historic Preservation Officer and Advisory Council
on Historic Preservation as signatories.
DHS Has Taken Actions Intended to Improve the Security of Its
Facilities, but Its Efforts Are Lacking in Certain Key Areas:
DHS has taken a number of actions intended to improve the security of
its facilities. Like other federal agencies, DHS has made physical
improvements at the individual building level, such as adding pop-up
bollards, installing bullet-resistant glass, and implementing access
controls in many buildings across the department. For example, ICE is
using new smart-card technology through a security pilot project at
several of its facilities across the country, including Federal Plaza
in New York City. The Coast Guard is using the latest technology to
evaluate the credentials of contractors. FLETC is using bullet-
resistant glass at key access control points and pop-up bollards to
repel unauthorized vehicles. FLETC has also established fingerprint
systems and captures facial images via digital cameras to improve
access control. FEMA has installed pop-up bollards and added
surveillance cameras to its headquarters in downtown Washington. TSA
told us that it utilizes closed circuit television, contract security
guards, access control, intrusion detection and vehicle security
barriers. TSA also told us that it has established network connectivity
for its closed circuit television at its Washington, D.C. facilities,
enabling the TSA Chief Security Officer and his headquarters staff to
monitor each facility.
DHS security officials said that increasing the use of technologies
like access controls, while requiring an initial up-front investment,
would save DHS money in the long run since fewer guards would be
needed. It would also improve security they said. At DHS's Nebraska
Avenue Complex, for example, where some of DHS' headquarters offices
are located, DHS uses glass-partitioned turnstiles with access control
card readers to give cleared employees access at this location.
Employees swipe their access card and if the card is approved, the
turnstile opens. The access control validates the card without
involving guards. DHS has backed up this system through the use of
closed circuit television cameras that monitor the turnstiles. All
activity is recorded by digital video that can be reviewed if necessary
following a breach. By efficiently using technology to supplement and
reinforce other security measures, DHS can more effectively address
vulnerabilities that are identified by the risk-management process with
appropriate countermeasures. Our past work showed broad concurrence
among GAO, Inspectors General, facility security experts, and agency
experts that making efficient use of security technology to protect
federal facilities is a key practice.[Footnote 39]
DHS Has Taken Actions to Improve Communication among Components and
across Functional Lines:
Besides taking actions at the individual building level, DHS has
implemented several management changes intended to improve facility
protection. DHS has designated a Chief Security Officer for the
department and established a Chief Security Officer Council to assist
the Chief Security Officer in evaluating security issues.[Footnote 40]
In addition, DHS's Chief Administrative Officer, Chief Security
Officer, and ISC personnel are working together to integrate physical
security programs and plans into DHS's overall real property management
program. DHS real property management officials and physical security
officials have begun to communicate and coordinate regularly through
meetings. For example, DHS real property and security officials are
collaborating on the design of the St. Elizabeths site headquarters
buildings to ensure that building designs are properly evaluated from a
security perspective. The security coordinator makes certain that
security features are considered early and incorporated into each
building's design. This coordination should reduce the need for making
costly changes later or creating security risks that are impossible to
mitigate later. The coordination has also led to discussions about
including physical security data, such as data on compliance with ISC
standards and security levels, in DHS's Real Property Information
System. Coordination also allows DHS's physical security officials to
provide input upfront about how real property decisions affect physical
security. For example, if DHS decides to rent one floor of a particular
office building, consideration must be given to the consequences of
DHS's presence there. DHS often ends up needing to secure the entire
building, which can be costly, or DHS cannot afford to secure the
entire building, which may pose a security risk. DHS currently occupies
about 2,400 office buildings that are leased or owned, so there is
considerable potential for security savings if security is considered
upfront.
DHS has also improved internal security coordination in other ways. For
example, DHS has formed the Facility Security Commodities Council,
which meets once every 2 months to discuss security issues and share
information, such as which companies are providing the best contract
guard service, what to include in a standard contract for guard forces,
or how to add on to security equipment contracts to get security
equipment such as X-ray machines less expensively. Information sharing
and coordination among organizations are crucial to producing
comprehensive and practical approaches and solutions to address
terrorist threats directed at federal facilities. Our work showed a
broad consensus--on the basis of prior GAO and Inspector General work
and information from agencies and the private sector--that by having a
process in place to obtain and share information on potential threats
to federal facilities, agencies can better understand the risk they
face and more effectively determine what preventive measures should be
implemented. Establishing a means of coordinating and sharing
information is crucial to determining the appropriate amount of
security for facilities.
DHS also plays an important role in developing guidance for federal
agencies and its own components to follow in protecting federal
facilities against the threat of terrorism through ISC, which DHS
chairs. ISC, which includes representatives of all the major property-
holding agencies and was established after the bombing of the Oklahoma
City federal building in 1995, has a range of governmentwide
responsibilities relating to protecting nonmilitary facilities. These
generally involve developing policies and standards, ensuring
compliance and overseeing implementation, and sharing and maintaining
information. To ensure that DHS itself follows ISC guidance, draft DHS
Management Directive 11001 formalizes the requirement that DHS
components meet ISC standards.[Footnote 41] The compliance reporting
process will begin in 2008. For example, beginning in 2008, each
component must report how many of its buildings are in compliance with
Management Directive 11001 and, if not, it must provide an explanation.
DHS has also recently developed a compliance checklist, which provides
a baseline of basic physical security considerations that DHS's
components can use in determining what facility protection activities
they need to undertake.
DHS Has Not Yet Fully Implemented Risk Management Practices for Its
Facilities:
Despite these improvements and DHS's prominent role in facility
protection governmentwide, most DHS components have not fully
implemented risk management for facility protection, which we have
recommended and DHS has advocated for other agencies, or the components
use risk management tools that DHS officials said have limited
capabilities. DHS components are in the process of determining risk
management methodologies to assist in prioritizing resources. Some
components, such as ICE, currently use a risk management tool with
capabilities that, according to FPS officials, are not as robust as
necessary to fully prioritize security needs. FPS, located within ICE
and responsible for protecting thousands of federal facilities,
conducts security risk assessments for ICE and for all DHS space leased
through GSA using risk management software. FPS officials said that
this tool is not sophisticated enough to effectively allow them to
prioritize physical security improvements building by building. FPS
officials have three primary concerns about the current risk management
tool. First, current risk management software does not allow FPS to
compare risks from building to building so that security improvements
to buildings can be prioritized. Second, current risk assessments need
to be categorized more precisely. Too many assessments are simply
categorized as high or low, which does not allow for a refined
prioritization of security improvements. Third, the risk management
tool does not allow for tracking the implementation status of security
recommendations based on assessments. CIS also uses FPS's risk
management tool to conduct its risk assessments. According to FPS, FPS
is leading the development of a new software tool that will meet
obligations under the National Infrastructure Protection Plan. In
partnership with other DHS components, including CBP and FEMA, this
risk assessment and management program will be made available to all
government entities in need of a risk assessment methodology. FPS
expects this tool to be available by fiscal year 2008.
Some components are closer to fully implementing risk management
practices to prioritize resources than others. For example, the Coast
Guard has an initiative under way to tier its assets into categories to
help prioritize facility protection resources for the assets that are
most critical to DHS's core mission. The Coast Guard has been
conducting vulnerability assessments within each tier for the past year
and a half. Components such as FEMA and TSA do not use formal risk
assessment tools to prioritize security resources across the component.
FEMA, for example, prioritizes security resources through the judgments
of security officials using criteria such as the seriousness of the
security issue, the location, and the resources available at the time.
TSA noted that although it does not use a formal risk assessment tool
to prioritize resources across the department, it has conducted a risk
assessment for its headquarters and Transportation Security Operations
Center, based on threat and vulnerability assessments and incorporated
additional appropriate security measures across its facilities.
DHS headquarters security officials said that while DHS components do
not have a formal, common tool to conduct risk assessments to
prioritize funding for facility protection, components can rely on ISC
criteria and DHS's June 2006 National Infrastructure Protection Plan
for risk management guidance.[Footnote 42] ISC places federal
facilities in five different categories (with corresponding security
standards) based on factors such as building size, agency mission and
function, tenant population, and level of public access. For example, a
level II building is defined as having between 2,500 to 80,000 square
feet and between 11 and 150 employees engaged in routine activities
with a moderate level of public access. A level IV building is defined
as occupying more than 150,000 square feet of space and housing more
than 450 employees with a "high volume of public contact." At each
level of security, ISC specifies minimum security standards that must
be met.[Footnote 43] The National Infrastructure Protection Plan risk
management framework establishes a process for combining consequence,
vulnerability, and threat information to produce a comprehensive,
systematic, and rational assessment of risk that drives protection
activities for a component. According to senior DHS headquarters
security officials, each component within DHS must develop its own risk
assessment program and ensure that they are aligned with its mission
and needs.
A more robust risk management approach can help DHS make decisions
systematically and is consistent with the National Strategy for
Homeland Security and DHS's strategic plan, which have called for the
use of risk-based decisions to prioritize DHS's resource investments in
homeland security-related programs. Likewise, the President and
Congress have widely supported a risk management approach for homeland
security, and the Secretary of Homeland Security has made risk
management the centerpiece of departmental policy. Allocating resources
using risk management is a systematic and analytical process to
consider the likelihood that a threat will endanger an asset, such as
real property, and identify, evaluate, select, and implement actions
that reduce the risk or mitigate the consequences of an event. Although
risk management principles can be applied to facility protection in
various ways, our past work has shown that most risk management
approaches generally involve identifying potential threats, assessing
vulnerabilities, identifying the assets that are most critical to
protect, in terms of mission and significance, and evaluating
mitigation alternatives for their likely effect on risk and their cost.
In short, risk management is useful for ensuring that security
resources are directed where they are needed most. Our past work has
also shown that there was consensus in the security community--
including GAO, inspectors generals, agencies, national experts, and the
private sector--that using risk management practices provides the
foundation for an effective facility protection program.
Some agencies we have reported on use more robust methods of risk
management. For example, as we reported in June 2005, the Department of
the Interior (Interior) has developed a uniform risk assessment and
ranking methodology called the National Monuments and Icons Assessment
Methodology.[Footnote 44] According to information from Interior, this
methodology is specifically designed to quantify risk, identify needed
security enhancements, and measure risk-reduction benefits at icons and
monuments. The National Monuments and Icons Assessment Methodology has
a consequence assessment phase and a risk assessment phase. During the
consequence assessment phase, there is an asset tier ranking process,
in which each asset's iconic significance is subjectively determined.
Specific attack scenarios--involving threats such as chemical/
biological agents, aircraft, or improvised explosive devices--are used
to evaluate security at each asset and score attack consequences.
Consequence categories include casualties, economic impact, and length
of disruption. During the risk assessment phase, Interior uses the
methodology to determine the effectiveness of existing security systems
for preventing or mitigating the specified attack scenarios. Using risk
values calculated from this comparison, Interior assigns asset risk
ratings of high, medium, or low, and formulates specific mitigation
recommendations. Before developing this approach, Interior did not have
a uniform, comprehensive risk management approach for icons and
monuments. It relied instead on the judgment of senior officials in
determining where resources should be directed, and the risk
assessments completed at individual sites were done by a number of
external experts using different methodologies.
DHS Has an Incomplete Set of Facility Protection Performance Measures
to Help Ensure Agency Accountability for Meeting Program Goals:
Under HSPD-7, the Government Facilities Sector, for which ICE is
responsible, is tasked with establishing performance measure guidance
for federal, state, and local governments so that they can better
assess the effectiveness of their facility protection programs. ISC is
working with the Government Facilities Sector to develop this
performance measure guidance. It is expected that this guidance will be
complete at the end of fiscal year 2007. This guidance is designed to
measure agency-level performance; it does not address facility-specific
performance measures.
Even though DHS has a leadership role in this area, none of its
components had a fully established set of agency-and facility-specific
physical security performance measures to evaluate the effectiveness of
physical security programs at the time of our review. Some components
are in the process of developing measures or have an incomplete set.
For example, TSA does not have a set of performance measures to fully
evaluate how it protects its facilities, but said it was currently
considering using performance measures such as the number of
unauthorized people who enter a building or the number of people who
are blocked at entrances. TSA also noted that it considers its facility
protection to be successful because it has no known breach in its
headquarters and Transportation Security Operations Center. FEMA
officials told us that in order to assess its progress in improving
security, the agency needs to develop performance measures that allow
it to track security assessments and recommendations. FPS, located
within ICE, currently has a number of performance measures to assess
facility protection effectiveness, but noted that the measures could be
improved. FPS said that it tracks measures such as whether building
countermeasures are working as designed, whether countermeasures are
deployed on time, and how quickly FPS responds to calls for service.
FPS officials said that upgraded risk assessment software would aid
them in tracing facility protection performance measures. For example,
FPS said that it would like to better track how long it takes for its
MegaCenters,[Footnote 45] which are FPS's regional emergency call
centers, to respond to alarm calls. FPS is tracking call response times
to some degree now but is unable to distinguish between major and minor
calls, which officials said can create misleading data. In September
2006, we reported that performance measures for assessing MegaCenter
operations are not always clearly stated or measurable and do not
address governmentwide priorities of efficiency, cost of service, and
outcome--which are among the attributes of successful performance
measures that we have identified.[Footnote 46] Other DHS components
noted that some facility protection efforts can be difficult to
measure. For example, CIS and TSA noted that it is difficult to
demonstrate when an agency has stopped or deterred an attempted
unauthorized entrance to a building with security countermeasures or
best practices because it is typically not possible to know when such
unauthorized attempts occur.
Performance measurement can ensure accountability for achieving broad
program goals and improving security at the individual facility level.
At the agency level, we have reported that tying security goals to
broader agency mission goals can help federal agencies measure the
effectiveness and ensure the accountability of their security programs.
Our work has shown a consensus among various stakeholders that
performance measurement is a key practice that agencies should follow.
Using performance measurement for facility protection is a practice
that--according to our review--is in the early stages of development at
DHS at the agency-and facility-specific levels. In May 2006, we
reported on performance measures that organizations outside the U.S.
government--including private-sector firms, state and local
governments, and foreign government agencies--use to help improve the
security of facilities, inform risk-management and resource-allocation
decisions, and hold security officials and others in their
organizations accountable for security performance.[Footnote 47] These
included output measures, such as the average time needed to process
background screenings, and outcome measures, such as the change in the
total number of security incidents relating to thefts, vandalism, and
acts of terrorism. For example, an agency in Australia monitors an
outcome measure--the impact of additional security expenditures on a
facility's risk rating--while controlling for existing security
enhancements that mitigate the risk, such as the number of guard
patrols and the adequacy of access control systems (e.g., electronic
locks). In another example, each business line in one financial
services organization conducts security compliance reviews of its
facilities, including confirming the presence of required key security
equipment and determining whether staff are following security
policies.
FPS Faces Ongoing Challenges:
FPS protects buildings under GSA's control, including those where DHS
is a tenant. After the creation of DHS, FPS moved from GSA to the new
department effective March 1, 2003. In fiscal year 2007, FPS has 1,208
full-time employees, including special agents, police officers,
inspectors, and support personnel.[Footnote 48] Approximately 15,000
contract security guards support FPS's workforce. FPS is required to
protect about 8,800 buildings under GSA's control, many of which are
leased by DHS. Even though it has the authority, FPS does not protect
any DHS buildings outside GSA space because it lacks resources. Most
DHS components rely on security arrangements that existed before DHS
was formed in 2003. The demands of its facility protection
responsibilities to protect GSA facilities challenge FPS. FPS charges a
basic security fee for services such as law enforcement and regular
building security assessments, but this fee does not adequately cover
the costs of the basic security services that FPS is required to
provide. One of the tasks that FPS must conduct in its role as a
protector of federal buildings is building security assessments.
Building security assessments are a type of security evaluation to
determine how susceptible a facility is to various forms of threat or
attack. These assessments include countermeasures to reduce threats and
thereby decrease vulnerability.[Footnote 49] DHS officials said that
some components conduct their own building security assessments over
and above the security assessment conducted by FPS. DHS components
sometimes conduct their own assessments because FPS's assessments are
not always timely or of sufficiently high quality.
Senior DHS physical security officials said that FPS does not have the
staff resources to conduct all of these regular assessments in a timely
manner, but these officials also say problems with the quality of the
assessments are most likely attributable to a lack of quality training
for FPS personnel in conducting the assessments. Conducting extra
assessments wastes resources, while not completing assessments in a
timely fashion imperils the security of DHS facilities. FPS agreed that
it does not have an adequate number of building security assessors for
the number of buildings in its inventory. FPS estimated that there are
about 450 inspectors for about 8,800 GSA buildings that FPS is required
to protect. FPS said that in some areas, especially in the western
United States, a single inspector must cover all of the buildings over
a wide area. FPS said that some inspectors are responsible for as many
as 50 buildings, and each inspection can take 1 week or more. FPS noted
that inspectors have responsibilities other than inspections, such as
teaching security training classes, crime prevention, and law
enforcement patrol and response. However, because of the large
geographic areas some inspectors are required to cover, they must spend
a significant amount of time and travel funds performing inspections.
According to FPS, the time it takes to conduct assessments, travel, and
perform other duties can make it difficult to conduct timely
inspections. FPS believes that an increased number of inspectors in
some regions would help save money in the long run by cutting travel
expenses.[Footnote 50]
In order to solve this problem, senior DHS physical security officials
suggested that DHS establish consistent building security assessment
training. This training would provide a core basis for conducting
assessments across DHS, regardless of whether FPS or the components
conduct them and would help ensure that assessments are completed
consistently. One senior DHS security official noted that GSA has a 4
to 5 week training course for procurement that might serve as a model
for how DHS could conduct the assessment training. DHS's Federal Law
Enforcement Training Center recently completed a feasibility study that
proposed the creation of a standard physical security training program
for all federal agencies involved in physical security. Physical
security assessment training would be part of this physical security
training program. Security assessment training would help ensure that
assessments are completed consistently and do not need to be conducted
twice.[Footnote 51]
As we reported in July 2004, maintaining a means of funding FPS that
will ensure adequate protection of federal facilities and allow FPS to
meet homeland security responsibilities is a challenge. DHS maintains
that the funding FPS receives from basic security fees is not nearly
enough for FPS to provide adequate basic security service.[Footnote 52]
FPS reported in November 2006 that it faced a funding shortfall of $60
million. FPS officials said that FPS cannot always provide basic
security services requested by some DHS and other non-GSA entities
because FPS lacks funding for additional employees. For example, FPS
has received requests for security services from Indian Reservation
Hospitals and the Social Security Administration that it was not able
to fulfill.
Compounding the challenges FPS faces, FPS officials noted that DHS
components are often unable to implement recommendations in FPS
assessments. For example, CIS is aware that it needs bollards and
garage and driveway barriers at its headquarters building, but it has
not been able to prioritize funding to implement these measures. In
other instances, FPS noted that it may conduct a security assessment
for a component, but because of a lack of funding or a lag in funding,
recommendations are not implemented for 18 to 24 months. That leaves a
component vulnerable for as long as 2 years, and by that time, the
recommendation may have changed in priority. In addition, some
components, such as FEMA, CIS, and S&T, said that the response time and
quality of FPS's security assessments need improvement, partially
because of the demands placed on FPS by its expanding mission. Senior
DHS physical security officials said that FPS needs to redefine its
role and core mission to focus on work that it can handle, given its
budget and the training and qualifications of its employees. In
response to our recommendation of almost 3 years ago, FPS is developing
a transformation plan, although this plan has not been
finalized.[Footnote 53]
DHS Has Not Developed a Physical Security Plan As Required under HSPD-
7:
DHS clearly faces a number of challenges related to the protection of
its own facilities but has not developed a physical security plan. The
challenges DHS faces--such as implementing risk management, measuring
performance, and funding needed security enhancements--are similar to
those faced by many agencies. HSPD-7 recognized the need for an
organized, carefully considered approach to protecting physical assets,
including facilities, and required that all federal departments and
agencies develop physical security plans. Specifically, HSPD-7 states:
"By July 2004, the heads of all Federal departments and agencies shall
develop and submit to the Director of the OMB for approval plans for
protecting the physical and cyber critical infrastructure and key
resources that they own or operate. These plans shall address
identification, prioritization, protection, and contingency planning,
including the recovery and reconstitution of essential capabilities."
DHS officials believe that the 2006 National Infrastructure Protection
Plan, which provides an overarching approach for integrating the
nation's many critical infrastructure and key resource protection
initiatives into a single national effort, serves as DHS's physical
security plan. However, the National Infrastructure Protection Plan
does not address the "identification, prioritization, protection, and
contingency planning, including the recovery and reconstitution of
essential capabilities," specifically for DHS-occupied facilities.
Having such a plan would be particularly useful for DHS and its
stakeholders--including OMB and Congress--in devising a course of
action for protecting DHS facilities and making associated funding
trade-offs. Furthermore, it is imperative that DHS, as the government's
central agency for protection against terrorism, lead by example in
formulating how the department itself is approaching the range of
difficult challenges that agencies across government also face in the
facility protection area.
Conclusions:
Like other agencies, DHS faces real property challenges, including
excess and deteriorating property, data quality issues, reliance on
costly leasing, and the threat of terrorism against its facilities. DHS
also faces funding and budgetary limitations, which are often at odds
with businesslike decisions. Given the size and diversity of DHS's
portfolio, the challenges it faces, and the importance of DHS's
mission, it is critical that DHS implement the requirements of the
President's real property initiative, which DHS has made progress in
doing recently. As DHS's efforts to strategically manage its property
progress, greater emphasis on long-term capital planning, which needs
improvement, could help DHS make the most of limited resources and make
timely and effective capital acquisitions. It would be particularly
beneficial for DHS to link such capital planning efforts--such as the
development of a departmentwide long-term capital plan--to its asset
management planning efforts under the real property initiative, because
DHS inherited the real property held by its components' former agencies
and is faced with realigning these assets in the coming years.
Shortcomings in the capital planning area have clear implications for
the administration's real property initiative. Real property is one of
the major types of capital assets that agencies require. Since asset
management plans developed under the real property initiative are
intended to guide agencies' year-to-year real property management
actions, capital plans could provide a useful longer term context for
agencies' real property decisions.
DHS faces a number of significant challenges related to its planned
consolidation of Washington, D.C., headquarters operations on the West
Campus of St. Elizabeths, which is a National Historic Landmark
District. DHS believes that by consolidating most of its headquarters
operations, greater efficiencies would result, mission integration
would occur, and the security of its facilities could be better
managed. The cost of the consolidation could be at least $3.26 billion,
according to GSA. GSA has conducted some analysis to justify developing
the West Campus of St. Elizabeths to consolidate DHS's headquarters.
However, GSA and DHS lack a more comprehensive cost analysis that would
improve transparency and in the context of all the other factors--such
as programmatic and security goals--would help decision makers,
including Congress, better understand the cost trade-offs of developing
a variety of densities and configurations at the site and assess the
merits of the consolidation from the perspective of the federal
government as a whole.
In the area of security for the buildings DHS itself occupies, DHS has
implemented a number of management-and building-specific actions.
However, DHS has not fully implemented risk management for facility
protection across all of its components, has not developed a full set
of performance measures, and has not developed a physical security plan
as is required under HSPD-7. DHS has also lagged in developing a
transformation strategy to address problems at FPS, which we
recommended almost 3 years ago. With its critical role in protecting
federal real property against the threat of terrorism and other
criminal activity and given its expanding mission and funding and
staffing shortfalls, FPS could benefit from a transformation strategy
that effectively makes the case for what type of organization it
believes it should become and provides a road map for getting there. We
made this recommendation previously in July 2004. FPS has drafted, but
not finalized, such a plan. Although the challenges DHS faces are
similar to those other agencies have faced, it is critical that DHS
lead by example in protecting its own facilities against the threat of
terrorism.
Recommendations for Executive Action:
We recommend that the Secretary of Homeland Security take the following
two actions:
* In order to make the most of limited resources and to make timely and
effective capital acquisitions that will result in a decrease of long-
term real property costs, the Secretary should use the Office of
Management and Budget's capital planning principles to link DHS's long-
term capital needs with the asset management planning activities
required under the President's real property initiative.
* In order to lead by example by formulating how the department itself
is approaching the range of difficult challenges that agencies across
government face in the facility protection arena, the Secretary should
develop a physical security plan for DHS, as required by HSPD-7, that
addresses DHS's plans to fully implement risk management and develop
performance measures for facility protection.
We recommend that both the Secretary of Homeland Security and
Administrator of the General Services Administration take the following
action:
* In order to better support DHS's preferred course of action at St.
Elizabeths, the Secretary and Administrator should jointly perform a
comprehensive analysis of the costs, from the perspective of the
federal government as a whole, that would result if DHS headquarters
operations are consolidated at St. Elizabeths, and compare these costs
to the costs of other alternatives at the St. Elizabeths campus.
Agency Comments and Our Evaluation:
We provided a draft of this report to DHS, GSA, NCPC, the Advisory
Council on Historic Preservation, the U.S. Commission of Fine Arts, and
the D.C. Office of Planning. DHS concurred with our recommendations to
link DHS's long-term capital needs with its asset management planning
activities and to develop a physical security plan, but it only
partially agreed with our recommendation to develop a comprehensive
cost analysis, from the perspective of the government as a whole, for
the St. Elizabeths site. DHS's comments are discussed below and are
contained in appendix III, along with our specific comments on issues
raised by DHS. DHS also provided technical clarifications, which we
incorporated, where appropriate. GSA partially agreed with the findings
related to the potential development of St. Elizabeths, but it did not
concur with our recommendation that GSA and DHS perform a comprehensive
analysis of the costs to consolidate DHS's headquarters at the St.
Elizabeths site. GSA's comments are discussed below and are contained
in appendix IV, along with our specific comments on issues raised by
GSA. GSA also provided technical clarifications, which we incorporated,
where appropriate. Comments received from NCPC, the Advisory Council on
Historic Preservation, the U.S. Commission of Fine Arts, and the D.C.
Office of Planning are contained in appendixes V through VIII,
respectively, and are discussed below in more detail. NCPC, the
Advisory Council on Historic Preservation, the D.C. Office of Planning,
and the U.S. Commission of Fine Arts commented on the St. Elizabeths
portion of the report. NCPC said that the document is an accurate
reflection of NCPC's concerns and understanding of the project. NCPC
also emphasized that all comments in the report are those of staff and
not of NCPC itself. The D.C. Office of Planning generally agreed with
the findings of the report and provided additional information, which
we have incorporated in this report as appropriate. The U.S. Commission
of Fine Arts did not comment on our recommendation related to DHS's
consolidation and provided additional information, which we
incorporated as appropriate. The Advisory Council on Historic
Preservation agreed with our recommendation that DHS and GSA jointly
perform a comprehensive cost analysis for the variety of alternatives
at the St. Elizabeths site and provided additional information, which
we incorporated as appropriate.
Evaluation of DHS and GSA Comments:
DHS concurred with our recommendations to link DHS's long-term capital
needs with its asset management planning activities and to develop a
physical security plan, but it only partially agreed with our
recommendation to develop a comprehensive cost analysis for the St.
Elizabeths site. According to GSA and DHS, GSA is actively engaged in
determining the overall real property costs for DHS in the Washington,
D.C., area. However, DHS stated that the recommendation ignores the
fact that DHS cannot operate effectively, as currently housed, and
believes that consolidation is a requirement, not a desire. DHS also
stated that it will not renew a lease after it expires unless it
consolidates functions, improves efficiencies, eliminates duplication
and is economically feasible. DHS further stated that our draft report
did not acknowledge that the "status quo" scenario is not acceptable.
GSA did not concur with our recommendation regarding a comprehensive
cost analysis. GSA stated that such an analysis would be misleading and
ignores the fact that DHS's current housing configuration is
unacceptable. GSA also stated that DHS would not renew leases in place,
but that the department would seek to consolidate its headquarters
functions through another vehicle.
We agree that DHS's current housing configuration is not optimal and
did not suggest that the status quo should be maintained. Instead, our
report intends to convey our belief, on the basis of work done for this
review, that Congress needs better information on the costs associated
with redeveloping St. Elizabeths--for a range of alternatives and from
the perspective of the government as a whole--in order to fund and
oversee a construction undertaking of this magnitude. Understanding the
costs associated with the "status quo," which would involve renewing
current leases and finding other housing solutions, would serve as an
important baseline for comparison. Having a comprehensive analysis of
the costs of various development scenarios at the St. Elizabeths site,
including DHS's and GSA's preferred development of 4.5 million square
feet of office space (plus parking) would improve transparency and help
Congress better understand the costs and operational trade-offs of
development at various densities and configurations at the site. We are
concerned that DHS and GSA will only analyze the 4.5 million square
foot options. We believe that the merits of other options could be
evaluated, given the concerns expressed by key stakeholders regarding
the DHS-and GSA-preferred density level and the fact that funding
availability for the project as a whole has not been determined by
Congress.
If anything less than the DHS-and GSA-preferred alternative is
unacceptable, as DHS and GSA have maintained, a comprehensive analysis
could be the vehicle for making this case to Congress. In this regard,
an assessment of DHS's current configuration would help Congress fully
understand why the status quo, or lesser densities than DHS and GSA are
pursuing, are unacceptable. The analysis could also help stakeholders
understand the long-term costs to the federal government as a whole--
whether incurred by DHS, GSA, or the Department of Health and Human
Services, as well as the District of Columbia--and how these long-term
costs would vary depending on the amount of square footage developed at
the St. Elizabeths site.
It is also important to note that in the report, in the interest of
being fair and balanced, we describe the arguments of DHS and GSA for
consolidation, while also describing the concerns of stakeholders, so
that Congress can understand the various viewpoints. We are also fully
aware, as GSA stated in its comments, that GSA has conducted some
analysis to justify developing the West Campus of St. Elizabeths to
consolidate DHS's headquarters. We also agree that use of the St.
Elizabeths site for DHS's headquarters would make use of previously
underutilized federal property and that excess and underutilized
property has been a GAO concern in previous reports. However, as
discussed above, a more comprehensive cost analysis--in the context of
all the other factors, such as programmatic and security goals--would
help decision makers better understand the cost trade-offs of
developing a variety of densities and configurations at the site.
After sending us its official comments, GSA revised its estimate of the
cost to develop St. Elizabeths to $3.26 billion with GSA incurring
$1.94 billion of costs and DHS incurring $1.32 billion of costs. GSA
also provided updated transportation improvement estimates to streets,
roads, and highways in the vicinity of St. Elizabeths to support the
federal redevelopment project. Updated total costs for transportation
improvements range from $27 million to $40 million, of which DDOT's
costs range between $4 million and $14 million, according to GSA. GSA
has budgeted for the difference between total costs and what DDOT will
pay, based on current GSA estimates. For the purposes of this report,
we used GSA's most recent estimates. However, we believe that these
changing cost estimates, and the confusion about them that we
encountered, demonstrate the value of a comprehensive cost analysis
that would improve transparency and allow for more informed decision
making.
We also examined the additional information that DHS and GSA provided
to us after agency comments. We incorporated this new information as
appropriate, but it did not change our recommendation that DHS and GSA
should jointly conduct a more comprehensive cost analysis.
Evaluation of the D.C. Office of Planning Comments:
The D.C. Office of Planning agreed with our recommendation calling for
a comprehensive analysis of the cost to develop St. Elizabeths under
various development scenarios for the St. Elizabeths. The Office of
Planning also appreciated the thorough and thoughtful assessment of the
numerous effects that arise from the potential consolidation of DHS
operations on the West Campus of St. Elizabeths Hospital. It also
provided additional comments. For example, the Office of Planning
clarified that it supported federal development at the St. Elizabeths
West Campus but is concerned with the magnitude of the project and its
effects. The Office of Planning also expressed concern that GSA is not
considering a development alternative of 2.0 to 2.5 million square feet
of office space that aligns with the views of most of the stakeholders
and consulting parties. The office is also concerned about how to
control growth at the St. Elizabeths site once an agreed upon square
footage is established. Lastly, the office said that eliminating the
lowest density alternatives--and failing to explore all of the feasible
alternatives--is contrary to both the expressed intention of the Master
Plan document itself and to the letter and spirit of both the NEPA and
the regulations implementing Section 106 of the National Historic
Preservation Act. See appendix V for the full comments provided by the
D.C. Office of Planning.
Evaluation of NCPC Comments:
NCPC, in a letter from its Executive Director, said that our report is
an accurate reflection of NCPC's concerns and understanding of the
project. NCPC also noted that it has not yet had the opportunity to
formally review and comment on the St. Elizabeths project. As a result,
all comments are those of the staff and not of NCPC itself. See
appendix VI for the full comments provided by NCPC.
Evaluation of the Advisory Council on Historic Preservation Comments:
The Advisory Council on Historic Preservation (Council) agreed with our
recommendation that DHS and GSA jointly perform a comprehensive cost
analysis for a variety of alternatives at the St. Elizabeths site. The
Council letter stated that insufficient information has been provided
to demonstrate how much cost savings may be realized by DHS through the
redevelopment of the St. Elizabeths campus in comparison to other
alternatives. The Council letter also stated that many other consulting
parties continue to express this concern in the context of the National
Historic Preservation Act consultation process and that further
justification and explanation would facilitate more effective
consultation. The Council letter also stated that the report adequately
documents the concerns of stakeholders and the challenges faced in
addressing these concerns. Lastly, the Council letter stated that it
would like to see further discussions on the importance of the National
Historic Landmark District and the criteria that the National Park
Service utilizes for determining the site's historic significance. See
appendix VII for the full comments provided by the Advisory Council on
Historic Preservation.
Evaluation of U. S. Commission of Fine Arts Comments:
The U.S. Commission of Fine Arts (Commission) did not comment on our
recommendations, but said that our report did not fully discuss the
value of the St. Elizabeths property. The Commission acknowledged that
we discussed the impact of the DHS consolidation on traffic, the cost
of providing public services, and the economic revitalization of the
community. However, the Commission said that we did not adequately
discuss the site's historic and cultural value related to the history
of the treatment of mental illness and as a hospital site during the
Civil War, the architectural value of many buildings, or the ecological
value of the site, including serving as a habitat for endangered
species. We incorporated a discussion of these factors into our report.
The Commission also stated that other values of St. Elizabeths include
its value as potentially positive generator of urban development and
its stunning views. We believe that we captured these points with our
statement that some community leaders support locating federal
development at St. Elizabeths as an economic driver and magnet for
additional development and revitalization and our discussion of the
scenic views of the District being available from the site. See
appendix VIII for the full comments provided by the U.S. Commission of
Fine Arts.
As agreed with your office, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days
from the report date. At that time, we will send copies to the
Secretary of DHS, the Administrator of GSA, the Chairman and Executive
Director of NCPC, the Chairman of the Advisory Council on Historic
Preservation, the Secretary of the U.S. Commission of Fine Arts, and
the Director of the D.C. Office of Planning. Additional copies will be
sent to interested congressional committees and the Director of OMB. We
will also make copies available to others upon request, and the report
will be available at no charge on the GAO Web site at
http://www.gao.gov.
If you have any questions about this report, please contact me at (202)
512-2834 or at goldsteinm@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last
page of this report. GAO staff who made key contributions to this
report are listed in appendix IX.
Sincerely yours,
Signed by:
Mark L. Goldstein:
Director, Physical Infrastructure Issues:
[End of section]
Appendix I: Scope and Methodology:
To answer our first question, we obtained and analyzed Department of
Homeland Security (DHS) and General Services Administration (GSA) real
property data from DHS's Real Property Information System, DHS's
centralized real property database and GSA's Federal Real Property
Profile, its centralized real property database. We also interviewed
(1) DHS real property officials from headquarters, (2) DHS officials
responsible for DHS's Real Property Information System, (3) a
contractor that is helping DHS develop its real property inventory, and
(4) GSA officials responsible for GSA's Federal Real Property Profile.
In addition to assessing the information we obtained about the data
from these interviews, we conducted electronic testing of the data.
These tests included logic tests, tests for duplicates, and checking
frequencies and values for outliers. It was during this assessment and
our interviews that we discovered deficiencies with some of the data
elements. For example, some DHS components are using data proxies for
some data elements--such as condition index, operating costs, and
restrictions--until these components can develop more robust data
measures. We do not present data on any of these data elements--which
DHS acknowledges it is working to improve--in the body of the report.
However, we determined that the DHS and GSA real property data (such as
total number of buildings and structures) that we are presenting in the
report were sufficiently reliable for the purposes of our review.
To answer question 2, we interviewed DHS real property officials from
headquarters and DHS's various components about challenges and used
Executive Order 13327, which implements the real property initiative of
the President's Management Agenda, as the basis for measuring DHS's
progress in real property management. For questions 1 and 2, we also
interviewed Office of Management and Budget (OMB) staff because of
OMB's oversight role in real property management. We reviewed and
analyzed key pertinent documentation, including DHS's asset management
plan, Federal Real Property Council guidance, OMB's assessment of DHS's
progress, and OMB guidance.
To answer question 3, we reviewed and analyzed key documents, reviewed
the relevant authorities, and interviewed DHS real property officials
from headquarters and GSA officials responsible for assisting DHS with
its headquarters consolidation efforts. This included reviewing
planning documents, including GSA's location alternatives analysis to
comply with the NEPA, GSA's 2005 land use feasibility analysis, DHS's
2006 housing master plan, and GSA's master planning documents, related
to a proposed consolidation of DHS headquarters on the West Campus of
St. Elizabeths Hospital in the District of Columbia. We also
interviewed additional stakeholders, including officials from the
National Capital Planning Commission (NCPC), the Advisory Council on
Historic Preservation, the U.S. Commission of Fine Arts, the Council on
Environmental Quality, the State Historic Preservation Officer, and
Ward 8 Coordinator from the D.C. Office of Planning.
To answer the fourth question, we interviewed DHS physical security
headquarters officials and officials from DHS's various components. We
also interviewed Federal Protective Service officials and GSA officials
responsible for security at locations where GSA houses DHS. We analyzed
Homeland Security Presidential Directive Number 7 and pertinent
physical security documents and policies from DHS and GSA. We conducted
our work between March 2006 and April 2007 in accordance with generally
accepted government auditing standards.
[End of section]
Appendix II: FRPC Inventory Data Elements and Descriptions:
Table 5:
Data element number: 1;
Data element name: Real property type;
Definition: Identifies the asset as one of the following categories of
real property: land; building; or structure.
Data element number: 2;
Data element name: Real property use;
Definition: Indicates the asset's predominant use in one of the
following categories: land; building; or structure.
Data element number: 3;
Data element name: Legal interest;
Definition: Identifies a real property as being owned by the federal
government, leased by the federal government (i.e., as lessee), or
otherwise managed by the federal government.
Data element number: 4;
Data element name: Status;
Definition: Reflects the predominant physical/operational status of the
asset as active, inactive, or excess.
Data element number: 5;
Data element name: Historical status;
Definition: Identifies owned and leased property as National Historic
Landmark (NHL); National Register Listed (NRL); National Register
Listed; National Register Eligible; Noncontributing element of NHL/NRL
district; Not evaluated; Evaluated, Not Historic.
Data element number: 6;
Data element name: Reporting agency;
Definition: Refers to the federal government agency/bureau reporting
the property to the FRPC Inventory database.
Data element number: 7;
Data element name: Using organization;
Definition: Refers to the predominant federal government agency/bureau
(or other nonfederal government entity) occupying the property.
Data element number: 8;
Data element name: Size;
Definition: Refers to the size of the real property asset according to
appropriate units of measure. The unit of measure used for the three
real property types is as follows:
* For land, the unit of measure is acreage and the land is designated
as either rural acres or urban acres;
* For buildings, the unit of measure is area in square feet and
designated as gross square feet (GSF);
For structures, a structure unit of measure table is provided that
contains reporting guidelines for the unit of measure for specific
types of structures.
Data element number: 9 (PM);
Data element name: Utilization;
Definition: Captures the rate of utilization for a building--that is,
the percentage of space (square footage) used for agency purposes;
Is reported;
* on a scale from 0 to 100;
* by building type--office, warehouse, hospital, laboratory, and
housing--and;
* by category-- overutilized, utilized, underutilized, or not utilized--
depending on where the utilization rate falls within percentage ranges
defined for each building type.
Data element number: 10;
Data element name: Value;
Definition: Defined as the functional replacement value; the cost of
replacing the existing constructed asset at today's standards. (value =
unit x unit cost x overhead factor).
Data element number: 11 (PM);
Data element name: Condition index;
Definition: Provides a general measure of a building or structure's
condition at a specific point in time;
Is calculated;
* annually,;
* as the ratio of repair needs to plant replacement value (PRV); (CI =
(1 - $repair needs/$PRV) x 100;
* "Repair needs" is the amount necessary to restore a building to a
condition substantially equivalent to its original condition;
- Agencies and departments will initially use an existing process to
determine their repair needs;
- Agencies will later refine and standardize their definition of repair
needs;
* PRV is the cost of replacing an existing building so that it meets
today's standards;
* The higher the CI, the better the condition of the building;
Is reported;
* for an entire agency or department,;
* on a scale from 0 to 100 percent;
Agencies and departments initially set target CI levels in consultation
with OMB.
Data element number: 12 (PM);
Data element name: Mission dependency;
Definition: The value a building brings to an agency's performance of
its mission as determined by the agency; May be categorized as;
* mission critical - without the building or land, the agency's mission
is compromised;;
* mission dependent, not critical - falls between mission critical and
not mission dependent; or;
* not mission dependent
- without the building or land, the agency's mission is unaffected.
Data element number: 13 (PM);
Data element name: Annual operating costs;
Definition: Includes costs for;
* recurring maintenance and repairs;
* utilities (plant operating and energy purchase costs);
* cleaning or janitorial services (pest control, refuse collection and
disposal, including recycling operations); and;
* roads/grounds (grounds maintenance, landscaping, and snow and ice
removal from roads, piers and airfields);
Will be reported annually.
Data element number: 14;
Data element name: Main location;
Definition: Refers to the street/delivery address for the asset or the
latitude and longitude coordinates. Either of the following will be
provided for the constructed asset or parcel of land: street address;
or latitude and longitude (if no security concerns).
Data element number: 15;
Data element name: Real property unique identifier;
Definition: A code that is unique to an item of real property that will
allow for linkages to other information systems. The real property
unique identifier is assigned by the reporting agency and can contain
up to 24 alpha-numeric digits.
Data element number: 16;
Data element name: City;
Definition: Provides the four-digit Geo Location Codes (GLC) for the
city or town associated with the reported main location in which the
land parcel, building, or structure is located.
Data element number: 17;
Data element name: State;
Definition: Provides the two-digit GLC for the state associated with
the reported main location in which the land parcel, building, or
structure is located.
Data element number: 18;
Data element name: Country;
Definition: Provides the three-digit GLC for the country associated
with the reported main location in which the land parcel, building, or
structure is located.
Data element number: 19;
Data element name: County;
Definition: Provides the three-digit GLC for the county associated with
the reported main location in which the land parcel, building, or
structure is located.
Data element number: 20;
Data element name: Congressional district;
Definition: Provides the value for the congressional district
associated with the reported main location in which the land parcel,
building, or structure is located.
Data element number: 21;
Data element name: ZIP code;
Definition: Provides the five-digit ZIP code associated with the
reported main location in which the land parcel, building, or structure
is located and, if known, the additional four-digit zip code suffix.
Data element number: 22;
Data element name: Installation/ Subinstallation identifier;
Definition: Headquarters installations - Land, buildings, other
structures, and facilities, or any combination of these. Examples of
installations are a national forest, national park, hydroelectric
project, office building, warehouse building, border station, base,
post, camp, or an unimproved site. Provide a 24- digit alpha-numeric
code for the installation ID assigned by the reporting agency;
Subinstallation - Part of an installation identified by a different GLC
than that of the headquarters installation. An installation must be
separated into subinstallations (and reported separately) when the
installation is located in more than one state or county. However, an
agency may elect to separate an installation into subinstallations even
if the installation is not located in more than one state or county.
Provide a six-digit alpha-numeric code for the subinstallation ID
assigned by reporting agency.
Data element number: 23;
Data element name: Restrictions;
Definition: Refers to limitations on the use of real property. Provides
one or more of the following values for each building, structure, and
parcel of land: environmental restrictions (cleanup-based restrictions,
etc.); natural resource restrictions (endangered species, sensitive
habitats, floodplains, etc.); cultural resource restrictions
(archeological, historic, Native American resources (except those
excluded by EO 13007, section 304 of the National Historical
Preservation Act), etc.); developmental (improvements) restrictions;
reversionary clauses from deed; zoning restrictions; easements
(including access for maintenance rights, etc.); rights-of-way; mineral
interests; water rights; air rights; other; nonapplicable.
Source: GSA, Interim FY 2005 Guidance for Real Property Inventory
Reporting as of October 11, 2005.
Note: PM = Performance measure.
[End of table]
[End of section]
Appendix III: Comments from the Department of Homeland Security:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
U.S. Department of Homeland Security:
Washington, DC 20528:
June 12, 2007:
Mr. Mark Goldstein:
Director, Physical Infrastructure Issues:
U.S. Government Accountability Office:
441 G Street, NW:
Washington, DC 20548:
Dear Mr. Goldstein:
RE: Draft Report GAO-07-658, Federal Real Property: DHS Has Made
Progress but Additional Actions Are Needed To Address Real Property
Management and Security Challenges (GAO Job Code 543163):
The Department of Homeland Security (DHS) appreciates the opportunity
to review and comment on the draft report referenced above. As noted in
the draft report, DHS has made considerable progress in meeting real
property management and security challenges. We agree with two
recommendations and partially agree with the third one.
Recommendation 1: The Secretary use the Office of Management and
Budget's (OMB's) capital planning principles to link DHS' long-term
capital needs with the asset management planning activities required
under the President's real property initiative.
The Department concurs with the recommendation. We agree that a capital
investment plan guided by OMB's capital planning principles will reduce
long-term real property costs and support the DHS mission. We are aware
of this investment planning weakness within DHS and have taken
proactive steps to address it using subject matter experts. The
Department is in the process of reviewing proposals from capital
investment experts who will be used to assist DHS officials in
developing recommendations on how best to integrate a single agency
(component) wide long-term capital investment planning process.
The report is fair and balanced in acknowledging Department efforts to
meet the requirements of the President's Management Agenda and real
property initiatives. DHS appreciates the Government Accountability
Office's (GAO's) recognition of the Office of Management and Budget's
approval of our Asset Management Plan and Three Year Timeline. GAO also
recognizes and reports on the challenges facing DHS in managing a
federal portfolio with limited resources. We will continue to work
diligently at improving the management and effective use of our real
property in support of the President's real property initiative.
Recommendation 2: The Secretary develop a physical security plan for
DHS, as required by HSPD-7 [Critical Infrastructure Identification,
Prioritization, and Protection], that addresses DHS' plans to fully
implement risk management and develop performance measures for facility
protection.
The Department concurs with this recommendation, and will continue its
efforts to develop a physical security plan in accordance with the
requirements of HSPD-7. Pursuant to HSPD-7, DHS developed a "Critical
Infrastructure Protection Report for Fiscal Year 2004," which was
provided to OMB. This information was subsequently incorporated into
the National Infrastructure Protection Plan (NIPP) Government
Facilities Sector (GFS) planning process. In May 2007, the GFS issued
its Sector Specific Plan, which addresses the use of risk management
and performance measurements for facility protection. DHS now
recognizes that the Sector Specific Plan does not fully satisfy the
HSPD-7 requirement. Accordingly, DHS will draw from the Sector Specific
Plan to develop a physical security plan for the Department.
Recommendation 3: The Secretary and Administrator of the General
Services Administration jointly perform a comprehensive analysis of the
costs, from the perspective of the federal government as a whole,
[which] would result if DHS headquarters operations are consolidated at
St. Elizabeths, and compare these costs to the costs of other
alternatives.
Many of the DHS following comments echo comments and explanations made
at or shortly thereafter the exit conference that were not incorporated
in the draft report.
DHS partially agrees with this recommendation. GSA is actively engaged
in determining the overall real estate costs for DHS in the National
Capital Region (NCR). They awarded a contract to a real estate firm,
Jones, Lang, LaSalle (JLL), who is developing the actual and projected
leasing costs for current locations housing components of DHS in the
NCR. In the fall of 2007 JLL is scheduled to deliver three different
scenarios that satisfy the requirement to consolidate DHS headquarters.
The GAO draft report recommends an analysis of the St. Elizabeths costs
and a comparison of these costs to the costs of other alternatives.
Currently, DHS is located in over 85 buildings in 53 locations across
the National Capital Region. The recommendation ignores the fact that
DHS can not operate effectively as currently housed and a consolidation
is a requirement, not a desire. The St. Elizabeths site was determined
to be the only site available that can achieve the consolidation of
mission execution functions on a secure campus in the time frame
required. If the St. Elizabeths site is not workable, DHS will request
GSA to find a site that is acceptable, either federally owned or
leased. Furthermore, DHS will not renew a lease after it expires unless
it consolidates functions, improves efficiencies, eliminates
duplication and is economically feasible: Absent development at St.
Elizabeths or another feasible location, DHS will consolidate
headquarters functions over the long term as leases expire. This
methodology will take many years and increase the time and costs of
improving operations.
The report also questions GSA's savings analysis. The occupancy plan
for St. Elizabeths is based on the guiding principle that the campus
must serve as the central hub for leadership, operations coordination,
policy, and program management in support of the Department's strategic
goals. The GAO draft report does not acknowledge that the "status quo"
scenario is not acceptable. Should St. Elizabeths prove unworkable, DHS
will ask GSA to lease facilities at current market rates that meet
DHS's operational and physical security requirements at greater overall
cost. To develop overall cost projections for the program, GSA uses The
Automated Prospectus System (TAPS). The TAPS incorporates all major
provisions mandated by OMB Circular Nos. A-104 and A-94 for the
analysis of federally owned and federally leased real estate. In
essence, TAPS provides a financial answer to the question of whether to
buy or lease. GSA's TAPS analysis includes DHS' costs estimated at $1.2
billion. Furthermore, these costs will not vary depending on the
alternative chosen. Since GSA is responsible for the construction of
the warm lit shell, GSA's costs could vary depending on the alternative
and the circumstances surrounding the property development. The
estimated tenant improvement costs are for the interior build out which
will remain consistent regardless of the alternative selected.
The report also states that DHS targeted the St. Elizabeths West Campus
which is not accurate. DHS provided GSA with its minimum requirements,
location neutral, for consolidating its headquarters elements. GSA
analyzed available properties in the NCR and determined that St.
Elizabeths West Campus is the only site capable of achieving the core
requirements for density and delivery time.
The section of the report titled Key Stakeholders Are Concerned about
Historic Preservation, Environmental Issues, and impact on the Local
Community erroneously presents the staff level opinions as the official
positions of the consulting parties (CP). The National Capital Planning
Commission (NCPC), the U. S. Commission on Fine Arts (CFA), and the
Advisory Council on Historic Preservation (ACHP) have not declared an
official position on the project. The National Environmental Policy Act
(NEPA) and Sections 106 and 110 of the National Historic Preservation
Act (NHPA) provide for stakeholder/public involvement and provide a
forum for the CPs to address their concerns. The Draft Environmental
Impact Statement, will be issued in the summer of 2007 and the CPs can
use into form an official position.
The CP staffs also advance the position that the St. Elizabeths campus
should be open for public use. St. Elizabeths campus has never been
open for unfettered public use. It has always been a closed campus with
a security wall. The wall was to protect the patients' privacy from the
public and the public from the patients. To provide balance and a more
complete understanding of the issues surrounding public access, we are
providing the following comments:
* DHS believes that public access to the St. Elizabeths West Campus is
a complicated issue that must be viewed in the context of the
historical nature of the campus as well as the Post 9-11 security
environment. As the historic wall on the St. Elizabeths West Campus
that runs along Martin Luther King Jr. Avenue indicates, the campus has
a long tradition of security and separation of the campus operations
from the local community. As the first federal mental institution in
the country, St. Elizabeths West Campus housed patients that could not
adequately function in the public domain. The historic wall served to
protect both the public from the patients and the patients from the
public, affording them the safety and privacy of receiving treatment
out of the public eye and without ridicule. Contrary to some
stakeholder and consulting parties' opinions, the campus never allowed
open and unfettered access. Most public access was through guests of
employees that worked on the campus or approved through special
permission from the Superintendent on a case by case basis. Since 9-11,
there has been no public access to the campus, due to the strategic
location and the surveillance vantage points it offers over several
critical federal facilities.
* Created in the aftermath of 9-11, the DHS mission is to lead a
unified effort to secure America. To accomplish this mission, DHS
requires an Interagency Security Committee Level 5 secure facility to
lead and manage operations across the Department. The campus will
include the national Operations Center collocated with the individual
component operations centers to facilitate unified action in response
to national disasters or terrorist attacks. While providing for our
operational security, DHS is also committed to working with the local
community to provide limited public access to portions of the campus
consistent with threat levels. For example, there has been a desire
expressed by the local community to view the 4Th of July fireworks from
the area on the campus known as "The Point". DHS believes this is a
reasonable request to accommodate and will work cooperatively with the
area neighborhood commissions and other local officials to establish a
framework for public access to this secure campus during the year.
* GSA has also received letters of concern over routine or continual
public access from the Presidential Helicopter Squadron (HMX-1) and the
White House Military Office, which overseas both HMX-1 and the White
House Communications Agency, which sit below and in plain view of the
campus on Bolling AFB and the Anacostia Naval Annex. As a result,
regardless whether DHS relocates to St. Elizabeths, routine or
continual public access is not a viable option for the site.
Other Concerns: Immigration and Customs Enforcement (ICE) officials
provided extensive technical comments that we are separately submitting
that relate to the narrative more than to the recommendations. In
brief, ICE officials note that the Federal Protective Service (FPS) is
transitioning to an inspector-based workforce that will increase the
number of inspectors assigned to the protection of Federal facilities.
Using a risk-based staffing model, the Inspectors are geographically
sited with the highest risk facilities.
With respect to references involving training quality for FPS personnel
conducting assessments and the reported need for additional training,
FPS plans to revise the Physical Security Academy (PSA) curriculum in
FY 2008 to support training on the use of a new Risk Assessment and
Management Program. In addition, FPS is partnering with the DHS Office
of Security and Federal Law Enforcement Training Center in an effort to
develop a standardized physical security training program for all
Federal agencies, drawing in part upon the experiences of the FPS PSA.
Technical comments will be provided under separate cover.
Sincerely,
Signed by:
Steven J. Pecinovsky:
Director:
Departmental GAO/OIG Liaison Office:
The following are GAO's comments on the Department of Homeland Security
letter dated June 12, 2007.
GAO Comments:
1. DHS describes the value of GSA's Automated Prospectus System (TAPS)
in its comments. While we agree that a TAPS analysis is a good tool to
make decisions about leasing and new construction options, it does not
allow a comprehensive analysis of the costs of various development
scenarios at the St. Elizabeths site that would help decision makers
better understand the costs of the trade-offs of developing a variety
of densities and configurations at the site. In addition, DHS is
incorrect in stating that GSA's TAPS analysis includes DHS's costs of
$1.32 billion. GSA acknowledged in its comments that DHS costs are not
part of the TAPS analysis, but argues that the costs would not vary
significantly, depending on the alternative selected at St. Elizabeths
so the costs exclusion does not affect the validity of the analysis.
2. DHS stated that the staff of the consulting parties advance the
position that the St. Elizabeths campus should be open for public use
and that the St. Elizabeths campus has never been open for unfettered
public use. We do not address the issue of public access in detail in
our report, but in general, most stakeholders with whom we talked
supported some type of limited public access to the site such as access
to the Point for certain holidays and access by permit to the Civil War
cemetery. Most stakeholders acknowledged that unlimited access was not
a realistic option. We agree with DHS that in the post 9-11 security
environment, access to the site is a complicated issue. As DHS states,
we believe that working with the community to come to an agreement
about limited public access to portions of the campus consistent with
threat levels and providing July 4th access to view fireworks is a
reasonable way to proceed.
[End of section]
Appendix IV: Comments from the General Services Administration:
Note: GAO comments supplementing those in the report text appear at the
end of this appendix.
GSA:
GSA Administrator:
June 6, 2007:
The Honorable David M. Walker:
Comptroller General of the United States:
Government Accountability Office:
Washington, DC 20548:
Dear Mr. Walker:
The U.S. General Services Administration (GSA) appreciates the
opportunity to review and comment on the draft report, "Federal Real
Property: DHS Has Made Progress but Additional Actions Are Needed to
Address Real Property Management and Security Concerns" (GAO-07-658).
The Government Accountability Office recommends that the Secretary of
Homeland Security and the Administrator of General Services "jointly
perform a comprehensive analysis of the costs, from the perspective of
the federal government as a whole, that would result if headquarters
operations are consolidated at St. Elizabeths, and compare these costs
to costs of other alternatives."
We partially agree with the findings and recommendations. Technical
comments that update and clarify statements in the draft report are
enclosed and incorporated herein by reference.
If you have any questions, please contact me. Staff inquiries may be
directed to Mr. Kevin Messner, Associate Administrator, Office of
Congressional and Intergovernmental Affairs, at (202) 501-0563.
Cordially,
Signed by:
Lurita Doan:
Administrator:
Enclosure:
cc: Mark Goldstein, Director, Physical Infrastructure:
Governmental Accountability Office (GAO) Draft Report Federal Real
Property: Department of Homeland Security Has Made progress but
Additional Actions Are Needed to Address Real Property Management and
Security Concerns GAO-07-668 -Date May 15'2007 General Services
Administration Comments to the Findings and Recommendations:
Recommendation to the Department of Homeland Security (DHS) and the
General Services Administration (GSA): GAO recommends that the
Secretary of Homeland Security and the Administrator of General
Services "jointly perform a comprehensive analysis of the costs, from
the perspective of the federal government as a whole, that would result
if headquarters operations are consolidated at St. Elizabeths, and
compare these costs to costs of other alternatives."
GSA's Response: GSA does not concur with this recommendation, This
analysis would be misleading. Including this analysis as a date point
for alternative DHS housing solutions ignores the fact that DHS's
current housing configuration is unacceptable unacceptable and, in any
event, DHS would not renew leases in place, but would seek to
consolidate its headquarters functions via another vehicle. DHS is
currently paying an average of $30 per square foot (so for its leased
locations totaling $135,000,000 annually.
GSA has already initiated a number of actions to address issues
identified in the draft report. For example, GSA has awarded a contract
to verify the DHS headquarters occupancies in the National Capital
Region and develop scenarios that identify the most cost effective
approach to achieve DHS's final housing solution, recognizing DHS's
collocation requirement. This study is scheduled for completion in the
fall of 2007.
GSA's General Response to the Findings in the Draft Audit Report: Since
January 2003, GAO has reported that Federal real property is a high-
risk area because of long-standing problems with excess and
underutilized property, deteriorating facilities, unreliable property
data, and heavy reliance on costly leasing. GSA's analysis indicates
that the redevelopment of the St. Elizabeths West Campus represents the
most judicious use of taxpayer money and addresses GAO's concerns
regarding the underutilization of Government assets.
We understand GAO's responsibility to provide a full project accounting
to Congress, however, we are concerned that the report does not
completely reflect the level of analysis performed to date by GSA.
GAO stated that GSA might have overstated the cost advantage of leasing
versus Federal construction for St. Elizabeths development. GSA agrees
tat the parking rent was overstated in The Automated Prospectus System
(TAPS) analysis. . GSA contracted with real estate firms for two
separate studies that determined GSA would have to pay $62 to $133 per
rentable square foot to procure leased space in Washington, DC, that
could meet the U.S. Department of Homeland Security's (DHS's) security
requirements, such as 100-foot setbacks in downtown Washington, DC.
Given the above rents, the present value cost advantage would be $743
million, at a minimum. Be advised that GSA's analysis is conceptual, as
our research indicates there is currently no development parcel in
Washington, DC, that can meet DHS's needs.
GAO further states that GSA and DHS could better make its case if an
analysis could demonstrate that the cost of security at St. Elizabeths
is more cost effective than providing similar security in downtown
locations, GSA has analyzed the cost of providing security for the
Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) and compared
that cost to the proposed cost at St. Elizabeths West Campus. GSA's
analysis shows that the cost for security per government employee at
ATF is more than double the cost of security per employee anticipated
at St. Elizabeths. The cost for the ATF project is approximately
$36,000 per employee compared to approximately $15,000 per employee at
St. Elizabeths West Campus.
GSA Comments on the Audit Focus: The Engagement Notice (April 20, 2006)
stated that the Engagement was to focus on the "plans DHS has to
consolidate its headquarters in Washington, DC, to ensure that it is
strategically managing the facilities where it is located." In the
Objectives paragraph of the draft Statement, that purpose appears to
have been revised to focus on the "challenges DHS faces in
consolidating its headquarters in Washington, DC" and, as a result,
much of the draft that GSA was provided to review focuses, not on DHS
plans, but on the GSA's proposed redevelopment of St. Elizabeths and
the various issues that we are working through. The scope of the
engagement appears to have been expanded significantly.
Additional Information that GSA could provide to GAO that may be useful
in compiling its final report:
* A copy of GSA's updated TAPS analysis and rationale,
* A benchmark analysis that indicates that the cost of providing
security on a per employee basis is more than double the cost per
employee at the St. Elizabeths West Campus.
* An MOU that transferred custody and control of the site from Health
and Human Services (HHS) to GSA stating that HHS is responsible
financially for the cost of site remediation.
* The initial estimate for the order of magnitude costs associated with
off-site transportation improvements that would accrue to the project
but would not necessarily be borne by GSA.
Other GSA comments and corrections with page number references for
GAO's consideration:
GSA's Comment: GAO should remove references to "4.5 million square
feet" and "4.5 million gross square feet" in pages 5, 35, 44, and 46,
as noted below, as these references should not be used without the
qualifier "plus parking" or "excluding parking."
* Page 5, second paragraph: "GSA and DHS estimate that overall
consolidation would cost at least $3.2 billion if 4.5 million square
feet of space is developed at the St. Elizabeths West Campus. Using an
analysis prepared by GSA, DHS has also testified that a consolidation
alternative of 4.5 million gross square feet would save an estimated $1
billion over 30 years in current dollars over an alternative involving
renewing leases..."
* Page 35, first paragraph: "The West Campus of St. Elizabeths is DHS's
preferred site for consolidation because, according to DHS, it can
accommodate the 4.5 million square feet of office space DHS maintains
it needs and is available immediately, two key requirements..."
* Page 35, second paragraph: "GSA and DHS estimate that the total cost
of a DHS consolidation at St. Elizabeths that involves 4.5 million
square feet of office space will be at least $3.2 billion, based on
alternatives currently under the study..."
* Page 44, first paragraph: "...NCPC and other stakeholders are
concerned that developing 4.5 million square feet of space for DHS at
St, Elizabeths will not protect the site's status as a National
Historic Landmark..."
* Pages 46, paragraph continued from page 45: "...GSA, it will be able
to preserve the site's historic and natural character while developing
4.5 million gross square feet of office space..."
Page 5, second paragraph, 4th sentence: GAO states, ".GSA may have
overstated the estimated savings because it assumes that the rental
rate for 1.5 million square feet of parking is the same as the rental
rate for office space - typically the rate for parking is considerably
less..."
GSA's Response. GSA agrees and has updated the TAPS analysis.
Page 31, first paragraph: Correction --First appearance of the word
"stakeholders" should be "stakeholders'" (with apostrophe).
Page 32, first paragraph: Correction - Insert the word "and" between
the words "setbacks" and "would."
Page 32 footnote: GAO states. "The Conference Report further stated
that DHS was prohibited from relocating Coast Guard headquarters or any
other DHS component until DHS completed the plan and GSA submitted a
prospectus for congressional review and approval."
GSA's Response: Footnote needs clarification. Is this referring to a
Conference Report that eventually became the Coast Guard's
appropriation law that contained Section 212 or something else? If it
is the appropriation law, GAO should reference that and not the
Conference Report leading up to it.
Page 33, last paragraph, 3rd sentence: GAO states, "This designation
recognizes the exceptional national significance of the property and is
the same designation given to the White House and the Capitol."
GSA's Response: What is the purpose of the statement ".and is the same
designation given to the White House and Capitol?"
Page 35, first paragraph, 5th sentence: GAO states, "No single site in
the Washington metropolitan area can accommodate DHS's entire portfolio
of about 7 million square feet."
GSA's Response: The statement should read, "No single site under the
Federal government's custody and control can accommodate DHS's need of
7 million square feet."
Page 35, footnote 21, 2nd sentence: Correction - "...This acreage is
necessary to develop an entrance/exit point to the West Campus to
reduce the increased traffic generated by the new federal campus"
should be revised to read, "This acreage is necessary to develop
entrance/exit points to the West Campus to reduce the increased traffic
generated by the new federal campus" (plural, not singular).
Page 36, 5th and 6th sentences: GAO states, "GSA's estimate does not
include additional transportation infrastructure improvements to be
funded by GSA that would be needed to provide access to and from the
campus and does not include all the mitigations, such as landscaping,
that may be required to meet the concerns of stakeholders. In addition,
access to the campus is dependent on transportation projects estimated
to cost over $1 billion to be borne by the DC government."
GSA's Response: GSA's estimate includes the cost of transportation
improvements that would be funded by GSA. The current estimate for
transportation improvements that may have to be funded by GSA pending
selection of the final transportation alternative is approximately $21
million. The estimate does not include off-site transportation
improvements at the Malcolm X Interchange that would be funded by the
District Department of Transportation (DDOT), but that are driven by
St. Elizabeths development. The preliminary estimate for these
improvements is approximately $33 million.
Page 37, Table 3: Reference GAO's Chart at the top of Page 37.
GSA's Response: GAO is double counting project infrastructure costs.
The current project development estimate, when rounded, is
approximately $3 billion.
Table:
GSA Total (Estimation);
Costs: $1,800,000,000.
DHS Costs;
Costs: $1,200,000,000.
Total;
Costs: $3,000,000,000.
Note: GSA's estimate of additional transportation costs because of St.
Elizabeths project at the Malcolm X Interchange is approximately $33
million. These costs would be borne by DDOT and are not included in the
project budget. GSA has also identified the presence of dioxin on-site.
The cost of remediation is unknown and would be borne by the Department
of Health and Human Services as required by a Memorandum of Agreement
signed when the site was transferred to GSA in December 2004.
[End of table]
Page 37, last paragraph continued to page 38: GAO states, ". While
GSA's cost analysis is useful in determining whether construction or
leasing is more cost-effective, a more comprehensive analysis that
includes additional factors is necessary to determine the cost of the
St. Elizabeths development to the government as a whole. For example, a
more comprehensive analysis could take into account." (See GAO's
continuation of its statement in the table below and GSA's response in
the right column):
Table:
GAO's Proposed Comprehensive Analysis: (1) DHS's actual and projected
leasing costs for locations where it is currently housed;
GSA's Response: This analysis would be misleading. Including this
analysis as a data point for alternative DHS housing solutions ignores
the fact that DHS's current housing configuration is unacceptable and,
in any event, DHS would not renew leases in place, but would seek to
consolidate its headquarters functions via another vehicle. DHS is
currently paying an average of $30 per of for its leased locations
totaling $135,000,000 annually;
Be advised that GSA has already initiated a number of actions to
address issues identified in the draft report. For example, GSA has
awarded a contract to verify the DHS headquarters occupancies in the
National Capital Region and to develop scenarios that identify the most
cost effective approach to achieve DHS's final housing solution,
recognizing DHS's collocation requirement. This study is scheduled for
completion in the fall of 2007.
GAO's Proposed Comprehensive Analysis: (2) DHS costs, including costs
such as tenant building improvements, which stand at $1.2 billion, and
how they would vary depending on the alternative ultimately selected,
to develop the site;
GSA's Response: GSA does not believe that DHS's tenant-specific costs
would vary significantly from location to location. The TAPS analysis
does not include these costs, as the Government would incur the costs
in any housing alternative that met DHS's programmatic needs.
GAO's Proposed Comprehensive Analysis: (3) a range of leasing and
construction alternatives and their associated costs for the St.
Elizabeths site;
GSA's Response: GAO needs to clarify this recommendation. The only
development option for St. Elizabeths West Campus currently under
consideration is Federal construction. DHS has a collocation
requirement of 4.5M gsf, plus parking. GSA requests that GAO clarify
this suggestion to state more specifically that GSA should analyze
those options that meet DHS's collocation need at St. Elizabeths.
[End of table]
Page 38, 1st paragraph (continued from page 37), 2nd full sentence: GAO
states, "...Actual and projected leasing costs for the locations where
DHS is currently housed would provide a more accurate estimate of costs
if a consolidation at St. Elizabeths does not occur..."
GSA's Response: GSA disagrees. If consolidation at St. Elizabeths West
Campus did not occur, GSA would initiate lease actions that would seek
to reconfigure DHS in a scenario that met its operational needs. The
current configuration does not meet DHS's needs; therefore, a stay-in-
place scenario is not feasible. GSA would initiate competitive actions
that would result in leases that would reflect market prices. GSA
believes the TAPS analysis is the best approximation of this scenario.
Page 41, 3rd bullet: GAO states, "According to GSA, GSA, DHS, and OMB
need to re-baseline the project funding schedule as a result of lack of
funding."
GSA's Response: This does not address fully the lack of FY 2007
funding. It implies that GSA can do all of the U.S. Coast Guard
requirements for $346 million when, in fact, GSA cannot.
Page 42, 1st full bullet: GAO states, "The balance of project funding
for phase 2 ($475 million) was to be requested in a future fiscal year.
The goal of phase 2 is to provide 2.0 million square feet..."
GSA's Response: These facts are from the FY 2008 prospectus submitted
to Congress; thus, the phase 2 number should be $491 million ($475
million for ECC plus $16 million for M&I). In addition, the goal of
phase 2 is to provide 1.6 million square feet.
Page 42, 2nd full bullet: GAO states, space to accommodate..."
GSA's Response: Phase 3 would add another 1.2 million square feet of
space; not 1.2 million square feet. This was taken directly from the
prospectus.
GSA's Response: Phase 3 would add another 1.6 million square feet of
space; not 1.2 million square feet. This was taken directly from the
prospectus.
Page 44, 6th sentence: GAO states, "Stakeholders generally maintain
that the site can hold about 2.0 million to 2.5 million square feet of
development (excluding parking) without compromising the site's status
as a National Historic Landmark."
GSA's Response: GAO is understating the level of development preferred
by the preservation community. GSA's understanding is that the 2.0-2.5
million square feet of development represents stakeholders' desired
development of the "built environment." Built environment is above
grade development and includes parking.
GAO's concerns in this section of its draft report are to be addressed,
discussed, and aired in the on-going statutory National Environmental
Policy Act (NEPA) and National Historic Preservation Act (NHPA)
decision-making processes.
GSA is required, as part of the Environmental Impact Statement (EIS),
to assess the impacts of the development alternatives on the site and
surrounding area. The EIS will include analysis of natural and cultural
resources, socioeconomic impacts, utilities, traffic and
transportation, air, and noise. This analysis will help GSA decision
makers to make a reasoned decision when selecting an alternative for
the development of the site.
GSA is the agency that is statutorily responsible for providing housing
of this nature. GSA is unaware of any Federal demand for the campus and
its buildings at the density that certain groups prefer and believes
that it is unlikely that the Federal government could be persuaded to
pay so much for a development that would house so few people.
Further, GSA has made no formal submissions to the National Capital
Planning Commission (NCPC), Commission on Fine Arts (CFA), and the
Advisory Council on Historic Preservation (ACHP) for their review and/
or approval under the specific statutory authorities applicable to
those agencies. The proposed statements in the draft report are
attributable to staff-not the agencies themselves. Absent formal action
by the agencies, he staffs have no authority to represent their
agencies' official position. The agencies' official positions are
rendered following the processes set forth in their enabling
authorities that require them to consider the submissions. Any report
issued by GAO must make this distinction; otherwise, it appears that
the agencies have unreasonably prejudged the submissions.
The draft report provided to GSA places an unwarranted emphasis on the
difficulties inherent in any redevelopment effort of this size and
complexity and inappropriately usurps the statutory review and decision-
making processes GSA currently is pursuing in accordance with the
National Environmental Policy Act (NEPA) and Section 106 of the NHPA.
The various staff GAO has relied on to provide comments in connection
with its draft report (NCPC, ACHP, and CFA, among others) represent
either consulting parties or cooperating agencies that GSA has
attempted to fully engage as GSA works through the complexities of this
project. Neither of these processes has been completed; for example,
GSA has not yet issued its draft preliminary EIS. GSA is aware of the
position of the staffs of these groups, but GAO's extensive airing of
the criticism (and the manner in which it is conveyed in the draft
report) from the various staffs, at this stage, is inappropriate.
Page 44, 1 st paragraph, last sentence: Correction - "Section 110 of
the Act" should be revised to read "the National Historic Preservation
Act,"
Pages 45 and 4: In addition, some stakeholders assert that GSA has not
adequately considered other DHS alternatives. GAO states that GSA could
explore financing the acquisition of an alternative site by disposing
of the St. Elizabeths campus for preservation-sensitive development.
The draft implies that might be possible to find some less-intense
alternative use of the site and ensure its historic restoration (see
e.g., last paragraph on page 45/first paragraph on page 46.)
GSA's Response: The implication is that it might be possible to find
some less-intense alternative use of the site and ensure its historic
restoration. In terms of GSA's demand to provide cost effective housing
for Federal agencies, the condition of the buildings (their interior
configuration not easily lending themselves to office use), and the
cost of the infrastructure necessary renders this implication
unsupportable.
Page 47, 1st paragraph, 1st sentence: GAO states, "Once the draft
Master Plan is completed, NCPC will assess GSA's compliance with NEPA
and NHPA requirements in determining whether to approve GSA's master
plan for the St. Elizabeths West Campus."
GSA's Response: GSA is unaware of NCPC possessing statutory authority
to assess GSA's compliance with NEPA and NHPA requirements.
Page 62: GAO states, "In order to better support DHS's preferred course
of action at St. Elizabeths, the Secretary and Administrator should
jointly perform a comprehensive analysis of the costs, from the
perspective of the federal government as a whole, that would result if
DHS headquarters operations are consolidated at St. Elizabeths (sic),
and compare those costs to the costs of other alternatives."
GSA's Response: See GSA's response to Page 38's comment (above).
General Comment, Page 45, last paragraph (continued on page 46): GAO
implies that it might be possible to find some less-intense alternative
use of the site and ensure its historic restoration. This implication,
in terms of GSA's demand to provide cost effective housing for Federal
agencies, the condition of the buildings (their interior configuration
not easily lending themselves to office use), and the cost of the
infrastructure necessary renders this implication unsupportable.
General Comment: The Engagement Notice (April 20, 2006) stated that the
Engagement was to focus on the "plans DHS has to consolidate its
headquarters in Washington, DC to ensure that it is strategically
managing the facilities where it is located." In the Objectives
paragraph of the Draft Statement, that purpose appears to have been
revised to focus on the "challenges DHS faces in consolidating its
headquarters in Washington, DC" and, as a result, much of the draft
that GSA was provided to review focuses not on DHS plans, but on the
GSA's proposed redevelopment of St. Elizabeths and the various issues
that we are working through. The scope of the Engagement appears to
have been expanded significantly.
The following are GAO's comments on the General Services Administration
letter dated June 6, 2007.
GAO Comments:
1. We have updated the report to include the updated transportation
costs to be borne by GSA and the District Department of Transportation
that were provided to us after receiving agency comments. These
transportation cost estimates supersede those provided in the agency
comments.
2. We disagree with GSA's statement that we double counted project
infrastructure costs. The $2 billion estimate for GSA's portion of St.
Elizabeths development costs, which was included in the draft report we
sent to GSA, was based on estimates discussed at interviews conducted
with GSA on November 29, 2006, as well as follow-up telephone
conversations with GSA in February and March 2007. Also, in a February
8, 2007, letter from GSA, we were provided documentation that listed
development costs for St. Elizabeths at about $2 billion. After sending
us official agency comments, GSA revised its estimate of the cost to
develop St. Elizabeths to $3.26 billion with GSA incurring $1.94
billion of costs and DHS incurring $1.32 billion of costs. Since GSA's
current estimate stands at $3.26 billion, we will use this estimate in
our report; but we believe that these changing cost estimates--and the
confusion about them--demonstrate that a comprehensive cost analysis
would, in our view, improve transparency and allow for more informed
decision making.
3. We disagree that including DHS's actual costs for its current
locations as a baseline would be misleading. We agree that DHS's
current housing configuration is not optimal and that DHS may pursue
other alternatives other than renewing current leases. However, it
would be useful for congressional decision makers to have an analysis
of what DHS is currently paying and will pay in leases over a 30-year
period as a baseline and compare the 30 year cost under that scenario
with the 30-year cost of ownership under other configurations and
square footages at the St. Elizabeths site (2.5, 3.0, and 4.5 million
square feet).
4. We are not saying that DHS tenant-specific costs would vary
significantly if DHS moved to a different location than St. Elizabeths.
We are suggesting that a comprehensive cost analysis of how DHS costs
would vary, depending on the configuration and square footage developed
at the St. Elizabeths site and would be useful to decision makers. For
example, if 3 million square feet of office space were developed at St.
Elizabeths, DHS's costs, such as build-out costs, moving costs, and
remaining leasing costs, would be a certain amount. However, if 4.5
million square feet of office space were developed at St. Elizabeths,
these DHS costs would certainly vary to some degree. An understanding
of the degree to which these costs might vary, depending on the
alternative selected, would promote informed decision making.
5. As discussed earlier, we believe that a comprehensive analysis of
the costs of various development scenarios at the St. Elizabeths site
ranging from zero development (for use as baseline) to DHS's and GSA's
preferred development of 4.5 million square feet of office space (plus
parking), or higher, would help decision makers at GSA, DHS, and
Congress better understand the cost trade-offs of developing a variety
of densities and configurations at the site. A comprehensive cost
analysis would also help stakeholders understand the long-term costs to
the federal government, whether incurred by DHS, GSA, or the Department
of Health and Human Services, as well as the District of Columbia
government and how these long-term costs would vary, depending on the
amount of square footage developed at the St. Elizabeths site. We would
not limit the analysis to those solutions that fully meet DHS's
colocation need, since alternatives that partially meet DHS's
colocation needs could be explored if only to understand the trade-offs
of developing a variety of densities and configurations at the site.
6. We agree that a stay-in-place scenario is not a good alternative for
DHS. However, we believe that an understanding of current and projected
leasing costs would provide a useful baseline of comparison against
other alternatives for decision makers. GSA's economic analysis does
this to some degree, but in our view it does not explore a complete
range of alternatives for the St. Elizabeths site.
7. We disagree. Based on the interviews conducted and letters provided
by NCPC, the D.C. Office of Planning, Advisory Council on Historic
Preservation, and National Trust for Historic Preservation, we believe
that stakeholders generally maintain that 2.0 to 2.5 million square
feet of office space can fit on the site, plus parking, without
compromising the site's historic character. Only the U.S. Commission of
Fine Arts expressed a preference for a lower amount of office
development on the site.
8. We agree that stakeholder statements in our report do not reflect
agencies' official positions, but we believe they accurately reflect
the concerns or views of key stakeholders that are senior officials in
these organizations. We have added a statement in our report that
states views expressed are generally the views of key staff, not
official positions of the organizations themselves who will officially
provide comment as consulting parties once GSA submits its draft Master
Plan in July 2007. We also attribute some statements to an individual
within a particular agency or cite the letter from which any statements
came. For example, NCPC expressed its views of the potential
consolidation of DHS at the St. Elizabeths campus through letters
signed by its Executive Director on January 19, 2006, and September 21,
2006. An analysis and description of the debate around the development
of St. Elizabeths would not be complete without this context of
stakeholder concerns. In our view, it would not be appropriate to wait
until after the Record of Decision regarding the St. Elizabeths site
became final to inform Congress of stakeholder concerns since
congressional debate about, and discussion of, funding for the project
is already under way.
9. We do not believe that describing the concerns of stakeholders is
inappropriate, even though GSA has not issued its draft environmental
impact statement. As discussed above, an analysis and description of
the debate around the development of St. Elizabeths would not be
complete without this context of stakeholder concerns. In our view, it
would not be appropriate to wait until after GSA's Record of Decision
regarding the St. Elizabeths site became final to inform Congress of
stakeholder concerns as this is an ongoing and deliberative process. We
acknowledge that GSA has attempted to fully engage stakeholders as it
works through the complexities of the project.
10. We agree that the St. Elizabeths site's infrastructure costs,
building conditions, and historic preservation demands make providing
cost-effective housing for federal agencies a challenge. That is
precisely why a comprehensive cost analysis of the total costs to the
federal government as a whole, at varying square footages, at the St.
Elizabeths site would be beneficial. We believe that such an analysis
would lead to more informed decision making.
11. See comment 10.
12. GSA correctly notes that our audit focus has changed from
evaluating DHS's plans to consolidate its headquarters in Washington,
D.C. to a focus on the challenges that DHS and GSA face in
consolidating DHS's headquarters in Washington, D.C. Given the large
role that GSA plays in efforts to consolidate DHS's headquarters at the
West Campus of St. Elizabeths, we determined during our engagement that
a focus on the challenges that both DHS and GSA face was warranted.
During the course of the engagement, most of the discussions with GSA
focused on the challenges it faces as it assists DHS in its need to
consolidate.
[End of section]
Appendix V: Comments from the District of Columbia Office of Planning:
Government Of The District Of Columbia:
Office Of Planning:
Office of the Director:
June 12, 2007:
David Sausville, Assistant Director:
Physical Infrastructure Issues:
Government Accountability Office:
441 G St, NW:
Washington, DC 20548:
Re: Comments on draft report "DHS Has Made Progress But Additional
Actions Are Needed To Address Real Property Management And Security
Challenges" (GAO-07-658):
Mr. Sausville:
Thank you for providing a draft copy of your report regarding the
Department of Homeland Security's progress in addressing the numerous
real property management, development and security challenges of
consolidating and relocating its operations to the West Campus of St.
Elizabeths and the impact on the District of Columbia. The analysis and
subsequent recommendations arising from this report offer compelling
reasons for DHS to reconsider their approach to the St Elizabeths
campus, in the context of how major capital planning and. investment
decisions are made. More specifically we appreciate the thorough and
thoughtful assessment of the numerous impacts that arise from the
potential consolidation of DRS operations on the West Campus of St.
Elizabeths Hospital, located in Ward 8 in Southeast Washington. This
letter incorporates and clarifies continents that you may have received
under separate cover from Tim Dennee of my Historic Preservation Office
staff.
I would like to briefly comment on your findings as they relate to the
potential development on the West Campus of St. Elizabeths Hospital and
the overall federal impact of the DHS consolidation in terms of capital
planning and investment.
Support for federal development at St Elizabeths West Campus:
The District Government has always been supportive of some sort of
federal campus being created on the West Campus of St. Elizabeths.
Aware that busy members of Congress may often have the time to only
review summaries of such documents, we would be grateful if the top
paragraph on page 6 could say, in addition to "DHS and GSA face
objections from several key stakeholders that are concerned about
whether the project would comply with historic preservation and
environmental laws," that those stakeholders "have supported
considerable redevelopment on the property and continued federal use"-
-that the problem is with the magnitude of the project and its effects.
The document does address this issue later in the text, but we would
naturally be concerned about any inadvertent creation of the appearance
of an either/or situation-preservation or DHS use---and we are loath to
have any readers, particularly decision-makers in Congress, come away
with a sense that our position or that of the stakeholders involved in
the Section 106 consultations has been one of intransigence or
unreasonableness about accepting substantial new construction on this
National Historic Landmark campus.
Beyond supporting redevelopment and federal use, we believe certain
broad development principles should serve as guidance for how to
develop the West Campus:
* Use the entire campus as context:
* Preserve public access to the grounds and bluffs:
* Work in conjunction with local development objectives:
* Sensitively integrate with the remainder of the campus and
surrounding neighborhood:
The aforementioned principles could be implemented through specific
actions by the General Services Administration and its clients
including the following:
* Create a seamless, integrated multi-use development zone that serves
as a transition to the high security campus while revitalizing Martin
Luther King, Jr. Avenue SE with parallel development on both sides.
* Preserve and maintain an accessible open space system that will allow
the public to continue enjoying the view from "the Point" as well as
protecting important green spaces and vistas.
* Improve transit and transportation connections to support any new
major federal employment center and increase the number of mobility
options for employees, visitors and the community.
* Aid local economic development through identification of potential
"spin-off' development (e.g., government contractors looking for nearby
office space) that could enhance the commercial opportunities along
Martin Luther King, Jr. Avenue SE.
* Strategically program retail operations (e.g., laundry, dining) by
exploring the placement of these kinds of operations along Martin
Luther King, Jr. Avenue to aid in its revitalization, while working
with District Government to attract compatible retail that can serve
the surrounding neighborhood and the federal employment center.
Development Density:
As mentioned in the draft, our office and most of the stakeholders and
consulting parties have suggested that development in the range of 2.0
to 2.5 million square feet might be appropriate as a maximum for the
site (with some demolition of both historic and non-contributing
buildings) carefully considering the space available and physical and
visual impacts on buildings, landscapes and views. We have repeatedly
requested GSA and DHS to study an alternative or alternatives of that
magnitude-in other words, alternatives corresponding to a
Congressionally-mandated development plan including the U.S. Coast
Guard and at least 2,000 other federal employees. These requests have
thus far been rebuffed despite the elimination of the previous "low-
density" alternatives.
In December, in response to several verbal and written requests for
planning documents or studies that might support the DHS-preferred
density alternatives for the campus, GSA forwarded two documents. One
of these was an August 2002 document "St. Elizabeths Hospital-West
Campus Federal Needs Screening" prepared by the Public Buildings
Service and AE W Capital Management. It concluded that a maximum build-
out in an office-only scenario:
Would be very hard to achieve, but is included to illustrate the end
range of possibility. The campus would offer 2.32 million rsf, with
1.75 million rsf in new space. At 200 rsf per federal employee, the
campus could house 11,600 workers. Many of the identified agencies
could relocate to the West Campus. (p. 34):
In addition to the fact that this "hard to achieve" amount of office
space is only 56 percent of that now proposed, it is important to note
that the scenarios in this AEW report also assumed underground parking
beneath the proposed office buildings (see, for instance, development
potential diagrams on pp. 25, 28 and 30). This distinguishes these
scenarios from the present ones for DHS because the present scenarios
separate the parking from the office uses resulting in less efficient
utilization of the land available and substantial additional parking
structures, both above ground and below, that add considerably to the
development bulk and the consequent physical and visual effects on the
campus, its buildings, landscapes and views.
The second document received in December was an August 2005 report "St.
Elizabeths West Campus Land Use Feasibility Analysis" prepared by GSA
and Jones Lang LaSalle, a multinational real estate construction,
management and consulting firm. This report evaluated the 4.5-million-
gross-square-foot (or 4.14 million rentable square feet) scenario as
follows:
Demolishes 16 historic buildings, affects 15 protected landscape
features, and affects six protected views. Impact on Center Building
area, impact on views of site from Monumental Core of Washington,
proximity to Civil War cemetery, and impact on protected views from
Center Building to Alexandria. Impact on historic context of Center
Building, views from the historic main gate. May affect visibility of
the perimeter wall and views from the east campus. Impacts the historic
spatial organization and the curvilinear network of roadway
circulation, specimen trees and small-scale landscape elements. Almost
entirely erases therapeutic agricultural landscape on both sides of
historic road to river landing. Agency approvals are unlikely without
major development downsizing. Will likely cause a serious delay in
schedule. (p. 51):
Because the adverse impacts would be less extensive, the report
concluded that agency approvals or agreements of some revision of the
three-million-rentable-square-feet scenario "may be possible with
extended consultation and significant development downsizing."
The AEW study and the Jones Lang LaSalle study thus agree that the
appropriate maximum intensity of reuse and redevelopment would be
something well below three million square feet and that such a level is
economically feasible. This level also coincides with the
Congressionally-mandated development plan addressing at least 2,000
employees in addition. to those of the Coast Guard. At the square-foot-
per-employee ratio used by the AEW study, the Coast Guard's space
preference plus room for another 2,000 employees would amount to about
1.5 million rentable square feet. Simply extrapolating from the larger
Coast Guard space-per-employee ratio, it would be approximately 1.65
million-in each case, probably not much more than two million gross
square feet, considering that most will be in new construction with
higher efficiencies. This would mean that there could be additional
room for additional employees. These findings are of great interest to
us, both because they so neatly coincide with the judgments of the many
stakeholders involved in the ongoing consultations and because GSA
sponsored the studies and DHS has been privy to them for a long period
of time. Both agencies should have responded appropriately.
The concurrence of three independent analyses of the site is more than
mere coincidence. We believe that any sensitive and conscientious
balancing of the agency needs with the reinvestment needs and
preservation protections of the site would result in roughly the same
numbers. We are aware of no party, except DHS, that disagrees with the
proposition that a development of the magnitude of 2.0 to 2.5 million
square feet would be an appropriate maximum solution to redeveloping
the site. DHS's assertion that "all the full build (4.5 GSF) master
plan alternatives can preserve and protect the important tangible, as
well as intangible, historic characteristics of the campus while
ensuring operational effectiveness" is simply unsupported in its
"housing master plan" and contrary to everyone else's understanding of
the site.
We applaud GAO's questioning of the comparison of costs between the
redevelopment of the West Campus and a "no move" option, including the
dependency of the development on highway and other infrastructure
investments and approvals by outside agencies. GSA analysis also
undoubtedly underestimates costs of historic preservation mitigation,
which could be enormous given the number and scope of adverse effects
proposed. An even more fundamental questioning of assumptions may be in
order, including whether all functions-including "border security,
biological research, computer security and disaster mitigation"truly
need to be located on the same historic property.
Given the fragile nature of the national historic landmark site and the
impact of both the development intensity proposed and the incredibly
high level of risk to those resources that is associated with
consolidating the intelligence and security operations of DHS, we are
reminded of the decision of the Turks to store gunpowder and munitions
in the Parthenon, which was destroyed in 1687 when those munitions were
blown up by attackers.
An important consideration commonly overlooked in discussions thus far
is the tendency of government agencies to grow. The idea that DHS
would, and should be permitted to, develop this National Historic
Landmark to a certain maximum extent implies that no further growth
would occur. We have no such assurances, nor do we believe that a no-
growth future is a reasonable assumption. Thus, it makes even more
sense for DHS to consider sites that more comfortably accommodate its
uses, with no more than 2.0-2.5 million GSF at historic Saint
Elizabeths.
Finally, and perhaps most important, in the ongoing Section 106
consultations, Department of Homeland Security representatives have
stated that DHS is not seriously considering any of the "master plan"
alternatives that consist of less than 4.5 million gross square feet of
office space. Page 45 of your draft states that only the lowest-density
alternatives have been excluded because of the Congressional mandate to
house an additional agency or agencies with the Coast Guard.
Unfortunately, this does not represent the present DHS position. To
have eliminated additional alternatives-and having failed to have
explored all of the feasible alternatives-is contrary to both the
express intention of the master plan document itself and to the letter
and spirit of both the National Environmental Policy Act and the
regulations implementing Section 106 of the National Historic
Preservation Act.
Cost savings benefit:
We agree that DHS and GSA should analyze its actual and projected
leasing costs from a broader federal perspective on leasing costs
rather than the insular approach based on consolidating its operations
at St. Elizabeths. We also agree that reliable data should be produced
that show any savings created as a result of reducing costs for
security measures such as the hardening of leased locations here in the
Washington Metropolitan Area.
We are very interested in seeing the results of the vacant space report
commissioned by DHS. According to your draft report, over 10 percent of
the facilities in the real estate portfolio of DHS are underutilized.
We hope that GAO would inquire about the completion of this report and
its impact on any consideration as to the agency's space needs at St.
Elizabeths.
Federal Capital Planning and Investment:
We recognize how agencies must do a better job of developing goals and
strategies that shape better decisions about how to invest capital
improvement funds. There must be long-term planning for how to utilize
and if necessary, dispose of capital assets. As the draft report
stated, many agencies do not use the Office of Management and Budget's
guide regarding capital planning. A greater effort should be initiated
that encourages federal agencies to actively use the guide - especially
here in the District. More forward thinking is required in order to
properly assess the space needs of not only DHS but other federal
agencies as well. In the long term GSA should spearhead an effort to
perform comprehensive capital planning in National Capitol Region.
Infrastructure Cost Impact on the District:
As stated in your report, GSA estimates a range of $150-$200 million is
needed for infrastructure improvements and design. Also, GSA has yet to
fully identify costs for additional improvements that will be required
to address issues such as landscaping and campus access. These
improvements will take place either on or adjacent to the site, but
will definitely impact an area well beyond the confines of the campus.
These improvements also rely on the implementation of projects already
identified but partially funded by the District at an estimated cost of
$1 billion. As your own previous studies have concluded, the District
suffers greatly from a structural deficit that adversely impacts
implementation of capital projects. The very direct relationship
between both local and federal infrastructure costs should yield
greater federal support for funding these infrastructure improvements.
Conclusion:
The Office of Planning appreciates the opportunity to weigh in on
various issues surrounding the Department of Homeland Security's
facilities needs. We really appreciate your conscientiousness and
willingness to entertain all views. We continue to strongly urge DHS
and GSA to develop a more viable master plan for the West Campus of St.
Elizabeths at a more reasonable density. We look forward to seeing our
comments incorporated into the final document. If you have further
queries, please do not hesitate to contact my office at 442-7600.
Sincerely,
Signed by:
Harriet Tregoning:
Director of Planning:
HT/at/cgb:
[End of section]
Appendix VI: Comments from the National Capital Planning Commission:
NCPC:
NATIONAL CAPITAL PLANNING COMMISSION:
401 9th Street, NW North Lobby, Suite 500:
Washington, DC 20004:
Tel 202 482-7200:
Fax 202 482-7272:
http://www.ncpc.gov:
Commission Members:
Presidential Appointees:
John V. Cogbill, III, Chairman:
Herbert F Ames:
Jose L. Galvez, III:
Mayoral Appointees:
Arrington Dixon:
Stacie S. Turner:
Ex Officio Members:
Secretary of Defense:
The Honorable Robert M. Gates:
Secretary of the Interior:
The Honorable Dirk Kempthome:
Administrator:
General Services Administration:
The Honorable Lurita Alexis Doan:
Chairman:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Joseph I. Lieberman:
Chairman:
Committee on Oversight and Government Reform:
U.S. House of Representatives:
The Honorable Henry A. Waxman:
Mayor:
District of Columbia:
The Honorable Adrian M. Fenty:
Chairman:
Council of the District of Columbia:
The Honorable Vincent C. Gray:
Executive Director:
Patricia E. Gallagher, AICP:
In Reply Refer To:
NCPC File No. MP 211:
June 12, 2007:
Mr. Mark Goldstein:
Director, Physical Infrastructure Issues:
U. S. Government Accountability Office:
441.G Street NW:
Washington, D.C. 20548:
Dear Mr. Goldstein:
Thank you for affording us the opportunity to read and comment on the
draft for Federal Real Property DHS Has Made Progress but Additional
Actions are Needed to Address Real Property Management and Security
Challenges (GAO-07-658). We find that the document is an accurate
reflection of NCPC's concerns and understanding of the project as staff
presented them during the development of the report, and we have no
additional comments.
Please note however, that the Commission has not yet had the
opportunity to formally review and comment on the St. Elizabeths
project. As a result, all comments are those of the staff and not of
the Commission itself.
Sincerely,
Signed by:
Patricia E. Gallagher, AICP:
Executive Director:
cc: David E. Sausville, GAO:
[End of section]
Appendix VII: Comments from the Advisory Council on Historic
Preservation:
John L. Nau, III:
Chairman:
Susan S. Barnes:
Vice Chairman:
John M. Fowler:
Executive Director:
Preserving America's Heritage:
June 13, 2007:
Mr. Mark Goldstein:
Director, Physical Infrastructure Issues:
U.S. Government Accountability Office:
441 G Street, NW.
Washington, DC 20548:
Re: Draft GAO Report (GAO-07-648):
Dear Mr. Goldstein:
We appreciate the opportunity to review this report and comment on your
findings. Through the process set forth by our regulations at 36 CFR
Part 800, "Protection of Historic Properties," the Advisory Council on
Historic Preservation (ACHP) has been formally involved in consultation
with the General Services Administration (GSA), the District of
Columbia State Historic Preservation Office, and numerous consulting
parties since 2006 to address the potential adverse effects to St.
Elizabeths National Historic Landmark (NHL) that may result from the
proposed redevelopment of the St. Elizabeths' campus by GSA.
As the proposed tenant of this facility, the Department of Homeland
Security (DHS) has provided some information about its proposed use of
the campus to these consulting parties, including much of the
information referenced in the GAO report. We offer the following
comments on this report.
General Comments:
* The ACHP is in agreement with the recommendations for Executive
Action as stated in the conclusions, particularly #2 which states: "In
order to better support DHS's preferred course of action at St.
Elizabeths, the Secretary [DHS] and Administrator [GSA] should jointly
perform a comprehensive analysis of the costs, from the perspective of
the federal government as a whole, that would result if DHS
headquarters operations are consolidated at St. Elizabeths, and compare
these costs to the costs of other alternatives. " Both DHS and GSA have
repeatedly stated that cost savings is a primary motive for selecting
the St. Elizabeths' campus as a consolidated site for DHS. However,
insufficient information has been provided to demonstrate how much cost
savings may be realized by DHS through the redevelopment of the St.
Elizabeths' campus in comparison to other alternatives. Many other
consulting parties continue to express this concern in the context of
Section 106 consultation, and the ACHP believes that further
justification and explanation would facilitate more effective
consultation.
* The ACHP feels that the discussions with regard to the challenges
faced in addressing preservation stakeholders' concerns have been
adequately expressed. We further believe that the expressions of
concern by the stakeholders have also been adequately expressed and
documented in the report.
* The ACHP would like to see further discussions on the importance of
the NHL and the criteria that the National Park Service (NPS) utilizes
for determining the site's historic significance. It does not appear
that the NPS was contacted or interviewed in the development of this
report. The importance of determining what level of development could
irreversibly impact the NHL is a key component in the evaluation by the
consulting parties, and the NPS is the federal agency with the
delegated authority to make such a determination. In accordance with
Section 213 of the National Historic Preservation Act (NHPA), the ACHP
has requested the opinion of the Secretary of the Interior on the
potential impact of this redevelopment on the St. Elizabeths NHL.
Technical Comments:
* Page 31, first full paragraph, fourth sentence: DHS states that it
expects its need for office space to grow to about 8 million square
feet over the next five years. Would this expansion be planned to occur
solely at St. Elizabeths? Or is it considering this expansion offsite
or at a national level? The consulting parties have not been informed
of this potential scenario that could have further impacts to the St.
Elizabeths NHL. If indeed this level of expansion is anticipated for
the St. Elizabeths' site, this information should be presented to and
considered by consulting parties.
* Page 33, second paragraph, second sentence: It should state that this
property is a National Historic Landmark (NHL) district, rather than a
"site" or "building."
* Page 33, second paragraph, fifth sentence: The report states that the
NHL designation, in addition to the buildings, covers the landscaping
and grounds, the scenic vistas of the river and city, and the Civil War
cemetery. It is important to note that the district is significant
primarily due to its social and medical history. As the first federal
mental health facility in the country, it was at the forefront of
groundbreaking discoveries in mental health. The NHL statement of
significance makes extensive reference to this issue. The buildings,
the landscape, and the vistas all tie into this medical use;
substantial redevelopment could impact this landscape and its ability
to maintain the characteristics that were fundamental in its
significance as a medical facility.
* Page 42, first full paragraph, last sentence: DHS maintains that it
currently plans to reuse 77 to 81 percent of the existing square
footage that contributes to the site's status as an NHL. Although this
level of building reuse is commendable, it may obscure the greater
impacts that may be realized upon other components of the NHL; namely,
the landscape and view sheds which provide context for many of the
significant events that occurred onsite. The failure to anticipate and
measure potential impacts to the landscape as a contributing component
of the NHL has been a major point of contention among the consulting
parties.
* Page 44, first paragraph, last sentence: This section should cite
Section I I 0(f) of the NHPA, which references an agency's
responsibilities when consulting about adverse effects to NHLs. This
section requires that, to the maximum extent possible, the agency finds
ways to avoid, minimize, and mitigate adverse effects to NHLs, and that
it invites the Secretary of the Interior to participate in consultation
to address these effects.
We appreciate the opportunity to review and comment on this report. If
you have any further questions, please feel free to contact Hector
Abreu Cintron, the ACHP's GSA Liaison, at 202-606-8517 or
habreu@achp.gov:
Sincerely,
Signed by:
John M. Fowler:
Executive Director:
[End of section]
Appendix VIII: Comments from the U.S. Commission of Fine Arts:
U.S. Commission Of Fine Arts:
Established By Congress 17 May 1910:
National Building Museum:
401 F Street, N,W., Suite 312:
Washington, D.C. 20001-2728:
202-504-2200:
202-504-2195 FAX:
June 14, 2007:
Dear Mr. Sausville,
This letter is to transmit our agency staff comments to you regarding
the GAO Draft Report GAO-07-658 regarding the consolidation of the
Department of Homeland Security to a headquarters complex on the St.
Elizabeths campus in Washington, D.C.
The most important concept to emphasize-which is not well articulated
in the report-is that the St. Elizabeths campus is a property of
tremendous and irreplaceable value. It is a National Historic Landmark
and must be considered a national treasure. The value of the property
exists in many ways:
1) Historic and cultural value in the history of the treatment of
mental illness, as a hospital site during the Civil War and as a
cemetery:
2) Architectural value as a campus of many buildings listed on the
National Register of Historic Place, but most significantly by the
1850s gothic revival Center Building designed by Thomas U. Walter,
architect of the dome of the U. S. Capitol:
3) As an ecological area within the city and habitat to endangered
species:
4) As a potentially positive generator of urban development in
Anacostia:
5) Value in its topographic prominence and potential symbolic
relationship to the monumental core of the national capital. St.
Elizabeths also has one of the most breathtaking views of the capital
city and this overlook location should be reserved as a major
commemorative site.
The St. Elizabeths site is highly visible from many points in the city
as well as from Reagan National Airport and the approach to Washington
from 1-395. It has the potential to be a dramatic focus for a vista
looking down the Washington Channel-creating a major commemorative link
between the monumental core and Anacostia. Such a -precious natural
feature should be developed only with the greatest sensitivity.
It is useful to note that GSA, in its documentation for the decision
made by GSA to consider the St. Elizabeths site for the DHS
consolidation, evaluated the site for its size and availability only,
but made no mention of its National Historic Landmark status and the
associated responsibilities of stewardship to the property.
In more than twenty meetings with the GSA and DHS under the Section 106
process of the NHPA over the past two years, there has consistently
been expressed a consensus of opinion among all the consulting parties
that anything above 2 to 2.5 million square feet of development would
destroy the character of the site and its standing as a National
Historic Landmark. Thus far, the GSA-DHS proposals have not been able
to accommodate in their designs solutions to the issues raised by the
consulting parties to preserve and protect the campus. These
fundamental principles articulated by the consulting parties are:
1) Provide full public access to "The Point" overlooking the city,
which must be outside the DHS security perimeter; and to reserve it for
potential use as a commemorative site.
2) Locate development away from the highly visible western slopes of
the campus which are part of the definition of the city's setting as
well as a goal of the District of Columbia's Comprehensive Plan:
3) Preserve the historic character of the campus itself, its buildings
and grounds (which contribute to its landmark status) with regard to
the scale and disposition of new development:
4) Rethink the high-security perimeter treatment with parallel anti-
personnel fences and wide buffers of minimal vegetation which would
destroy the NHL-listed therapeutic landscape, mature natural habitat,
and historic forested hillsides:
The GSA-DHS proposals have not been able to accommodate in their design
solutions to the issues raised by the consulting parties to preserve
and protect the campus. The current proposal includes a total of 6.4
million square feet of development (including parking) and is roughly
three times what can be accommodated. Obviously, other solutions need
to be considered if the campus is to be protected; these may include
looking at co-locating components of DHS in adjacent areas, such as on
the District-controlled east campus of St. Elizabeths or possibly in
the federal properties just below the site across 1-295 along the
Potomac River; or considering more radical ideas such as building
deeply into the ground.
Many of the other arguments that have been made about the impact of the
DHS consolidation to the site-traffic, infrastructure and services
costs, and questionable benefit to the revitalization of this sector of
the city-are mentioned in your report and do not belong to the
essential concerns of the Commission of Fine Arts.
We appreciate the opportunity to comment on the report and would like
emphasize again the enormous (and unrealized) value of the site. The
current proposal by the GSA for DHS would diminish that value, both for
its existing characteristics and for its future potential.
Sincerely,
Signed by:
Thomas Luebke, AIA:
Secretary:
Mr. David E. Sausville:
Assistant Director, Physical Infrastructure Team:
Government Accountability Office:
441 G Street, N.W.
Washington, DC 20548:
[End of section]
Appendix IX: GAO Contact and Staff Acknowledgments:
GAO Contact:
Mark Goldstein, 202-512-2834:
Acknowledgments:
In addition to the individual listed above, David Sausville, Assistant
Director; Michaela Brown; Tonnyé Conner-White; George Depaoli; Sharon
Dyer; Brandon Haller; Grant Mallie; Kieran McCarthy; Joshua Ormond; and
Susan Michal-Smith made significant contributions to this report.
FOOTNOTES
[1] GAO, High Risk Series: An Update, GAO-07-310 (Washington, D.C.:
Jan. 31, 2007).
[2] In August 2006, FRPC added a 24th data element on disposition of
real property.
[3] Otherwise-managed properties are those owned by a state government
or foreign government that holds title to the real property, but has
granted rights for use to a federal government entity in other than a
leasehold arrangement.
[4] GAO, High Risk Series: Federal Real Property, GAO-03-122
(Washington, D.C.: January 2003).
[5] Service buildings are used for service activities, such as
maintenance and repair shops, dry cleaning plants, post exchange
stores, airport hangars, and buildings primarily used for vehicle
maintenance and repair. Institutional buildings are used for
institutional purposes other than schools, hospitals, and prisons, such
as libraries, chapels, outpatient clinics, dining facilities, and
buildings housing entertainment and recreational activities.
[6] GSA Management Regulations define underutilized property as an
entire property or portion of a property that is used only at irregular
periods or intermittently by the accountable agency or property that is
being used for the agency's current program purposes that can be
satisfied with only a portion of the property. (41 C.F.R. 102-75.50).
[7] GAO, Federal Real Property: Progress Made Toward Addressing
Problems, but Underlying Obstacles Continue to Hamper Reform, GAO-07-
349 (Washington, D.C.: Apr. 13, 2007).
[8] Although DHS has yet to assess the accuracy and reliability of its
real property data, we deemed the dataset complete and reliable enough
to report broadly on its profile.
[9] Deferred maintenance is maintenance that was not performed when
scheduled and is put off for the future.
[10] In commenting on this report, CBP stated that although there are
ongoing difficulties in gathering some of this operating cost data,
changes made to CBP's enterprise system in fiscal year 2007 will allow
CBP to start tracking expenditures for specific utility and service
contract material groups by building. CBP is also working with local
and regional energy providers to update account and location
information to provide better tracking of utility costs.
[11] The National Historic Lighthouse Preservation Act of 2000 amended
NHPA. See 16 U.S.C. § 470w-7.
[12] 16 U.S.C. § 470w-8.
[13] Enhanced-use lease agreements are lease agreements for property
under an agency's control or custody that the agency can (1) enter into
with a public or private entity and (2) receive as payment under the
lease either cash or other consideration such as repairs of the
facilities.
[14] Capital plans, covering 5 years or more, explain and justify an
agency's long-term capital asset decisions. These plans should be the
result of an executive review process that has determined the proper
mix of existing assets and new investments needed to fulfill the
organization's missions, goals, and objectives. Capital assets are
land, structures, equipment, and intellectual property that are used by
the federal government and have an estimated useful life of 2 years or
more.
[15] GAO, Executive Guide: Leading Practices in Capital Decision-
Making, GAO/AIMD-99-32 (Washington, D.C.: December 1998).
[16] GAO, Agency Implementation of Capital Planning Principles Is
Mixed, GAO-04-138 (Washington, D.C.: Jan. 16, 2004).
[17] GAO, Federal Capital: Three Entities Implementation of Capital
Planning Principles Is Mixed, GAO-07-274 (Washington, D.C.: Feb. 23,
2007).
[18] See the background section of this report for background on the
key real property management requirements DHS is required to meet.
[19] An asset management plan lays out an agency's plan to promote the
efficient use of its real property assets by, among other things,
accurately inventorying and describing its assets, aligning its assets
with its mission, and disposing of unneeded assets.
[20] DHS's Second Stage Review was a systematic evaluation of its
operations, policies, and structures completed in June 2005.
[21] DHS was directed to submit a comprehensive headquarters master
plan for the future location of all DHS offices and components. See H.
R. Conf. Rep. No. 109-699, at 118 -119 (2006) accompanying the
Department of Homeland Security Appropriations Act for Fiscal Year
2007, P. L. 109-295 (2006). The Conference Report further stated that
DHS was prohibited from relocating Coast Guard headquarters or any
other DHS component until DHS completed the plan and GSA submitted a
prospectus for congressional review and approval. DHS submitted its
National Capital Region Housing Master Plan to Congress in October
2006.
[22] GSA's alternative location analysis lists locations that GSA
considered to house DHS and why each was eliminated from further study.
[23] GSA is requesting funds in its fiscal year 2008 budget to purchase
about 2 acres of land from both the District of Columbia and CSX
Corporation; a similar request was submitted for land necessary to
access the site from Malcolm X Drive. This acreage is necessary to
develop entrance/exit points to the West Campus to reduce the increased
traffic generated by the new federal campus.
[24] According to construction industry standards, estimates made
during the conceptual design phase of a construction project, the
current phase of the Coast Guard component of the St. Elizabeths
development, generally have a degree of accuracy of plus or minus 30
percent.
[25] The Record of Decision is the decision document for an
environmental impact statement that identifies all alternatives and
describes the reasons for the selection of an alternative.
[26] Infrastructure costs include costs such as planning and design,
demolition of selected structures, utility upgrades, roadwork,
perimeter security, and landscape repair.
[27] GSA has identified the presence of dioxin on-site. The cost of
remediation is unknown and would be borne by the Department of Health
and Human Services, as required by a Memorandum of Agreement signed
when the site was transferred to GSA in December 2004.
[28] DHS testified on the results of GSA's cost analysis on March 1,
2007, before the House of Representatives Homeland Security Committee,
Subcommittee on Management, Investigations, and Oversight. GSA
conducted this analysis using the Automated Prospectus System (TAPS), a
cost analysis tool used by federal agencies to assist in real estate
decision making. GSA uses TAPS analysis to make decisions about leasing
and new construction options. GSA's St. Elizabeths cost analysis looked
at the present value of the cost of ownership over 30 years--not the
overall costs to develop St. Elizabeths, currently estimated at $3.26
billion--which occur at the front end of this 30 year period and then
do not recur. GSA's cost of ownership analysis does not include DHS's
$1.32 billion in development costs, but does include costs for
utilities and repairs that would not be part of development costs.
[29] According to GSA, DHS is currently paying an average of $30 per
square foot for its leased locations totaling $135 million annually. In
addition, in commenting on a draft of this report, GSA said that it has
awarded a contract to verify the DHS headquarters occupancies in the
National Capital Region and to develop scenarios that identify the most
cost-effective approach to achieve DHS's final housing solution,
recognizing DHS's colocation requirement. This study is scheduled for
completion in the fall of 2007.
[30] GSA provided us with an analysis that compared the cost of
providing security to the Bureau of Alcohol, Tobacco, Firearms, and
Explosives to the cost of providing security at the St. Elizabeths West
Campus. However, because it was provided right before this report was
published, we did not assess it.
[31] The Revised Continuing Appropriations Resolution for Fiscal Year
2007 specifically stated none of the funds appropriated or otherwise
made available for GSA's Real Property Activities, Federal Buildings
Fund may be obligated for the Coast Guard consolidation and development
of St. Elizabeths campus in the District of Columbia. P.L. No. 110-5,
121 Stat. 8, 57 (2007).
[32] DHS said that this lease expiration will be bridged until the new
headquarters is completed.
[33] Despite not receiving funding in fiscal year 2007, DHS states that
due to delays in the Master Plan and Environmental Impact Statement
development, the actual delay in the project due to the lack of fiscal
year 2007 funding is only about 2 to 4 months.
[34] GSA was required to submit the plan to the House Committee on
Transportation and Infrastructure and the Senate Committee on Commerce,
Science, and Transportation and the Senate Committee on Environment and
Public Works. See P. L. No. 109-241, 120 Stat. 516, 523-524 (2006).
[35] If parking is included, the square footage for each Master Plan
alternative ranges from 4.34 million square feet to 6.36 million square
feet.
[36] 16 U.S.C. § 470f and 16 U.S.C.§ 470h-2.
[37] According to the District of Columbia Historic Preservation
Office, a few years ago the District of Columbia Office of Planning
conducted a study of St. Elizabeths for the purpose of a redevelopment
plan. That study proposed 2.7 million gross square feet for the West
Campus prior to any preservation reviews. In addition, both NCPC and
the D.C. State Historic Preservation Officer point to GSA's own August
2005 Land Use Feasibility Study, which lays out the risks associated
with various development scenarios, to illustrate risks to historic
resources under the alternatives considered. Of the eight scenarios
considered, only the 1.6 million square foot scenario was not high risk
for protecting St. Elizabeths as a National Historic Landmark.
[38] We do not address the issue of public access in detail in our
report, but in general, most stakeholders with whom we talked supported
some type of limited public access to the site such as access to the
Point for certain holidays and access by permit to the Civil War
cemetery. Most stakeholders acknowledged that unlimited access was not
a realistic option. We agree with DHS that in the post 9-11 security
environment, access to the site is a complicated issue.
[39] GAO, Homeland Security: Further Actions Needed to Coordinate
Federal Agencies' Facility Protection Efforts and Promote Key
Practices, GAO-05-49 (Washington, D.C.: Nov. 30, 2004).
[40] OMB has directed DHS to move the chairman of the Interagency
Security Committee in fiscal year 2008 to DHS's Office of the Under
Secretary for National Protection and Programs.
[41] Management directives for DHS are under a top to bottom review by
order of the Deputy Secretary. The issuance of Management Directive
11001 is dependent on the results of the review.
[42] The National Infrastructure Protection Plan provides the
overarching approach for integrating the nation's many critical
infrastructure and key resource protection initiatives into a single
national effort.
[43] Under its Action Plan for 2007 and 2008, the Interagency Security
Committee has a work group updating the physical security standards for
existing buildings, which includes updates to building levels I to V
and the Department of Justice's Vulnerability Assessment of Federal
Facilities, published in 1995.
[44] GAO, Homeland Security: Actions Needed to Better Protect National
Icons and Federal Office Buildings from Terrorism, GAO-05-790
(Washington, D.C.: June 24, 2005).
[45] FPS MegaCenters provide three primary security services: alarm
monitoring, radio monitoring, and dispatching of FPS police officers
and contract guards.
[46] GAO, Homeland Security: Federal Protective Service Could Better
Measure the Performance of Its Control Centers, GAO-06-1076
(Washington, D.C.: Sept. 29, 2006).
[47] GAO, Homeland Security: Guidance and Standards Are Needed for
Measuring the Effectiveness of Agencies' Facility Protection Efforts,
GAO-06-612 (Washington, D.C.: May 31, 2006).
[48] The President's fiscal year 2008 budget request provides for 950
full-time employees.
[49] Security assessments for existing buildings are conducted on a
cyclical schedule based on the buildings' designated Department of
Justice security level--every 2 years for Level 4; every 3 years for
Level 3, and every 4 years for Levels 1 and 2. FPS uses Federal
Security Risk Management software to assist in developing building
security assessments.
[50] In commenting on our report, ICE officials noted that FPS was
transitioning to an inspector-based workforce that will increase the
number of inspectors assigned to the protection of federal facilities.
FPS will use a risk-based staffing model to assign inspectors to the
highest risk facilities.
[51] In commenting on our report, ICE noted that FPS plans to revise
the Physical Security Academy curriculum in fiscal year 2008 to support
training on the use of a new Risk Assessment and Management Program. In
addition, FPS is partnering with the DHS Office of Security and Federal
Law Enforcement Training Center in an effort to develop a standardized
physical security training program for all federal agencies, drawing in
part upon the experiences of the FPS Physical Security Academy.
[52] FPS provides three categories of security services: (1) basic
security, (2) building-specific security, and (3) tenant-specific
security. Basic security is provided by DHS (ICE/FPS) to GSA-controlled
properties and includes law enforcement, such as building alarm
monitoring, and physical security, such as building security
assessments. Basic security fees are included in fees paid directly to
FPS on a cost-per-square foot basis. The basic security fee is
currently capped at 39 cents per square foot,which DHS and FPS maintain
is not nearly enough to cover costs for basic security services. The
President's fiscal year 2008 budget proposes to increase the current
basic security from 39 cents to 57 cents per square foot. Building-
specific security is provided in addition to the basic security
provided in a particular building as a result of DHS building security
assessment recommendations. Examples of building-specific security
measures include contract guards, security equipment, and security
fixtures. Agencies pay for these security services out of their own
budget if they determine that they want them. Tenant-specific security
includes additional reimbursable services and equipment for agencies to
meet their HSPD-12 requirements, which include card readers and
contractor background suitability determinations. Most of FPS's funding
comes from the building-specific and tenant-specific security that it
provides.
[53] GAO, Homeland Security: Transformation Strategy Needed to Address
Challenges Facing the Federal Protective Service, GAO-04-537,
(Washington, D.C.: July 14, 2004.)
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