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Report to the Subcommittee on Financial Services and General 
Government, Committee on Appropriations, U.S. Senate: 

United States Government Accountability Office: 
GAO: 

June 2010: 

Federal Energy Management: 

GSA's Recovery Act Program Is on Track, but Opportunities Exist to 
Improve Transparency, Performance Criteria, and Risk Management: 

GAO-10-630: 

GAO Highlights: 

Highlights of GAO-10-630, a report to the Subcommittee on Financial 
Services and General Government, Committee on Appropriations, U.S. 
Senate. 

Why GAO Did This Study: 

The American Recovery and Reinvestment Act of 2009 (Recovery Act) 
provided the General Services Administration (GSA) with $5.55 billion 
to invest in federal buildings and promote economic recovery. This 
funding includes $4.5 billion to convert buildings to high-performance 
green buildings (HPGB), which seek to reduce energy and water use, 
among other goals. 

GAO was asked to address the (1) steps GSA has taken to implement the 
program and make its Recovery Act projects transparent to the public, 
(2) extent to which GSA’s Recovery Act projects are helping the agency 
convert buildings to HPGB and addressing federal energy and water 
conservation requirements and goals, and (3) extent to which GSA has 
identified potential risks to its Recovery Act program and developed 
strategies to mitigate those risks. GAO reviewed GSA documents and 
relevant laws and executive orders, and interviewed GSA officials at 
headquarters and staff for 12 projects, which varied in type, size, 
and location. 

What GAO Found: 

GSA has put an organizational structure in place to implement its 
Recovery Act program and, as of April 30, 2010, had obligated just 
over $4 billion of its $5.55 billion appropriation, and is on track to 
meet the act’s obligation deadlines. GSA also has published 
information on its Recovery Act program, such as agencywide plans for 
spending funds and lists of projects, but this information does not 
identify the nature of the work being conducted or describe the 263 
projects GSA has selected for Recovery Act funding. Without this 
information, the program is less than fully transparent—a key GSA 
Recovery Act goal—because the public cannot readily discern what 
individual projects entail or are expected to achieve with Recovery 
Act funding. 

Table: GSA Recovery Act Obligation Milestones and Deadlines: 

Milestone: 
Amount to be obligated: Not less than a total of $1 billion; 
Time frame: August 1, 2009; 
Amount obligated (cumulative): $1.1 billion. 

Milestone: 
Amount to be obligated: Not less than a total of $1.2 billion; 
Time frame: September 7, 2009; 
Amount obligated (cumulative): $1.3 billion. 

Milestone: 
Amount to be obligated: Not less than a total of $2 billion; 
Time frame: December 31, 2009; 
Amount obligated (cumulative): $2.1 billion. 

Milestone: 
Amount to be obligated: Not less than a total of $4 billion; 
Time frame: March 31, 2010; 
Amount obligated (cumulative): $4.0 billion. 

Deadline: 
Amount to be obligated: Not less than a total of $5 billion; 
Time frame: September 30, 2010. 

Deadline: 
Amount to be obligated: Not less than a total of $5.55 billion; 
Time frame: September 30, 2011. 

Source: GAO analysis of GSA data. 

[End of table] 

GSA’s Recovery Act projects will enhance energy and water conservation 
performance in the 263 projects to varying degrees. GSA has begun 
collecting the data it would need to measure the likely extent of 
improvement. GSA set minimum performance criteria for its projects, 
which include reducing energy use by 30 percent. The criteria do not, 
however, include reducing the energy and environmental impacts of 
transportation through building location and site design, although 
this is part of the statutory definition of a HPGB. Under the Recovery 
Act, GSA is to use this definition when converting existing buildings. 
According to GSA, some managers are designing transportation-related 
improvements into their projects. However, because it is not part of GSA
’s criteria, other managers may not be systematically considering such 
improvements. According to GSA, the agency has begun to roll out a new 
centralized data system to collect and report on specific information 
for Recovery Act projects’ green improvements and performance. 

GSA has identified risks to its Recovery Act program, such as the risk 
that Recovery Act reporting is inaccurate or incomplete, and risk 
mitigation strategies. In addition, GSA’s approach to risk management 
is generally consistent with best practices we have developed. 
However, GSA relies on informal communication to identify project-
level risks and has not taken steps to ensure the completion of 
project-level risk planning documents required by GSA. GAO found that 
the required documents, which are intended to help plan for project-
level risks, had not been fully completed for 9 of the 12 projects 
reviewed. Unidentified risks to GSA’s Recovery Act projects could 
potentially limit GSA’s ability to achieve Recovery Act goals. 

What GAO Recommends: 

GAO is recommending that the GSA Administrator should make more 
information publicly available on Recovery Act projects, include 
transportation improvements in GSA’s criteria for projects, and do 
more to plan for project-level risks. On commenting on a draft of this 
report, the GSA Administrator agreed with the recommendations. 

View [hyperlink, http://www.gao.gov/products/GAO-10-630] or key 
components. For more information, contact Terrell Dorn at (202) 512-
2834 or dornt@gao.gov or Mark Gaffigan at (202) 512-3841 or 
gaffiganm@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

GSA Has Processes to Manage Its Program and Meet Obligation Deadlines 
but Has Not Provided Key Information about Its Projects to the Public: 

Projects Could Result in Greener Buildings, but GSA's Data Are Not Yet 
Available to Measure the Extent of Progress: 

GSA Identifies Risks to Its Program and Risk Mitigation Strategies, 
but Some Project-Level Risk Plans Are Not Complete: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Scope and Methodology: 

Appendix II: GSA's Minimum Performance Criteria for Recovery Act 
Projects: 

Appendix III: Descriptions for 12 Case Studies: 

Appendix IV: Comments from the General Services Administration: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: GSA's Recovery Act Program: 

Table 2: GSA's Recovery Act Project Selection Criteria for Full and 
Partial Building Modernizations: 

Table 3: Elements of a High-Performance Green Building: 

Table 4: Selected Federal Energy and Water Conservation Requirements 
and Goals from Statutes and Executive Orders: 

Table 5: GSA's Recovery Act Obligation Milestones and Deadlines: 

Table 6: Revisions to GSA's Recovery Act Project Plan: 

Table 7: Twelve GSA Recovery Act Projects That We Selected as Case 
Studies: 

Table 8: Fourteen Key Risks Identified for PBS's Recovery Act Program: 

Table 9: Risk Management Best Practices Used to Assess GSA's Risk 
Management Approach: 

Figures: 

Figure 1: Organization Chart for GSA's Program Management Office: 

Figure 2: GSA's Recovery Act Zones and Regions: 

Abbreviations: 

ADA: Americans with Disabilities Act: 

ASHRAE: American Society of Heating, Refrigerating and Air-
Conditioning Engineers: 

CPP: comprehensive project plan: 

EISA: Energy Independence and Security Act: 

E.O.: executive order: 

EPA: Environmental Protection Agency: 

EPAct: Energy Policy Act: 

FEMP: Federal Energy Management Program: 

GSA: General Services Administration: 

HPGB: high-performance green building: 

HVAC: heating, ventilation, and air conditioning: 

IPC: International Plumbing Code: 

LCC: life-cycle costing: 

LEED: Leadership in Energy and Environmental Design: 

MOU: memorandum of understanding: 

MPC: minimum performance criteria: 

NIST: National Institute of Standards and Technology: 

OFHPGB: Office of Federal High-Performance Green Buildings: 

OIG: Office of Inspector General: 

OMB: Office of Management and Budget: 

PBS: Public Buildings Service: 

PDRI: project development rating index: 

PMO: Program Management Office: 

PV: photovoltaic: 

Recovery Act: American Recovery and Reinvestment Act of 2009: 

Recovery.gov: www.recovery.gov: 

SME: subject matter experts: 

UPC: Uniform Plumbing Code: 

USDA: U.S. Department of Agriculture: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

June 16, 2010: 

The Honorable Richard J. Durbin: 
Chairman: 
The Honorable Susan M. Collins: 
Ranking Member: 
Subcommittee on Financial Services and General Government: 
Committee on Appropriations: 
United States Senate: 

In January 2003, we designated federal real property as a high-risk 
area, in part because of deteriorating facilities and unreliable real 
property data.[Footnote 1] In addition, in 2007, we reported that 
addressing the needs of aging and deteriorating federal facilities 
remains a problem for major real property-holding agencies, and that, 
according to recent estimates, tens of billions of dollars will be 
needed to repair or restore these assets.[Footnote 2] The American 
Recovery and Reinvestment Act of 2009 (Recovery Act)[Footnote 3] 
provided the General Services Administration (GSA) with $5.55 billion 
to invest in federal buildings, create jobs, and promote economic 
recovery. Of this $5.55 billion, over $1 billion is being used by GSA 
for new federal buildings, courthouses, border stations, and land 
ports of entry. Additionally, the Recovery Act provided that at least 
$4.5 billion be used "for measures necessary to convert GSA facilities 
to high-performance green buildings" as defined by section 401 of the 
Energy Independence and Security Act of 2007 (EISA).[Footnote 4] High- 
performance green buildings are designed to achieve a number of 
environmental goals, including reducing energy, water, and material 
resource use and the buildings' impact on the environment and on 
building occupants, by means such as using recycled or nontoxic 
products in the buildings. 

The federal government is the nation's single largest energy consumer, 
and federal buildings accounted for about 35 percent of the 
government's total energy use in fiscal year 2009.[Footnote 5] 
Converting federal facilities to high-performance green buildings 
could help reduce the federal government's energy consumption and 
bring federal buildings more in line with federal energy and water 
conservation requirements and goals. Over the last several years, a 
number of laws and executive orders have established new requirements 
and direction for improving the energy and water conservation 
performance of federal facilities. For example, in December 2007, EISA 
established new requirements for reducing energy use at federal 
buildings, reducing fossil fuel use for certain federal buildings, and 
managing storm water runoff. GSA's Recovery Act funding, which is more 
than three times greater than the agency's 2009 funding for new 
construction and renovations, provides a unique opportunity for GSA to 
address the deterioration of some of its aging buildings while also 
improving their energy and water conservation performance. However, to 
obligate this funding within the time frame required by the Recovery 
Act,[Footnote 6] GSA will have to implement hundreds of projects 
across the country at an accelerated pace. 

Given the magnitude of GSA's Recovery Act program and the associated 
time frame, you asked us to review GSA's plans and efforts related to 
the use of Recovery Act funds. This report provides information and 
analysis on (1) the steps GSA has taken to implement the program and 
make its Recovery Act projects transparent to the public, (2) the 
extent to which GSA's Recovery Act projects are helping the agency 
convert buildings to high-performance green buildings and address 
energy and water conservation requirements and goals, and (3) the 
extent to which GSA has taken steps to identify potential risks to its 
Recovery Act program and developed strategies to mitigate those risks. 

To address these questions, we reviewed key documents describing GSA's 
efforts to organize and implement the program, publicly available 
information about GSA's Recovery Act program, the scope of GSA's 
Recovery Act projects, and GSA's progress in obligating and spending 
funds. We compared criteria GSA established for Recovery Act projects 
with selected legislation and executive orders relevant to the energy 
and water conservation performance of federal buildings. Also, we 
interviewed GSA officials in headquarters and regional offices, 
including project management staff for 12 full and partial building 
modernization projects we selected as case studies using a judgmental 
sample. Because the sample is judgmental, the information we obtained 
from those projects cannot be generalized to all of GSA's Recovery Act 
projects. Among the factors we considered in selecting the 12 projects 
was whether GSA had identified them as being far enough along in the 
design process to have information on their expected performance. In 
addition, we used the projects' type, size, and geographic location as 
selection criteria. We collected information from our 12 case studies 
on their expected energy and water conservation performance. Finally, 
we reviewed GSA's efforts to develop and implement a risk management 
plan, compared those efforts with accepted risk management best 
practices, and compared the project risk planning efforts from our 12 
case studies with GSA policies and Office of Management and Budget 
(OMB) guidance on project-level risk planning. See appendix I for a 
more complete description of our scope and methodology. 

We conducted this performance audit from June 2009 through June 2010 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

Background: 

Of the $5.55 billion the Recovery Act provided to GSA's Federal 
Buildings Fund,[Footnote 7] $750 million is being used by GSA for new 
federal buildings and U.S. courthouses, $300 million is being used for 
new border stations and land ports of entry, and $4.5 billion is being 
used for measures necessary to convert existing GSA facilities to high-
performance green buildings.[Footnote 8] Overall, for its Recovery Act 
program, GSA selected 263 projects in all 50 states, [Footnote 9] the 
District of Columbia, and 2 U.S. territories. As shown in table 1, 
GSA's Recovery Act projects fall into the following four main 
categories: (1) new construction, (2) full and partial building 
modernizations, (3) limited scope projects, and (4) small projects. 

Table 1: GSA's Recovery Act Program: 

Project category: New construction: Federal buildings and U.S. 
courthouses; 
Total projects: 11; 
Recovery Act funding[A]: $750 million. 

Project category: New construction: Border stations and land ports of 
entry; 
Total projects: 7; 
Recovery Act funding[A]: $300 million. 

Project category: Full and partial building modernizations: Full 
building modernizations; 
Total projects: 32; 
Recovery Act funding[A]: $2.708 billion. 

Project category: Full and partial building modernizations: Partial 
building modernizations; 
Total projects: 13; 
Recovery Act funding[A]: $483 million. 

Project category: Limited scope projects: 
Total projects: 200; 
Recovery Act funding[A]: $933 million. 

Project category: Small projects[B]: 
Total projects: [Empty]; 
Recovery Act funding[A]: $140 million. 

Project category: Other[C]: 
Total projects: [Empty]; 
Recovery Act funding[A]: $235 million. 

Source: GAO analysis of GSA data. 

Note: Data are based on GSA's original March 2010 project plan. 

[A] Values may not add up to $5.55 billion because of rounding. 

[B] GSA does not specifically identify the number of small projects in 
its project plan. As of March 31, 2010, GSA had funded 140 small 
projects. 

[C] Other refers to funds provided for rental of space, building 
operations, GSA's Office of Federal High-Performance Green Buildings, 
and an apprenticeship program. 

[End of table] 

The following information describes the four main categories for GSA's 
Recovery Act projects: 

* New construction: Projects associated with building entirely new 
structures or significant extensions to existing structures, including 
the construction of new federal buildings and courthouses, as well as 
border stations and land ports of entry. 

* Full and partial building modernizations: Projects associated with 
the replacement or upgrade of multiple building systems and components 
(such as windows, roofs, and plumbing, electrical, and mechanical 
systems), which are intended to significantly increase the usable life 
of the buildings. Full modernizations are comprehensive renovations 
that replace or restore nearly all the major systems in a building. 
Partial modernizations are more limited and address one or a few 
systems in the building. 

* Limited scope projects: Projects associated with a single building 
system--such as lighting or plumbing--that could include upgrading 
existing systems or installing energy and environmental improvements, 
such as installing energy-generating photovoltaic panels on the roof 
of a building. 

* Small projects: Limited scope projects whose costs are below the 
prospectus level.[Footnote 10] 

GSA officials told us that in selecting Recovery Act projects, they 
gave priority to those projects that would help transform federal 
buildings into high-performance green buildings and obligate funds 
quickly. Obligating funds quickly was important because the Recovery 
Act requires GSA to obligate $5 billion by September 30, 2010, and to 
obligate the full Recovery Act funding amount, $5.55 billion, by 
September 30, 2011. To reflect these priorities, GSA developed 
selection criteria for full and partial building modernization 
projects, which are presented in table 2 in descending order of 
weight.[Footnote 11] 

Table 2: GSA's Recovery Act Project Selection Criteria for Full and 
Partial Building Modernizations: 

Criterion: Helping transform federal buildings into high-performance 
green buildings; 
Description: Ability of a project to implement high-performance 
features--such as energy conservation and renewable energy generation. 

Criterion: Execution timing; 
Description: Speed at which a contract for the project could be 
awarded. 

Criterion: Minimizing execution risk; 
Description: Lower risk of facing schedule delays, such as a project 
where design work had already been completed. 

Criterion: Improving facility condition; 
Description: Extent to which a project would improve the condition of 
the asset by addressing identified repair needs. 

Criterion: Improving asset utilization; 
Description: Extent to which a project would increase asset 
utilization by reducing vacant space or increasing the intensity of 
asset use. 

Criterion: Return on investment; 
Description: Expected time it would take GSA to recover the cost of 
the project through lower opportunity costs. 

Criterion: Lease cost avoidance; 
Description: Degree to which lease costs would be avoided by 
completing the project. 

Criterion: Historical significance; 
Description: Extent to which a building has been recognized as having 
historical significance. 

Source: GAO analysis of GSA information. 

Note: The execution timing and minimizing execution risk criteria were 
given equal weight. 

[End of table] 

GSA scored projects in accordance with the relative priority it 
assigned to each criterion and then ranked potential Recovery Act 
projects on the basis of these results. GSA assigned the highest 
priority to the first three criteria listed in table 2. The execution 
timing and minimizing execution risk criteria are designed to identify 
projects that could be started quickly, would create jobs as soon as 
possible, and would also have a low risk of not being completed within 
the Recovery Act's deadlines. Recovery Act funds must be spent no 
later than 5 years after the end of the fiscal year in which the funds 
are required to be obligated. Typically, the funds for a large 
construction project are obligated throughout the life of the project, 
and the 5-year limitation on expenditures generally does not apply to 
funds made available to GSA for acquisition and construction. 
Therefore, the Recovery Act's establishment of deadlines for 
obligating and spending funds differs from the typical time frames for 
GSA's construction projects. 

Many of the projects GSA selected for new construction and full and 
partial building modernizations had previously received partial 
funding for design or for early project phases. For example, 41 of the 
63 new construction and full and partial building modernization 
projects had received funding from previous fiscal year 
appropriations. GSA officials said that they used Recovery Act funding 
to quickly start or expand construction on these projects, while also 
identifying ways to incorporate energy savings or environmental 
improvements into their design. Additionally, GSA funded cost 
escalation for some ongoing projects--that is, projects that needed 
additional funding to start or to complete construction. For example, 
according to GSA officials, the renovation of the Thurgood Marshall 
U.S. Courthouse in New York, a full building modernization, needed 
Recovery Act funding to address an increase in cost after bids from 
contractors came in higher than expected. 

According to GSA officials, the other five criteria listed in table 2 
are those GSA typically uses when selecting capital projects, such as 
improving facility condition. In GSA's supplemental information to its 
financial statements for fiscal year 2009, GSA reported an inventory 
of capital repairs and alterations estimated to cost approximately 
$5.0 billion. The buildings GSA selected for its Recovery Act program 
account for about $3.7 billion of this estimate, but the Recovery Act 
funding will not fully address the needs of each selected building, 
since reducing GSA's capital repairs and alterations inventory was not 
the intent of the Recovery Act, according to GSA officials. GSA 
officials also stated that they will use Recovery Act funds for 
projects or elements of projects that are not among the estimated 
capital improvement needs, such as projects to incorporate high- 
performance green building features. While improving facility 
condition was one of GSA's selection criteria, making facilities 
greener and obligating funds quickly received higher priority. GSA 
officials estimated that Recovery Act projects will reduce the 
agency's total capital repairs and alterations estimate by $1.5 to 
$2.0 billion. 

According to the Web site, [hyperlink, http://www.recovery.gov] 
(Recovery.gov), the Recovery Act has three immediate goals: (1) create 
new jobs and save existing ones, (2) spur economic activity and invest 
in long-term growth, and (3) foster "unprecedented" levels of 
accountability and transparency in government spending. In addition, 
GSA's Recovery Act program plan states that GSA will maintain an 
unprecedented level of openness and transparency in operations. 
[Footnote 12] GSA has published information on its Recovery Act 
program on both its own Recovery Act Web site[Footnote 13] and 
Recovery.gov. The information includes the following documents: 

* The Agencywide Recovery Plan details GSA's broad Recovery Act goals 
for the entire agency, GSA programs funded by the Recovery Act, 
contracting operations, and agency accountability efforts. The 
agencywide plan also outlines the public benefits GSA expects from its 
investments, such as job creation and environmental benefits. 

* The Federal Buildings Fund Program Plan contains a summary of the 
objectives and activities that GSA's Public Buildings Service (PBS) 
[Footnote 14] plans to implement with the $5.55 billion in Recovery 
Act funds. The plan also includes information on the projects' 
selection, delivery schedule, and performance measures. Additionally, 
the plan describes how GSA will address issues such as monitoring and 
evaluation, transparency, and accountability for its Recovery Act 
program. 

* The PBS Project Plan details how GSA will spend its $5.55 billion in 
Recovery Act funds. The project plan lists all of the GSA building 
projects that will receive Recovery Act funds and, for each project, 
includes the name, location (city and state), and estimated cost. GSA 
has the ability to shift funds from one project to another but must 
give the Senate and House Committees on Appropriations 15 days notice 
before doing so. Agency officials stated that they will continue to 
revise GSA's project plan in the future. 

* The weekly financial and activity reports contain information on 
GSA's Recovery Act weekly appropriations, obligations, and 
disbursements, along with activities and planned actions. 

* The Federal Buildings Fund Investments Map shows where GSA is 
spending its Recovery Act funds and provides information on spending 
to date, measured in obligations and expenditures, for individual 
projects or states. GSA posted an interactive map on its Web site, 
which graphically depicts its Recovery Act obligations and 
expenditures by state and project. 

* Recipient reporting guidance for registration and reporting offers 
assistance for prime recipients of Recovery Act funds, who must 
register with the government and report on how Recovery Act funds were 
used. GSA posts its recipient reporting data on Recovery.gov, along 
with other participating agencies. 

GSA also reports frequently to OMB and congressional committees on 
Recovery Act plans, progress, and accomplishments. For example, at the 
request of OMB and the White House, GSA produced a 100 Days Report, 
which updated current Recovery Act obligations and reported planned 
obligations to the end of calendar year 2009. GSA also produces 
monthly reports on obligations versus expenditures for the House 
Committee on Transportation and Infrastructure. 

Since the 1970s, federal statutes and executive orders have 
established and revised a number of requirements and goals for 
changing the way federal agencies use or obtain energy. For example, 
EISA established new energy management requirements and goals, such as 
energy-efficiency performance standards for new buildings and major 
renovations. In addition, EISA defined a high-performance green 
building, which includes eight elements, as shown in table 3. 

Table 3: Elements of a High-Performance Green Building: 

Number: 1; 
Element: Reduces energy, water, and material resource use. 

Number: 2; 
Element: Improves indoor environmental quality, including reducing 
indoor pollution, improving thermal comfort, and improving lighting 
and acoustic environments that affect occupant health and productivity. 

Number: 3; 
Element: Reduces negative impacts on the environment throughout the 
life cycle of the building, including air and water pollution and 
waste generation. 

Number: 4; 
Element: Increases the use of environmentally preferable products, 
including biobased, recycled content, and nontoxic products with lower 
life-cycle impacts. 

Number: 5; 
Element: Increases reuse and recycling opportunities. 

Number: 6; 
Element: Integrates systems in the building. 

Number: 7; 
Element: Reduces the environmental and energy impacts of 
transportation through building location and site design that supports 
a full range of transportation choices for users of the building. 

Number: 8; 
Element: Considers indoor and outdoor effects of the building on human 
health and the environment, including improvements in worker 
productivity, the life-cycle impacts of building materials and 
operations, and other factors that the Director of GSA's Office of 
Federal High-Performance Green Buildings considers to be appropriate. 

Source: GAO analysis of EISA, 2007 (Pub. L. No. 110-140). 

[End of table] 

While the Recovery Act specifies that GSA should use Recovery Act 
funds for measures necessary to convert GSA facilities to high-
performance green buildings, as defined in section 401 of EISA, GSA 
also has to follow federal energy and water conservation requirements 
and goals established in federal statutes and executive orders. The 
federal energy and water conservation requirements and goals which we 
refer to later in this report are summarized in table 4. 

Table 4: Selected Federal Energy and Water Conservation Requirements 
and Goals from Statutes and Executive Orders: 

Statute or executive order: EISA 2007 Sec. 431 (12/19/2007); 
Issue: Energy intensity reduction[A]; 
Building category: Federal buildings; 
Energy and water conservation requirements and goals: Each agency 
shall apply conservation measures to reduce energy consumption per 
gross square foot of the federal buildings of the agency by 15 percent 
by 2010 and 30 percent by 2015 compared with 2003. 

Statute or executive order: EISA 2007 Sec. 433 (12/19/2007); 
Issue: Fossil fuel energy reduction; 
Building category: New federal buildings and federal buildings 
undergoing major renovations; 
Energy and water conservation requirements and goals: Reduce fossil 
fuel-generated energy consumption by 55 percent by 2010 and 65 percent 
by 2015 compared with 2003. 

Statute or executive order: EISA 2007 Sec. 434 (12/19/2007); 
Issue: Metering; 
Building category: All buildings; 
Energy and water conservation requirements and goals: Each agency 
shall provide for equivalent metering of natural gas and steam by 2016. 

Statute or executive order: EISA 2007 Sec. 438 (12/19/2007); 
Issue: Storm water runoff; 
Building category: Federal facility with a footprint that exceeds 
5,000 square feet; 
Energy and water conservation requirements and goals: Maintain or 
restore, to the maximum extent technically feasible, the 
predevelopment hydrology of the property with regard to the 
temperature, rate, volume, and duration of flow. 

Statute or executive order: EISA 2007 Sec. 523 (12/19/2007); 
Issue: Solar hot water heaters; 
Building category: New federal buildings or federal buildings 
undergoing major renovations; 
Energy and water conservation requirements and goals: Not less than 30 
percent of the hot water demand must be met through the installation 
and use of solar hot water heaters, provided such heaters are life-
cycle cost-effective. 

Statute or executive order: E.O. 13423[B[(1/24/2007)] 07); 
Issue: Water consumption intensity[C]; 
Building category: All buildings; 
Energy and water conservation requirements and goals: Reduce the 
agency's water consumption intensity by 2 percent annually through the 
end of 2015 or 16 percent by 2015 compared with 2008. 

Statute or executive order: Energy Policy Act of 2005 (8/8/2005); 
Issue: Energy-efficiency performance standards; 
Building category: New federal buildings; 
Energy and water conservation requirements and goals: Achieve energy 
consumption levels that are at least 30 percent below the levels 
established in the standard established by the American Society of 
Heating, Refrigerating and Air-Conditioning Engineers, if life-cycle 
cost-effective. 

Statute or executive order: Guiding principles[D[(12/1/2008)] 08); 
Issue: Energy use reduction; 
Building category: New construction; 
Energy and water conservation requirements and goals: Reduce energy 
use by 30 percent compared with 2007. 

Statute or executive order: Guiding principles (12/1/2008); 
Issue: Energy use reduction; 
Building category: Major renovations; 
Energy and water conservation requirements and goals: Reduce energy 
use by 20 percent compared with 2003. 

Statute or executive order: Guiding principles (12/1/2008); 
Issue: Indoor potable water; 
Building category: New construction and major renovations; 
Energy and water conservation requirements and goals: Use a minimum of 
20 percent less potable water than the indoor water use baseline 
calculated for the building. 

Statute or executive order: Guiding principles (12/1/2008); 
Issue: Outdoor potable water; 
Energy and water conservation requirements and goals: Building 
category: New construction and major renovations; 
Reduce outdoor potable water consumption by a minimum of 50 percent 
over that consumed by conventional means, such as plant species. 

Source: GAO analysis of EISA, 2007; the Energy Policy Act of 2005; 
Executive Order 13423; and high-performance and sustainable buildings 
guidance. 

[A] Energy intensity is defined as energy consumption, measured in 
British thermal units, per gross square foot. 

[B] Executive Order 13514, issued in October 2009, strengthened this 
water intensity consumption goal by extending the fiscal year-end date 
to 2020. For example, the executive order says to "reduce potable 
water consumption intensity by 2 percent annually through 2020 or 26 
percent by 2020." 

[C] Water consumption intensity is defined as gallons per gross square 
foot of facility space. 

[D] The Interagency Sustainability Working Group, as a subcommittee of 
the Steering Committee established by Executive Order 13423, initiated 
development of the guidance for the Guiding Principles for Federal 
Leadership in High Performance and Sustainable Buildings to assist 
agencies in meeting the high-performance and sustainable building 
goals of Executive Order 13423. 

[End of table] 

GSA Has Processes to Manage Its Program and Meet Obligation Deadlines 
but Has Not Provided Key Information about Its Projects to the Public: 

GSA Has Processes in Place to Manage Its Program and Is on Track to 
Meet Recovery Act Obligation Deadlines: 

In March 2009, GSA created a national program management office (PMO) 
to oversee its Recovery Act program and established interim obligation 
milestones to help it achieve its Recovery Act obligation deadlines. 
The PMO is supported by the Recovery Program Executive Steering 
Committee headed by the PBS Deputy Commissioner. The Executive 
Steering Committee has developed a nationwide program strategy and 
priorities for the program. Figure 1 illustrates the organization of 
the PMO. A program management recovery executive heads the PMO and is 
supported by zone and regional recovery executives, who are 
responsible for monitoring and reviewing the performance of Recovery 
Act projects and managing risks at the regional level. In addition, 
subject matter experts support the regional teams in delivering 
projects, and two contractors are responsible for project tracking and 
for reporting and communication. The PMO uses data from projects to 
look for trends in cost and schedule performance for the program. 

Figure 1: Organization Chart for GSA's Program Management Office: 

[Refer to PDF for image: Organization Chart] 

Top level: 
Recovery Program Executive Steering Committee. 

Second level, reporting to the Recovery Program Executive Steering 
Committee: 
Human Resources Support; 
Recovery Executive; 
Legal Support. 

Third level, reporting to the Recovery Executive: 
Chief of Staff; 
- Program Analyst. 

Fourth level, reporting to the Chief of Staff: 
Director of Operations. 

Fifth level, reporting to the Director of Operations: 
Executive Assistant. 

Sixth level, reporting to the Executive Assistant: 
* Communications: 
- Director; 
- Program Analyst; 
- Communications Support. 
* Recovery Zone Executives: 
- Zone A Executive; 
- Zone B Executive; 
- Zone C Executive; 
* Recovery Zone Managers: 
- Zone A Manager; 
- Zone B Manager; 
- Zone C Manager; 
* Program Management: 
- Support Services; 
- Contract Support; 
- Compliance/Risk Support; 
* Subject Matter Experts (SME): 
- Director; 
- Sustainability SME; 
- Energy SME; 
- Preservation SME; 
* Budget Reporting: 
- Director; 
- Program Analyst; 
- Budget Reporting Support; 
* Acquisition: 
- Director; 
- Acquisitions Support. 

Regional Recovery Executives: 
* Region 1 Executive; 
* Region 2 Executive; 
* Region 3 Executive; 
* Region 4 Executive; 
* Region 5 Executive; 
* Region 6 Executive; 
* Region 7 Executive; 
* Region 8 Executive; 
* Region 9 Executive; 
* Region 10 Executive; 
* Region 11 Executive. 

Source: GAO presentation of GSA information. 

[End of figure] 

As shown in figure 2, GSA has grouped its 11 regions into three 
Recovery Act zones.[Footnote 15] GSA officials stated that the 
objectives of the zone structure are to create and foster the sharing 
of ideas and resources and to provide project oversight. Also, the 
zone structure provides a link between the project leadership and the 
PMO. According to GSA officials, the PMO's efforts and success have 
also contributed to improvements in GSA's other operations. For 
example, GSA is reorganizing PBS's internal structure to create more 
national coherence by having all 11 regions work together, as under 
the Recovery Act zone structure, rather than independently. 
Furthermore, GSA is realigning its Office of Design and Construction 
[Footnote 16] to directly coordinate with the PMO, which will allow 
the two offices to share ideas. 

Figure 2: GSA's Recovery Act Zones and Regions: 

[Refer to PDF for image: illustrated map of the U.S.] 

Zone A: 
Region 1: New England; 
Region 2: Northeast and Caribbean; 
Region 3: Mid-Atlantic; 
Region 11: National Capital. 

Zone B: 
Region 4: Southeast; 
Region 5: Great Lakes; 
Region 6: The Heartland; 
Region 7: Greater Southwest. 

Zone C: 
Region 8: Rocky Mountain; 
Region 9: Pacific Rim; 
Region 10: Northwest Arctic. 

Sources: GSA; Map Resources (map). 

[End of figure] 

The PMO established interim milestones to help GSA achieve the two 
Recovery Act obligation deadlines. As we have previously noted, the 
Recovery Act requires GSA to obligate $5.0 billion by September 30, 
2010, and to obligate the full Recovery Act funding amount, $5.55 
billion, by September 30, 2011. Table 5 shows the four interim 
milestones that the PMO set and the cumulative amount that GSA 
obligated by each of the milestones. As of April 30, 2010, GSA had 
obligated just over $4.0 billion. According to GSA officials, GSA 
remains on track to achieve its overall Recovery Act obligation 
deadlines. 

Table 5: GSA's Recovery Act Obligation Milestones and Deadlines: 

Milestone: 
Amount to be obligated: Not less than a total of $1 billion; 
Time frame: August 1, 2009; 
Amount obligated (cumulative): $1.1 billion. 

Milestone: 
Amount to be obligated: Not less than a total of $1.2 billion; 
Time frame: September 7, 2009; 
Amount obligated (cumulative): $1.3 billion. 

Milestone: 
Amount to be obligated: Not less than a total of $2 billion; 
Time frame: December 31, 2009; 
Amount obligated (cumulative): $2.1 billion. 

Milestone: 
Amount to be obligated: Not less than a total of $4 billion; 
Time frame: March 31, 2010; 
Amount obligated (cumulative): $4.0 billion. 

Deadline: 
Amount to be obligated: Not less than a total of $5 billion; 
Time frame: September 30, 2010. 

Deadline: 
Amount to be obligated: Not less than a total of $5.55 billion; 
Time frame: September 30, 2011. 

Source: GAO analysis of GSA data. 

Note: Data for the amount obligated (cumulative) column are rounded. 

[End of table] 

According to GSA's Agencywide Recovery Plan, GSA's goal is to award 99 
percent of Recovery Act dollars through competitive awards. GSA has 
identified approximately 1 percent of Recovery Act funds that may be 
awarded through other-than-fully-competitive means.[Footnote 17] To 
help achieve this goal, GSA plans to add Recovery Act projects to 
existing, competitively awarded contracts when they are within the 
scope of work, award ceiling, and terms of the agreement. In March 
2010, the GSA Office of Inspector General (OIG) reported that GSA 
incorrectly executed the construction portion of the contract to which 
a Recovery Act project was added--a federal courthouse in Austin, 
Texas--and concluded that the award was not competitive.[Footnote 18] 
PBS disagreed with the OIG's findings. GSA has awarded additional work 
to this project using Recovery Act funding and considered it to be 
competitively awarded because it considers the initial contract to 
have been competitively awarded.[Footnote 19] 

GSA's $5.55 billion in Recovery Act funding, which must be obligated 
over 2 fiscal years, is over three times the agency's 2009 funding for 
new construction and renovations. To address this increase in its 
workload, GSA determined that it would need to add over 200 full-time- 
equivalent personnel, including contracting officers. Additionally, 
GSA officials said they have transferred experienced personnel from 
other work to Recovery Act projects. GSA is also hiring temporary 
federal personnel and contractors, both to address the increased 
workload and to fill the gaps created by transferring experienced 
staff to Recovery Act work. As of April 23, 2010, GSA had hired 96 
full-time-equivalent personnel and 38 contractors, and it plans to 
hire an estimated 68 additional personnel by the end of fiscal year 
2010. 

The Recovery Act requires recipients to report data on jobs funded 
each calendar quarter. GSA established an outreach and call center to 
assist recipients in meeting their reporting requirements. According 
to GSA officials, 99.0 percent of GSA's prime recipients have reported 
during the April 2010 reporting period, which represents 99.8 percent 
of GSA's Recovery Act obligations for PBS. For the most recent 
reporting period--January 1, 2010, to March 31, 2010,--GSA recipients 
reported 2,847 jobs funded. GSA officials stated that the requirement 
for recipient reporting, including jobs data, is a contractual 
obligation, and if recipients do not report it is considered a breach 
of contract. 

The GSA OIG received $7 million from the Recovery Act for oversight 
and audit of programs, grants, and projects. To promote accountability 
and transparency on the use of Recovery Act funds, the Recovery 
Accountability and Transparency Board worked with Federal Inspectors 
General to establish a multiphased approach for reviewing agencies' 
oversight of recipients' Recovery Act data. The first phase, conducted 
before the start of the first recipient reporting cycle, provided a 
snapshot of agencies' data review processes.[Footnote 20] The second 
phase, conducted after the first reporting cycle ended, reviewed data 
oversight at seven agencies, including GSA, by their respective OIG. 
[Footnote 21] The GSA OIG is currently examining the effectiveness of 
GSA's review process, comparing GSA and OMB guidance to determine 
whether any conflict exists, and will issue a report no later than 
June 2010. We did not evaluate recipient-reported data as part of this 
review. However, we have reported on problems with data reported by 
recipients of Recovery Act funds administered by federal agencies 
generally, though not by GSA specifically. For example, in November 
2009, we reported that although the job data reported by recipients 
provided some insight into their use of Recovery Act funding, a range 
of significant reporting and quality issues needed to be addressed. 
[Footnote 22] In December 2009, OMB issued guidance to further improve 
the quality of the data that Recovery Act recipients submit.[Footnote 
23] Furthermore, in March 2010, we reported that while progress was 
achieved in addressing some data quality and reporting issues 
identified in the first round of recipient reporting, data errors, 
reporting inconsistencies, and decisions made by some recipients not 
to use the new job reporting guidance for the second round compromised 
data quality and the ability to aggregate the data.[Footnote 24] 
Overall, while significant issues remain, the second round of 
reporting appears to have gone more smoothly as recipients have become 
more familiar with the reporting system and requirements. 

GSA Makes Overall Information on Its Recovery Act Program Publicly 
Available but Has Not Provided Key Information about Its Projects to 
the Public: 

While GSA has provided information on the goals of its Recovery Act 
program, the projects selected to receive Recovery Act funding, and 
its own progress in obligating and expending Recovery Act funding, it 
has not included details on the nature of the work being conducted on 
individual projects or clearly identified or explained why it has 
added or removed projects from its program in GSA's project plan 
revisions. According to Recovery.gov, one of the goals of the Recovery 
Act is to foster "unprecedented" levels of accountability and 
transparency in government spending. In addition, GSA states in its 
Federal Buildings Fund program plan that it will maintain an 
unprecedented level of openness and transparency in operations. As we 
have previously discussed, GSA posted information on its program 
plans, project plan, funding activities, and recipient-reported data 
on its Web site and Recovery.gov. 

The lack of information on the nature of work being conducted on 
individual projects and their expected outcomes makes it difficult for 
the public to determine what improvements are being funded by the 
Recovery Act, such as which building systems are being upgraded or 
what types of building improvements are being made. Project scopes can 
cover a range of activities, including improvements to lighting, 
mechanical/electrical system upgrades, water use, roof repair, or 
window work. Individual projects can also address multiple areas and 
can be designed to achieve renewable energy targets. Such information 
on the nature of the work being conducted, while not required, could 
provide context for the public to understand how Recovery Act funds 
are being used to meet these goals. GSA's project plan, which is 
available on the agency's Web site and Recovery.gov, contains 
information for each GSA Recovery Act project, such as its name, 
location (city and state), and estimated cost. Descriptive information 
about the projects is limited to their category--new construction, 
full and partial building modernization, and limited scope. 
Additionally, full and partial building modernizations are listed 
together, without information on which project falls under which 
category, thereby making it difficult to distinguish between the two 
types. This distinction is important because a full building 
modernization, which is a complete renovation of an entire building, 
would be expected to incorporate more green features than a partial 
building modernization. Moreover, without this distinction, the public 
lacks context for evaluating GSA's efforts to convert existing federal 
facilities to high-performance green buildings, as provided in the 
Recovery Act. 

OMB reviewed GSA's project plan, and on March 31, 2009, GSA submitted 
the plan, with the list of selected projects, to the Senate and House 
Committees on Appropriations as required by the Recovery Act. GSA 
later published project plan revisions--dated November 2009, January 
2010, and March 2010--which reflected adjustments to the original 
project plan's allocations for existing projects. GSA officials said 
they made these adjustments, in part, to take advantage of cost 
savings that they realized when bids came in lower than expected, 
partly because of current economic conditions.[Footnote 25] These 
adjustments led to changes in the amounts of funds allocated for 
certain project categories, primarily affecting small projects, as 
shown in table 6. 

Table 6: Revisions to GSA's Recovery Act Project Plan: 

Project type: New construction: federal buildings and U.S. courthouses; 
Allocations: Initial (March 2009): $733,703,000; 
Allocations: Current (March 2010): $750,000,000; 
Allocations: Change from initial: $16,297,000. 

Project type: New construction: border stations and land ports of 
entry; 
Allocations: Initial (March 2009): $300,000,000; 
Allocations: Current (March 2010): $300,000,000; 
Allocations: Change from initial: 0. 

Project type: Full and partial building modernizations; 
Allocations: Initial (March 2009): $3,168,844,000; 
Allocations: Current (March 2010): $3,191,463,000; 
Allocations: Change from initial: $22,619,000. 

Project type: Limited scope projects; 
Allocations: Initial (March 2009): $806,877,000; 
Allocations: Current (March 2010): $933,225,000; 
Allocations: Change from initial: $126,348,000. 

Project type: Small projects; 
Allocations: Initial (March 2009): $298,576,000; 
Allocations: Current (March 2010): $140,463,000; 
Allocations: Change from initial: -$158,113,000. 

Source: GAO analysis of GSA data. 

[End of table] 

While the revisions to GSA's project plan to date track the changes in 
project cost estimates, they do not fully explain the addition or 
removal of projects, nor do they address the lack of information on 
project scope. For example, in the November 2009 revised project plan, 
GSA states that it removed a project because it was no longer 
appropriate to go forward. GSA did not clearly highlight or mention 
which project it removed or the type of project. The removed project 
can be identified only by looking through the entire list of all 
Recovery Act projects and comparing the previous and new project cost 
totals. In the January 2010 revision, GSA added nine new projects to 
its program--one new construction project, two projects in the full 
and partial building modernization category, and six limited scope 
projects. These nine projects are expected to cost a total of 
approximately $86 million, but the project plan did not clearly 
highlight which projects were new additions to the plan. GSA has an 
opportunity to further meet its Recovery Act transparency goals by 
clearly identifying projects that have been added to or deleted from 
its program. 

Projects Could Result in Greener Buildings, but GSA's Data Are Not Yet 
Available to Measure the Extent of Progress: 

GSA has developed minimum performance criteria that will help it 
convert buildings to high-performance green buildings and address 
energy and water conservation requirements and goals, although these 
criteria do not align completely with federal requirements. The 
resulting modernized buildings will likely vary greatly in the extent 
of their green improvements, for several reasons. Finally, GSA does 
not yet have sufficient data on the progress of its Recovery Act 
improvements, but it is implementing a system to track this. 

GSA's Minimum Performance Criteria for Recovery Act Projects Align 
with Federal Requirements, with Two Exceptions: 

GSA has developed minimum performance criteria (MPC) to help ensure 
that Recovery Act funding results in improvements to buildings' energy 
and water conservation performance. The MPC are to be incorporated 
into the project designs and cover the areas of energy, water, indoor 
environmental quality, materials, and building design. The following 
are examples of the MPC that are expected to be incorporated in GSA's 
Recovery Act projects: 

* install advanced meters that measure the building's consumption of 
electricity, natural gas, steam, and other sources of energy; 

* use high-efficiency water fixtures to help reduce water consumption; 

* use occupancy sensors on lighting to help conserve energy in areas 
of the building that are unoccupied; and: 

* salvage, recycle, or reuse at least 50 percent of construction and 
demolition waste generated on a project. 

Each Recovery Act project is required to meet all MPC that are 
applicable to its scope of work, unless it receives a waiver from the 
Regional Recovery Executive and the PMO. Meeting the MPC for reducing 
water consumption by 20 percent could be waived for projects that do 
not include significant plumbing system upgrades, for example. As we 
have noted previously, federal energy and water conservation 
requirements and goals differ for different building categories. 
Therefore, GSA has established two sets of MPC, one for new 
construction and full building modernization projects and a second, 
less stringent set for partial building modernizations and limited 
scope projects. (Appendix II provides more detailed information on the 
two sets of MPC.) 

We found that both sets of MPC generally align with most of the 
elements of a high-performance green building, as established by EISA, 
and with key federal energy and water conservation requirements and 
goals (see tables 3 and 4). However, the MPC do not address one 
statutory high-performance green building element--to reduce the 
environmental and energy impacts of transportation through building 
location and site design. For example, a project could address this 
element by installing the infrastructure necessary for alternative 
fuel vehicles or giving priority parking to carpool and van-share 
participants. According to GSA officials, they did not include this 
element in the MPC because the MPC are based on the Guiding Principles 
for Federal Leadership in High Performance and Sustainable Buildings, 
[Footnote 26] which does not specifically address transportation. GSA 
officials noted that a number of the GSA Recovery Act projects are 
making transportation-related improvements as part of their efforts to 
obtain a Leadership in Energy and Environmental Design (LEED) Silver 
rating.[Footnote 27] However, because the MPC do not require such 
improvements, project managers may not be systematically determining 
whether transportation-related improvements can be included in 
projects, as they are for energy and water conservation improvements, 
thereby missing opportunities to incorporate that high-performance 
green building element. Furthermore, because GSA has not given 
transportation-related improvements the MPC designation, GSA will not 
be collecting data on those improvements that are being done as part 
of Recovery Act projects. 

We also found that the MPC are expected to contribute toward meeting 
the federal conservation requirements and goals to reduce energy and 
water intensity, although they do not explicitly address these 
objectives. The MPC do not mention the specific percentages and dates 
set out in law and executive order for reducing energy and water 
intensity. GSA officials said that this is because the objectives 
apply to GSA's building inventory as a whole, rather than to 
individual buildings. Nevertheless, the officials stated that they 
expect Recovery Act projects to contribute significantly toward 
meeting the agency's inventorywide federal requirements and goals for 
both energy and water. According to the officials, new construction 
and full building modernization projects should exceed these 
requirements and goals because they must meet other, more stringent, 
MPC for energy and water conservation. For example, they explained, 
the MPC require new construction and full modernization projects to 
exceed ASHRAE Standard 90.1-2007[Footnote 28] by 30 percent, which is 
a higher energy conservation standard than the federal requirement to 
decrease energy intensity by 3 percent per year. GSA officials said 
they expect partial building modernizations and limited scope projects 
to make a more modest contribution toward meeting these requirements 
due to their reduced scope. 

GSA Recovery Act Projects Are Likely to Vary Greatly in the Extent of 
Their Energy and Water Conservation Improvements: 

According to GSA officials, all buildings receiving Recovery Act funds 
are expected to move toward becoming high-performance green buildings. 
The officials stated they have not developed an exact number of 
projects that could result in a high-performance green building 
because the definition from EISA is too broad and is a relative 
measure. For example, two projects that reduce water consumption by 1 
percent and 10 percent, respectively, both meet the high-performance 
green buildings element of reducing water usage. In addition, GSA 
officials said that the high-performance green building criteria in 
EISA can sometime be at odds. Applying high-performance green building 
criteria by increasing the amount of space for tenants in an effort to 
improve worker productivity, for example, can actually result in an 
increase in the building's energy use as opposed to a decrease. 
Consequently, GSA officials said that they developed the MPC in an 
attempt to provide a better structure for gauging the expected energy 
and water conservation performance of Recovery Act projects. 

Furthermore, the buildings are likely to vary greatly in the extent of 
their energy and water conservation improvements because of a variety 
of factors. Some Recovery Act projects, for example, are broad in 
scope and are being used to modernize multiple building systems--such 
as electrical; water; and heating, ventilation, and air conditioning 
systems (HVAC)--while others are modernizing relatively few systems or 
a specific component of a building. Additionally, existing 
infrastructure may affect the extent of energy and environmental 
improvements for certain buildings. For example, it will likely be 
more difficult to make certain green improvements to historic federal 
buildings because of the need to preserve features of the buildings, 
such as historic windows or ornate wall coverings. Finally, some 
projects were designed prior to the Recovery Act and may only have 
included a small number of green improvements. To include more green 
improvements at this juncture may mean that the projects would have to 
undergo significant redesign. Finally, the number of green 
improvements employed for a project may also be affected because of 
unanticipated problems discovered during the modernization. The 
discovery of asbestos on a project, for example, may result in the 
need to shift project funds originally slated for green improvements 
to asbestos abatement. In general, according to GSA officials, the new 
construction and full modernization projects are expected to 
significantly improve their energy and water conservation performance 
and exceed some federal energy and water conservation requirements and 
goals, especially those related to energy and water reduction. 
Conversely, GSA officials expect smaller projects to have less 
significant green improvements and to address only those federal 
energy and water conservation requirements and goals that fall within 
their scope of work. For example, a project primarily involving 
plumbing upgrades might only address the federal water conservation 
goal concerning reductions in water intensity. 

The 12 GSA Recovery Act projects (8 full and 4 partial modernizations) 
we examined differed significantly in their planned green 
improvements. (Appendix III provides more detailed information on the 
12 projects we examined.) For 3 of the projects, GSA is either 
implementing or planning to implement a broad array of green 
improvements that will touch on multiple systems throughout the 
buildings. These full building modernizations will principally focus 
on replacing older, less efficient mechanical, electrical, and 
plumbing systems with newer, high-efficiency systems. While these 
projects had already been receiving agency funding for some time, 
Recovery Act funding, according to some project managers, has enabled 
them to add features that will enhance buildings' energy and water 
conservation performance. Many of these features were not originally 
planned. Examples of full building modernization projects that are 
expected to result in extensive improvements include the following: 

* Edith Green-Wendell Wyatt Federal Building in Portland, Oregon. GSA 
plans to transform the deteriorating 30-year-old federal building into 
a high-performance green building by replacing the building's 
electrical, plumbing, and HVAC systems. GSA also plans to upgrade the 
building's life safety, mechanical, elevator, and security systems as 
well as install photovoltaic panels and rain harvesting features on 
the building's roof. The project management staff said that Recovery 
Act funding gave them the opportunity to vacate the entire building 
during the renovation, rather than proceeding two floors at a time, a 
key decision that allowed them to expand the scope of the project and 
add significant green improvements to the building. GSA is exploring 
the option of adding wire mesh or a perforated metal screen up the 
side of the building to shade the facade from the sun, thus helping to 
reduce the amount of energy needed for cooling the building. 

* Mary Switzer Building in Washington, D.C. GSA is also planning 
extensive green improvements for the Switzer building. The project 
includes new HVAC, plumbing, and emergency power systems; replacement 
of aged plumbing; asbestos abatement; and restoration work performed 
on the building's historic windows. According to project management 
staff, the Recovery Act allowed them to accelerate the modernization 
of the building by 1 year. It also allowed them to exceed some of the 
MPC issued by GSA, including an estimated 55 percent reduction in 
water use--above the 20 percent called for in the MPC for water use. 
In addition, the project estimates that it will address 30 percent of 
its hot water demand using solar hot water equipment. GSA also expects 
that approximately 70 to 75 percent of all the materials from the 
demolition phases of the project will be recycled. 

In five of the full building modernization projects we examined, GSA 
is planning to implement green improvements that are less extensive 
but that still address major systems or building components. These 
projects will generally focus on upgrades to current building 
components, but some building systems will also be replaced. Two 
projects contain historical elements that will have to be addressed as 
well. Several of the project managers stated that many of the green 
improvements slated for their projects would not have been funded 
without the Recovery Act. Examples of these projects include the 
following: 

* John W. Peck Federal Building in Cincinnati, Ohio. The modernization 
of the 44-year-old John W. Peck Federal Building in Cincinnati, Ohio, 
includes extensive exterior upgrades, such as installing insulated, 
dual-glass windows to decrease the heating and cooling loads for the 
entire building. GSA estimates the improved windows alone will reduce 
energy consumption for heating and cooling by about 24 percent 
compared with the industry standard. The project also includes 
extensive interior work that will save energy--for example, new 
lighting fixtures and controls. The lighting improvements are expected 
to reduce energy consumption for lighting by about 50 percent, 
according to the project manager. This reduction would be significant 
since lighting consumes about 30 percent of the building's energy. 

* Birch Bayh U.S. Courthouse in Indianapolis, Indiana. The project 
involves numerous system upgrades while preserving the historical 
character of the 1905 courthouse. For example, the project will 
upgrade the courthouse's HVAC system, where most of the air handling 
units and associated controls and equipment will be replaced. This 
change will allow the building managers to keep a more constant 
temperature and humidity in the historic courtrooms, while conserving 
energy in other areas of the building when they are not in use. 
Another green improvement will be the installation of a vegetative 
roof and a 10,000 gallon rainwater collection system. The system will 
allow the building to meet the federal requirement for storm water 
control, according to the project manager, and reduce indoor potable 
water use by using the collected rainwater for toilets. The project 
manager anticipates a 20 to 30 percent reduction in indoor potable 
water use. 

Finally, four partial modernization projects we examined plan to 
implement relatively few green improvements. The focus of each project 
was primarily to improve the efficiency of individual building 
components, as opposed to replacing or upgrading an entire building 
system. In general, project managers stated that these projects would 
have been slow to receive funding or would probably not have received 
funding at all if had it not been for the Recovery Act. Examples of 
these projects include the following: 

* Denver Federal Center in Lakewood, Colorado. The Lakewood project 
will upgrade an approximately 70-year-old utility system that provides 
both water and sewer services to the center. According to the project 
manager, the current system leaks profusely. Since 2001, there have 
been 90 water line breaks exceeding $1 million in repair costs. GSA 
officials further stated that although the project is not specifically 
building-related, it is an important project to GSA and its tenants 
because the federal center houses approximately 6,000 federal 
employees from 30 agencies. Failure of this system could force the 
center to close, with associated lost wages of about $1.5 million per 
day, according to the GSA manager for the project. 

* 26 Federal Plaza in New York City. The project will address severe 
water damage to the plaza's underground parking garage caused by leaks 
in the plaza. The project's green improvements include photovoltaic 
lighting and security cameras that will work with lower-intensity 
lighting, a new chiller, and lighting controls on several floors of 
the building. 

Table 7 shows details of the 12 GSA Recovery Act projects we examined. 

Table 7: Twelve GSA Recovery Act Projects That We Selected as Case 
Studies: 

Building: Edith Green-Wendell Wyatt Federal Building; 
Location: Portland, OR; 
Recovery Act funding: $133,098,000; 
Year built: 1975; 
Type of modernization: Full; 
Historic elements: No; 
Expected completion date: December 20, 2013. 

Building: Prince Jonah Kuhio Kanaianaole Federal Building and U.S. 
Courthouse; 
Location: Honolulu, HI; 
Recovery Act funding: $121,000,000; 
Year built: 1977; 
Type of modernization: Full; 
Historic elements: No; 
Expected completion date: December 30, 2014. 

Building: G.T. Leland Federal Building; 
Location: Houston, TX; 
Recovery Act funding: $109,053,000; 
Year built: 1983; 
Type of modernization: Full; 
Historic elements: No; 
Expected completion date: May 15, 2014. 

Building: Birch Bayh Federal Building and U.S. Courthouse; 
Location: Indianapolis, IN; 
Recovery Act funding: $73,994,000; 
Year built: 1905; 
Type of modernization: Full; 
Historic elements: Yes; 
Expected completion date: June 1, 2012. 

Building: Mary Switzer Building; 
Location: Washington, DC; 
Recovery Act funding: $66,194,000; 
Year built: 1940; 
Type of modernization: Full; 
Historic elements: Yes; 
Expected completion date: December 15, 2011. 

Building: Thurgood Marshall U.S. Courthouse; 
Location: New York, NY; 
Recovery Act funding: $64,000,000; 
Year built: 1936; 
Type of modernization: Full; 
Historic elements: Yes; 
Expected completion date: October 30, 2011. 

Building: Minton-Capehart Federal Building; 
Location: Indianapolis, IN; 
Recovery Act funding: $49,776,000; 
Year built: 1974; 
Type of modernization: Full; 
Historic elements: No; 
Expected completion date: April 1, 2012. 

Building: John W. Peck Federal Building; 
Location: Cincinnati, OH; 
Recovery Act funding: $42,571,000; 
Year built: 1964; 
Type of modernization: Full; 
Historic elements: No; 
Expected completion date: September 1, 2011. 

Building: Denver Federal Center Infrastructure; 
Location: Lakewood, CO; 
Recovery Act funding: $65,380,000; 
Year built: Varies; 
Type of modernization: Partial; 
Historic elements: No; 
Expected completion date: November 1, 2011. 

Building: 26 Federal Plaza; 
Location: New York, NY; 
Recovery Act funding: $22,207,000; 
Year built: 1968; 
Type of modernization: Partial; 
Historic elements: No; 
Expected completion date: September 30, 2015. 

Building: Federal building; 
Location: Huntington, WV; 
Recovery Act funding: $20,752,000; 
Year built: 1958; 
Type of modernization: Partial; 
Historic elements: No; 
Expected completion date: April 15, 2015. 

Building: Federal building; 
Location: Hilo, HI; 
Recovery Act funding: $7,247,000; 
Year built: 1917; 
Type of modernization: Partial; 
Historic elements: Yes; 
Expected completion date: June 30, 2011. 

Source: GAO analysis of GSA data. 

[End of table] 

GSA Does Not Have Sufficient Data to Measure Progress but Is Taking 
Steps to Improve Data Collection: 

In adhering to the MPC that include both high-performance green 
building and energy and water conservation requirements and goals, 
GSA's Recovery Act projects are making the buildings greener and 
addressing the requirements and goals. However, GSA cannot measure the 
extent of progress because it does not have sufficient data on 
improvements resulting from the projects. In October 2009, GSA began 
collecting energy and performance information on Recovery Act projects 
through a "data call" that asked project managers to categorize the 
status of each of a project's MPC as either "not started," "in 
progress," "complete," "not applicable," or "waiver." However, GSA 
officials said their guidance was not detailed enough to clearly 
define the response categories, thereby making it difficult for 
project managers to determine when each status should be selected. In 
December 2009, GSA reported[Footnote 29] that the data collected 
through this effort were, in some instances, incomplete and 
unreliable. GSA concluded that it needed to revise future data calls 
to gather more specific information on how projects would address 
their MPCs and to facilitate the tracking and reporting of the data. 
Furthermore, the data were limited to about 28 percent of the Recovery 
Act projects because those were the only projects that had progressed 
far enough to have such data. Several of the project managers from the 
12 Recovery Act projects we examined reported problems in responding 
to the data call. For example, two project managers stated that they 
initially misinterpreted the appropriate response category for their 
projects and consequently inadvertently completed the incorrect MPC 
checklist. However, these mistakes were corrected in subsequent 
updates to the MPC checklists for the projects. 

To obtain more complete and reliable data, GSA is rolling out a new 
centralized system for collecting data on Recovery Act projects' 
energy and water conservation performance. GSA officials told us the 
goals of the system are to (1) collect information on the MPC for each 
project and to aggregate that information, thereby allowing GSA to 
know the extent to which projects are collectively addressing MPC; (2) 
provide subject matter experts with a means of reviewing projects' 
progress in achieving the MPC and suggesting changes as appropriate; 
and (3) generate customized reports upon request. GSA officials said 
the agency began using the system in April 2010 and expects it to be 
available online to all project managers soon. 

According to GSA officials, the new system will include more detailed 
information on each project's MPC, such as the types of green 
improvements that will be installed, as well as supporting 
documentation that demonstrates exactly how the MPC will be 
accomplished. Moreover, the system will include supporting 
documentation for cases in which a project was scheduled to meet a 
MPC, like using renewable energy, but was unable to do so. Supporting 
documentation could include such things as projections, calculations, 
milestones, constraints, and associated cost-benefit analyses. GSA 
officials cautioned, however, that energy and environmental 
performance is difficult to project accurately and can be affected by 
a number of variables beyond GSA's control, such as tenants' behavior 
and changes in a tenant agency's mission. For example, GSA's estimate 
of energy savings for a building could be based on a tenant's expected 
13-hour workday, while the tenant's actual workday might be longer. 
Similarly, an agency may need to hire additional staff in order to 
respond to an emergency, which would unexpectedly increase energy use. 
According to the GSA officials, a design-phase estimate that falls 
within about 20 percent of actual performance would be considered 
"pretty good." GSA officials stated that the system will be used to 
track the progress of Recovery Act projects until their completion. 

According to GSA officials, they have nearly finished developing 
guidance for project staff who will use the system. GSA has also begun 
to train staff, starting with those with new construction or full and 
partial building modernization projects that are far enough along in 
the design process to have information on how they will achieve the 
MPC. To date, six project managers have been trained in using the 
system, according to GSA officials. GSA plans to use a separate 
training module for managers of limited-scope projects because less 
information is required for them than for new construction and full 
and partial building modernization projects. GSA officials have not 
estimated when all project managers would be trained. However, these 
officials said they expect to have preliminary or high-level data in 
the system for all projects by the end of July 2010. 

GSA Identifies Risks to Its Program and Risk Mitigation Strategies, 
but Some Project-Level Risk Plans Are Not Complete: 

GSA has identified risks to its Recovery Act program and risk 
mitigation strategies. GSA's approach to risk management is generally 
consistent with best practices we have developed.[Footnote 30] GSA 
focuses on broad risks that could affect GSA's ability to address 
objectives for the agency as a whole, such as ensuring program goals 
are achieved and fraud, waste, and abuse are minimized; stimulating 
the economy; and improving the environmental performance of federal 
buildings. Broadly defined, risk management is a strategic process for 
helping policymakers make decisions about assessing risk and typically 
involves appraising and evaluating risks to a program or project and 
selecting mitigation strategies. In April 2009, GSA developed a plan 
to guide risk management efforts for agencywide risks to its Recovery 
Act program and developed an initial inventory of those risks. In 
March 2010, PMO developed a Recovery Risk Mitigation Plan specific to 
PBS. This plan identified 48 risks to PBS's program, 14 of which were 
considered key risks, shown in table 8. 

Table 8: Fourteen Key Risks Identified for PBS's Recovery Act Program: 

Project management: 

Risk: Ineffective or untimely project selection; 
Risk description: Recovery Act deadlines may not be met if project 
selection is untimely. 

Risk: Funds not used for authorized purposes; 
Risk description: GSA may not fulfill the accountability objectives of 
the Recovery Act and may lose the confidence of the public. 

Risk: Untimely or inaccurate outlays; 
Risk description: Projects may fail to meet job creation and 
construction objectives in the expedited time frame. 

Risk: Untimely or ineffective management of project contingencies; 
Risk description: Cost overruns may occur, schedule delays may occur, 
and contingency funding may not be used before the expiration of 
Recovery Act funding. 

Risk: Untimely or ineffective project management of savings; 
Risk description: Savings may not be used before the expiration of 
Recovery Act funding. 

Risk: Inadequate, inefficient, or untimely project planning and design; 
Risk description: Cost overruns may occur, schedule delays may occur, 
and construction projects may not meet customer requirements. 

Reporting: 

Risk: Inaccurate and incomplete external Recovery Act reporting; 
Risk description: Benefits of and use of Recovery Act funding may not 
be fully tracked, may not be fully reported, or may not be transparent 
to the public, or the perception of GSA or a GSA project may be 
negatively affected. 

Risk: Untimely external Recovery Act reporting; 
Risk description: Benefits of and use of Recovery Act funding may not 
be fully tracked, may not be fully reported, or may not be transparent 
to the public, or the perception of GSA or a GSA project may be 
negatively affected. 

Risk: Incomplete, inaccurate, or untimely recipient reporting; 
Risk description: Benefits of and use of Recovery Act funding may not 
be transparent to the public. 

High-performance green buildings: 

Risk: Incorporation of performance requirements for green buildings in 
Risk description: Recovery Act contracts; 
Completed projects may not include green building elements. 

Risk: Absence of green building elements in project design; 
Risk description: Construction may not be executed with green building 
elements. 

Acquisitions: 

Risk: Untimely contract awards; 
Risk description: Recovery Act deadlines may not be met or schedule 
delays may occur. 

Risk: Incorporation of Recovery Act requirements into Recovery Act 
contracts; 
Risk description: Construction and management of construction may not 
comply with Recovery Act requirements, including but not limited to 
expedited time frames and recipient reporting. 

Reimbursable work authorizations[A]: 

Risk: Ineffective financial oversight of reimbursable work 
authorizations; 
Risk description: GSA and the customer agencies may face cost 
overruns, project delays, and expiration of Recovery Act funding. 

Source: GSA. 

[A] The Reimbursable Work Authorization program allows GSA to capture 
and bill the costs of altering, renovating, repairing, or providing 
services in space managed by GSA over and above the costs of basic 
operations financed through rent. 

[End of table] 

This plan also contains assessments of the likelihood and potential 
impact of the key risks, identifies mitigation strategies, and 
establishes mechanisms for monitoring the risks and mitigation 
actions. The key risks are associated with areas such as financial 
tracking and reporting, acquisitions, and project management. For 
example, as indicated in table 8, GSA identified a risk that Recovery 
Act funds could be used for unauthorized purposes, limiting GSA's 
ability to meet Recovery Act accountability goals. To mitigate this 
risk, GSA identified various internal processes, including national 
and regional approval of a project's scope, multiple levels of review 
of project expenditures, and a process for reviewing contractor 
invoices to ensure services are valid and authorized. Agency officials 
told us that internal auditors, as part of GSA's existing internal 
audit program, will test the mitigation actions put in place for the 
14 key risks. In addition, they plan to assess and update the key 
risks on a monthly basis. 

We assessed GSA's risk management approach against best practices that 
we developed in the areas of strategic planning, risk assessment, 
evaluation and selection of alternatives for addressing risks, and 
implementation and monitoring of risk-mitigation strategies (see table 
9). 

Table 9: Risk Management Best Practices Used to Assess GSA's Risk 
Management Approach: 

Area: Strategic planning; 
Best practices: 
* Encourages the use of a strategic plan or risk planning documents to 
address risk-related issues. 
* Risk-based information informs efforts to align the agency's 
activities, core processes, workforce, and other resources to support 
its mission-related outcomes. 
* Encourages monitoring of external factors and identification of 
actions to reduce the impact of such factors. 
* Encourages monitoring of internal factors and identification of 
actions to reduce the impact of such factors. 

Area: Risk assessment; 
Best practices: 
* Encourages the use of reliable information during the risk 
assessment process. 
* Requires documentation of the risk assessment process. 
* Allows for updates of information. 
* The result of the risk assessment is a quantitative or qualitative 
characterization of the probability of an outcome that has a 
consequence related to the agency's mission or the program. 

Area: Alternative evaluation and management selection; 
Best practices: 
* Encourages that potential mitigation alternatives are assessed to 
determine the extent to which the actions reduce risks. 
* Considers benefits and costs when selecting alternative mitigation 
strategies. 
* Establishes a formal review and approval process for selecting from 
alternative mitigation strategies. 
* Encourages documentation to prove management decisions were reached 
using risk-based information. 

Area: Implementing and monitoring risk responses; 
Best practices: 
* Considers the communication of risk issues to stakeholders.[A].
* Requires ongoing monitoring and evaluation of mitigation strategies. 
* Steps taken to identify and deal with risks affected by changing 
circumstances or new information. 
* Mitigation strategies include time frames and are implemented in a 
timely fashion. 

Source: Best practices developed by GAO. 

[A] The best practices GAO developed identified risk communication as 
a critical component in high-level risk management strategies that 
involve communication to stakeholders. Monitoring may take place in 
several time periods that involve frequent operational information for 
management and broader, periodic evaluations. 

[End of table] 

We found that GSA's approach generally reflected the best practices in 
all four areas noted in table 9. In the area of strategic planning, 
GSA clearly identifies Recovery Act goals and objectives as well as 
GSA program goals when considering potential risks to the program, 
such as stimulating the economy by spending Recovery Act funds quickly 
and improving the environmental performance of federal facilities. In 
addition, in the area of assessing risks, GSA established a process 
for documenting its assessment of risks that allows for updates and 
results in a qualitative assessment of the likelihood and potential 
impact of the risks on its Recovery Act goals and strategic 
objectives. Also, for monitoring the implementation of risk responses, 
GSA officials said the risk management team holds monthly meetings 
with senior officials to review key risks, identify any new risks, and 
ensure that proper controls are in place. However, there were areas 
where GSA could improve its risk management efforts. For example, in 
the area of evaluating and selecting alternatives for addressing 
risks, GSA had limited information in its plan and other risk 
management documents about its process for evaluating and selecting 
alternative mitigation strategies. GSA officials said that many of the 
mitigation strategies were put in place before the formal risk 
assessment was completed as part of GSA's planning to implement the 
program and during ongoing discussions about risks facing the program. 
Therefore, a full analysis of potential risk mitigation alternatives 
was not completed. 

During our review of 12 Recovery Act case study projects, project 
management staff told us about some of the key project-level risks 
that could affect the success of the projects. Staff at 5 of the 12 
case study projects we examined cited risks associated with the 
accelerated timelines imposed by the Recovery Act. Project management 
staff with whom we spoke at one case study said the tight timeline 
imposed by the Recovery Act was the most serious risk to their 
project. They said the project faces a challenge to complete all of 
the work necessary to achieve its environmental and energy goals, 
including completing a study of the building to identify potential 
energy-reducing upgrades, working through the study recommendations 
for upgrading the building with all of the stakeholders on the 
project, and completing the additional design work related to the 
selected upgrades. This study must be completed at an accelerated pace 
to enable the additional work to be awarded and the associated funding 
to be obligated within the Recovery Act's time frames. In addition, 8 
of the 12 case study project staff with whom we spoke said that they 
faced the more typical project risks associated with uncertainty about 
aspects of a building that is slated to receive upgrades, such as the 
degree of contamination with hazardous material, the absence of 
building system and structural drawings, or questions about the 
drawings' accuracy. For example, project management staff for one 
project said that they had concerns about the accuracy of the as-built 
drawings--the plans that detail the construction of the building and 
other work performed on the building. These staff noted that if the 
building needs more structural work than originally planned, the 
project's cost could increase and less funding might be available for 
green improvements to the building. 

Although GSA has developed a systematic process for identifying and 
planning for risks for its Recovery Act program, GSA officials said 
that to address project-level risks, such as those we have previously 
discussed, they rely on informal communication between headquarters 
and project management staff in the regions. Specifically, regional 
staff discuss project-level risks or challenges during weekly 
telephone calls with the PMO. In addition, GSA officials said they 
track whether projects are on budget and on schedule so they can 
identify when projects are encountering problems. GSA officials said 
that because so many projects are being implemented, it would be 
difficult for GSA to systematically assess and respond to individual 
project risks at the PMO level. In addition, because of the 
accelerated pace necessary to implement the program within Recovery 
Act deadlines and the additional responsibilities for regional staff 
associated with Recovery Act funding, such as new reporting 
requirements, GSA officials said they were reluctant to add new risk 
management reporting requirements for project management staff. 

GSA officials said they rely on project management staff in the 
regions to manage project risks and complete risk planning documents 
that are required by GSA's Project Management Guide for the Public 
Buildings Service. The guide, issued by the PBS Office of the Chief 
Architect, is GSA's road map for project management and details what 
project management staff should do to manage risks at the project 
level. The guide discusses two planning documents for projects, the 
Comprehensive Project Plan (CPP) and the Project Definition Rating 
Index (PDRI), both of which GSA project management staff identified as 
related to risk planning. The guide says the CPP ensures efficient and 
effective project delivery by articulating project goals and 
implementation strategies and should be updated throughout a project 
to evaluate the success of the plan to date and to adapt it to 
changing circumstances. In addition, the guide says the PDRI provides 
an objective evaluation of the project at various stages of its 
development and its benefits include a more refined definition of the 
scope of a project and an assessment of risk. Instructions for filling 
out the PDRI say the tool should be updated during the development of 
the project, from the preliminary stages to the start of construction. 
Finally, OMB's Capital Programming Guide[Footnote 31] cites the need 
for developing and documenting a systematic plan to address project 
risk and calls for risk planning to continue throughout the life of 
the project. 

In September 2009, GSA's OIG found that the PMO was not requiring full 
CPPs for Recovery Act projects and raised concerns about the adequacy 
of risk planning at the project level. During our review, we found 
that 9 of our 12 case study projects had not fully completed the 
required risk planning documents. For example, for 1 project we 
visited, the CPP had not been updated since before Recovery Act 
funding was received and did not list Recovery Act funding in the 
section detailing project funding sources. For 1 project we visited, 
staff said that although they did not complete a PDRI, they 
continually work to identify potential risks and develop risk 
mitigation strategies as needed. Some of the project management staff 
with whom we spoke for our 12 case studies said they have regular 
meetings with regional management about their projects to discuss 
potential risks or challenges facing the project. Staff from 1 project 
that had not completed GSA's risk planning documents said they had 
completed other documents that were similar.[Footnote 32] Finally, 
some project staff told us that they considered the PDRI a requirement 
for projects that go through GSA's normal project approval process, 
but that GSA's Recovery Act-funded projects were unique and they did 
not think it was required. GSA officials said that the PDRI is 
typically completed during the approval process for prospectus-level 
projects, but that Recovery Act projects did not go through this 
process to get funding. However, GSA officials from the PMO said that 
a CPP was required for all full and partial modernizations, adding 
that Recovery Act projects should complete the risk planning documents 
called for in the guide. In addition, project management staff in the 
regions said that Recovery Act projects are being implemented at an 
accelerated pace and that this presents challenges to the agency. 
Finally, as we have previously mentioned, OMB's Capital Programming 
Guide calls for risk planning at the project level. OMB's guide calls 
for project managers to develop and document a systematic approach to 
risk planning that continuously identifies, assesses, responds to, and 
monitors project-level risks, adding that risk management is an 
integral part of project management. It is important for GSA to ensure 
that risk planning at the project-level meets the agency's standards, 
as laid out in GSA's guide or other guidance, such as OMB's Capital 
Programming Guide. GSA's reliance on informal communication channels 
for overseeing project-level risks, without ensuring that project-
level risks are being identified and planned for, could result in some 
vulnerabilities going unidentified and increase the potential for 
risks to negatively affect GSA's program as projects move from 
preliminary stages to construction. 

Conclusions: 

The Recovery Act has provided GSA with an unprecedented opportunity to 
repair or restore aging, deteriorating federal buildings and, in so 
doing, to enhance their energy and environmental performance. With 
this opportunity comes a responsibility to be accountable for how the 
funds are spent and to ensure that the projects are successful and the 
buildings progress toward becoming high-performance green buildings. 
GSA has the opportunity to enhance its accountability by making 
publicly available information about the nature of work being 
performed through its Recovery Act projects. In addition to knowing 
which buildings are receiving funding, this will enable the public to 
understand how Recovery Act funding is being used to improve GSA's 
buildings. While GSA has made progress in moving buildings modernized 
under the Recovery Act toward high-performance green buildings, by not 
including criteria for reducing transportation's energy and 
environmental impacts for Recovery Act projects, GSA's minimum 
performance criteria for projects are not in alignment with the 
definition of a high-performance green building called for by the 
Recovery Act. GSA may also be missing opportunities to include 
transportation-related improvements in the projects, where 
appropriate, and to track those improvements. Finally, given the 
accelerated pace at which many projects are being implemented, taking 
steps to ensure that project management staff are systematically 
addressing risks to the projects could decrease the potential for 
risks to negatively affect GSA's program as projects move from 
preliminary stages to construction. 

Recommendations for Executive Action: 

We recommend that the GSA Administrator take the following three 
actions: 

* Consistent with GSA's Recovery Act transparency goal of providing 
the public with an understanding of how its tax dollars are being 
spent, make information on the nature of the work being conducted and 
its expected outcome publicly available for each Recovery Act project. 

* To reduce the environmental and energy impacts of transportation 
through site designs that support a full range of transportation 
choices for users of buildings, revise the MPC to require that project 
managers consider transportation-related improvements for Recovery Act 
projects, as appropriate. 

* To ensure that steps are being taken to identify and plan for 
project-level risks, require Recovery Act project management staff to 
complete risk planning documents. 

Agency Comments and Our Evaluation: 

The GSA Administrator provided written comments on a draft of this 
report, which are reproduced in appendix IV. The Administrator agreed 
with our recommendations and noted that GSA has begun to take action 
to implement them. GSA officials also provided technical comments, 
which we incorporated as appropriate. 

We are sending copies of this report to the appropriate congressional 
committees, the GSA Administrator, and other interested parties. In 
addition, the report will be available at no charge on GAO's Web site 
at [hyperlink, http://www.gao.gov]. 

If you or your staffs have questions about this report, please contact 
Terrell Dorn at (202) 512-2834 or dornt@gao.gov or Mark Gaffigan at 
(202) 512-3841 or gaffiganm@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 V. 

Signed by: 

Terrell G. Dorn: 
Director, Physical Infrastructure: 

Signed by: 

Mark Gaffigan: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Scope and Methodology: 

To examine the steps the General Services Administration (GSA) has 
taken to implement the program and make its Recovery Act projects 
transparent to the public, we collected publicly available supporting 
documentation, including GSA's Recovery Act program plans, spending 
plans, weekly financial activity reports, and recipient reported data 
on the number of jobs created or retained and funded. In addition, we 
collected documentation of GSA's hiring resources and competitive 
contract awards. Furthermore, we collected information on individual 
project scopes, master schedules, the factors considered when 
selecting projects, and estimates of needed capital improvements in 
buildings receiving Recovery Act funds. We also interviewed senior 
staff from GSA's Recovery Act Program Management Office (PMO), 
including the Recovery Executive, Directors, Zone Executives, Zone 
Managers, and subject matter experts. In addition, we interviewed 
senior staff from GSA's Office of Federal High-Performance Green 
Buildings (OFHPGB). Specifically, we discussed GSA's goals for its 
Recovery Act program, efforts to identify and select projects, 
progress in meeting Recovery Act goals for obligating funds, and 
efforts to collect data and report on the program. We also interviewed 
and coordinated with officials from the GSA Office of Inspector 
General and collected their reports identifying GSA's Recovery Act 
implementation challenges and reviewing specific Recovery Act 
projects. Furthermore, we collected a report examining the data 
quality of recipient reported data for GSA and several other agencies, 
which was the result of coordinated efforts of various Federal 
Inspectors General and the Recovery Accountability and Transparency 
Board. 

To determine the extent to which GSA's Recovery Act projects will help 
the agency convert buildings to high-performance green buildings and 
meet federal energy and water conservation requirements and goals from 
statutes and executive orders, we compared GSA's minimum performance 
criteria with the elements of a high-performance green building as set 
forth in the Energy Independence and Security Act (EISA) of 2007. We 
also compared GSA's minimum performance criteria with federal energy 
and water conservation requirements and goals from statutes and 
executive orders. These include EISA, the Energy Policy Act of 2005, 
Executive Orders 13423 and13514, and the Interagency Sustainability 
Working Group's[Footnote 33] Guiding Principles for Sustainable New 
Construction and Major Renovations. Also, we interviewed senior staff 
and subject matter experts from the PMO and OFHPGB to determine what 
information GSA was collecting with regards to energy and water 
conservation performance and what type of system GSA used for 
gathering this type of information. We interviewed senior staff and 
subject matter experts from the PMO and OFHPGB. Furthermore, we 
selected 12 GSA Recovery Act projects as case studies and collected 
information on the types of improvements being made to help convert 
the buildings to high-performance green buildings and the extent to 
which the projects are expected to meet future energy and 
environmental performance requirements. We selected 12 full and 
partial modernizations--since GSA allocated the majority of its 
Recovery Act funds to these project categories--on the basis of a 
number of factors, including whether the project had been identified 
by GSA as having information on its expected performance. In addition, 
we selected a range of project types and sizes and projects from 
various geographic locations. We did not select any projects from the 
new construction, limited scope, or small project categories for our 
case studies. Because the sample is judgmental, the information we 
obtained from them cannot be generalized to all of GSA's Recovery Act 
projects. 

We visited 5 of our case study projects, including the following: 

* 26 Federal Plaza, New York, New York; 

* Birch Bayh U.S. Courthouse, Indianapolis, Indiana; 

* Mary Switzer Building, Washington, D.C.; 

* Minton-Capehart Federal Building, Indianapolis, Indiana; and: 

* Thurgood Marshall U.S. Courthouse, New York, New York. 

At the remaining 7 case study projects, we spoke with senior staff 
from the regions and project managers: 

* Denver Federal Center Infrastructure, Lakewood, Colorado; 

* Edith Green-Wyndell Wyatt Federal Building, Portland, Oregon; 

* Federal Building, Huntington, West Virginia; 

* Federal Building, Hilo, Hawaii; 

* G.T. Leland Federal Building, Houston, Texas; 

* John W. Peck Federal Building, Cincinnati, Ohio; and: 

* Prince Jonah Kuhio Kalanianaole Federal Building Courthouse, 
Honolulu, Hawaii. 

To determine the extent to which GSA has taken steps to identify 
potential risks to its Recovery Act program and developed strategies 
to mitigate those risks, we reviewed supporting documentation, 
including GSA's risk management plan, risk mitigation plan, 
assessments of identified risks and mitigation strategies, and GSA's 
project management guide for the Public Buildings Service. We also 
assessed GSA's risk management documents against GAO-developed best 
practices. Furthermore, we collected documentation of project-level 
risk planning efforts from our case study projects and compared them 
with the risk planning efforts called for in GSA's project management 
guidance. In addition, we interviewed senior staff from the Office of 
the Chief of Financial Officer and the PMO. Finally, we interviewed 
managers from our 12 case study projects to discuss project-specific 
risks and GSA's efforts to mitigate them. 

We conducted this performance audit from June 2009 to June 2010 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: GSA's Minimum Performance Criteria for Recovery Act 
Projects: 

Minimum Performance Criteria for New Construction and Full 
Modernizations: 

Criteria: Integrated design; 
Elements: 
* Use an integrated design process to establish performance goals for 
sustainable design principles and develop a plan to ensure 
implementation of high-performance green building goals throughout the 
project; 
* Hire a qualified, independent commissioning agent working for GSA at 
the beginning of design; 
* Include commissioning tailored to the size and complexity of the 
project, including an experienced commissioning provider from the 
project initiation through the project closeout. 

Criteria: Energy; 
Elements: 
* Use Energy Star Target Finder to set an energy goal that achieves a 
fossil-fuel reduction of 55 percent for 2010 design starts; 
* Achieve at least 30 percent reduction in energy use compared with an 
American Society of Heating, Refrigerating and Air-Conditioning 
Engineers (ASHRAE) Standard 90.1-2007 baseline building; 
* Install advanced meters. Include meters for electricity, natural 
gas, steam, and water; 
* Use Energy Star or Federal Energy Management Program (FEMP)-
designated Energy Efficient Products; 
* Install solar thermal systems to meet at least 30 percent of the hot 
water demand. If not life-cycle cost-effective, provide an engineering 
study and letter of explanation signed by the Regional Recovery 
Executive; 
* Plan for on-site renewable energy systems (photovoltaic, wind, 
geothermal, and solar thermal/hot water). If no on-site renewable 
energy systems are included, provide a letter of explanation signed by 
the Regional Recovery Executive; 
* Assess the effects of solar heat gain based on site conditions and 
building orientation; 
* Provide a complete envelope design to include thermal breaks, 
insulation, continuous air barriers, external sun control devices, and 
green roof potential; 
* Choose glazing systems, including frames, glass, films, and gasses 
based on visual needs, elevation, orientation, heat loss, and solar 
load; 
* Cooling and heating plants will use a Life Cycle Cost (LCC) 
methodology (e.g., National Institute of Standards and Technology 
Handbook 135) for equipment selection to include lifetime operating 
costs based on efficiency, reliability, and maintainability of 
equipment; 
* Evaluate the use of; 
- variable frequency drives, high-efficiency chillers and boilers with 
modular design for part load efficient operations in HVAC design; 
- radiant space conditioning and thermal storage systems; 
- natural ventilation; 
- energy recovery ventilators to recover heat from exhaust to preheat 
outdoor air; 
- separate HVAC for 24x7 spaces; and; 
- evaporative cooling (direct or indirect) strategies, in suitable 
climates. 

Criteria: Water; 
Elements: 
* Reduce indoor potable water use by at least 20 percent compared with 
EPAct 1992, Uniform Plumbing Code (UPC) 2006, and International 
Plumbing Code (IPC) 2006; 
* Reduce outdoor potable water use for irrigation by at least 50 
percent compared with conventional baseline for the building. Smart 
controllers using evapotranspiration and weather data are required for 
irrigation systems; 
* Evaluate strategies to capture rainwater for nonpotable uses, 
including flushing fixtures, cooling tower, and irrigation. Consider 
harvesting condensation from all cooling coils for nonpotable use. 
(See GSA Recovery Act Program Management Office Design Build Guidance 
Criteria--Water Efficiency Requirements issued 5/29/2009); 
* Evaluate alternative strategies to reduce cooling tower use of 
potable water. Strategies include the use of captured rainwater and 
HVAC condensate recovery; 
* Manage the 95th percentile rain event on-site through infiltration, 
reuse, or evapotranspiration. Strategies include permeable paving, 
vegetated roofs, or other low-impact development techniques. 
Environmental Protection Agency (EPA) guidance is under development; 
* Where available, use EPA's WaterSense labeled products--faucets, 
toilets, urinals, showerheads, and irrigation controls; 
* Use high-efficiency fixtures in accordance with new GSA water 
guidance; 
Meter cooling tower water makeup. 

Criteria: Indoor environmental quality; 
Elements: 
* Provide occupant lighting controls in accordance with new GSA 
lighting specifications; 
* Provide occupancy sensors; 
* Provide daylight sensors for fixtures within 15 feet of windows; 
* At a minimum, comply with ASHRAE Standard 55-2004 and ASHRAE 
Standard 62.1-2007; 
* Consider moisture control strategies to reduce risk for mold and 
damaging moisture; 
* Use demand control ventilation to control indoor air quality; 
* Use low-emitting building materials; 
* Follow Sheet Metal and Air Conditioning Contractors' National 
Association Indoor Air Quality Guidelines for Occupied Buildings under 
Construction; 
* Flush out space for a minimum of 72 hours. 

Criteria: Materials; 
Elements: 
* Select products with lesser or reduced effect on human health and 
the environment. See [hyperlink, http://www.epa.gov/epp]; 
* Use products with recycled content according to the Comprehensive 
Procurement Guidelines. See [hyperlink, 
http://www.epa.gov/cpg/products]; 
* Use products with biobased content according to U.S. Department of 
Agriculture's (USDA) BioPreferred program. See [hyperlink, 
http://www.biopreferred.gov/DesignationltemList.aspx]; 
* Salvage, recycle, or reuse at least 50 percent of construction and 
demolition waste generated on a project. Develop a construction waste 
management plan to quantify material diversion goals and maximize the 
materials to be salvaged, recycled, or reused; 
* Eliminate the use of ozone-depleting compounds where alternative 
environmentally preferable products are available. 

Minimum Performance Criteria for Partial Modernizations and Limited 
Scope Projects: 

Criteria: Integrated design; 
Elements: 
* Use an integrated team to assess conditions, identify areas for 
improvement, establish performance goals for sustainable design 
principles, and develop a plan to ensure implementation of high-
performance green building objectives; 
* Hire a qualified, independent commissioning agent working for GSA at 
the beginning of design; 
* Include commissioning tailored to the size and complexity of the 
project, including an experienced commissioning provider from the 
project initiation through 1 year after occupancy; or: Recommission 
the building to determine performance improvement goals. 

Criteria: Energy; 
Elements: 
* Target an Energy Star score of 80 or higher; and; Achieve at least 
20 percent reduction in energy use from the 2003 baseline for the 
building; or; Achieve at least 20 percent reduction in energy use 
compared with an ASHRAE Standard 90.1-2007 baseline building; 
* Use Energy Star or FEMP-designated Energy Efficient Products; 
* Consider renewable energy generation through photovoltaic, building 
integrated photovoltaic, solar thermal, and building integrated wind 
power, when life-cycle cost-effective; 
* Evaluate lighting in office areas, stairwells, parking garages, 
exterior parking lots, and mechanical spaces for redesign in 
accordance with new GSA lighting specifications; 
* HVAC retrofits must consider the use of: 
- an LCC methodology (e.g., National Institute of Standards and 
Technology Handbook 135) for cooling and heating plant equipment 
selection to include lifetime operating costs based on efficiency, 
reliability, and maintainability of equipment; 
- variable frequency drives, high efficiency chillers and boilers with 
modular design for part load efficient operations; 
- radiant space conditioning and thermal storage systems; 
- natural ventilation; 
- energy recovery ventilators to recover heat from exhaust to preheat 
outdoor air; 
- separate HVAC systems for 24x7 spaces; and; 
- evaporative cooling (direct or indirect) strategies, in suitable 
climates. 

Criteria: Water; 
Elements: 
* Reduce indoor potable water use by at least 20 percent from the 2003 
baseline for the building; or; Reduce water use by 20 percent compared 
with 120 percent of UPC 2006 or IPC 2006 for fixtures installed after 
1994 or 160 percent for fixtures installed before 1994; 
* Reduce outdoor potable water use for irrigation by at least 50 
percent compared with conventional baseline or compared with 2003 
measured baseline for the building. Smart controllers using 
evapotranspiration and weather data are required for irrigation 
systems; 
* Consider harvesting condensation from cooling coils for nonpotable 
use; 
* Evaluate alternative strategies to reduce cooling tower use of 
potable water. Strategies include increased cycles of concentration, 
use of captured rainwater, and systems that treat the water for a 
longer use without chemicals; 
* Manage the 95th percentile rain event on-site through infiltration, 
reuse or evapotranspiration. Strategies include permeable paving, 
vegetated roofs or other low impact development techniques. EPA 
guidance is under development; 
* Where available, use EPA's WaterSense labeled products - faucets, 
toilets, urinals, showerheads and irrigation controls; 
* Consider fixture retrofits in accordance with new GSA water 
guidance, including high-efficiency single or dual flush handles or 
the installation of automatic flush valves; 
* Meter cooling tower water makeup. 

Criteria: Indoor environmental quality; 
Elements: 
* Provide occupant lighting controls in accordance with new GSA 
lighting specifications; and; Provide occupancy sensors; and; Provide 
daylight sensors for fixtures within 15 feet of windows; 
* At a minimum, comply with ASHRAE Standard 55-2004 and ASHRAE 
Standard 62.1-2007; 
* Use demand control ventilation to enhance indoor air quality; 
* Consider moisture control strategies to reduce risk for mold and 
damaging moisture; 
* Use low-emitting building materials. 

Criteria: Materials; 
Elements: 
* Select products with lesser or reduced effect on human health and 
the environment. See [hyperlink, http://www.epa.gov/epp]; 
* Use products with recycled content according to the Comprehensive 
Procurement Guidelines. See [hyperlink, 
http://www.epa.gov/cpg/products]; 
* Use products with bio-based content according to USDA's BioPreferred 
program. See [hyperlink, 
http://www.biopreferred.gov/DesignationltemList.aspx]; 
* Salvage, recycle or reuse at least 50 percent of construction and 
demolition waste generated on the project. Develop a construction 
waste management plan to quantify material diversion goals and 
maximize the materials to be salvaged, recycled or reused; 
* Eliminate the use of ozone depleting compounds where alternative 
environmentally preferable products are available. 

Source: GSA. 

[End of table] 

[End of section] 

Appendix III: Descriptions for 12 Case Studies: 

Case study: Edith Green - Wendell Wyatt Federal Building Portland, OR; 
Project description: The 18-story building contains 510,659 gross 
square feet, including 199 inside parking spaces, and houses 
approximately 1,200 federal employees. A comprehensive modernization 
is planned for the project; 
Recovery Act funding scope of work: The modernization will include the 
replacement and upgrades to building systems, including the exterior 
façade, accessibility, life safety, mechanical, electrical, elevator, 
and security. 

Case study: Mary Switzer Washington, DC; 
Project description: The overall objective of this project is to 
provide a full building modernization of the Federal Building located 
at 330 C Street, SW, in Washington, D.C. This two-phase major 
modernization will replace all major building systems and includes 
historic restoration; 
Recovery Act funding scope of work: The American Recovery and 
Reinvestment Act (ARRA) project comprises Phase II of the 
modernization of the Mary E. Switzer building. Work items include new 
HVAC systems, automatic sprinkler systems where not currently in 
place, new emergency generator, new emergency power distribution 
system, replacement of electric branch circuit wiring and selected 
panel boards, replacement of aged plumbing equipment and piping, new 
Americans with Disabilities Act (ADA)/Uniform Federal Accessibility 
Standards water coolers, toilet room finish restoration and 
modification, minor exterior repairs and lighting, selective asbestos 
abatement, modifications to C and D Street lobbies, security 
modifications, forced pressure (blast) resistance upgrades, and an 
additional floor and new telecommunications backbone. 

Case study: Prince Jonah Kuhio Kalanianaole Federal Building and U.S. 
Courthouse Honolulu, HI; 
Project description: The Prince Jonah Kuhio Kalanianaole Federal 
Building and Courthouse consists of a nine-story and a five-story 
concrete and glass complex built in 1977. A two-phased, full 
modernization and renovation is scheduled for the building; 
Recovery Act funding scope of work: ARRA funding will be used to fund 
Phase I of the project, which includes design for both the courthouse 
and federal building and construction for the courthouse. The 
building's HVAC systems will be upgraded to meet required energy 
performance standards, the building's plumbing and electrical systems 
will be upgraded, the building will be renovated to meet ADA 
requirements, the building's elevators will be improved, the 
building's life safety systems will be improved, the building's 
hazardous materials will be abated, and the interior spaces will be 
altered to result in a more modern and efficient facility. 

Case study: Birch Bayh Federal Building & U.S. Courthouse 
Indianapolis, IN; 
Project description: The proposed project is focused on transforming 
the Federal Building into a high-performance green building through 
upgrades to the building's infrastructure; 
Recovery Act funding scope of work: The project includes upgrades to 
the HVAC, plumbing, electrical service, and fire protection systems. 
New energy-efficient lighting will be installed. The roof will be 
replaced, and windows will be replaced or restored as needed, 
resulting in energy savings. The HVAC improvements will result in 
improved air quality, temperature control, and energy efficiency. 

Case study: John W. Peck Federal Building Cincinnati, OH; 
Project description: The project proposes to transform the building 
into a high-performance green building through improvements to the 
building envelope as well as interior upgrades to the building 
infrastructure; 
Recovery Act funding scope of work: The project includes window 
replacements, energy-efficient HVAC and electrical system upgrades, 
security enhancements, fire alarm system replacement, and sprinkler 
protection improvements. 

Case study: Minton-Capehart Federal Building Indianapolis, IN; 
Project description: The Minton-Capehart Federal Building is a 636,000 
gross square feet office building that was constructed in 1974. The 
scope of this project includes upgrades to the HVAC system to align 
with high-performance green building goals; 
Recovery Act funding scope of work: The HVAC upgrades will improve air 
quality and temperature control and will significantly reduce energy 
consumption. This project will also provide a new fire alarm system, 
sprinkler system installation and other fire protection improvements. 
Lighting and ceiling in the building will be upgraded with energy-
efficient light fixtures and occupancy sensors. In addition, 
electrical upgrades will be accomplished in support of the HVAC and 
fire and life safety upgrades. 

Case study: Thurgood Marshall U.S. Courthouse New York, NY; 
Project description: The project will upgrade the infrastructure of 
the Thurgood Marshall U.S. Courthouse and extend the useful life of 
the asset. The project will also address life safety and accessibility 
issues. The project is a two-phased modernization. Phase I work 
includes bulk demolition and exterior facade work. Phase II work is 
discussed in the next column; 
Recovery Act funding scope of work: ARRA funding will be used for 
Phase II work, which includes selective interior demolition and new 
mechanical, electrical, plumbing, and architectural work associated 
with the mechanical work. 

Case study: G.T. Leland Federal Building Houston, TX; 
Project description: The window system at the 22-story Leland Federal 
Building has been leaking for several years. There are also air 
infiltration issues, which make the facility expensive to heat and 
cool. The modernization is two-phased and is intended to remedy those 
issues and create a more comfortable environment for the building's 
tenants. Major tenants of the building include the Internal Revenue 
Service, U.S. Department of State, Equal Employment Opportunity 
Commission, and Social Security Administration; 
Recovery Act funding scope of work: Phase I for the project will 
include some or all of the following: replacing and upgrading the 
window systems; improving and upgrading the outdoor plaza; installing 
a new breezeway; making garage improvements, including a new elevator 
from tunnel to breezeway; building exterior repairs and interior 
upgrades to public spaces inclusive of finish, ceilings, lighting 
fixtures, ADA upgrades, and first-floor upgrades; and will include an 
option for significant improvements to the HVAC system. Phase II of 
this project includes full HVAC modernization and advanced lighting 
controls in the window zone of the building. 

Case study: Federal Building Huntington, WV; 
Project description: The Federal Building in Huntington is a seven-
story office building containing 94,307 usable square feet, 125,246 
rentable square feet, and 138,588 gross square feet with no parking 
spaces on a 1.33 acre lot. This seven-story building was constructed 
in 1956 and is made of brick with a polished granite base. The ARRA 
project for this building will reduce energy consumption; 
Recovery Act funding scope of work: Work on the project will include 
installing a new high-performance HVAC system, replacing windows, 
facade replacement, and installing solar panels on the roof to 
generate electricity. 

Case study: Hilo Federal Building Hilo, HI; 
Project description: The Hilo Federal Building and Post Office was 
built in 1917 and is a two-story Classical Revival style building. The 
building is scheduled to receive a partial modernization; 
Recovery Act funding scope of work: Major work to be performed 
includes a seismic upgrade. The building's plumbing and electrical 
systems will be upgraded, the building will be altered to meet ADA 
requirements; the building's security and life safety systems will be 
improved; and the building's hazardous materials will be abated. 

Case study: Denver Federal Center Infrastructure Lakewood, CO; 
Project description: The Denver Federal Center in Lakewood, CO, 
contains 52 buildings on a 670-acre site, housing 6,000 employees from 
30 federal agencies. The utilities include 13.4 miles of underground 
fire lines, 11.3 miles of domestic water and drain lines, 8.3 miles of 
sanitary sewer lines, 25 miles of sidewalks, and 9 miles of roads. The 
primary goal of the project is to provide a reliable utility 
infrastructure to service tenant agencies for the next 50 years; 
Recovery Act funding scope of work: Work on the project will include 
replacement of the water systems and sanitary sewer lines, removal of 
an inactive gauging station, installation of storm drainage, and 
repair of site drainage. 

Case study: 26 Federal Plaza (Plaza Repair) New York, NY; 
Project description: This project will repair and upgrade the grand 
plaza on the Lafayette Street side of 26 Federal Plaza above the 
underground parking garage, which is leaking; 
Recovery Act funding scope of work: Work on the project will include 
waterproofing and replacing the plaza. 

Source: GSA. 

[End of table] 

[End of section] 

Appendix IV: Comments from the General Services Administration: 

U.S. General Services Administration: 
GSA Administrator: 
1800 F Street NW: 
Washington, DC 20405-0002: 
Telephone: (202) 501-0800: 
Fax: (202) 219-1243: 
[hyperlink, http://www.gsa.gov]: 

June 9, 2010: 

The Honorable Gene L. Dodaro: 
Acting Comptroller General of the United States: 
U.S. Government Accountability Office: 
Washington, DC 20548: 

Dear Mr. Dodaro: 

The U.S. General Services Administration (GSA) appreciates the 
opportunity to comment on the draft U.S. Government Accountability 
Office (GAO) report titled, Federal Energy Management: GSA's Recovery 
Act Program Is on Track, but Opportunities Exist to Improve 
Transparency, Performance Criteria, and Risk Management (GA0-10-630). 
The report proposes the following three recommendations: 

1. GSA make information on the scope of the work and the expected 
outcome of each Recovery Act project publicly available; 

2. GSA revise the Recovery Act Minimum Performance Criteria to require 
project managers to consider transportation-related improvements for 
Recovery Act projects as appropriate; and, 

3. GSA require completed risk planning documents from Recovery Act 
project management staff. 

We are already taking appropriate action to implement these 
recommendations. In addition, enclosed are technical comments that 
update and clarify statements in the draft report. 

Should you have any questions, please contact me or Mr. Robert A. 
Peck, Commissioner, Public Buildings Service at (202) 501-1100. Staff 
inquiries may be directed to Mr. William J. Guerin, Recovery 
Executive, National Recovery Program Management Office, at (202) 219-
0837. 

Sincerely, 

Signed by: 

Martha Johnson: 
Administrator: 

[End of section] 

Appendix V: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Terrell Dorn, (202) 512-2834 or dornt@gao.gov Mark Gaffigan, (202) 512-
3841 or gaffiganm@gao.gov: 

Staff Acknowledgments: 

In addition to the contacts named above, Maria Edelstein, Assistant 
Director; Karla Springer, Assistant Director; Daniel Cain; Elizabeth 
Eisenstadt; Brandon Haller; John Johnson; Susan Michal-Smith; Ben 
Shouse; and Adam Yu made significant contributions to this report. 

[End of section] 

Footnotes: 

[1] GAO, High-Risk Series: Federal Real Property, [hyperlink, 
http://www.gao.gov/products/GAO-03-122] (Washington, D.C.: January 
2003). 

[2] GAO, Federal Real Property: Progress Made Toward Addressing 
Problems, but Underlying Obstacles Continue to Hamper Reform, 
[hyperlink, http://www.gao.gov/products/GAO-07-349] (Washington, D.C.: 
Apr. 13, 2007). 

[3] Pub. L. No. 111-5, Div. A, Title V, 123 Stat. 115, 149-150 (2009). 

[4] For a definition of a "high-performance green building," see the 
Energy Independence and Security Act of 2007, Pub. L. No. 110-140, 
Title IV, 121 Stat. 1492, 1598-1599 (2007). 

[5] According to a U.S. Department of Energy official, this 
information is based on preliminary fiscal year 2009 data. 

[6] The Recovery Act requires GSA to obligate $5 billion by September 
30, 2010, and to obligate the full Recovery Act funding amount, $5.55 
billion, by September 30, 2011. 

[7] GSA's real property activities are financed through the Federal 
Buildings Fund, a revolving fund that includes the rent federal 
agencies pay for the space that GSA provides to them. 

[8] According to EISA, the term "high-performance building" means a 
building that integrates and optimizes on a life-cycle basis all major 
high-performance attributes, including energy conservation, 
environment, safety, security, durability, accessibility, cost- 
benefit, productivity, sustainability, functionality, and operational 
considerations. See Pub. L. No. 110-140, Title IV, 121 Stat. 1492, 
1598 (2007). The term "high-performance green building" means a high- 
performance building that, during its life cycle, as compared with 
similar buildings, incorporates the eight elements listed in table 3. 

[9] GSA will continue to make revisions to its project plan over time. 

[10] Before Congress makes an appropriation, GSA submits to the Senate 
Committee on Environment and Public Works and the House Committee on 
Transportation and Infrastructure detailed project descriptions, 
called prospectuses, for authorization by these committees when the 
proposed construction, alteration, or acquisition of a building to be 
used as a public building exceeds a specified threshold. For fiscal 
year 2009, the threshold for construction, alteration, and lease 
projects was $2.66 million (see 40 U.S.C. § 3307). 

[11] The execution timing and minimizing execution risk criteria were 
given equal weight. 

[12] We will soon publicly release a report on the extent to which 
recipient reports on Recovery.gov, including reports related to GSA's 
Federal Buildings Fund, provided a basic understanding of Recovery Act 
spending and outcomes. See GAO, Recovery Act: Increasing the Public's 
Understanding of What Funds Are Being Spent on and What Outcomes Are 
Expected, [hyperlink, http://www.gao.gov/products/GAO-10-581] 
(Washington, D.C.: May 27, 2010). 

[13] See the following Web address: [hyperlink, 
http://www.gsa.gov/recovery] (last accessed on June 4, 2010). 

[14] PBS is the landlord for the civilian federal government, acquires 
space on behalf of the federal government through new construction and 
leasing, and acts as a caretaker for federal properties across the 
country. PBS is funded primarily through the Federal Buildings Fund, 
which is supported by rent from federal customer agencies. 

[15] Recovery Act Zone A includes GSA regions 1, 2, 3, and 11 (New 
England, Northeast and Caribbean, Mid-Atlantic, and National Capital). 
Recovery Act Zone B includes GSA regions 4, 5, 6, and 7 (Southeast, 
Great Lakes, Heartland, and Greater Southwest). Recovery Act Zone C 
includes GSA regions 8, 9, and 10 (Rocky Mountain, Pacific Rim, and 
Northwest/Arctic). 

[16] The Office of Design and Construction is responsible for 
providing national leadership and policy direction in the areas of 
architecture, engineering, urban development, construction services, 
and project management. 

[17] These were primarily for sole-source HUBZone or 8(a) awards. 

[18] Specifically, the GSA OIG found that the contracting approach was 
incorrectly executed and resulted in the construction portion of the 
contract being awarded as an unpriced option for $102 million without 
justification for using other than full and open competition. 
According to PBS officials, the construction phase was not an unpriced 
option and proper evaluation and competition occurred. See General 
Services Administration, Office of Inspector General, Recovery Act 
Report--Austin Courthouse Project Review of PBS's Major Construction 
and Modernization Projects Funded by the American Reinvestment and 
Recovery Act of 2009, A090172/P/R/R10001 (Washington, D.C.: March 
2010). 

[19] We did not evaluate the courthouse project in Austin, Texas, or 
its contract as part of our review. 

[20] Department of Health and Human Services, Summary of Inspectors 
General Reports on Federal Agencies' Data-Quality Review Processes, 
OIG Report No. A-09-10-01002 (Washington, D.C.: Nov. 2009). 

[21] U.S. Department of Transportation, Office of Inspector General, 
Recovery Act Data Quality: Errors in Recipients' Reports Obscure 
Transparency (Washington, D.C.: Feb. 23, 2010). 

[22] GAO, Recovery Act: Recipient Reported Jobs Data Provide Some 
Insight into Use of Recovery Act Funding, but Data Quality and 
Reporting Issues Need Attention, [hyperlink, 
http://www.gao.gov/products/GAO-10-223] (Washington, D.C.: Nov. 19, 
2009). 

[23] Office of Management and Budget, Updated Guidance on the American 
Recovery and Reinvestment Act--Data Quality, Non-Reporting Recipients, 
and Reporting of Job Estimates, M-10-08 (Washington, D.C.: Dec. 18, 
2009). 

[24] GAO, Recovery Act: One Year Later, States' and Localities' Uses 
of Funds and Opportunities to Strengthen Accountability, [hyperlink, 
http://www.gao.gov/products/GAO-10-437] (Washington, D.C.: Mar. 3, 
2010). 

[25] GSA officials also stated that adjustments were made because they 
changed how the $16 million operating budget for Recovery Act 
activities was allocated. Specifically, the operating budget is now 
its own line item. In the March 2009 project plan, the operating 
budget was funded from the new construction category--resulting in GSA 
allocating $734 million to new construction projects, instead of $750 
million as stated by the Recovery Act. In the March 2010 project plan, 
GSA fully funded the $750 million to new construction projects. 

[26] The Guiding Principles for Federal Leadership in High Performance 
and Sustainable Buildings emanated from a 2006 memorandum of 
understanding (MOU) between 19 federal agencies. Under the MOU, the 
signatory agencies committed to federal leadership in the design, 
construction, and operation of high-performance and sustainable 
buildings. A major component of the MOU is for agencies to develop 
common strategies for planning, acquiring, siting, designing, 
building, operating, and maintaining high-performance and sustainable 
buildings. 

[27] LEED is a third-party certification program and a national 
benchmark for the design, construction, and operation of high- 
performance green buildings, according to the U.S. Green Building 
Council. LEED Silver is the second level on the four-tier rating 
scale, followed by Gold and preceded by Platinum. 

[28] ASHRAE 90.1-2007 is a standard developed by the American Society 
of Heating, Refrigerating and Air-Conditioning Engineers. The purpose 
of the standard is to provide minimum requirements for the energy 
efficient design of buildings, except low-rise residential buildings. 

[29] General Services Administration Public Building Service Recovery 
PMO, Short-Term Report on High Performance Green Buildings (HPGB) 
Initiatives for Recovery Act Projects (Washington, D.C.: December 
2009). 

[30] GAO developed these best practices to use in assessing risk 
management practices in the absence of statutory or other 
authoritative guidance. The best practices are based on existing 
criteria for management, previous GAO reports, and external sources. 

[31] Office of Management and Budget, Supplement to Circular No. A-11, 
Part 7, Capital Programming Guide (Washington, D.C.: June 2006). The 
guide provides a single, integrated capital programming process for 
agencies to follow to ensure that capital assets successfully 
contribute to the achievement of agency strategic goals and objectives. 

[32] We did not assess whether these documents were sufficient for 
identifying and addressing project-level risks. 

[33] The Interagency Sustainability Working Group, as a subcommittee 
of the Steering Committee established by Executive Order 13423, 
initiated development of the guidance for the Guiding Principles for 
Federal Leadership in High Performance and Sustainable Buildings to 
assist agencies in meeting high performance and sustainable building 
goals of the order. 

[End of section] 

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