General Services Administration's Interpretation of Section 7 of the Public Buildings Act of 1959, as Amended

The General Services Administration (GSA) requested review of its interpretation of amended section 7 of the Public Buildings Act of 1959 prior to the issuance of guidelines based on that interpretation. It is proper to interpret average annual rental as the amount paid for the use of land and buildings or parts of buildings, excluding the cost of any services. It appears that Congress did not intend to impair existing contracts; therefore, congressional approval of leases and contracts obligating leasing entered into prior to the enactment date of the amendments is not required. There is also no necessity for congressional approval of amendments to leases now under the $500,000 annual rental limit even though the total average annual rental will exceed that amount. However, there should be no splitting of the space requirement for purposes of evading the legislation.