oversight

Federal Real Property: Improved Data Needed to Strategically Manage Historic Buildings, Address Multiple Challenges

Published by the Government Accountability Office on 2012-12-11.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                United States Government Accountability Office

GAO             Report to the Chairman, Subcommittee on
                Federal Financial Management, Government
                Information, Federal Service, and International
                Security, Committee on Homeland Security and
                Governmental Affairs, U.S. Senate


                FEDERAL REAL
December 2012



                PROPERTY

                Improved Data
                Needed to
                Strategically Manage
                Historic Buildings,
                Address Multiple
                Challenges




GAO-13-35
                                               December 2012

                                               FEDERAL REAL PROPERTY
                                               Improved Data Needed to Strategically Manage
                                               Historic Buildings, Address Multiple Challenges
Highlights of GAO-13-35, a report to the
Chairman, Subcommittee on Federal Financial
Management, Government Information,
Federal Service, and International Security,
Committee on Homeland Security and
Governmental Affairs, U.S. Senate

Why GAO Did This Study                         What GAO Found
The federal government has made                The General Services Administration (GSA), the National Park Service (NPS),
some progress addressing previously            and the Department of Veterans Affairs (VA) have undertaken portfolio-wide
identified issues with managing federal        efforts in recent years to identify historic buildings they hold, nominate some of
real property. This includes                   those buildings to the National Register of Historic Places, and manage their
establishing the Federal Real Property         historic buildings in an effort to comply with the requirements in the National
Council (FRPC) and creating the FRPP           Historic Preservation Act (NHPA) and relevant executive orders. While these
database to identify and report                agencies use and preserve some of their historic buildings to meet mission
agencies’ real property, including             needs, others are excess or unsuited for current mission needs. GAO found
attributes such as historic status. GAO
                                               several instances in which these agencies leased part or all of some historic
was asked to assess issues related to
                                               buildings to non-federal entities that could use and preserve the buildings. GAO
historic preservation at nondefense
agencies. GAO’s review focused on—
                                               also found that these agencies had implemented projects in some of their historic
GSA, NPS, and VA—three nondefense              buildings to improve their sustainable performance, such as installing green roofs
agencies that hold significant numbers         and energy-efficient heating and cooling systems.
of historic buildings. This report
identifies (1) actions these agencies          GSA, NPS, and VA face an array of challenges in managing historic buildings,
have taken to manage historic federal          including functional limitations of older buildings in relation to contemporary
buildings, and (2) any challenges they         mission needs and current building codes, budgetary limitations, and competing
have faced. GAO selected and visited           stakeholder interests. Competing stakeholder interest can become apparent
a sample of 31 historic buildings              during the required consultation with stakeholders, such as the state historic
managed by the three agencies. The             preservation officers, prior to implementing projects that may affect a historic
results of these site visits cannot be         building. Compounding these property management challenges, the selected
generalized but provide important              agencies’ data on historic buildings in the Federal Real Property Profile (FRPP)
insights. GAO interviewed agency               are not complete. GSA and VA are still working to evaluate many buildings that
officials and reviewed agencies’ efforts       are over 50 years old. Also, GSA and NPS have not reported complete and
to preserve, use or lease, and improve         consistent historic-building data to the FRPP—in comparison to data they track
the sustainable performance of those           within their agencies’ historic-building databases. GAO reported its concerns
buildings. GAO also interviewed                with the reliability of FRPP data in 2012. This review emphasizes the relevance
officials from the selected agencies
                                               of these concerns to the historic-building data included in the database. In June
about their agencies’ preservation
                                               2012, GAO recommended improvements to the FRPP database to enhance its
programs, including actions to identify
and report on their historic buildings.        consistency, completeness, and usefulness in federal decision making. Such
                                               improvements are also necessary to increase the consistency and completeness
                                               of historic-building data in the FRPP.
What GAO Recommends
GSA—in collaboration and consultation
with NPS, VA, and FRPC member
agencies, and others—should ensure
that the action plan being developed to
improve FRPP also addresses the
need for improved data on historic
buildings. GSA agreed with GAO’s
recommendation and further reported
that it has, in part, already taken action
to rectify inconsistencies GAO found
between GSA’s FRPP data and its                In Milwaukee, the U.S. Federal Building and Courthouse, built in 1899, was recently rehabilitated by
internal data sources.                         GSA (left), while VA’s “Old Main” building, built in 1869, is at risk of collapse (center and right).

View GAO-13-35. For more information,
contact David Wise at (202) 512-2834 or
wised@gao.gov.

                                                                                                 United States Government Accountability Office
Contents


Letter                                                                                      1
               Background                                                                    4
               GSA, NPS, and VA Are Taking Action to Manage Their Historic
                 Buildings                                                                 10
               GSA, NPS, and VA Face Challenges in Managing Historic Buildings             19
               Conclusions                                                                 35
               Recommendation for Executive Action                                         36
               Agency Comments and Our Evaluation                                          36

Appendix I     Objectives, Scope, and Methodology                                          38



Appendix II    List of 31 Federal Historic Buildings Where GAO
               Conducted Site Visits                                                       42



Appendix III   Comments from the General Services Administration                           43



Appendix IV    Comments from the Advisory Council on Historic
               Preservation                                                                47



Appendix V     GAO Contact and Staff Acknowledgments                                       48



Tables
               Table 1: Examples of Inconsistencies between GSA’s Historical
                        Status Data in FRPP and Its Historic-Buildings Database            31
               Table 2: List of 31 Federal Historic Buildings Visited during Site
                        Visits                                                             42


Figures
               Figure 1: Milwaukee Federal Building and Courthouse Window
                        Repair                                                             14




               Page i                                           GAO-13-35 Federal Real Property
Figure 2: Fort Mason Pier #2 Space Leased for Performing Arts
         Purposes                                                                         15
Figure 3: Actions to Improve the Sustainability of 10 West Jackson
         Boulevard, Chicago                                                               17
Figure 4: VA—Proposed Design for VA’s Old Grist Mill at Perry
         Point, Maryland, Including New Stair, Elevator, and
         Bathroom                                                                         21
Figure 5: Deterioration of the “Old Main” Hospital, Built in 1869, at
         VA’s Medical Center in Milwaukee, Wisconsin                                      28




Abbreviations

ACHP                       Advisory Council on Historic Preservation
FRPC                       Federal Real Property Council
FRPP                       Federal Real Property Profile
GSA                        General Services Administration
Guiding Principles         Guiding Principles for Federal Leadership in High
                           Performance and Sustainable Buildings
National Register          National Register of Historic Places
NHPA                       National Historic Preservation Act of 1966
NPS                        National Park Service
OMB                        Office of Management and Budget
Recovery Act               American Recovery and Reinvestment Act of 2009
VA                         Department of Veterans Affairs



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Page ii                                                   GAO-13-35 Federal Real Property
United States Government Accountability Office
Washington, DC 20548




                                   December 11, 2012

                                   The Honorable Thomas R. Carper
                                   Chairman
                                   Subcommittee on Federal Financial Management,
                                   Government Information, Federal Service,
                                    and International Security
                                   Committee on Homeland Security
                                    and Governmental Affairs
                                   United States Senate

                                   Dear Mr. Chairman:

                                   The federal government’s real property portfolio is vast and diverse,
                                   including almost 400,000 buildings that are owned or leased. Thousands
                                   of these buildings have been recognized as historically significant. The
                                   National Historic Preservation Act of 1966 (NHPA), as amended1 requires
                                   agencies to establish a preservation program to identify, evaluate, and
                                   nominate historic federal buildings to the National Register of Historic
                                   Places (National Register)2 and manage those buildings in a manner that
                                   considers their historic character. As federal buildings continue to age
                                   and become eligible for historic designation, agencies will increasingly
                                   face decisions about balancing preservation with the best use, which may
                                   include leasing or selling these assets.

                                   Historic preservation is one of many challenges federal agencies face in
                                   the area of real property management. We have designated federal real
                                   property management as a high-risk area.3 In 2007 we reported that



                                   1
                                    Pub. L. No. 89-665, 80 Stat. 915 (Oct. 15, 1966), codified as amended at 16 U.S.C. §
                                   470 et seq.
                                   2
                                    NHPA authorized the Secretary of the Department of the Interior to maintain and expand
                                   a National Register. The Secretary of the Interior is also responsible for The Secretary of
                                   the Interior’s Standards and Guidelines for Federal Agency Historic Preservation
                                   Programs Pursuant to the National Historic Preservation Act, 63 Fed. Reg. 20496 (Apr.
                                   24, 1998).
                                   3
                                    GAO, High-Risk Series: An Update, GAO-11-278 (Washington, D.C.: February 2011).
                                   Our high-risk series identifies areas at high risk because of their greater vulnerabilities to
                                   waste, fraud, abuse, and mismanagement or major challenges associated with their
                                   economy, efficiency, or effectiveness.




                                   Page 1                                                       GAO-13-35 Federal Real Property
federal agencies have large backlogs of deferred maintenance,4 and we
highlighted the deteriorated conditions of some federal buildings,
including some that were historic.5 Other management problems affect
both historic and non-historic buildings, and have included, for example,
issues pertaining to the use and disposition of underutilized and excess
property, over-reliance on costly leasing, and unreliable real property
data. Over the last decade, the federal government has taken steps to
manage this area more strategically, including developing the Federal
Real Property Profile (FRPP)—a government-wide database—and
establishing the Federal Real Property Council (FRPC).6 These efforts
notwithstanding, challenges to federal real property management persist.7
For example, as we reported in 2007, competing stakeholder interests—
such as those of historic building advocates and local communities—can
present obstacles to disposing of real property, including historic
buildings.8 Various versions of the Civilian Property Realignment Act are




4
 Deferred maintenance is defined by the Statement of Federal Financial Accounting
Standard No. 6, which includes the accounting standards for deferred maintenance, as
maintenance that was not performed when it should have been or scheduled maintenance
that was delayed or postponed. Maintenance is the act of keeping fixed assets in
acceptable condition, including preventative maintenance, normal repairs, and other
activities needed to preserve the assets, so that they can continue to provide acceptable
services and achieve their expected life.
5
 GAO, Federal Real Property: Progress Made Toward Addressing Problems, but
Underlying Obstacles Continue to Hamper Reform, GAO-07-349 (Washington, D.C.: Apr.
13, 2007).
6
 The FRPC is comprised of certain executive branch agencies including the departments
of Agriculture, Commerce, Defense, Education, Energy, Health and Human Services,
Homeland Security, Housing and Urban Development, the Interior, Justice, Labor, State,
Transportation, the Treasury, and VA; the Environmental Protection Agency; the National
Aeronautics and Space Administration; the U.S. Agency for International Development;
GSA; the National Science Foundation; the Nuclear Regulatory Commission; the Office of
Personnel Management; the Small Business Administration; and the Social Security
Administration. FRPC is chaired by the Deputy Director for Management of the Office of
Management and Budget (OMB). Exec. Order No. 13327, Federal Real Property Asset
Management, 69 Fed. Reg. 5897 (Feb. 6, 2004). The order does not apply to the U.S.
Postal Service.
7
 For example, See GAO, Federal Real Property: Proposed Civilian Board Could Address
Disposal of Unneeded Facilities, GAO-11-704T (Washington, D.C.: June 9, 2011); High-
Risk Series: An Update, GAO-11-278 (Washington, D.C.: February 2011); and,
GAO-07-349.
8
GAO-07-349.




Page 2                                                   GAO-13-35 Federal Real Property
pending in Congress and are aimed at, among other things, disposing of
and consolidating civilian real property.9

You requested that we assess issues related to historic preservation at
non-defense agencies. In response, we focused on three non-defense
agencies that hold significant numbers of historic buildings10—the General
Services Administration (GSA), the Department of the Interior’s National
Park Service (NPS), and the Department of Veterans Affairs (VA).11 Our
objectives were to identify (1) actions these agencies have taken to
manage historic federal buildings, and (2) any challenges they have
faced.

To address our objectives, we reviewed relevant laws, regulations, and
executive orders governing how agencies should identify, report on, and
manage the historic buildings in their portfolios. Not only do GSA’s, NPS’s
and VA’s portfolios include significant numbers of historic buildings, but
these agencies also include a diverse range of building types, such as,
office buildings, courthouses, park facilities, museums, and hospitals. We
interviewed agency officials about their historic preservation programs
and obtained and analyzed related agency documents. To gather detailed
examples of agencies’ historic preservation efforts, we visited a non-
probability sample12 of 31 federal historic buildings in five metropolitan
areas: (1) Boston, Massachusetts; (2) Washington, D.C.-Baltimore,
Maryland; (3) Chicago, Illinois; (4) Milwaukee, Wisconsin; and (5) San
Francisco, California. We selected buildings based on input received from


9
 See e.g., S. 2232, 112th Cong. (2012); H.R. 1734, 112th Cong. (2011).
10
  We focused our review on historic buildings, and did not examine other federal assets
such as historic lands (such as national forests) or structures (such as bridges) held by the
selected agencies.
11
  Our review of FRPP’s fiscal year 2010 summary report found that GSA, the Department
of the Interior, and VA account for just under 50 percent of non-defense buildings and
structures held by the federal government (it does not disaggregate buildings and
structures). Additionally, our review of the Department of the Interior’s fiscal year 2010
data submitted to FRPC showed that NPS managed nearly 60 percent of all of
Department of the Interior’s buildings.
12
  Because this is a non-probability sample, observations from these site visits, taken
alone, do not support generalizations about other properties. Rather, the observations
provided specific, detailed examples of challenges agencies face managing their historic
buildings and some actions taken to address some of the challenges. Also, the sites we
visited were largely located in urban and suburban areas and the challenges facing
historic buildings in rural and isolated locations may be different.




Page 3                                                     GAO-13-35 Federal Real Property
             agency officials, the Advisory Council on Historic Preservation (ACHP),13
             state historic preservation officers, and our own judgment. This approach
             yielded a diverse group of buildings in terms of use, age, size, and
             condition that provided illustrative examples of the agencies’ broader
             policy initiatives. We reviewed agencies’ documentation on recent,
             current, or planned efforts to manage these historic buildings. We also
             gathered and analyzed agency data on historic buildings, including data
             reported by these agencies to government-wide data sources such as
             FRPP, the National Register, and the ACHP’s triennial Preserve America
             reports.14 Appendix I provides a more detailed description of our scope
             and methodology. Appendix II provides a list of the 31 buildings where we
             conducted site visits.

             We conducted this performance audit from November 2011 to December
             2012 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.


             The federal government’s real property portfolio reflects the diversity of
Background   agencies’ missions and includes a variety of building types, such as office
             buildings, courthouses, post offices, hospitals, prisons, laboratories,
             border stations, and park facilities. That portfolio includes many historic
             buildings held by GSA, NPS, and VA. GSA and NPS’s real property
             policies place an emphasis on historic building stewardship. GSA serves
             as broker and property manager for many civilian federal agencies while
             NPS manages the nation’s national park system for current and future
             generations.15 GSA established its “Legacy Vision” in 2002 as a strategy


             13
               ACHP is an independent federal agency that advises the President and Congress on
             national historic preservation policy and federal agencies’ preservation programs.
             14
               In accordance with Executive Order 13287, ACHP issues a report every 3 years on the
             state of the federal government’s historic properties. To facilitate the report, executive
             agencies with real property management responsibilities are required to provide
             assessments of their inventories of historic properties and their progress in identifying,
             protecting, and using their historic properties to ACHP and the Secretary of the Interior.
             Preserve America, 68 Fed. Reg. 10635 (Mar. 5, 2003).
             15
              In general, GSA does not serve as a broker for NPS and VA real property actions.




             Page 4                                                     GAO-13-35 Federal Real Property
for meeting its federal historic stewardship responsibilities16 and declared
a policy preference for using, preserving, and leasing historic buildings.17
Similarly, in providing for the stewardship of the nation’s cultural
resources, NPS reinforced its commitment and goal to preserve historic
buildings in its 2011 Call to Action: Preparing for a Second Century of
Stewardship and Engagement.18 VA’s core mission is to provide care and
services to the nation’s veterans. While hospital buildings, some of which
are historic, are critical to providing healthcare services, VA began to
realign its real property portfolio in 2004 to better respond to the
demographic shifts and evolving needs of both its older and younger
veteran populations. As VA realigns its portfolio, it has determined many
of its historic buildings are not suitable to support modern healthcare
delivery and are now inactive or excess to VA’s needs.

In NHPA, Congress expressed concern that historic properties significant
to the nation’s heritage—which include both public and privately owned
buildings—were being lost or substantially altered.19 Thus, NHPA
authorized the Secretary of the Department of the Interior to maintain and
expand the National Register as a means of identifying historic
properties,20 including those owned by the federal government, and
NHPA requires federal agencies to identify and nominate their historic
properties to the National Register.21 The National Register is comprised
of many different types of historic properties to include historic districts,
sites, buildings, structures (such as a bridge), and objects (such as a
fountain) that are significant to American history, architecture,



16
  GSA’s policy manual, Procedures for Historic Properties, issued in 2003, contains the
agency’s comprehensive policies detailing roles and procedures for complying with NHPA.
17
  Under GSA’s “Legacy Vision”, the agency gives priority to retaining and investing in
those historic buildings that best represent the federal government’s monumental public
building legacy. GSA reports its “legacy buildings” are those that are well-constructed,
made of durable materials, and designed in a manner that has made them adaptable to
serve the changing federal space needs.
18
 U.S. Department of the Interior, National Park Service, A Call to Action: Preparing for a
Second Century of Stewardship and Engagement (Washington, D.C.: August 2011).
NPS’s Management Policies 2006 contains NPS’ policies governing its historic buildings.
19
 Pub. L. No. 96-515, tit I, § 101(a) (Dec. 12, 1980), codified at 16 U.S.C. § 470(a)(3).
20
 Pub. L. No. 89-665, § 101, codified as amended at 16 U.S.C. § 470a(a).
21
 Pub. L. No. 96-515, § 206, codified as amended at 16 U.S.C. § 470h-2(a).




Page 5                                                     GAO-13-35 Federal Real Property
archaeology, engineering, and culture.22 A building is generally not
eligible for National Register listing until it is at least 50 years old, unless
its historic significance is considered exceptional. While many federal
buildings are historic because of the passage of time and a corresponding
recognition of their historical or architectural significance locally or
regionally, a smaller subset are treasured assets considered significant to
the nation’s history. In recognition of this, the National Register also
includes buildings meeting the criteria for a national historic landmark.23
National historic landmarks are designated by the Secretary of the Interior
as possessing exceptional value or quality in representing the heritage of
the nation.24 The NPS reports that public and privately held national
historic landmarks constitute more than 2,400 of almost 87,000 “entries”
(i.e., listings) in the National Register (nearly 3 percent).

Other statutory and regulatory provisions also govern agencies’
stewardship of their historic buildings. For example, agencies are required
to: (1) assume responsibility for the preservation of their historic
properties;25 (2) consider, when a historic property is no longer needed,
alternative uses or lease to persons or organizations if the action will
preserve the property;26 and (3) consult with ACHP and non-federal
stakeholders, such as state and tribal historic preservation officers,27
before undertaking actions that may affect a historic property listed or




22
 See 36 C.F.R. § 60.4 for the criteria used in evaluating properties for nomination to the
National Register.
23
  See 36 C.F.R. § 65.4 for the criteria used in evaluating a property for possible
designation as a national historic landmark.
24
  Before a property can be designated as a national historic landmark, it must be
evaluated by NPS’s national historic landmark survey, reviewed by the National Park
System Advisory Board, and recommended to the Secretary of the Interior.
25
  16 U.S.C. § 470h-2.
26
  16 U.S.C. § 470h-3(a). An agency may also exchange a historic property owned by the
agency for a comparable historic property.
27
  Pursuant to NHPA, state historic preservation officers and tribal preservation officials
administer the national historic preservation program at the state level and on tribal lands,
identify and nominate eligible properties to the National Register, and consult on federal
agencies’ undertakings. State historic preservation officers are designated by the governor
of their respective state or territory, while tribal historic preservation officials are
designated by their respective tribes.




Page 6                                                     GAO-13-35 Federal Real Property
eligible for listing on the National Register.28 NHPA does not mandate a
particular governmental decision, but instead mandates a particular
process for reaching decisions.

The Secretary of the Interior’s Standards and Guidelines for Federal
Agency Historic Preservation Programs29 indicate that where it is not
feasible to maintain a historic building or to rehabilitate it for contemporary
use, an agency may decide to modify it in ways that are inconsistent with
the Secretary’s treatment standards,30 limit maintenance and repair
investments in the building, or demolish it.31 Such a decision can be
reached only after following appropriate consultation with stakeholders as
required by NHPA.32 Federal historic buildings that are declared surplus
may be made available for other uses, such as a public benefit
conveyance. Under the public benefit conveyance program, state or local
governments and certain tax-exempt nonprofit organizations can obtain
surplus federal real property, including historic buildings, for an approved
public benefit use, such as for educational facilities or to assist the
homeless. Additionally, property declared excess to the federal
government’s need may be sold. Certain land-holding agencies have
independent authority to sell real property.33




28
  16 U.S.C. § 470f; See 41 C.F.R. § 102-78.30. An “undertaking” means a project, activity,
or program funded in whole or in part by a federal agency. 36 C.F.R. § 800.16(y).
29
  63 Fed. Reg. 20496 (Apr. 24, 1998).
30
  The Secretary of the Interior’s Standards for the Treatment of Historic Properties set
forth standards pertaining to the preservation, rehabilitation, restoration, and
reconstruction of historic properties. 36 C.F.R. § 68.3.
31
  The standards and guidelines for federal agency preservation programs do not advocate
federal historic buildings should be allowed to deteriorate or be demolished, but rather
recognize that agencies’ changing needs, limited budget resources, and preservation
priorities may lead agencies to make those decisions after appropriate consultation.
32
  In instances where federal agencies are unable to modify historic buildings in
accordance with the Secretary’s treatment standards, the consultation process facilitates
reaching appropriate agreement on other measures that could be implemented to
preserve as much of the historic fabric as possible. Thus, the preservation review process
does not provide an absolute barrier to such modifications.
33
  GSA has general authority to sell real property. See, e.g., 40 U.S.C. § 543. VA has the
authority to sell real property under certain conditions. See, e.g., 38 U.S.C. §§ 8118, 8164.
NPS does not have general authority to sell real property.




Page 7                                                     GAO-13-35 Federal Real Property
In addition to NHPA and other statutory and regulatory provisions, several
Executive Orders also provide guidance for the management of federal
historic buildings.

     Executive Order 13287, Preserve America, sets forth federal historic
      stewardship requirements, including, requiring executive agencies to
      report to ACHP on their efforts to identify, protect, and use historic
      federal properties, which include historic federal buildings.34 In fiscal
      year 2011, GSA reported to ACHP that more than one-third of the
      1,676 federally-owned buildings under its custody and control 35 are
      more than 50 years old and 479 buildings are listed on or eligible for
      the National Register. In fiscal year 2011, NPS reported to ACHP that
      it held historic properties totaling 26,636 buildings and structures (out
      of more than 70,000 real property assets).36 It further indicated that
      among these historic properties, 1,482 are listed on the National
      Register. In fiscal year 2011, VA did not provide to ACHP a reporting
      of the number of historic buildings that it owns or has listed on the
      National Register.
     Executive Order 13514, Federal Leadership in Environmental,
      Energy, and Economic Performance, requires agencies to ensure,
      among other things, that new construction, major renovations, repairs,
      and alterations of federal buildings comply with the Guiding Principles
      for Federal Leadership in High Performance and Sustainable Building
      (Guiding Principles), such as optimizing energy performance and
      conserving water.37 Also, agencies should ensure, when rehabilitating
      historic buildings, that sustainable technologies (to achieve energy
      and environmental conservation goals) are used to promote the long-
      term viability of the buildings. We have reported that the Office of
      Management and Budget (OMB) has incorporated information about



34
    68 Fed. Reg. 10635 (Mar. 5, 2003).
35
 GSA’s report on its federally-owned buildings under its custody and control was as of
October 2010 (i.e., end of fiscal year 2010, start of fiscal year 2011).
36
  NPS’s portfolio of 70,000 real property assets is comprised of buildings, structures, and
land. In addition to historic buildings and structures (such as a bridge), NPS’s inventory
includes features of cultural landscapes that are managed as structures including walls,
fences, and roads. NPS’s reporting was based on end-of-fiscal-year-2010 data.
37
  74 Fed. Reg. 52117 (Oct. 8, 2009). Those Guiding Principles include: (1) employ
integrated design principles; (2) optimize energy performance; (3) protect and conserve
water; (4) enhance indoor environmental quality; and (5) reduce environmental impact of
materials.




Page 8                                                     GAO-13-35 Federal Real Property
      agencies’ progress in implementing those green building requirements
      into scorecards that OMB uses to rate agencies’ performance, but that
      agencies face challenges.38
     Executive Order 13327, Federal Real Property Asset Management,
      requires GSA to collect data from executive branch agencies
      describing the nature, extent, and use of federal real property.39 The
      data are reported within FRPP and include data on the historic status
      of federal buildings and other data, such as a building’s condition and
      if the building meets the Guiding Principles. The FRPP is maintained
      by GSA on behalf of FRPC.40 The FRPP database includes
      approximately 400,000 buildings that are owned and leased by the
      federal government, many thousands of which have been determined
      to be historically significant. GSA releases a summary level FRPP
      report each fiscal year to provide an overview of the federal
      government’s real property, but those reports do not identify how
      many historic federal buildings are held by individual agencies or the
      executive branch as a whole.
GSA and FRPC require agencies to update their FRPP data on a fiscal
year basis. FRPP guidance to agencies on coding historic status
indicates agencies should code their federally owned buildings within
FRPP as one of the following:

     national historic landmark,
     National Register listed,
     National Register eligible,
     non-contributing element of a national historic landmark/National
      Register listed district,41
     not evaluated, and
     evaluated, not historic.


38
  For example, we reported that benchmarking the energy use of some federal facilities
and finding facility energy managers with an appropriate level of expertise may be
challenging for agencies. GAO, Federal Energy Management: Agencies Are Taking Steps
to Meet High-Performance Federal Building Requirements, but Face Challenges,
GAO-10-22 (Washington, D.C.: Oct. 30, 2009).
39
    69 Fed. Reg. 5897 (Feb. 6, 2004).
40
  In addition to collecting real property data on buildings, FRPP is used to collect data on
structures and land. For the purposes of this report, we are focusing only on buildings.
See appendix I for a more detailed description of our scope and methodology.
41
  A non-contributing element could be, for example, a non-historic building located within
a national historic district.




Page 9                                                      GAO-13-35 Federal Real Property
                        The three agencies we reviewed are taking steps to improve the
GSA, NPS, and VA Are    management of their historic buildings. For example, all three agencies
Taking Action to        have undertaken portfolio-wide management initiatives directed at
                        nominating historic buildings in their portfolios to the National Register as
Manage Their Historic   required by NHPA.42 In addition, among the buildings we reviewed, we
Buildings               found examples where agencies were utilizing their historic buildings to
                        the extent feasible for current mission needs. We also found that when
                        the buildings were no longer suitable for current mission purposes,
                        agencies were leasing all or part of some historic buildings to non-federal
                        entities, as authorized by NHPA and other real property authorities.43
                        Also, we found that GSA, NPS, and VA were implementing projects in
                        some historic buildings to improve their sustainable performance.


Portfolio-Wide          All three agencies have undertaken efforts in recent years to identify the
Management Efforts      historic buildings across their real property portfolios, nominate those
                        buildings to the National Register, and are working to manage those
                        buildings in an effort to comply with the requirements of NHPA and the
                        executive orders. For example, GSA started a multiyear initiative in 2004
                        to assess many of its older buildings that it believed were eligible for
                        listing on the National Register. GSA officials reported this effort is
                        nearing completion and has resulted in National Register nominations for
                        more than 150 buildings.44 In particular, GSA evaluated the National
                        Register eligibility for all of its legacy monumental buildings as part of this
                        effort. These include buildings such as courthouses, post offices, and
                        agency headquarters, which were designed to serve symbolic,
                        ceremonial, and functional purposes. In addition, GSA’s “Legacy Vision”


                        42
                          Listing on the National Register provides a level of protection and review for federal
                        buildings before federal agencies can demolish or alter the buildings in ways that impact
                        their historic character. Listing enables federal agencies to identify those federal buildings
                        for which agencies will seek consultations with stakeholders, such as state historic
                        preservation officers, when planning a federal project that may adversely affect a historic
                        building. Listing also enables federal agencies to lease out, or exchange, the building
                        pursuant to NHPA authorities.
                        43
                          See e.g., Pub. L. No. 89-665, § 111, codified as amended at 16 U.S.C. § 470h-3(a).
                        According to VA officials, it can make use of other real property authorities to lease space
                        no longer needed. See e.g., 16 U.S.C. § 1a-2(k).
                        44
                          GSA’s multiyear program to evaluate and nominate historic buildings included a diverse
                        group of buildings to include monumental buildings, border inspection stations, surplus
                        World War II military-industrial buildings that have been adapted for other federal uses,
                        and mid-century modern public buildings.




                        Page 10                                                      GAO-13-35 Federal Real Property
policy in 2002 laid the groundwork for the agency’s current stewardship
efforts that are focused on the preservation, use, and disposal of historic
buildings, as appropriate. GSA also used American Recovery and
Reinvestment Act of 2009 (Recovery Act) funding to rehabilitate and
modernize 150 of its historic buildings.45 These projects were intended to
address GSA’s historic building repair and alterations backlog and ranged
from comprehensive modernizations of entire buildings, such as the
Federal Building at 50 United Nations Plaza in San Francisco, California,
to limited scope sustainability projects such as the roof replacement
project at the Milwaukee Federal Building and Courthouse in Wisconsin.46

Similarly, NPS implemented an agreement with ACHP to address NHPA
compliance and streamline consultation for its projects at national parks
nationwide. NPS also recently completed its first 5-year cycle of
comprehensive condition assessments on what NPS termed as a critical
subset of its buildings that included accessibility assessments to identify
barriers to disabled persons. This information will be used to prioritize
preservation and improvement of its historic buildings, among others, and
help ensure compliance with federal accessibility requirements.47 In
addition, NPS published The Secretary of the Interior’s Standards for
Rehabilitation and Illustrated Guidelines on Sustainability for
Rehabilitating Historic Buildings in 2011, which, for example, outlined
approaches for improving the energy efficiency of historic buildings while
preserving their historical character.




45
  Based on GSA’s fiscal year 2011 reporting to ACHP, approximately $1.7 billion in
Recovery Act funding was used to fund repairs, alterations, modernizations, and
sustainability projects in those historic buildings.
46
  NPS and VA also used Recovery Act funding for rehabilitation and sustainable
improvement for some of their historic buildings.
47
  For example, the Architectural Barriers Act requires that buildings and facilities
designed, built, altered, or leased with federal funds meet federal standards to insure
whenever possible that physically handicapped persons will have ready access to, and
use of, such buildings and facilities. Pub. L. No. 90-480 (Aug. 12, 1968), codified as
amended at 42 U.S.C. §§ 4151-4157.




Page 11                                                   GAO-13-35 Federal Real Property
                            To enhance the management of its portfolio of historic buildings, VA
                            began two multi-year national studies of 90 of its medical centers that
                            resulted, as of April 2012, in 45 in-process or recently completed National
                            Register district nominations. In addition, five individual medical center
                            National Register nominations not associated with these studies were
                            completed and four VA campuses were designated national historic
                            landmarks in the last 3 years. Further, VA recently updated its policies
                            and procedures governing historic preservation including identifying and
                            evaluating historic properties, and complying with various historic
                            preservation laws and regulations. In 2011, VA also completed a review
                            and identified unused and underused buildings—many of which are
                            historic—with the potential to develop, through public-private
                            partnerships,48 affordable housing for homeless or at-risk veterans and
                            their families.49 VA has also developed training on NHPA requirements for
                            VA field staff. This training, for example, focuses on the need to consult
                            with stakeholders such as the ACHP and state historic preservation
                            officers as required by NHPA and its implementing regulations.


Agencies’ Approaches to     Among the buildings we reviewed, we found examples where GSA, NPS,
Manage Historic Buildings   and VA preserved, used, and adapted historic buildings to meet their
                            current mission needs. When historic buildings were either excess or
                            unsuited for mission needs, we found several instances in which agencies
                            leased part or all of a building to a non-federal entity that could use the
                            building while preserving its historic character. As noted previously, these
                            cases provide useful insights into agency actions related to historic
                            preservation but are not generalizable to agencies’ actions across their
                            historic building portfolios or across the government. Among the 31
                            historic buildings we reviewed, we found:

                                 20 buildings that were used by the federal government;50


                            48
                               The basic structure of a public-private partnership entails the private sector providing
                            financing to renovate or redevelop real property contributed by the federal government.
                            Public-private partnerships are essentially financial business deals for the private sector;
                            but for the federal government’s benefits may include the possible sharing of any net cash
                            flow resulting from a project or attainment of efficient and repaired federal space.
                            49
                                VA Building Utilization Review and Repurposing Initiative.
                            50
                              At one building we visited, the GSA headquarters building in Washington, D.C., which is
                            currently undergoing modernization, the design includes space that is being constructed at
                            the street-level to house four retail vendors.




                            Page 12                                                     GAO-13-35 Federal Real Property
    5 buildings that were used, in part, by federal agencies while some
     space was leased within those buildings—or used under a
     cooperative agreement—by non-federal entities;51
    4 buildings that were leased in their entirety to non-federal entities;
     and
    2 buildings that were vacant.52
Continued use of historic buildings to meet mission needs often involves
balancing the need to modernize building systems, such as mechanical
systems, while preserving historical features. For example, in its
renovation of the Stewart Udall Building in Washington, D.C. (Department
of the Interior headquarters), GSA installed fire-rated emergency egress
stairs within office space that is not historically significant in a manner that
preserved the building’s historic corridors. In another example, GSA
repaired and restored nearly 500 historic wooden windows in the
Milwaukee Federal Building and U.S. Courthouse—built in 1899—in
Wisconsin, while also retrofitting the window frames with modern
insulated glass. Figure 1 shows a representative window before the
rehabilitation (left), a window after the rehabilitation (center photos), and
an exterior view of the building (right).




51
  NHPA permits agencies to lease out space within federal historic buildings if such
leases will ensure the property’s preservation. 16 U.S.C. § 470h-3(a). NPS is authorized
to enter into contracts and cooperative agreements to protect, preserve, maintain, and
operate historical property for public use. 16 U.S.C. § 462(e). Additionally, NPS is
authorized to, among other things, restore, reconstruct, rehabilitate, preserve, and
maintain historic or prehistoric sites, buildings, objects, and properties of national historic
or archaeological significance. 16 U.S.C. § 462(f).
52
  Both buildings—the historic “Old Main” hospital building at the Clement Zablocki Medical
Center in Milwaukee, Wisconsin, and the Old Grist Mill at Perry Point Medical Center in
Maryland—are owned by VA. In the case of “Old Main,” VA is trying to identify an
alternative use for the building. In the case of the Old Grist Mill, a plan to reuse the
building has been developed but has not been implemented pending funding.




Page 13                                                       GAO-13-35 Federal Real Property
Figure 1: Milwaukee Federal Building and Courthouse Window Repair




                                       Among the buildings we reviewed, we found examples where agencies
                                       sought to lease historic buildings that were not used for mission needs to
                                       non-federal entities that could fund their preservation, maintenance, and
                                       repair, and use them in ways that were sometimes supportive of the
                                       agency’s mission. As previously mentioned, the selected agencies were
                                       leasing out either all or part of 9 of the 31 historic buildings we reviewed.
                                       For example, when the Golden Gate National Recreation Area was
                                       created in 1972 in California, a number of Department of Defense
                                       installations were transferred to NPS, including Fort Mason. Through a
                                       public-private partnership, NPS has leased the 100-year old Pier #2 Shed
                                       at Fort Mason—a former military warehouse that served as an
                                       embarkation point for the U.S. Army during World War II—to a non-profit
                                       group that facilitates performing arts events within the building, thus
                                       providing a cultural resource to the public consistent with NPS’s mission.
                                       See figure 2.




                                       Page 14                                          GAO-13-35 Federal Real Property
Figure 2: Fort Mason Pier #2 Space Leased for Performing Arts Purposes




                                        When a federally owned historic building becomes underutilized because
                                        it no longer serves mission needs, agencies may sell a building or
                                        exchange it for comparable historic property so long as the exchange will
                                        ensure the preservation of the historic property.53 Although the 31
                                        buildings we reviewed did not include any executed sales or exchanges,
                                        at the time of our review, NPS was considering the sale or exchange of
                                        Old City Hall—at Lowell National Historic Park in Lowell,
                                        Massachusetts—which NPS has leased to a commercial bank for more




                                        53
                                          16 U.S.C. § 470h-3. Additionally, GSA is authorized to convey to any state or locality
                                        surplus property that the Department of the Interior determines is suitable and desirable
                                        for use as a historic monument for the benefit of the public. 40 U.S.C. § 550(h). As noted
                                        earlier, NPS does not have authority to sell real property.




                                        Page 15                                                    GAO-13-35 Federal Real Property
                          than 25 years.54 Outside the 31 historic buildings included in our review,
                          examples of sales or exchanges of federally owned historic buildings
                          include a former U.S. Courthouse in Cedar Rapids, Iowa, that was
                          transferred to the City of Cedar Rapids in 2010 in exchange for a site to
                          support the construction of a new federal courthouse. In addition, the
                          building that formerly housed the Immigration and Naturalization Service
                          in Seattle, Washington, was sold at auction in 2008 for $4.4 million. In a
                          third example, GSA sold a historic building in Washington, D.C., in 2001
                          that housed the Clara Barton Apartment and Missing Soldiers Office. The
                          sale included a preservation easement55 that provides for the operation of
                          a museum within the building by a non-profit group to recognize Clara
                          Barton’s efforts to aid Civil War soldiers.


Sustainable Performance   In addition to efforts to preserve and use historic buildings, we found that
of Historic Buildings     GSA, NPS, and VA were implementing projects in some of the historic
                          buildings we reviewed to improve the sustainable performance of the
                          buildings and begin meeting the Guiding Principles, as required by
                          Executive Order 13514.56 Because buildings and their sites affect the
                          natural environment, the economy, and the health of people that use
                          them, the Guiding Principles established a common strategy for federal
                          agencies to use for planning, designing, constructing, and operating their
                          buildings. More specifically, the Guiding Principles address five
                          performance goals:

                              integrating the planning, design and construction process;
                              optimizing energy performance;


                          54
                            The tenant, a commercial bank, holds a 60-year lease and is responsible for the
                          maintenance of the building in accordance with NPS standards. According to NPS, the
                          tenant has funded many recent capital improvements to the building, and has invested
                          about $500,000 into a recent rehabilitation project. As noted earlier, NPS does not have
                          authority to sell real property, thus it would need specific legislation to sell a park historic
                          building. See footnote 33.
                          55
                            According to NPS, a historic preservation easement is a voluntary legal agreement,
                          typically in the form of a deed, which permanently protects a significant historic property.
                          Since it is a perpetual easement, an owner is assured that the property’s historic character
                          will be preserved. In addition, an owner who donates a preservation easement may be
                          eligible for tax benefits.
                          56
                            Executive Order 13514 specifically requires agencies to utilize sustainable technologies
                          when retrofitting their historic buildings to promote their long term viability. 74 Fed. Reg.
                          52117, 52119 (Oct. 8, 2009).




                          Page 16                                                        GAO-13-35 Federal Real Property
                                            reducing water consumption and storm runoff;
                                            enhancing indoor environmental conditions such as air quality; and
                                            reducing the environmental impact of materials used to construct and
                                             operate buildings.
                                        Sustainable projects we observed at some of the buildings we visited
                                        included improved energy-efficient heating and cooling systems, “green”
                                        vegetated and “white” reflective roofs, and window retrofits or
                                        replacements, among others. For example, as part of the modernization
                                        of the federal building located at 10 West Jackson Boulevard in Chicago,
                                        Illinois, GSA is installing energy-saving “daylight harvesting” technology
                                        that automatically adjusts office lighting according to the amount of
                                        natural light entering through the building’s windows. GSA recently
                                        installed both green roof and white reflective roof technologies to reduce
                                        the amount of heat gain and loss through the building’s roof. See figure 3
                                        below.

Figure 3: Actions to Improve the Sustainability of 10 West Jackson Boulevard, Chicago




                                        According to OMB’s January 2012 sustainability scorecards for the
                                        agencies, GSA’s and VA’s efforts to assess and incorporate sustainable



                                        Page 17                                         GAO-13-35 Federal Real Property
Guiding Principles in their buildings are on track, but Department of the
Interior’s effort is not.57 While NPS has a Sustainable Buildings
Implementation Plan, agency officials report that they have not assessed
many of their historic buildings to determine if they currently meet the
Guiding Principles. NPS officials told us that their efforts thus far to
comply with the Guiding Principles have focused largely on new
construction projects—such as new visitor centers—or on existing
building rehabilitations rather than on historic buildings where there are
no planned projects. While NPS is not currently on track to meet the
Guiding Principles as assessed by OMB, we found that NPS had
implemented sustainable projects in 9 of 13 NPS buildings we visited and,
in some cases, had conducted energy audits to identify where future
projects could improve the sustainable performance of its historic
buildings.

We discussed the issues faced by federal agencies to make historic
buildings sustainable with three outside experts.58 Based on our
discussions with those experts—and a review of professional articles
written by those individuals—we found that many historic buildings may
be inherently sustainable. In general, historic buildings built before World
War II often incorporated many sustainable principles, such as orienting a
building for solar efficiency and making effective use of natural light and
ventilation. In addition, generally, the rehabilitation and reuse of a historic
building consumes fewer raw materials and affects the environment to a
lesser degree than constructing a new building of comparable size. All
three experts indicated that NPS has generally been an effective
advocate for disseminating information about incorporating sustainable
improvements in historic buildings. They identified actions—by NPS’s
National Center for Preservation Training and Technology or its Technical
Preservation Services—to make sustainable green building information
available to the preservation community such as NPS’s recently released



57
  Buildings managed by NPS comprise the majority of all of Department of the Interior’s
buildings. Through OMB’s performance scorecard process, agencies are assessed by
OMB on their progress toward implementing sustainability and energy targets in a number
of areas such as sustainable green building practices. Executive Order 13514 requires
that executive branch agencies are to ensure that 15 percent of their buildings and
building leases—that are over 5,000 gross square feet in size—meet the green building
Guiding Principles by 2015.
58
  In addition to expertise in sustainability, the individuals we spoke with have professional
or academic expertise in the areas of architecture, preservation, and engineering.




Page 18                                                     GAO-13-35 Federal Real Property
                             technical preservation brief entitled Improving Energy Efficiency in
                             Historic Buildings.59 Independent of our discussion with these experts, we
                             found that GSA and VA have been partnering with NPS as well as other
                             federal agencies—such as the Department of Energy—to further advance
                             federal initiatives aimed at improving the sustainability of historic federal
                             buildings.


                             The three agencies we reviewed face challenges related to the
GSA, NPS, and VA             functionality of historic buildings, the amount of funding available for
Face Challenges in           preservation projects, and federal requirements to consult stakeholders
                             on historic preservation. Maintaining and making historic buildings
Managing Historic            functional for contemporary purposes in a constrained budget
Buildings                    environment poses a challenge. Also, competing stakeholder interests
                             can arise when agencies consult with stakeholders. Compounding these
                             challenges, agencies are required to identify and report on their historic
                             buildings and their reported data is not consistent and complete.


Functional, Budgetary, and   Functional and budgetary limitations as well as competing stakeholder
Stakeholder Challenges       interests have been long-standing challenges in the area of federal real
                             property management and to agencies’ efforts to preserve historic
                             buildings. These challenges are significant for the selected agencies
                             given they have reported that identified historic buildings represent
                             approximately 25 to 30 percent of their buildings.

Functional Limitations       Based on our site visits and discussions with agency officials, we found
                             that the three agencies faced challenges in rehabilitating and modernizing
                             historic buildings for contemporary use because of age, specific
                             characteristics of buildings’ original designs, and their particular historical
                             features. For instance, it can be difficult to address current building codes
                             in some historic buildings, install modern building systems—particularly
                             with regard to heating, ventilation, and cooling—and provide access for
                             disabled persons. For example, NPS officials reported they have not been
                             able to improve accessibility at the John F. Kennedy house in Brookline,
                             Massachusetts—which now serves as a museum—as it would adversely




                             59
                               NPS, Technical Preservation Services, Preservation Brief 3: Improving Energy
                             Efficiency in Historic Buildings, (Washington, D.C., Dec. 2011).




                             Page 19                                                 GAO-13-35 Federal Real Property
affect the historic character of the building.60 In lieu of being able to make
accessibility improvements to the John F. Kennedy house’s narrow
hallways and stairwell, NPS officials report they are considering leasing
space in a nearby commercial building to create a new visitor center that
could accommodate visitors with special accessibility needs and provide
additional interpretation exhibits for all visitors.

Similarly, in the case of the Old Grist Mill—built sometime around 1735—
at VA’s Perry Point Medical Center in Maryland, installing modern building
systems and making building code improvements—such as adding a
bathroom and a stairwell—will be challenging. VA’s plan to reuse the
building as a training facility will require penetrating some historic beams
and floors. See figure 4 for representative exterior and interior photos of
the Old Grist Mill as it exists today and the proposed design for the
adaptive reuse of building.




60
  An NPS official at the site reported that the agency provides interpretative photos,
historic pieces, and a ranger located on the outside of the house for those individuals who
cannot access the house.




Page 20                                                    GAO-13-35 Federal Real Property
Figure 4: VA—Proposed Design for VA’s Old Grist Mill at Perry Point, Maryland, Including New Stair, Elevator, and Bathroom




Budgetary Limitations                    We have previously reported on how real property funding limitations—
                                         such as funding needed to maintain, repair, and modernize federal



                                         Page 21                                              GAO-13-35 Federal Real Property
buildings—have been a long-standing challenge for agencies and that
agencies’ actions to defer maintenance have resulted in large backlogs of
deferred maintenance and the deteriorated condition of some federal
buildings, including historic buildings.61 Agencies’ total annual budgets
allotted for historic preservation are difficult to determine because funding
requested to implement projects to maintain, repair, rehabilitate, and
modernize historic buildings is dispersed across multiple budget
accounts. Projects are identified within agencies’ budgets as line items,
and funding for historic preservation can also be allotted in programmatic
and operating budget accounts for conducting other activities like routine
maintenance. Also, funding across those sources includes funding for
non-historic buildings.

We recently reported that GSA has identified a $4.6 billion maintenance
and repair liability (i.e., needed projects) for its federally owned real
property over the next 10 years,62 which includes both historic and non-
historic buildings. According to GSA officials, its historic buildings require
comparatively more maintenance and repair work than its non-historic
buildings.63 We also reported that the annual funding Congress has made
available to GSA for obligation from the Federal Buildings Fund64 has
trended downward in recent years, and much of this reduction has been
absorbed by the repairs and alterations funding account, meaning that



61
  GAO, Federal Real Property: Progress Made Toward Addressing Problems, but
Underlying Obstacles Continue to Hamper Reform, GAO-07-349 (Washington, D.C.: Apr.
13, 2007).
62
  GSA assesses the basic structure and systems of each building on a biannual basis to
estimate the cost of needed maintenance and repairs that contribute to the overall
maintenance liability. Within its 10-year maintenance and repair estimate GSA categorizes
maintenance and repair cost into subcategories that reflect repairs needed immediately (1
year), within 1-2 years, within 3-5 years, and more than 5 years from now.
63
  GAO, Federal Buildings Fund: Improved Transparency and Long-Term Plan Needed to
Clarify Capital Funding Priorities, GAO-12-646 (Washington, D.C.: July 12, 2012).
64
  Instead of GSA’s receiving direct appropriations, the Federal Buildings Fund operates as
the primary means of financing the operating and capital costs associated with federal
space. The Federal Buildings Fund is financed by income from rental charges assessed to
tenant agencies occupying federal and leased space. Congress exercises control over the
Federal Buildings Fund through the appropriations process that sets annual limits—called
obligational authority—on how much of the fund can be obligated for various activities.
GSA requests obligational authority from Congress as part of the annual President’s
budget request for activities, including maintenance, repair, and modernization of historic
buildings.




Page 22                                                   GAO-13-35 Federal Real Property
GSA has reduced its spending on repairs and alterations.65 According to
GSA officials, the constrained federal budget and competing project
demands have affected GSA’s ability to complete historic building
modernizations. For example, GSA allocated $162 million in Recovery
Act funding to undertake the first phase in its renovation of half of the 95-
year old GSA headquarters building in Washington, D.C.; however, GSA
does not have funding to complete the second phase of the project.66
Similarly, the final phase of GSA’s 12-year, six-phase modernization to
the Department of the Interior’s headquarters building in Washington,
D.C., has been delayed pending funding availability.67 GSA officials
reported that because of shrinking budgets and increasing reinvestment
needs within GSA’s real property portfolio, GSA evaluated the risks of
delaying various projects, and determined that delaying the completion of
the GSA headquarters building project posed a lower risk as compared
with more critical projects. GSA officials further reported that GSA’s fiscal
year 2013 construction program incorporates OMB’s response to the
nation’s economic distress by including fewer projects and focusing on
critical needs such as safety improvements.

According to NPS’s fiscal year 2013 budget justification, less than 60
percent of its historic buildings and structures are in good condition.68
NPS headquarters officials report that limited funding is the greatest
challenge NPS faces in maintaining its historic buildings. We found that
some NPS sites have experienced maintenance staffing reductions as
NPS has faced declining operating budgets. For example, the
maintenance unit that jointly serves the Fort McHenry National Monument
and Historic Shrine and Hampton National Historic Site, both located in
Maryland, has been reduced from 15 to 10 positions over the last 3


65
  GAO-12-646.
66
  GSA estimates the total project cost for phases one and two at $295 million.
67
  GSA estimates the final phase will cost $56.5 million and the total project cost for the six
phases at $276 million.
68
  NPS conducts condition assessments on its buildings and calculates a facility condition
index for a building based on the amount of its deferred maintenance needs divided by the
current replacement value of the building. The National Academies of Science has
reported that what constitutes an acceptable facility condition can differ across agencies
and building types based on an agency’s mission. In general, NPS considers a facility
condition index rating of less than 11 percent to be reflective of good condition; 11 to 15
percent is considered fair condition; 15 to 50 percent is considered poor condition; and a
facility condition index greater than 50 percent is considered serious condition.




Page 23                                                     GAO-13-35 Federal Real Property
years.69 One NPS official commented that staffing reductions pose a risk
to historic buildings because maintenance projects may get deferred,
which can lead to such projects needing to be addressed later as larger,
bundled, and more costly capital projects. Delaying maintenance projects
may also cause irreversible damage to historic buildings, according to the
NPS official.

In reviewing NPS’s fiscal year 2013 budget justification, we found that
NPS has requested $96.3 million for its cyclical maintenance program,
aimed at conducting preventative maintenance on a predictive cycle to
keep buildings—both historic and non-historic—in acceptable condition.
However, NPS’s fiscal year 2013 budget justification also shows that its
annual cyclical maintenance requirements for its buildings exceed $450
million.70 Since NPS’s budget request is substantially less than its stated
requirement, it is likely that some maintenance projects will be deferred.71

In June 2012, VA reported to us that much of its inventory is over 50
years old, with an average building age of 57 years.72 In addition to the
age of its buildings, VA reported that many of those buildings have been
designated as historic and many are in poor condition.73 In VA’s fiscal
year 2013 budget justification, 18 of 21 Veteran Integrated Service
Networks (i.e., regional administrative offices for their hospitals,



69
  The maintenance staff is responsible for over 30 buildings and many structures—like
barns, greenhouses, gun batteries, trails, etc.—on approximately 100 acres (60 acres at
Hampton National Historic Site; 40 acres at Fort McHenry National Monument and Historic
Shrine). The fort alone, receives approximately 650,000 visitors a year.
70
  The figure is based on the annual cyclical maintenance requirements in both historic and
non-historic buildings.
71
  In addition, we found NPS’s fiscal year 2013 line item construction budget request—
which, in part, funds the repair and rehabilitation of some NPS’s historic buildings—will
enable NPS to fund only its highest priority construction projects that are critical to visitor
and employee health and safety.
72
  GAO, Federal Real Property: National Strategy and Better Data Needed to Improve
Management of Excess and Underutilized Property, GAO-12-645 (Washington, D.C.: June
20, 2012).
73
  VA assesses the condition of its buildings’ systems (for example, structural, mechanical,
and plumbing)—on a 3-year cycle—to estimate remaining useful life and identify systems
that need to be repaired or replaced. Each system is rated on an A to F grade scale.
Systems rated “D” are considered to be in “poor” condition, and those receiving a rating of
“F” are in “critical” condition.




Page 24                                                       GAO-13-35 Federal Real Property
                        comprised of multiple hospital campuses) reported that, in general, their
                        aging and historic buildings are a significant infrastructure challenge
                        because of the poor condition of many of the buildings, the functional
                        limitations of some historic buildings,74 and stakeholder interests about
                        rehabilitating, reusing or disposing of historic buildings. VA’s fiscal year
                        2013 budget request included $1.1 billion for major and minor
                        construction projects,75 which includes funding for rehabilitation of both
                        non-historic and historic buildings. The budget request also included $712
                        million to fund non-recurring maintenance requirements in VA’s existing
                        buildings, including historic buildings.76 The latter includes funding for
                        repairs and life-cycle projects, such as modernizing mechanical or
                        electrical systems and replacing windows and roofs. However, VA’s
                        budget request also shows it would need over $9 billion to adequately
                        address the condition deficiencies in its buildings.77 One VA official
                        indicated that VA expects to seek funding in future budget requests, for
                        projects to correct those deficiencies.

Competing Stakeholder   We have reported that in addition to Congress, OMB, and real property-
Interests               holding agencies, several other stakeholders have an interest in how the
                        federal government carries out its real property acquisition, management,
                        and disposal practices. In the case of historic buildings, these
                        stakeholders may include, but are not limited to, state, local, and tribal
                        governments; business interests in the local communities; historic




                        74
                          For example, floor-to-floor heights, column spacing, and structural floor loading are
                        difficult to change to accommodate new uses. Thus, achieving needed program
                        adjacencies and appropriate space for laboratory, clinic, and patient rooms can be difficult
                        to provide within the existing floor plan of a historic building.
                        75
                          Funding for VA major and minor construction projects provides for constructing, altering,
                        extending, and improving any VA facility. Major projects are those estimated to cost more
                        than $10 million and minor projects are those estimated to cost equal to or less than $10
                        million.
                        76
                          Funding for VA non-recurring maintenance projects are part of VA’s construction
                        programs budget request although they are funded from VA’s medical facilities operating
                        account.
                        77
                          In testifying before the House Committee on Veteran’s Affairs on VA’s fiscal year 2013
                        budget request, the Director of the National Legislative Service for the Veterans of Foreign
                        Wars—which serves as an independent reviewer in VA’s budget process—reported that
                        VA would need to spend approximately $2 billion annually on nonrecurring maintenance to
                        fully maintain its buildings.




                        Page 25                                                    GAO-13-35 Federal Real Property
preservation groups; and the general public.78 For example, in the case of
VA, veterans’ organizations have had an interest in being consulted on
VA’s plans to reuse or demolish its historic buildings and how those plans
affect the services provided to veterans. Competing interests over how to
reuse a historic building, or whether to demolish a building, may arise
between an agency and its stakeholders. As a result, final decisions
about a property may reflect broader stakeholder considerations which
may not necessarily align with what an agency views as the most cost-
effective or efficient alternative.

Stakeholders for historic buildings include state historic preservation
officers and ACHP, both of which have a role in consulting and advising
federal agencies on preservation, repair, or alteration of historic buildings.
For example, in 2011, the California state historic preservation officer was
concerned that VA had not solicited his office’s consultation on some
projects at the San Francisco VA Medical Center, which included the
development of a master plan to address the campus’ future needs and
its effect on the site’s historic buildings. We found that VA is reexamining
its master plan—and the extent of new construction proposed on the
campus—to try to address concerns raised, in part, by the California state
historic preservation officer.79 According to ACHP officials, preservation
organizations, such as the National Trust for Historic Preservation, and
members of the public may also have an interest in being consulted about
decisions affecting federal historic buildings.80

Among the buildings we reviewed, we found examples where competing
stakeholder interests have affected the preservation, reuse, or lease of
historic buildings. For example, VA attempted to use its enhanced-use



78
  In 2011, we reported that the Department of Defense faces the same challenge in
having to consult non-federal stakeholders before making decisions about reusing its
historic buildings. Also, we reported that DOD officials indicate that the timing and
complexity of the historic preservation consultation process is a factor that needs to be
considered when planning for demolition of a historic facility. See GAO, Excess Facilities:
DOD Needs More Complete Information and a Strategy to Guide Its Future Disposal
Efforts, GAO-11-814 (Washington, D.C.: Sept. 19, 2011).
79
  VA’s Federal Preservation Officer also reported that VA is working to improve its
consultation process and has begun to provide training on consultation requirements to
VA’s regional site offices.
80
  The National Trust for Historic Preservation is a privately funded, nonprofit organization
that seeks to preserve America’s historic places.




Page 26                                                     GAO-13-35 Federal Real Property
lease authority81 to enter into a long-term public-private partnership with a
non-federal entity for the use of some of VA’s historic buildings in
Milwaukee, Wisconsin.82 However, public stakeholder groups raised
concerns about aspects of the lease proposal and the related
construction plans for a high-tech business park, which contributed to the
failure of the Milwaukee proposal.83 We have previously reported on VA’s
challenges with its non-federal stakeholders when trying to implement
plans to repurpose some historic buildings.84 The failure of enhanced-use
lease negotiations in Milwaukee has, in part, contributed to the failure to
find a suitable use for one building in particular, the “Old Main” hospital
building, which is in an advanced state of deterioration. During our site
visit we observed that the roof was partially collapsed.85 ACHP officials
said that VA funding for maintenance of the building was severely limited
over many years and that VA’s medical center staff lacked a familiarity
with the historic preservation review process, which contributed to the
building’s current condition. In 2011, VA and ACHP initiated
consultations—which included NPS, the state historic preservation officer,
veterans’ groups, and others—to discuss planned projects on the historic
campus to include a project to stabilize Old Main from further collapse.86



81
  Congress had authorized VA to enter into enhanced use leases for up to 75 years for
cash or in-kind consideration with public and private entities for leases that contributed to
VA’s mission and enhanced the use of the property. This authority expired in December
2011. In August 2012, Congress reauthorized VA’s enhanced use lease authority. As
reauthorized, VA may enter into enhance use leases only for the provision of supportive
housing. VA may no longer accept in-kind consideration, but it may enter into enhanced
use leases without receiving consideration. 38 U.S.C. §§ 8161-8169.
82
  In 2003, GAO reported that the medical center in Milwaukee tried to generate interest in
reusing its historic buildings and had held discussions with other government agencies,
school organizations, a labor union, and charitable organizations without success. See
GAO, VA Health Care: Improved Planning Needed for the Management of Excess Real
Property, GAO-03-326 (Washington, D.C.: Jan. 29, 2003).
83
 One of the concerns raised by stakeholders about the proposal was related to the
amount of housing that would be made available to veterans.
84
 GAO, VA Real Property: Realignment Progressing, but Greater Transparency about
Future Priorities Is Needed, GAO-11-197 (Washington, D.C.: Jan. 31, 2011).
85
  The roof partially collapsed during a snow storm in the winter of 2010.
86
  In 2011, the campus was designated a national historic landmark district. Of the 38
buildings on the campus, 24 are considered historic to include Old Main. In November
2012, VA reported most of the buildings within the historic district are being utilized to
provide services to veterans and that VA has prepared condition assessments and
maintenance plans for all the buildings, including those no longer in use.




Page 27                                                      GAO-13-35 Federal Real Property
                                          The work to stabilize Old Main began in September 2012. The medical
                                          center director told stakeholders that VA will continue to seek alternative
                                          uses for Old Main. See figure 5 for representative views of the exterior
                                          and interior of the building.

Figure 5: Deterioration of the “Old Main” Hospital, Built in 1869, at VA’s Medical Center in Milwaukee, Wisconsin




Lack of Complete and                      Compounding the challenges the three agencies face in managing their
Consistent Data for                       historic buildings, we also found that the data the three agencies reported
Managing Historic                         on historic buildings were not complete or consistent. FRPP was intended
                                          to provide a comprehensive database of federal buildings, including
Buildings                                 identifying historic buildings, but data collection and control issues have
                                          hindered the reporting of complete and consistent data.87 However, if data
                                          reported to FRPP were improved, FRPP could be used as a vehicle to
                                          strategically manage and oversee the government’s historic buildings.

Executive Order 13287 and the             Under Executive Order 13287, agencies are required to report to ACHP
Preserve America Report                   on their progress in identifying, protecting, and using historic buildings


                                          87
                                            In our June 2012 report on excess and underutilized federal real property, we reported
                                          that key data elements in FRPP are not always defined and reported consistently and
                                          accurately and that FRPC has not followed sound data collection practices in designing
                                          and maintaining the FRPP database, raising concern that the data are not a useful tool for
                                          describing the nature, use, and extent of excess and underutilized federal real property,
                                          and that some of those properties are historic buildings. See GAO-12-645.




                                          Page 28                                                   GAO-13-35 Federal Real Property
                    and other properties, as well as their condition. ACHP consolidates
                    agency-reported data every 3 years into the Preserve America report on
                    the state of the federal government’s historic properties. The three
                    selected agencies, however, did not report consistent information on their
                    historic properties. For example, in 2011, GSA reported to ACHP the total
                    number of historic buildings it evaluated and nominated to the National
                    Register over the last 3 years, but NPS did not report how many
                    additional buildings achieved historic status and were listed on the
                    National Register within the reporting period. Also, according to an ACHP
                    official, VA did not meet ACHP’s fiscal year 2011 reporting requirement
                    because of VA’s internal review processes.88 Therefore, ACHP could not
                    report the number of historic buildings held by VA in its recent Preserve
                    America report.89

National Register   As noted, NPS manages the National Register. Historic property records
                    are listed on the National Register after a building is nominated by an
                    agency and the NPS agrees with the agency’s determination that the
                    building meets the historic designation criteria.90 The National Register is
                    intended to be an authoritative guide and planning tool to identify
                    properties agencies should consider for protection and, before
                    undertaking a project related to such properties, to provide ACHP, state
                    historic preservation officers, and other stakeholders a reasonable
                    opportunity to comment on the project. According to GSA and VA
                    officials, the data in the National Register are not complete. Specifically,
                    GSA and VA are still working to complete backlogs of National Register
                    nominations to fully report on historic buildings that the federal
                    government owns. GSA still needs to conduct evaluations on 5 percent of


                    88
                      In addition to VA, ACHP reported to us that other executive agencies—not under our
                    review—did not meet the fiscal year 2011 reporting requirement. In April 2012, VA
                    submitted its report to ACHP but it was considered late and could not be incorporated into
                    the triennial Preserve America report.
                    89
                      In addition, ACHP’s 2012 Preserve America report did not include a total number of
                    historic buildings, or structures, held by the entire executive branch. ACHP, In the Spirit of
                    Stewardship: A Report on Federal Historic Property Management. The Preserve America
                    Executive Order Report to the President (Washington, D.C.: Feb. 15, 2012).
                    90
                      36 C.F.R. § 63.1 et seq.. Prior to submitting historic building nominations to the National
                    Register, agencies should seek the appropriate state historic preservation officer’s
                    concurrence that the building meets National Register criteria. In cases where a federal
                    agency and state historic preservation officer do not agree on the historic eligibility of a
                    federal building, NPS will make the determination of eligibility based on information
                    submitted by both parties.




                    Page 29                                                      GAO-13-35 Federal Real Property
                            its buildings over 50 years old, and VA is still conducting evaluations for
                            30 of its medical campuses, which encompass hundreds of buildings,
                            built approximately between 1918 and 1960.91 Further, according to the
                            official that manages the National Register, listings are typically not
                            updated to denote the federal agency currently responsible for a building
                            or a non-federal entity if the building were sold or transferred. Rather,
                            listings generally reflect the federal agency that was responsible for the
                            building at the time of its nomination.92

FRPP Data Inconsistencies   Executive Order 13327 directs the Administrator of GSA, in consultation
                            with FRPC, to establish and maintain a database (which became the
                            FRPP) and to establish data and information technology standards to
                            facilitate reporting on a uniform basis. In June 2012, we reported that data
                            elements in the FRPP database are not always defined and reported
                            consistently and accurately.93 In our current review of agencies’ FRPP
                            historic building data, we found that the historic status of over 75 percent
                            and 63 percent of GSA and NPS buildings, respectively, are categorized
                            as “not evaluated” in FRPP.94 See table 1 below for examples of
                            inconsistencies we identified. A noteworthy example is the West Wing of
                            the White House, which is a GSA-held property that was designated a
                            national historic landmark in 1960, but is listed as “not evaluated” in
                            FRPP.95




                            91
                              In general, GSA regional offices use an eligibility evaluation tool—developed specifically
                            for GSA’s modern era buildings—to conduct on-going assessments of buildings before
                            they reach 50 years of age.
                            92
                              NPS officials report that agencies, as part of their NHPA obligations to manage
                            information regarding their historic buildings, should file amended documentation to reflect
                            subsequent actions, such as a sale or transfer.
                            93
                              GAO-12-645.
                            94
                              In September 2012, GSA officials reported that GSA anticipates reducing the proportion
                            of unevaluated properties to 60 percent by the end of fiscal year 2013.
                            95
                              VA’s FRPP data indicate that nearly nine percent of its buildings are “not evaluated.”




                            Page 30                                                    GAO-13-35 Federal Real Property
Table 1: Examples of Inconsistencies between GSA’s Historical Status Data in
FRPP and Its Historic-Buildings Database

                                                  Historical status GSA –   Historical status GSA –
Building                            State         FRPP 2011 data            historic-buildings data
White House – West                  DC            Not evaluated             National Historic
Wing                                                                        Landmark – Designated
                                                                            in 1960
Elijah Barrett Prettyman DC                       Not evaluated             National Register listed –
Courthouse                                                                  2007
U.S. Tax Court                      DC            Not evaluated             National Register listed –
                                                                            2008
Source: GAO analysis of FRPP data and GSA data.

Note: GSA’s FRPP data reflect its fiscal year reporting ending September 30, 2011. We compared
GSA’s fiscal year 2011 FRPP data to its historic building data also ending September 30, 2011.
FRPP’s reporting guidance to agencies indicates that the historical status of the federal government’s
owned assets should be reported as one of the following: (1) national historic landmark; (2) National
Register listed; (3) National Register eligible; (4) non-contributing element of a national historic
landmark or National Register listed district; (5) not evaluated; or (6) evaluated, not historic.


In addition, FRPP data for NPS in fiscal year 2011 showed that NPS had
almost 1,500 national historic landmark buildings, while its reporting to
ACHP in 2011 indicates NPS had 177 national historic landmarks. These
data inconsistencies are because of FRPP’s lack of a status code for
buildings that are “contributing” elements in a national historic landmark
(or National Register listed) site or district. We found that in internal data
on historical buildings, NPS categorizes many buildings as “contributing”
historic buildings. For example, the Frederick Law Olmstead House in
Brookline, Massachusetts, is reported as a single national historic
landmark site on the National Register, but is comprised of five buildings
including a shed and barn. While the house is categorized as “nationally
significant,” the historic significance of the shed and barn are categorized
as “contributing.”

In 2009, the Department of the Interior recommended that FRPC add a
new “contributing” category within FRPP coding options for historic status
to better clarify how many buildings have actually been designated as
historic, particularly for those within national historic landmark and
National Register listed sites and districts. FRPC did not implement the
recommendation, in part, because it was considered too specific to the
Department of the Interior’s portfolio. However, we also found this
recommendation to have relevance to many of the historic buildings
reported by VA and GSA. For example, in the case of VA, most of its
historic buildings are not individually listed to the National Register, but
are considered to be included within a historic site or district. Therefore,


Page 31                                                               GAO-13-35 Federal Real Property
the lack of a “contributing” category makes it unclear whether historic
building status data are being reported consistently or accurately across
agencies and whether the executive branch can reliably identify the total
number of historic buildings it holds, and also distinguish those that are
exceptionally significant to the nation and commensurate with national
historic landmark status.

GSA and NPS historic building officials also stated that FRPP data on the
number of historic buildings they hold are inconsistent with data
maintained within their internal historic buildings databases.96 The
agencies have not fully reconciled their historic building databases with
their real property databases, the latter of which are used to report to
FRPP. FRPP data, therefore, cannot be used to assess the numbers of
federal buildings individually designated or account for those that are
“contributing buildings” within a larger historic site or district.

Lastly, ACHP officials told us that they do not have access to FRPP
data—despite their request to GSA—to conduct analyses on federal
historic buildings.97 We found that FRPC allows access to agency FRPP
data only when access is granted by individual agency data
administrators.98 ACHP officials also noted it is difficult for ACHP to draw
quantifiable summary data from individual agencies’ Preserve America
submissions because agencies inconsistently report historic building




96
  A NPS preservation official reported that NPS’s historic building database tracks a larger
number of historic buildings (approximately 9,600) than NPS’s real property database
(approximately 8,000). The official attributed the difference, in part, to some ancillary
outbuildings—such as a historic barn—which are not counted individually because they
are included within the property record for the main building within NPS’s real property
database. He further indicated that NPS has been working to improve the completeness of
historic buildings data tracked in NPS’s real property database. GSA officials also noted
that data in GSA’s historic buildings database were not uploaded to GSA’s real property
database prior to its fiscal year 2010 and 2011 FRPP reporting, which resulted in GSA’s
underreporting of the number of its historic buildings. A GSA official indicated the agency
plans to correct the data for GSA’s fiscal year 2012 reporting to FRPP.
97
  While ACHP advises Congress and the executive branch on agencies’ preservation
efforts and federal historic properties, ACHP is not an advisor to or a member of FRPC.
98
 In effect, each agency may only see its own FRPP data.




Page 32                                                    GAO-13-35 Federal Real Property
                                  data.99 ACHP officials further indicated that ACHP would like some
                                  consistency in how historic building data are reported and said the
                                  responsibility is on individual agencies to report uniform data as was
                                  intended by FRPP.

                                  The FRPP database’s lack of completeness and consistency for historic
                                  data are not consistent with sound data collection practices. We have
                                  long held that results-oriented organizations assure that data they collect
                                  are sufficiently complete, accurate, and consistent enough to document
                                  performance and support decision making, as well as to collaborate with
                                  others who would benefit from the data.

                                  In June 2012, we reported that FRPC has not followed sound data
                                  collection practices in designing and maintaining the FRPP database,
                                  raising concern that the data are not a useful tool for describing the
                                  nature, use, and extent of excess and underutilized federal real
                                  property.100 For example, FRPC has not ensured that key data
                                  elements—including buildings’ utilization, condition, annual operating
                                  costs, mission dependency, and replacement value—are defined and
                                  reported consistently and accurately. As a result, we recommended that
                                  GSA, in collaboration with FRPC member agencies, develop and
                                  implement an action plan to improve FRPP, consistent with sound data
                                  collection practices, so that data collected are sufficiently complete,
                                  accurate, and consistent, and collaboration between agencies is effective.

Development of Performance        In addition to developing the database, Executive Order 13327 required
Measures for Historic Buildings   FRPC to be a clearinghouse of best practices for real property
                                  management and establish performance measures to determine the
                                  effectiveness of federal real property management. The executive order
                                  specifically states that performance measures shall be designed “to
                                  enable the heads of executive branch agencies to track progress in the
                                  achievement of government-wide property management objectives, as
                                  well as allow for comparing the performance of executive branch



                                  99
                                    ACHP’s 2012 Preserve America report stated that despite the general trend toward
                                  improving data, agencies continue to face challenges managing historic properties
                                  including the lack of accurate and available information regarding the presence and value
                                  of historic assets held by the agencies and limited resources to support historic property
                                  identification, condition assessments, maintenance, and capital improvement projects.
                                  100
                                       GAO-12-645.




                                  Page 33                                                   GAO-13-35 Federal Real Property
agencies against industry and other public sector agencies.”101 FRPP has
four data elements that FRPC considers performance measures: (1)
utilization (overutilized, utilized, underutilized, and not utilized); (2)
condition index (general measure of the constructed asset’s condition at a
specific point in time); (3) annual operating costs (expenses for recurring
maintenance and repair costs, utilities, cleaning or janitorial costs, and
roads or grounds expenses); and (4) mission dependency (the
importance an asset brings to the performance of the agency’s
mission).102 However, we reported in June 2012 that these performance
measures are ineffective because they are not routinely linked to any
performance goals, and FRPC guidance does not explain what
constitutes acceptable performance on these measures.103

These performance measures, if tied to performance goals, could
potentially be useful to the agencies and OMB in the area of historic
preservation, where, OMB and FRPC could benchmark performance
across agencies and, potentially identify progress, areas of concerns, or
lessons learned. For example, of the three agencies we reviewed, only
NPS had a performance metric reported within its fiscal year 2013 budget
justification that showed the number and percentage of historic buildings
in good condition for prior fiscal years, the planned goal for the fiscal year
2012, and a proposed goal for fiscal year 2013.104 Furthermore, data on
mission-dependent buildings with historic status could help agencies
justify funding requests for those buildings’ maintenance and
rehabilitation, and historic buildings with high operating costs could be
candidates for sustainability investment. The data could also show how
the condition of mission-dependent historic buildings may either be
adversely or positively affected given reduced or increased funding
scenarios. Lastly, complete and accurate data identifying agencies’
historic buildings would be needed to assess whether agencies have
managed and provided for those buildings’ continued use or have
pursued leases with persons or organizations to provide for the buildings’
reuse and preservation as called for by NHPA.



101
  Exec. Order No. 13327, 69 Fed. Reg. 5897 (Feb. 4, 2004).
102
   Based on General Services Administration, FRPC 2011 Guidance for Real Property
Inventory Reporting (Washington, D.C.: Oct. 4, 2011).
103
  GAO-12-645.
104
  NPS’s performance metric includes both buildings and structures in good condition.




Page 34                                                 GAO-13-35 Federal Real Property
              In June 2012, we recommended that FRPP performance measures
              should be linked to clear performance goals consistent with Executive
              Order 13327. GSA agreed with the recommendation and has begun to
              take action to address the recommendation. GSA also reported that it will
              propose refining the performance measures and limit the number of
              measures to ensure that only essential measures, linked to performance
              goals, are collected consistent with directives in Executive Order 13327.
              Improving historic building data could complement this recommendation,
              not only at the agency-level for GSA, NPS, and VA, but for all executive
              agencies included in FRPP and in GSA’s capacity as the agency
              responsible for establishing and maintaining FRPP.


              Federal real property management is a challenging area, and
Conclusions   requirements to preserve and manage historic buildings place added
              expectations on federal agencies that are stewards of many treasured
              assets. NHPA, executive orders, and other requirements establish the
              overall federal policy regarding historic buildings. Those requirements
              reflect that federal historic buildings are an important part of America’s
              heritage and should be preserved, protected, enhanced, and where
              possible, adapted for contemporary use.

              In 2004, the President issued an executive order establishing the FRPC
              and requiring GSA to collect data from executive branch agencies
              describing the nature, extent, and use of federal real property.105 While
              this was a positive step, we reported in June 2012 that GSA needed to
              improve FRPP so that data are consistent, complete, and collaboration
              among agencies is effective.106 GSA agreed with this recommendation
              and is taking steps to implement it. In the case of historic building data,
              FRPP data are similarly limited, which negates the potential for agencies
              and stakeholders, including OMB and Congress, to use the data to
              strategically manage the historic building subset of the federal real
              property portfolio and try to address related challenges. Focusing on how
              to improve the historic building data in FRPP, in conjunction with GSA
              efforts under way to improve FRPP data on all federal buildings, would
              better equip stakeholders to make decisions about where to direct limited




              105
                Exec. Order 13327, 69 Fed. Reg. 5897 (Feb. 6, 2004).
              106
                GAO-12-645.




              Page 35                                                  GAO-13-35 Federal Real Property
                     federal resources for historic preservation and foster greater
                     accountability and transparency.


                     We recommend that the Acting Administrator of GSA—in collaboration
Recommendation for   and consultation with ACHP, NPS, VA, and FRPC member agencies—
Executive Action     ensure that the action plan being developed to improve FRPP data
                     includes actions to improve historic-building data by addressing the
                     following areas, at a minimum:

                        determining whether changes are needed—to historic data elements
                         or guidance—to ensure that data are consistently and accurately
                         reported;
                        developing, in FRPP fiscal-year summary reports, data that will better
                         convey to the public and stakeholders—including OMB and
                         Congress—a sense of the extent of historic buildings held by
                         agencies, such as total numbers or percentages; and,
                        facilitating ACHP’s access to FRPP data, as appropriate, so that
                         ACHP can better fulfill its historic-building advisory role to Congress
                         and the President.

                     We provided a draft of this report to GSA, the Department of the Interior,
Agency Comments      VA, and ACHP for review and comment.
and Our Evaluation
                     GSA agreed with our recommendation and further reported that it has, in
                     part, already taken action to rectify inconsistencies we found between
                     GSA’s FRPP data and its internal data sources used for NHPA
                     compliance and reporting required by Executive Order 13287. GSA also
                     indicated it will: (1) assess and determine whether changes are needed to
                     the FRPP historic status data element and guidance; (2) provide future
                     data on historic buildings within GSA’s FRPP fiscal-year summary
                     reports; and, (3) work with ACHP by sharing FRPP data and reports, as
                     appropriate. GSA’s response is reprinted in appendix III.

                     The Department of the Interior and VA provided technical comments,
                     which we incorporated as appropriate.

                     In commenting on our draft, ACHP said this report provides a useful
                     analysis of these agencies’ programs and their stewardship of historic
                     buildings. However, ACHP emphasized that the greatest challenge facing
                     agencies’ federal buildings—irrespective of historic status—is that their
                     buildings have not been maintained because of agencies’ decisions to



                     Page 36                                          GAO-13-35 Federal Real Property
defer maintenance. While we understand ACHP’s perspective, our
assessment pointed to budgetary limitations as a challenge that can
cause agencies to defer maintenance on historic buildings. Nonetheless,
in recognition of ACHP’s comment, we have included a reference to
GAO’s past reporting on agencies’ deferred maintenance backlogs for
federal buildings and have noted the link between budgetary limitations
and deferred maintenance, in the report. It is also important to note that,
in addition to budgetary limitations, as discussed in the report, the
agencies face challenges in adapting some historic buildings to meet
contemporary needs and in involving stakeholders on proposals—such as
building reuse and demolition plans—that may adversely affect a historic
building. ACHP’s response is reprinted in appendix IV. ACHP also
provided technical comments, which we incorporated as appropriate.


As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from the
report date. At that time, we will send copies to the Acting Administrator of
GSA, the Secretaries of the Interior and VA, and the Executive Director of
ACHP. Additional copies will be sent to interested congressional
committees. We will also make copies available to others upon request,
and the report is available at no charge on the GAO website at
http://www.gao.gov.

If you have any questions about this report, please contact me at
(202) 512-2834 or wised@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. Major contributors to this report are listed in appendix V.

Sincerely yours,




David J. Wise
Director
Physical Infrastructure Issues




Page 37                                          GAO-13-35 Federal Real Property
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology



Methodology

              Our objectives were to identify (1) actions selected nondefense agencies
              have taken to manage historic federal buildings, and (2) any challenges
              they have faced. We identified three agencies for our review: (1) the
              General Services Administration (GSA); (2) the National Park Service
              (NPS) within the Department of the Interior; and (3) the Department of
              Veterans Affairs (VA). We selected GSA, in part, because it is the federal
              government’s principal real property steward for many federal agencies.
              In addition, GSA was selected because it also maintains the Federal Real
              Property Profile (FRPP) database that is used to identify and report on
              federal real property, to include the historic status of federal buildings,
              held by executive branch agencies. We selected NPS, in part, because it
              is responsible for the stewardship of most of the Department of the
              Interior’s historic buildings, many of which reside within the nation’s
              national historic parks, districts, and sites. In addition, we selected NPS
              because it establishes and manages the nation’s historic preservation
              standards such as the Secretary of the Interior’s: (1) Standards for the
              Treatment of Historic Properties with Guidelines for Preserving,
              Rehabilitating, Restoring, and Reconstructing Historic Buildings; (2)
              Standards for Rehabilitation & Illustrated Guidelines on Sustainability for
              Rehabilitating Historic Buildings; and (3) Standards and Guidelines for
              Federal Agency Historic Preservation Programs Pursuant to the National
              Historic Preservation Act. In addition, on behalf of the Secretary of the
              Interior, NPS manages the National Register of Historic Places, the
              nation’s official list of historic places, both publically and privately held.
              Lastly, we sought and received recommendations from the Advisory
              Council on Historic Preservation (ACHP)1 on a third federal agency to add
              to our review. Based on recommendations received from ACHP and our
              judgment and knowledge of the inventories of the agencies
              recommended, we selected VA because it is the steward for the nation’s
              historic veterans’ hospitals and many of its buildings are over 50 years
              old. In finalizing our selection, we estimated that the federally owned
              building portfolios of the three non-defense agencies encompassed over
              33,500 buildings, including at least 10,000 identified historic buildings
              (based on our preliminary review of those agencies’ FRPP 2010 fiscal
              year data) and that these agencies’ real property portfolios would provide




              1
               ACHP is an independent federal agency that advises the President and Congress on
              national historic preservation policy and federal agencies’ preservation programs.




              Page 38                                                GAO-13-35 Federal Real Property
Appendix I: Objectives, Scope, and
Methodology




a diverse range of building types including office buildings, courthouses,
park facilities, museums, and hospitals.2

To understand the issues and requirements related to federal historic
preservation, we reviewed relevant laws, regulations, and executive
orders governing how agencies should identify, report, and manage
historic buildings in their portfolios. We reviewed NHPA and its
implementing regulations as well as the following executive orders: (1)
Executive Order 13287, entitled Preserve America; (2) Executive Order
13327, entitled Federal Real Property Asset Management; and (3)
Executive Order 13514, entitled Federal Leadership in Environmental,
Energy, and Economic Performance. Executive Order 13514 requires
agencies, among a number of initiatives, to improve the sustainable
performance of their existing buildings and ensure that all new
construction, major renovation, or repair and alteration of federal buildings
complies with the Guiding Principles for Federal Leadership in High
Performance and Sustainable Buildings (Guiding Principles). We
reviewed those Guiding Principles, as well as ACHP’s sustainability
guidance to federal agencies entitled Sustainability and Historic Federal
Buildings, and The Secretary of the Interior’s Illustrated Guidelines on
Sustainability for Rehabilitating Historic Buildings. In addition, we
reviewed the aforementioned federal standards and guidelines on historic
preservation managed by NPS on behalf of the Secretary of the Interior.
We also reviewed past GAO reports on federal real property.

To understand the challenges faced by agencies in managing their
historic buildings and to identify agencies’ portfolio-wide efforts to


2
  Statement of Federal Financial Accounting Standards No. 29 requires agencies to report
information about “heritage assets and stewardship land”—to include their condition and
the number of “physical units” added or withdrawn in the fiscal year—in their annual
financial reports. The federal financial accounting standard indicates that the reporting
categorization of physical units may be determined by the agency based on its mission,
types of heritage assets, and how it manages the assets. We found, GSA has categorized
its historic buildings as its heritage assets. The Department of the Interior—including
NPS—reporting of heritage assets—includes many broader unit categories such as, but
not limited to, national historic landmarks, national historic sites, national historic parks,
national seashores, and national wildlife refuges. VA’s reporting of heritage assets
consists of six unit categories to include (1) art collections; (2) buildings and structures; (3)
monuments and historic flag poles; (4) other non-structure items (such as a historic gate);
and (5) archaeological sites; and (6) cemeteries. Because the standard allows agencies
wide latitude on defining categorical reporting units, we did not examine the extent
agencies’ reporting on their heritage assets was fully reflective of the historic buildings
they hold.




Page 39                                                       GAO-13-35 Federal Real Property
Appendix I: Objectives, Scope, and
Methodology




preserve their historic buildings, we interviewed our selected agencies’
real property and preservation officials about their agencies’ preservation
programs. We also reviewed agencies’ fiscal year 2013 budget requests,
but we did not independently verify agencies’ fiscal year 2013 budget
requirements. To gather detailed examples of selected agencies’ actions
to manage historic buildings, we visited a nonprobability sample3 of 31
federally owned historic buildings held by GSA, NPS, and VA, in five
metropolitan areas: (1) Boston, Massachusetts; (2) Chicago, Illinois; (3)
Milwaukee, Wisconsin; (4) San Francisco, California; and (5) Washington,
D.C.-Baltimore, Maryland. We selected buildings to visit based on a
combination of input received from agencies’ preservation officials,
ACHP, state historic preservation officers, and our own judgment as
informed by our review of selected agencies’ preservation documents and
their FRPP submissions. This approach yielded a diverse group of
buildings in terms of use, age, size, and condition that provided illustrative
examples of agencies’ broader policy initiatives and specific preservation
and sustainability projects.

Prior to our site visits, we reviewed selected agencies’ documentation on
recent, current, or planned efforts to manage those historic buildings. To
the extent documents were available, we requested and reviewed
National Register nomination forms, facility condition assessments,
historic structure reports, and sustainability scorecards for buildings we
visited. In preparation for our visits, we also provided agency officials
knowledgeable about our selected nonprobability sample of buildings with
a series of questions, and asked for written responses, regarding their
historic preservation, maintenance and repair, and sustainable
improvements, if any. For example, we inquired about the current building
condition and asked the officials to identify specific major renovation,
rehabilitation, or sustainability projects that were undertaken in the
buildings within the last 3 fiscal years, if any. While we reviewed projects
that were in-process or recently completed in those buildings, we did not
review the extent projects were within scope, cost, and schedule. We also
inquired about agencies’ progress in meeting government-wide
sustainable Guiding Principles for their existing buildings, and specifically
if the buildings currently met the Guiding Principles. We also conducted a
literature review about historic preservation and sustainability. Finally, to



3
 Because this is a non-probability sample, observations from these site visits do not
support generalizations about other properties.




Page 40                                                    GAO-13-35 Federal Real Property
Appendix I: Objectives, Scope, and
Methodology




better understand the challenges that agencies may face, we spoke with
three experts with academic or professional expertise in improving the
sustainable performance of historic buildings. We selected these experts
based on a combination of input received from the selected agencies’
preservation officials, ACHP, and our own judgment as informed by our
literature search.

To determine whether FRPP could be used to reliably identify the
historical status of selected agencies’ federally owned buildings and the
numbers of historic buildings held by those agencies, we reviewed GSA’s
annual FRPP reporting guidance to executive branch agencies on how to
report their historic buildings. We also obtained and analyzed selected
agencies’ FRPP data submissions for fiscal year 2011, and other real
property data such as agencies’ past and current Preserve America
reports submitted to ACHP about the agencies’ historic buildings and their
efforts to preserve those buildings. We also interviewed agency officials
about data and reviewed FRPP guidance and other documents related to
the agencies’ real property data and FRPP database. In the case of GSA
and NPS—which maintain separate historic building databases in addition
to their respective agencies’ real property databases—we obtained and
reviewed data from those agencies respective historic buildings
databases about the historic status of their buildings and compared it with
data agencies reported to FRPP and in their reports to ACHP.

We conducted this performance audit from November 2011 to December
2012 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.




Page 41                                         GAO-13-35 Federal Real Property
Appendix II: List of 31 Federal Historic
                                             Appendix II: List of 31 Federal Historic
                                             Buildings Where GAO Conducted Site Visits



Buildings Where GAO Conducted Site Visits

Table 2: List of 31 Federal Historic Buildings Visited during Site Visits

Agency      Building Name                                                                            City              State
GSA         John W. McCormack Post Office and Courthouse                                             Boston            MA
GSA         John F. Kennedy (JFK) Federal Building                                                   Boston            MA
VA          Bedford VA Medical Center - Main Infirmary Building (Building #2)                        Bedford           MA
VA          Bedford VA Medical Center - Main Administrative Building (Building #1)                   Bedford           MA
NPS         John F. Kennedy National Historic Site                                                   Brookline         MA
NPS         Longfellow-Washington’s Headquarters National Historic Site                              Cambridge         MA
NPS         Frederick Law Olmsted National Historic Site                                             Brookline         MA
NPS         Lowell National Historic Park - Boott Mill #6                                            Lowell            MA
NPS         Lowell National Historic Park - Old City Hall                                            Lowell            MA
GSA         Federal Building, 50 United Nations Plaza                                                San Francisco     CA
GSA         James R. Browning U.S. Courthouse                                                        San Francisco     CA
VA          San Francisco VA Medical Center - Building #1                                            San Francisco     CA
VA          San Francisco VA Medical Center - Building #18                                           San Francisco     CA
NPS         San Francisco Maritime National Historical Park - Aquatic Park Bathhouse (Maritime       San Francisco     CA
            Museum)
NPS         Golden Gate National Recreation Area- Fort Mason – Headquarters Building 201             San Francisco     CA
NPS         Golden Gate National Recreation Area- Fort Mason - Pier #2 Shed                          San Francisco     CA
NPS         Golden Gate National Recreation Area- Fort Baker - Building 601                          San Francisco     CA
NPS         Golden Gate National Recreation Area- Fort Baker - Building 605                          San Francisco     CA
GSA         Chicago Federal Building, 536 South Clark Street                                         Chicago           IL
GSA         U.S. Post Office Loop Station                                                            Chicago           IL
GSA         10 West Jackson Building                                                                 Chicago           IL
VA          Clement J. Zablocki VA Medical Center – “Old Main” hospital building (Building #2)       Milwaukee         WI
VA          Clement J. Zablocki VA Medical Center - Building #6                                      Milwaukee         WI
GSA         Federal Building and U.S. Courthouse                                                     Milwaukee         WI
GSA         General Services Administration Building                                                 Washington        D.C.
GSA         Stewart Lee Udall Department of the Interior Building                                    Washington        D.C.
NPS         Fort McHenry National Monument and Historic Shrine                                       Baltimore         MD
            Commanding Officer’s Quarters (Building A)
NPS         Fort McHenry National Monument and Historic Shrine                                       Baltimore         MD
            Enlisted Men’s Barracks (Building E)
NPS         Hampton National Historic Site                                                           Towson            MD
VA          Perry Point VA Medical Center - Historic Mansion (Building 501)                          Perry Point       MD
VA          Perry Point VA Medical Center - Old Grist Mill (Building 504)                            Perry Point       MD
                                             Source: GAO.




                                             Page 42                                             GAO-13-35 Federal Real Property
Appendix III: Comments from the General
              Appendix III: Comments from the General
              Services Administration



Services Administration




              Page 43                                   GAO-13-35 Federal Real Property
Appendix III: Comments from the General
Services Administration




Page 44                                   GAO-13-35 Federal Real Property
Appendix III: Comments from the General
Services Administration




Page 45                                   GAO-13-35 Federal Real Property
Appendix III: Comments from the General
Services Administration




Page 46                                   GAO-13-35 Federal Real Property
Appendix IV: Comments from the Advisory
             Appendix IV: Comments from the Advisory
             Council on Historic Preservation



Council on Historic Preservation




             Page 47                                   GAO-13-35 Federal Real Property
Appendix V: GAO Contact and Staff
                  Appendix V: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  David Wise, (202) 512-2834 or wised@gao.gov
GAO Contact
                  In addition to the individuals named above, other key contributors to this
Staff             report were David Sausville, Assistant Director; John Bauckman, Analyst-
Acknowledgments   in-Charge; Lindsay Bach; Leia Dickerson; Colin Fallon; Catherine Kim;
                  Hannah Laufe, Joshua Ormond; Crystal Wesco; and Elizabeth Wood.




(542197)
                  Page 48                                        GAO-13-35 Federal Real Property
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