FEDERAL BUREAU 

OF INVESTIGATION 

Actions Needed to 

Document Security 

Decisions and Address 

Issues with Condition 

of Headquarters 

Buildings 

Report to Congressional Committees

November 2011 

GAO-12-96 

United States Government Accountability Office

GAO 
 United States Government Accountability Office 

Accountability • Integrity • Reliability 

Highlights of GAO-12-96, a report to 

congressional committees 

November 2011 

FEDERAL BUREAU OF INVESTIGATION 

Actions Needed to Document Security Decisions and 

Address Issues with Condition of Headquarters 

Buildings 

Why GAO Did This Study 

Since September 11, 2001, the 

Federal Bureau of Investigation’s (FBI) 

mission and workforce have expanded, 

and the FBI has outgrown its aging 

headquarters, the J. Edgar Hoover 

Building (Hoover Building). As a result, 

the FBI also operates in over 40 

annexes, the majority located in the 

National Capital Region. In the 

explanatory statement accompanying 

the 2009 Omnibus Appropriations Act, 

GAO was directed to examine the 

FBI’s headquarters facilities. In 

response, GAO examined the extent to 

which (1) these facilities support the 

FBI’s security, space, and building 

condition requirements and (2) the FBI 

and the General Services 

Administration (GSA)—the real 

property steward for the Hoover 

Building—have followed leading capital 

decision-making practices in identifying 

alternatives for meeting the FBI’s 

facility needs. GAO reviewed security, 

space, and condition assessments and 

planning studies; visited FBI facilities; 

and interviewed FBI and GSA officials. 

What GAO Recommends 

The FBI should document decisions 

about, and track its implementation 

of, all security recommendations for 

the Hoover Building and the FBI’s 

headquarters annexes. GSA should 

reassess its decision to limit 

recapitalization investments in the 

Hoover Building, since the FBI is 

likely to stay in it for several more 

years while its long-term facility 

needs are being planned. The FBI 

agreed with these recommendations. 

GSA indicated it is working to 

implement GAO’s recommendation. 

What GAO Found 

According to FBI and GSA assessments, the FBI’s headquarters facilities—the 

Hoover Building and the headquarters annexes—do not fully support the FBI’s 

long-term security, space, and building condition requirements. The FBI has 

addressed many security concerns at the Hoover Building by implementing 

protective measures. Furthermore, in response to a recommendation GAO made 

in a law enforcement sensitive version of this report issued in July 2011, the FBI 

has updated its security assessment of the Hoover Building in accordance with 

security standards issued in 2010. The assessment includes recommendations 

but does not indicate whether recommended actions will be implemented. While 

this is reasonable given the short period of time since GAO’s July 2011 report, 

documentation of decisions on the recommendations and tracking 

implementation is important because of facility planning and budget 

implications—for both the Hoover Building and a new headquarters—and time 

needed to coordinate with GSA. FBI officials told GAO that the annexes will be 

assessed against the 2010 security standards. The officials noted, though, that 

the dispersion of staff in annexes creates security challenges. The Hoover 

Building’s original design is inefficient, according to GSA assessments, making it 

difficult to reconfigure space to promote staff collaboration. Staff dispersion 

across annexes likewise hampers collaboration and the performance of some 

classified work. Furthermore, the condition of the Hoover Building is 

deteriorating, and GSA assessments have identified significant recapitalization 

needs. However, GSA has decided to limit investments in the Hoover Building to 

those necessary to protect health and safety and keep building systems 

functioning while GSA assesses the FBI’s facility needs. This decision increases 

the potential for building system failures and disruption to the FBI’s operations. 

Through studies conducted over the past decade, the FBI and GSA have 

considered three broad alternatives, each with variations, to try to meet the FBI’s 

facility needs—(1) modernize the Hoover Building, (2) demolish the Hoover 

Building and construct a new headquarters on the existing site, and (3) acquire a 

new headquarters on a new site. In doing so, the FBI and GSA thus far have 

generally followed leading practices for capital decision making. To varying 

degrees, these alternatives would improve security, space, and building 

conditions, but each would take several years to implement. Estimates of the 

alternatives’ costs, developed in the studies, are not comparable because they 

were prepared at different times and for different purposes. The FBI and GSA 

plan to discuss the FBI’s facility needs with the Office of Management and 

Budget, and GSA and the FBI will need to present a business case, including 

current, comparable cost estimates, to support the choice of a preferred 

alternative and financing strategy. The FBI’s 2011 security assessment of the 

Hoover Building, as well as information on any security improvements that may 

be needed at the annexes, could inform the agencies’ decisions and help ensure 

that limited budgetary resources are allocated effectively. 

This is a public version of a law enforcement sensitive report that GAO issued in 

July 2011, which has been updated, including a modification to a 

recommendation, to reflect recent FBI actions. Information that the FBI and the 

Department of Homeland Security deemed sensitive has been omitted. 

View GAO-12-96. For more information, 

contact David C. Maurer at (202) 512-9627 or 

maurerd@gao.gov or David J. Wise at 

(202) 512-2834 or wised@gao.gov. 
Page i GAO-12-96 Federal Bureau of Investigation 

Letter 1 

Background 5

FBI Headquarters Facilities Present Security, Space, and Condition 

Challenges 11

Consistent with Leading Practices Thus Far, the FBI and GSA Have 

Identified Alternatives for Better Meeting the FBI’s Facility 

Needs and Are Developing an Approach for Moving Forward 24

Conclusions 34

Recommendations for Executive Action 35

Agency Comments and Our Evaluation 36

Appendix I Objectives, Scope, and Methodology 38 

Appendix II FBI and GSA Studies Related to FBI Headquarters Planning 42 

Appendix III Financing Strategies Available for Capital Projects 50 

Appendix IV Comments from the Federal Bureau of Investigation 53 

Appendix V Comments from the General Services Administration 55 

Appendix VI Comments from the Department of Homeland Security 57 

Appendix VII GAO Contacts and Staff Acknowledgments 59

Figures 

Figure 1: J. Edgar Hoover Building Facing Pennsylvania Avenue 

and 10th Street 6

Contents 
Page ii GAO-12-96 Federal Bureau of Investigation 

Figure 2: Map Showing the J. Edgar Hoover Building and 

Surrounding Streets 7

Figure 3: Design Features That Limit the Hoover Building’s 

Efficiency 18

Figure 4: Conditions GAO Observed at the Hoover Building 22

Figure 5: Timeline of FBI and GSA Studies of FBI Facility 

Requirements 25

Figure 6: The Baseline Status Quo and Alternative 1 Consider 

Continued Use of the Hoover Building 29

Figure 7: Alternatives 2 and 3 Consider New Construction on the 

Existing Hoover Site or a New Site 30

Abbreviations 

DHS Department of Homeland Security 

FBF Federal Buildings Fund 

FBI Federal Bureau of Investigation 

FPS Federal Protective Service 

FSL facility security level 

GSA General Services Administration 

ISC Interagency Security Committee 

LEED Leadership in Energy and Environmental Design 

NCPC National Capital Planning Commission 

OMB Office of Management and Budget 

SCIF sensitive compartmented information facility 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately. 
Page 1 GAO-12-96 Federal Bureau of Investigation 

United States Government Accountability Office

Washington, DC 20548 

November 8, 2011 

The Honorable Barbara A. Mikulski 

Chairwoman 

The Honorable Kay Bailey Hutchison 

Ranking Member 

Subcommittee on Commerce, Justice, 

 Science and Related Agencies 

Committee on Appropriations 

United States Senate 

The Honorable Frank Wolf 

Chairman 

The Honorable Chaka Fattah 

Ranking Member 

Subcommittee on Commerce, Justice, 

 Science and Related Agencies 

Committee on Appropriations 

House of Representatives 

The Federal Bureau of Investigation (FBI), within the Department of 

Justice, acts to protect and defend the United States against crime, 

terrorism, and foreign intelligence threats. Since September 11, 2001, the 

FBI’s antiterrorism mission has greatly expanded and its efforts in other 

areas—such as cyber crime—have also grown. The agency’s total 

headquarters workforce has increased by approximately 5 percent 

annually since 2001. As a result, the FBI has outgrown its main 

headquarters facility, the J. Edgar Hoover Building (Hoover Building) in 

Washington, D.C. Headquarters staff who cannot be accommodated in 

the Hoover Building are dispersed in over 40 leased annexes (annexes), 

the majority of which are located in the National Capital Region. FBI 

officials report that the dispersion of staff, combined with condition 

deficiencies at the Hoover Building and site, affects security and creates 

operational inefficiencies. In addition, these security, space, and building 

condition issues have raised congressional concerns about how well the 

Hoover Building and annexes meet the FBI’s security requirements and 

operational needs. In its 2005 Asset Management Plan, the FBI identified 

the need for a new headquarters facility to support its strategic objectives, 

which include providing security for personnel and information in an 

efficient and cost-effective workspace. To meet these objectives, the FBI 

has taken steps to document its headquarters facility requirements and, in 

collaboration with the General Services Administration (GSA), the 

 
 

Page 2 GAO-12-96 Federal Bureau of Investigation 

government’s real property steward, has studied a number of alternatives 

for meeting its needs. 

Congress directed us, in the explanatory statement accompanying the 

2009 Omnibus Appropriations Act,1

 to review the Hoover Building and 

associated off-site locations in light of its concerns about the security 

posture of the Hoover Building and its inability to house the current FBI 

Headquarters workforce. We examined (1) the extent to which the 

Hoover Building and annexes support the FBI’s operational requirements 

for security, space, and building condition and (2) the extent to which the 

FBI and GSA have followed leading capital decision-making practices in 

identifying alternatives for meeting the FBI’s operational requirements and 

the extent to which each alternative would address these requirements. 

This report is a public version of a law enforcement sensitive report that 

we issued in July 2011. It communicates the publicly releasable aspects 

of our findings while omitting information that the FBI and DHS 

considered sensitive about the FBI’s operations, the security posture of 

the FBI’s facilities, and measures the FBI has put in place to protect its 

workforce. The overall methodology used for both reports is the same. 

To determine the extent to which the Hoover Building and annexes 

support the FBI’s operational requirements for security, space, and 

building condition, we visited the Hoover Building and five annexes—

which we selected to illustrate different facility security levels and degrees 

of staff fragmentation—to examine conditions firsthand and interview onsite representatives from FBI divisions (programs) and security officials 

about those conditions. More specifically: 

 For security, we compared past site-specific facility security 

assessments (security assessments) for the Hoover Building and 15 

of the annexes to federal security standards. For the Hoover Building, 

we also assessed whether recommendations to improve security were 

implemented. We spoke with agency security officials about the 

security assessments, risks, and challenges resulting from dispersed 

operations. Following our issuance of the law enforcement sensitive 

 

1

Explanatory statement in the 2009 Committee Print of the House Committee on 

Appropriations on H.R. 1105, at 1764 accompanying the 2009 Omnibus Appropriations 

Act, Pub. L. No. 111-8, Div. B, Title II, 123 Stat. 524, 574 (2009). 
 

Page 3 GAO-12-96 Federal Bureau of Investigation 

version of this report in July 2011, the FBI updated its security 

assessment of the Hoover Building, which we reviewed. 

 For space, we reviewed the size and location of current facilities and 

programs, and we interviewed FBI program officials to understand the 

effects on operations of having different programs housed in several 

locations. We also compared attributes of the Hoover Building—such 

as its efficiency (how much of its space is usable for mission needs)—

to GSA standards and guidance. 

 For building condition,2 we analyzed assessments of the Hoover 

Building’s physical condition and compared this information to GSA 

policies for building condition. In addition, we examined GSA’s asset 

business plan for the building3

 and other studies to identify completed 

maintenance projects, deferred maintenance, and planned major 

repair and recapitalization projects, and we asked FBI and GSA 

officials about their assessments of the Hoover Building’s condition.4

To determine the extent to which the FBI and GSA have followed leading 

capital decision-making practices in identifying alternatives for meeting 

the FBI’s operational requirements, we compared the FBI’s and GSA’s 

planning actions against leading practices we have reported on in this 

 

2

GAO has reported that buildings require adequate maintenance, repair, and 

recapitalization—replacing systems at the end of their useful life—to keep them in good 

condition. See GAO, Federal Real Property: Government’s Fiscal Exposure from Repair 

and Maintenance Backlogs Is Unclear, GAO-09-10 (Washington, D.C.: Oct. 16, 2008). 

3

An asset business plan is a repository for critical facts about a GSA asset and is used to 

guide business decisions and to track the asset’s financial performance and progress 

toward mandated building performance criteria. 

4

Since 1994, GSA has delegated routine maintenance and operations authority for the 

Hoover Building to the FBI, but GSA retains responsibility for major capital repair and 

replacement projects in the building. One of GSA’s objectives as the government’s real 

property steward is that the physical condition of federal buildings will be maintained to 

reflect market standards. In general, the responsibility for maintenance and repair of the 

annexes resides with the building landlord, and therefore we did not assess the physical 

condition of annex spaces. 
 

Page 4 GAO-12-96 Federal Bureau of Investigation 

area.5 In addition, we reviewed FBI and GSA studies of the FBI’s facilities 

and operational requirements and identified the alternatives discussed in 

these studies for meeting the requirements. We determined that the 

alternatives fell into three broad categories—(1) modernize the Hoover 

Building, (2) demolish the Hoover Building and construct a new 

headquarters on the existing site, and (3) construct a new headquarters 

on a new site—each of which included a number of variations. For our 

analysis, we focused on the categories, since the appropriateness of the 

variations could not be determined without further study and would 

depend on site-specific conditions. We then assessed the extent to which 

each alternative would address the FBI’s security, space, and building 

condition requirements. 

We did not independently analyze the FBI’s requirements for security, 

which are based on its assessments of the threats it faces and their 

probability of occurrence; its requirements for space, which are based on 

its projections of each FBI program’s future staffing and space needs, 

such as the need for secure conference rooms; or its process for deciding 

which programs to house in a new consolidated facility. In our view, such 

analyses were outside the scope of our review and would require 

extensive reviews of classified intelligence on threats and hostile groups, 

as well as of programmatic mission justifications for FBI branches and 

their associated staffing levels. We did, however, determine that the FBI 

senior leadership was involved in deciding which FBI programs should be 

colocated. Furthermore, because the FBI and GSA are still in the early 

stages of the facility planning process and had not finalized cost 

estimates for budgetary purposes at the time of our review, we did not 

validate cost estimates for new construction or past cost estimates for 

modernizing or redeveloping the Hoover Building and site. Appendix I 

contains a more detailed discussion of our scope and methodology. 

We conducted this performance audit from July 2010 to November 2011, 

in accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

 

5

Our assessment was based on past GAO work, including Executive Guide: Leading 

Practices in Capital Decision-Making, GAO/AIMD-99-32 (Washington, D.C.: Dec. 1, 1998); 

Public-Private Partnerships: Factors to Consider When Deliberating Governmental Use as 

a Real Property Management Tool, GAO-02-46T (Washington, D.C.: Oct. 1, 2001); and 

Budget Issues: Alternative Approaches to Finance Federal Capital, GAO-03-1011 

(Washington, D.C.: Aug. 21, 2003). 
 

Page 5 GAO-12-96 Federal Bureau of Investigation 

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. 

In 1964, the National Capital Planning Commission (NCPC) approved the 

design concept for FBI headquarters. Construction started in 1967, and in 

1974, FBI personnel began moving into the new building, which was 

named for the FBI’s first director, J. Edgar Hoover (see fig. 1). Situated on 

one entire city block in downtown Washington, D.C., and containing 

approximately 2.4 million gross square feet of space, the building is 

bounded by four major city streets—9th, 10th, and E Streets and 

Pennsylvania Avenue—all of which are open to public traffic (see fig. 2). 

The building is a concrete structure, 7 stories high on its Pennsylvania 

Avenue side and 11 stories high on its E Street side. A dry moat6

 protects 

the building in addition to numerous antivehicular barriers. 

 

6

This moat is a trench that helps to limit how close pedestrians and vehicles can get to the 

building and directs access to specific entry points. 

Background 
 

Page 6 GAO-12-96 Federal Bureau of Investigation 

Figure 1: J. Edgar Hoover Building Facing Pennsylvania Avenue and 10th Street 

Source: GSA.
 

Page 7 GAO-12-96 Federal Bureau of Investigation 

Figure 2: Map Showing the J. Edgar Hoover Building and Surrounding Streets 

When the FBI first occupied the Hoover Building, it was primarily a law 

enforcement organization. Since then, its mission has grown in response 

to evolving threats and now includes counterterrorism, 

counterintelligence, weapons of mass destruction deterrence, and cyber 

security. Accordingly, use of the Hoover Building has changed to support 7th Street NW 9th Street NW 12th Street NW

Constitution Ave NW

Pennsylvania Ave NW

E Street NW

D Street NW

Madison Drive NW

8th Street NW

10th Street NW

National Mall

1

50

J. Edgar

Hoover

Building

Source: National Park Service.
 

Page 8 GAO-12-96 Federal Bureau of Investigation 

new programs in these areas. For example, the Hoover Building originally 

housed a crime laboratory, and more space was dedicated to records 

storage. These functions have since been transferred to off-site locations, 

making space available for new programs in the Hoover Building. 

The FBI’s headquarters workforce has grown as the agency has assumed 

new mission responsibilities. In 2001, the FBI had 9,700 headquarters 

staff,7

 working in 7 locations. Today, the FBI has 17,300 headquarters 

staff, including those housed in more than 40 annexes, the majority of 

which are located within the National Capital Region.8

 According to the 

FBI, programs in 21 of these off-site locations and in the Hoover Building 

should be colocated to meet the agency’s mission requirements.9

 In 

projecting its staffing levels from fiscal year 2010 through fiscal year 

2018, the FBI estimated that its headquarters workforce will grow by a 

total of 7 percent during that period. 

The FBI’s headquarters facilities, like all facilities in the United States 

occupied by federal employees for nonmilitary activities, are subject to the 

Interagency Security Committee’s (ISC) baseline facility security 

standards. The ISC, chaired by the Department of Homeland Security 

(DHS) and composed of representatives from all major federal 

departments and agencies, is tasked with coordinating federal agencies’ 

facility protection efforts, developing security standards, and overseeing 

the implementation of security measures.10 In 2004, the ISC issued 

security criteria for federally owned facilities and space leased by 

agencies (hereafter referred to as the 2004 ISC standards),11 establishing 

facility security standards for space owned or leased by the federal 

government. In 2010, the ISC issued new standards that superseded the 

2004 standards. The new security criteria (hereafter referred to as the 

 

7

Staff counts include both federal and contractor positions. 

8

A few FBI headquarters annexes are located outside the National Capital Region. 

9

The other FBI annexes that are not proposed to be colocated house functions such as 

warehousing, records management, continuity of operations, and a van shop. 

10Following the bombing of the Alfred P. Murrah federal building in Oklahoma City, 

Executive Order 12977 was issued and called for the creation of an interagency security 

committee to address the quality and effectiveness of physical security requirements for 

federal facilities by developing and evaluating security standards. 

11ISC, “2004 ISC standards” (Washington, D.C.: 2004). 
 

Page 9 GAO-12-96 Federal Bureau of Investigation 

2010 ISC standards) were intended to make security an integral part of 

the operations, planning, design, construction, renovation, or acquisition 

of federal facilities—whether in owned or leased space.12 The 2010 ISC 

standards establish a baseline set of protective measures 

(countermeasures) to be applied at each facility according to its security 

level and outline a risk management process for agencies to follow as 

they assess the security of their facilities.13

To determine the security level of a federal facility, the ISC uses criteria 

that it issued in 2008. Factors considered in determining the facility 

security level (FSL) include the criticality of an agency’s mission, the 

symbolism of the facility, and the building’s size and population. The 

Hoover Building is categorized at the same FSL applied to the 

headquarters facilities of other agencies with national security missions, 

such as the Central Intelligence Agency and the Department of Defense. 

The FSLs of the FBI’s annexes in the National Capital Region vary. 

In meeting its needs for office space, the FBI generally works through 

GSA, although it has received direct appropriations to construct 

specialized facilities, such as the FBI laboratory and academy training 

facilities,14 and has entered into leases on its own. GSA can use 

government-owned or leased facilities to meet an agency’s space 

needs.15 If a facility is not available to meet the agency’s needs and the 

estimated cost of a new facility exceeds a defined dollar threshold,16 GSA 

can request congressional authorization to construct or lease a new 

 

12ISC, “2010 ISC standards” (Washington, D.C.: 2010). 

13The ISC released its 2010 standards as an interim standard with a 24-month validation 

period. The validation period is intended to allow for user input to inform the final standard. 

14In those instances, the facilities were constructed on a Department of Defense site in 

Quantico, Virginia. 

1540 U.S.C. § 584 provides that the Administrator of General Services may assign or 

reassign space for an executive agency in any federally owned or leased building after 

consultation with the head of the affected agency and a determination by the Administrator 

that the assignment or reassignment is advantageous to the government in terms of 

economy, efficiency, or national security. 

16The fiscal year 2011 threshold for proposed new construction, alterations, and leases 

was $2.79 million. 
 

Page 10 GAO-12-96 Federal Bureau of Investigation 

facility by submitting a project prospectus.17 GSA typically funds new 

federal construction and the acquisition of leased space from the Federal 

Buildings Fund (FBF).18 Agencies occupying GSA-controlled space 

(owned or leased) pay rent to GSA, which GSA deposits into the FBF. 

GSA then pays the landlord from the FBF for those buildings it leases.19

In addition to federal construction or leasing, GSA has the authority to 

enter into a sale-leaseback20 or a ground lease and leaseback21

arrangement through which GSA sells or leases federal land to a 

developer that builds a facility on the site and leases it back to GSA.22 We 

have previously reported that the FBF is not large enough to meet GSA’s 

construction and major repair needs23 and that alternative financing 

 

17A prospectus is a document containing project and cost information that GSA submits to 

the Office of Management and Budget and Congress for approval as part of the 

authorization process for new construction or leasing projects. 

18The FBF is a revolving fund managed by GSA that finances—from rent charged to 

occupants of GSA-controlled space—real property management and related activities of 

GSA’s Public Buildings Service. Principal activities include the operation, maintenance, 

and repair of GSA-owned and -leased buildings and the construction of new federal 

facilities. The FBF also provides for the rental of space in privately owned buildings. In this 

report, we refer to property that is owned by the federal government and under the control 

and custody of GSA as GSA-owned property. 

19If an agency enters into a lease with a private building owner or through another federal 

agency, the agency would pay rent directly to one of those entities and not to GSA. 

20Under a sale-leaseback arrangement, a federal agency sells an asset and then leases 

back some or all of the asset from the purchaser. 

21Under a ground lease and leaseback arrangement, a federal site is leased to a 

developer and a facility is constructed to government specifications and leased back to the 

government. The title to the parcel never leaves government ownership. At the expiration 

of the lease, the title to the building passes to the United States. 

2240 U.S.C. § 585(c) authorizes GSA to lease a federal site to a developer and then pay 

rent for space, for a period of not more than 30 years, in buildings erected on land owned 

by the government. Also, Section 412 of Pub. L. No. 108-447 118, Stat. 2809, 3259, 

enacted in 2004, provides GSA with additional authority to dispose of and use its real 

property by various means, including leaseback arrangements. 

23GAO, Federal Buildings: Funding Repairs and Alterations Has Been a Challenge—

Expanded Financing Tools Needed, GAO-01-452 (Washington, D.C.: Apr. 12, 2001). 
 

Page 11 GAO-12-96 Federal Bureau of Investigation 

strategies may be viable options for GSA to meet agencies’ facilities 

needs.24

GSA has generally provided space in leased facilities for the FBI’s 

expanded headquarters staff. We have also reported that GSA has used 

operating leases extensively to meet agencies’ long-term space needs, 

even though building ownership is generally less costly.25 Both GSA and 

the FBI have generally concluded that the FBI has long-term space needs 

and that its operations should be consolidated to achieve greater security 

and efficiency. Working with GSA, the FBI has studied a number of 

alternatives for consolidation. 

According to FBI officials, the Hoover Building does not meet the FBI’s 

long-term security requirements.26 We found that planning for the FBI’s 

headquarters security requirements has evolved over time. A 2005 GSA 

study and a 2009 FBI study cited different planning assumptions about 

the security requirements for a new FBI headquarters. The 2010 ISC 

standards do not prescribe security requirements for federal facilities like 

the Hoover Building or new facilities that an agency proposes to construct 

or lease. Instead, the 2010 standards indicate that, in establishing 

requirements for existing or new facilities, agencies should determine 

what combination of countermeasures would provide an appropriate level 

of protection against identified threat scenarios that the ISC refers to as 

 

24GAO, Public-Private Partnerships: Pilot Program Needed to Demonstrate the Actual 

Benefits of Using Partnerships, GAO-01-906 (Washington, D.C.: July 25, 2001). In 

addition, Congress may also appropriate moneys from the General Fund of the Treasury 

to the FBF as it deems necessary. 

25GAO, Federal Real Property: Reliance on Costly Leasing to Meet New Space Needs Is 

an Ongoing Problem, GAO-06-136T (Washington, D.C.: Oct. 6, 2005). 

26Our previously issued law enforcement sensitive report contains additional information 

on the security posture of the Hoover Building and the FBI’s security requirements. 

FBI Headquarters 

Facilities Present 

Security, Space, and 

Condition Challenges 

The Hoover Building Does 

Not Meet the FBI’s LongTerm Security 

Requirements 
 

Page 12 GAO-12-96 Federal Bureau of Investigation 

the “design-basis threat.” Furthermore, the 2010 ISC standards indicate 

that whenever an agency-determined threat level deviates from the ISC 

design-basis threat baseline, the factors that influenced the agency’s 

threat assessment must be documented and fully supported by detailed 

information as part of the assessment. 

In addition to the Hoover Building not meeting the FBI’s long-term security 

requirements, FBI security officials told us on our site visits that they have 

some security concerns—to varying degrees—about some of the 

headquarters annexes, including the following: 

 Proximity of non-FBI tenants to FBI employees performing 

sensitive operations. At least nine annexes are located in multitenant 

buildings, where some space is leased by the FBI and other space is 

leased by nonfederal tenants. While this arrangement does not 

automatically put FBI operations at risk, it heightens security concerns. 

 Lack of control over common areas. FBI security officials also cited a 

lack of control over common areas in multitenant buildings. For 

example, at one annex we visited, FBI officials told us that the 

building’s landlord denied the FBI’s request to implement some 

recommended countermeasures made in 2007 and in 2009 by DHS’s 

Federal Protective Service (FPS), which conducts security 

assessments of facilities under the control or custody of GSA. The 

landlord chose not to implement the countermeasures, citing costs and 

concerns about inconveniencing nonfederal tenants in the building.27

 FBI Police response. According to FBI officials, security at the 

annexes is primarily handled by contract guards, local police, or the 

FBI’s internal police force, the FBI Police, depending on the location 

and circumstances. The FBI Police does not physically station its 

personnel at the annexes; rather, it periodically conducts patrols of 

annexes. 

 

27We have previously reported on the challenges associated with protecting leased space 

in facilities with nonfederal tenants, such as the lack of control over common areas like 

building lobbies and elevators. This lack of control stems, in part, from the inability of 

federal tenants to negotiate changes to those areas, such as the installation of X-ray 

machines, because private landlords frequently believe that such countermeasures would 

inconvenience other tenants and the public. See GAO, Building Security: New Federal 

Standards Hold Promise, But Could Be Strengthened to Better Protect Leased Space,

GAO-10-873 (Washington, D.C.: Sept. 22, 2010). 
 

Page 13 GAO-12-96 Federal Bureau of Investigation 

Over the past several years, the FBI has implemented countermeasures 

at the Hoover Building to improve security, including 

 upgrading the building’s exterior windows; 

 moving and upgrading the security of the FBI business visitor center 

so that it now provides internal queuing for identification checks, an Xray screening area, a badge office, and a secure waiting area; 

 strengthening barriers to prevent unauthorized access; 

 installing new doors to the building to meet the FBI’s requirements for 

protection against forced entry; 

 securing air intakes to keep airborne contaminants out of the building; 

and 

 paying the District of Columbia government to restrict public metered 

parking along one side of the building in order to prevent unscreened 

vehicles from parking or idling near the building.

Although the FBI has implemented these countermeasures, others have 

yet to be implemented, and FBI officials did not provide historical 

documentation of the agency’s rationale for not implementing them. FBI 

security officials we spoke with were not part of the earlier decision 

making, but suggested that some past recommendations were not 

implemented because of their high cost and potential impact on 

operations. A 2005 GSA study concluded that some of the 

recommendations would have been costly and disruptive to the FBI’s 

operations within the building. Because FBI officials did not provide 

historical documentation of the FBI’s rationale for not implementing some 

recommendations, it is difficult for us to determine why the FBI and GSA 

did not pursue them. More recently, in 2008, the FBI received approval 

from NCPC for one security project at the Hoover Building, but FBI 

officials reported they were unsuccessful in obtaining funding for the 

project before NCPC’s approval expired. The FBI said it intends to 

resubmit its request for NCPC approval at the end of fiscal year 2011, 

and if the request is approved, it may attempt to obtain funding in fiscal 

year 2012. 

While implementing recommended countermeasures may not always be 

feasible—because of physical limitations or budgetary restrictions, for 

example—the 2010 ISC standards require agencies to document any 

FBI Has Implemented 

Several Countermeasures 

to Improve the Security of 

the Hoover Building 
 

Page 14 GAO-12-96 Federal Bureau of Investigation 

decision to reject or defer the countermeasures’ implementation, including 

whether the agency is willing to accept risk and whether there are any 

alternative strategies to meet the agency’s required level of protection. 

This ISC standard is consistent with a component of our risk management 

framework that calls for agencies to identify and evaluate alternatives to 

mitigate risk, taking into account the alternatives’ likely effect on risk and 

their cost.28 

FBI officials performed a comprehensive security assessment of the 

Hoover Building in 2011 using the 2010 ISC facility security standards. 

This assessment, which the FBI provided to us after we issued our law 

enforcement sensitive version of this report in July 2011, was the FBI’s 

first comprehensive review of the building’s security since 2002, although 

FBI officials told us they had assessed the security of selected portions of 

the building during the interim. For federal buildings under the control or 

custody of GSA, such as the Hoover Building, FPS normally conducts 

periodic security assessments unless the tenant agency waives the 

requirement for FPS to do so. The FBI waived the requirement for FPS to 

conduct security assessments of the Hoover Building, acknowledging that 

it would assume responsibility for conducting the assessments itself. 

However, the FBI did not conduct a comprehensive assessment of the 

Hoover Building from 2002 until 2011 because, according to FBI officials, 

the FBI had concluded that an updated assessment would be unlikely to 

yield new information. 

Under the current ISC standards, agencies are to conduct security 

assessments of their facilities at regular intervals, depending on the 

building’s FSL. The requirement for the Hoover Building is every 3 years. 

The ISC also requires agencies to document their security assessment 

findings in a report, including the threats and vulnerabilities they have 

identified and the specific countermeasures they have recommended 

based on their building’s FSL. Conducting regular security assessments 

is also an important component of one of our key practices in protecting 

federal facilities—allocating resources using a risk management 

approach. This practice emphasizes the need to identify threats and 

 

28GAO, Homeland Security: Further Actions Needed to Coordinate Federal Agencies’ 

Facility Protection Efforts and Promote Key Practices, GAO-05-49 (Washington, D.C.: 

Nov. 30, 2004). 

FBI Recently Performed a 

Comprehensive Security 

Assessment of the Hoover 

Building and Intends to 

Have the Security of Its 

Annexes Assessed against 

the 2010 ISC Standards 
 

Page 15 GAO-12-96 Federal Bureau of Investigation 

assess vulnerabilities in order to develop countermeasures and to 

prioritize the allocation of resources as conditions change.29

In July 2011, we reported that an updated security assessment would 

allow the FBI to fully assess the building against the 2010 ISC standards, 

evaluate if additional security technologies could be implemented, and 

document decisions about whether to implement certain 

recommendations or accept risk going forward. We also noted that an 

updated security assessment would provide the FBI with current 

information to help prioritize its allocation of security-related resources 

across all of its facilities. We recommended that the FBI update the 

Hoover Building’s security assessment using the 2010 ISC standards, 

including (1) documenting threats, (2) analyzing the building security 

requirements, and (3) indicating whether recommendations would be 

implemented. 

Subsequent to our July 2011 law enforcement sensitive report, the FBI 

completed a security assessment of the Hoover Building. This security 

assessment was conducted by the FBI’s Physical Security Unit and 

coordinated with the FBI Police and the FBI’s Facilities and Logistics 

Services Division. FBI security staff evaluated security conditions against 

specific criteria outlined in the 2010 ISC standards. According to our 

analysis, the assessment covered some areas that were not covered in 

the 2002 assessment. Moreover, the assessment documented both the 

security posture of the Hoover Building and the FBI’s building security 

requirements in relation to baseline ISC requirements. Where 

appropriate, the assessment included recommendations, and those 

recommendations were recently forwarded to the FBI’s executive 

management for consideration. Currently, the FBI is in the process of 

determining its response to these recommendations, some of which 

would require capital investments in the building. FBI needs time to make 

final decisions on some recommendations and may need to reach 

agreement with GSA as the federal steward for the building. As the FBI 

determines its response to the recommendations, it is important that it 

document decisions because of their budget implications and effect on 

the planning for its long-term facility needs. 

 

29GAO, Homeland Security: Greater Attention to Key Practices Would Improve the 

Federal Protective Service’s Approach to Facility Protection, GAO-10-142 (Washington, 

D.C.: Oct. 23, 2009). 
 

Page 16 GAO-12-96 Federal Bureau of Investigation 

According to FBI security officials, they were not aware of any 

countermeasures that needed to be implemented at the annexes. 

Although they indicated that they do have security concerns about 

headquarters annexes, such as lack of control over building common 

areas, the officials told us the annexes generally meet the 2004 ISC 

standards for leased space. 

We received security assessments or other security-related information—

from both FPS and the FBI—for most, but not all, of the 21 annexes.30

According to the FBI, it intends to request that FPS assess the annexes’ 

compliance with the 2010 ISC standards when the new standards are 

fully implemented and then evaluate the need for any additional 

countermeasures.31 Tracking the implementation status of all 

countermeasures recommended in FPS or FBI security assessments will 

provide the FBI with complete, current information on any security 

vulnerabilities at its annexes, and help it determine the extent to which the 

annexes meet the 2010 ISC standards and the FBI’s security 

requirements. 

Although the Hoover Building is large, occupying an entire city block, 

much of its approximately 2.4 million gross square feet of space is 

unusable, and the remaining usable space32—according to a 2007 study 

conducted for GSA and the FBI—is not designed to meet the needs of 

today’s FBI.33 According to a 2008 GSA market appraisal of the building, 

its design is inefficient and functionally obsolete.34 According to the FBI, 

 

30For those FBI annexes under the control or custody of GSA, the extent to which FPS 

assesses the security of the building depends on whether the FBI is the sole tenant or one 

of several federal tenants. In cases where the FBI is the sole tenant in the facility, the FBI 

usually signs a waiver stating that the FBI is responsible for conducting its own 

assessments. FPS officials stated that for multitenant buildings, FPS normally assesses 

the security of the facility’s exterior and the common areas within the building, but does 

not enter the office space in which the FBI conducts its operations. 

31See footnote 13. 

32Usable square footage is space that is generally assignable for the tenant’s use, such as 

office space, conference rooms that are not shared, computer server rooms, and tenant 

storage areas. It does not include nonassignable space, such as vertical ducts and public 

elevators and stairs. 

33GSA, “Space study” (unpublished study, 2007). 

34GSA, “Real estate appraisal” (unpublished opinion, 2008). 

The Hoover Building’s 

Design Limits Space 

Efficiencies and Hampers 

Collaboration; Dispersion 

of Staff Causes 

Operational and Logistical 

Challenges 
 

Page 17 GAO-12-96 Federal Bureau of Investigation 

the space is laid out as efficiently as possible, but the original design of 

the building’s floor plates is inefficient.35 For example, the building 

provides a lower percentage of usable square footage for office and 

mission functions than a federal office building built to current design 

standards. In its 2010 facilities standards,36 GSA established a space 

efficiency target of 75 percent for new federal office buildings, based on 

the ratio of usable to gross square footage.37 The Hoover Building’s 

efficiency ratio is 53 percent. Figure 3 illustrates some of the features that 

limit the building’s efficiency. 

 

35A floor plate refers to the entirety of the floor layout, including both the usable space and 

the nonassignable space. The design of the nonassignable space and the size of the 

building elements within that space, such as elevators and stairs, influence the space 

efficiency of the building. 

36GSA, Facilities Standards for the Public Buildings Service (November 2010).

37GSA defines space efficiency as the minimum necessary space for an agency’s desired 

functions to be properly accommodated, with minimum “waste” between usable area and 

gross area. 
 

Page 18 GAO-12-96 Federal Bureau of Investigation 

Figure 3: Design Features That Limit the Hoover Building’s Efficiency 

To accommodate additional staff at the Hoover Building, the FBI has 

reconfigured parts of the building’s interior, including converting about 

200,000 square feet of basement, cafeteria, and storage space to offices. 

Renovations were implemented reactively as the agency’s mission grew. 

Some areas could not be renovated as open spaces, as desired, because 

the building’s original design hampered such changes. While converting 

building support space has provided the FBI with some additional offices 

in the Hoover Building, GSA’s facility condition assessment38 indicates 

that those offices may not be adequately ventilated and cooled. As a 

result, some space may provide an uncomfortable working environment 

for staff. GSA has a project planned to address ventilation requirements. 

While the project was proposed as early as 2004, we found that GSA has 

been unable to get the design approvals needed to implement the 

 

38GSA, “Building evaluation” (unpublished study, 2011). 

9th Street

Pennsylvania Ave

E Street

10th Street

Pennsylvania

Ave

10th Street

P

th Street

Street

ylvan

9t

E S

Source: GAO analysis of a GSA-commissioned space effectiveness study and GSA facility design standards.

e

Courtyard results in some 

interior space being 

allocated to long, inefficient 

corridors, limiting circulation 

within the building. 

Building structural 

elements—such as 

load-bearing columns and 

trusses associated with 

cantilevered upper 

stories—limit opportunities to 

reconfigure interior spaces and 

convert some closed office 

areas to open space.

Work areas are too 

deep—from the windows to 

the building core area—which 

limits access to natural 

daylight. Today’s federal 

construction standards 

advocate access to daylight as 

a means of improving energy 

and environmental efficiency. 

Open-air second level is not 

usable for office space. 
 

Page 19 GAO-12-96 Federal Bureau of Investigation 

project.39 FBI officials we spoke with also indicated that the building lost 

some functionality—for example, they said less space was available for 

meetings—after those spaces were converted to offices to accommodate 

the agency’s rapid growth. 

The FBI and GSA have concluded that the Hoover Building’s interior 

design remains a significant barrier to staff collaboration and information 

sharing across teams.40 Furthermore, GSA has concluded that the 

building’s structure constrains further increases in its efficiency.41 For 

example, a 2007 study for GSA and the FBI found that the Hoover 

Building’s long corridors and closed office suites result in significant 

fragmentation among working groups that hampers communication and 

collaboration and that the building’s inflexible design is incompatible with 

changing mission needs. FBI officials told us that whereas newer office 

buildings with modular designs can be quickly and cost-efficiently 

reconfigured to accommodate new missions or staff growth, the Hoover 

Building would likely require months of modernization work to achieve 

similar results.42 According to senior FBI and GSA officials, space 

restrictions at the Hoover Building limit the FBI’s ability to meet two GSA 

workplace goals for the next decade—to improve collaboration and 

communication and to make more efficient use of space.43

Because the Hoover Building cannot readily be modified to accommodate 

new mission needs and staff growth, and because core headquarters 

 

39In 2007, the Commission of Fine Arts requested that GSA revise the proposed design to 

address the commission’s concerns about proposed architectural details. Established in 

1910 by an act of Congress, the commission reviews and approves designs for buildings 

erected by the federal government in the nation’s capital. 

40GSA, “Space study” (2007). 

41FBI space-programming studies show that if the FBI were to consolidate into more 

efficient, modern space, it would need approximately 2.2 million rentable square feet 

compared with the 3.1 million rentable square feet that it occupies today in the Hoover 

Building and 21 off-site annexes. 

42At one location we visited, where the FBI leases space from another intelligence 

agency, FBI officials identified “smart walls” that can easily be modified to meet new task 

forces’ operational and security requirements. For example, one official said that the FBI 

transformed a conference room area into secure office space for 15 workstations within a 

week. 

43GSA, The New Federal Workplace: A Report on the Performance of Six Workplace 

20-20 Projects (Washington, D.C.: June 2009). 
 

Page 20 GAO-12-96 Federal Bureau of Investigation 

staff are therefore dispersed among multiple annexes, the FBI now faces 

several operational and logistical challenges. According to FBI officials, 

space constraints at the Hoover Building and the resulting dispersion of 

staff sometimes prevent the FBI from physically locating certain types of 

analysts and specialists together. For example, according to an FBI 

report, one FBI division within the Hoover Building is not able to embed 

analysts within other offices—to facilitate greater collaboration—because 

of the lack of available space. During our site visits, FBI officials reported 

logistical challenges as well, including a lack of facilities at a few annexes 

for discussing some classified information, known as sensitive 

compartmented information facilities (SCIF). As a result, some FBI 

personnel told us they have to travel to meetings in different locations 

across the National Capital Region, resulting in inefficient use of their time 

and the FBI’s transportation resources. Furthermore, FBI officials at three 

annexes we visited reported that the private landlords responsible for 

building maintenance at their sites were often slow to respond to 

maintenance requests from the FBI, such as requests for repairs to 

malfunctioning heating and cooling systems. 

To mitigate the operational and logistical challenges of dispersion and to 

avoid further complications as its workforce continues to grow, the FBI 

has centralized its real property management functions for headquarters 

and has begun to take a more focused approach to managing its space 

needs. In 2005, the FBI established a central Space Management Unit44

and started assessing its headquarters space needs twice a year. In 

addition, it initiated an interim phased plan to consolidate some leases 

into fewer facilities based on the lease expiration dates until it can obtain 

a facility designed to consolidate operations in the Hoover Building and in 

the 21 annexes it has determined should be colocated. 

 

44In 2004, the FBI Director proposed the establishment of a Facilities and Logistic 

Services Division to consolidate and standardize real property management throughout 

the FBI. In June 2005, the Attorney General approved the establishment of this division. 

Within that division, a headquarters Space Management Unit was created to better 

manage the growth in FBI headquarters space needs by standardizing and formalizing 

space assignments, allocations, and projections, and by coordinating new leasing actions. 
 

Page 21 GAO-12-96 Federal Bureau of Investigation 

Although the Hoover Building is nearing its life-cycle age and exhibiting 

signs of deterioration,45 GSA has decided to limit major repair and 

recapitalization investments to those systems or components that affect 

life safety and building functionality until it is determined whether the FBI 

will remain a long-term occupant of the building.46 According to GSA, its 

investments have been appropriate to ensure that FBI operations are not 

at risk. For example, since 2004, GSA has spent approximately $22 

million to upgrade components and systems in the Hoover Building.47

Nevertheless, a 2009 GSA physical condition survey estimated that the 

building requires about $80.5 million in further repairs and upgrades. The 

condition survey identifies repair needs to the building’s air-handling 

distribution systems and ductwork ($44.2 million), electrical switchgear 

($23.3 million), and elevators ($2.3 million), among other systems.48 GSA 

officials told us these repairs have been deferred. GSA also has plans to 

repair the building’s concrete façade ($8.9 million)49 and to replace the 

entire fire alarm system ($22 million), but has not yet obtained funding for 

either project. GSA officials indicated that the fire alarm system 

replacement would most likely be included in any future renovation of the 

Hoover Building. 

During a tour of the Hoover Building given by FBI officials, we observed 

several signs of exterior and interior deterioration. One FBI official stated 

 

45The National Research Council has reported that facilities and their building systems—

such as the electrical system—generally have a finite, expected useful life, over which 

time proper maintenance should occur and after which time the systems may need to be 

replaced. Most buildings are designed for a minimum service life of 30 years, but with 

proper maintenance may perform for 40 to 100 years. 

46In 2010, GSA awarded a maintenance contract that provides for routine operations and 

maintenance of the heating, ventilation, and cooling systems in the Hoover Building. 

47Since 2004, GSA has completed or is in the process of completing several 

recapitalization projects at the Hoover Building, including an $11.4 million chiller 

replacement, a $5 million upgrade to the building’s electrical closets, and a $5.2 million 

project to install energy-efficient lighting. 

48GSA’s Public Buildings Service assesses the physical condition of GSA assets regularly 

through the use of a physical condition survey. Every 2 years, a team of Public Buildings 

Service associates, including the asset manager and the property manager, physically 

inspect a building to assess its current condition and needs and to document changes in 

condition over time using a series of questions contained in the survey. 

49GSA plans to treat the building’s concrete façade with a chemical consolidant to make it 

less porous and thus less susceptible to deterioration. 

The Hoover Building Is 

Aging and Showing Signs 

of Deterioration, but 

Needed Repairs and 

Recapitalization Projects 

Have Been Deferred 
 

Page 22 GAO-12-96 Federal Bureau of Investigation 

that some areas of the upper-level exterior façade have deteriorated over 

time, heightening the risk that pieces of concrete could fall and strike 

pedestrians below. As a precautionary measure, GSA and the FBI have 

installed netting around the upper level of the building to catch any falling 

debris. In addition, water infiltration from the courtyard has corroded parts 

of the parking garage ceiling. The basement is also prone to flooding from 

the interior courtyard during periods of rain. Figure 4 depicts conditions 

we observed during our tour. 

Figure 4: Conditions GAO Observed at the Hoover Building 

At the time of our review, the Hoover Building was categorized as a “core 

asset” in GSA’s asset business plan.50 However, this categorization was 

inconsistent with GSA’s decision to limit major repair and recapitalization 

investments in the building. GSA core assets generally have a long-term 

holding period of at least 15 years. For buildings with a long-term holding 

 

50GSA, “Asset Business Plan for the J. Edgar Hoover Building” (unpublished plan, 

May 24, 2010). 
 

Page 23 GAO-12-96 Federal Bureau of Investigation 

period, GSA policy states that reinvestment will be funded to ensure 

maintenance of the building’s quality and condition at levels appropriate 

to meet continuing mission and customer needs.51 This includes all 

preventative maintenance, necessary upgrades, and enhancements to 

the building and its systems to maintain the asset in appropriate 

condition. GSA’s near-term maintenance policy for the Hoover Building is 

more consistent with GSA’s policy for a “transition asset.” A transition 

asset typically has a 6- to 15-year holding period as its tenant prepares 

for relocation to a new federal building or a leased building. For such an 

asset, GSA funds projects that meet basic needs in transition, but avoids 

any major reinvestment. In its technical comments on our draft law 

enforcement sensitive report, GSA reported that it has recently 

recategorized the Hoover Building as a transition asset to reflect the FBI’s 

concerns about the building’s security, condition, and efficiency, as well 

as GSA’s own decision to limit investments in the building. GSA further 

reported that its categorization of the building may change again if the FBI 

moves or further study of the asset points to a change. Regardless of how 

the building is categorized, it will likely be used for several more years, 

and its large backlog of deferred maintenance, major repairs, and 

recapitalization requirements increases the potential for systems or 

components to fail and potentially disrupt FBI operations. 

 

51GSA, “FY10 Asset Management Plan” (unpublished plan, 2010). 
 

Page 24 GAO-12-96 Federal Bureau of Investigation 

Over the past decade, the FBI and GSA have conducted a number of 

studies (see fig. 5) to assess the FBI headquarters facilities’ strategic and 

mission needs. Through these studies, they have determined the 

condition of the FBI’s current assets and identified gaps between current 

and needed capabilities, as well as studied a range of alternatives to 

meet the FBI’s requirements. (See app. II for more detail on the studies 

undertaken by the FBI and GSA.) These activities are consistent with 

applicable GAO leading practices in capital decision making.52

 

52See GAO/AIMD-99-32. We developed our leading practices for use in conjunction with 

the Office of Management and Budget’s Capital Programming Guide, a supplement to its 

Circular A-11, which provides detailed guidance to federal agencies on planning, 

budgeting, acquiring, and managing capital assets. 

Consistent with 

Leading Practices 

Thus Far, the FBI and 

GSA Have Identified 

Alternatives for Better 

Meeting the FBI’s 

Facility Needs and 

Are Developing an 

Approach for Moving 

Forward 

FBI and GSA Planning 

Actions Have Been 

Generally Consistent with 

Applicable Leading 

Practices in Capital 

Decision Making 
 

Page 25 GAO-12-96 Federal Bureau of Investigation 

Figure 5: Timeline of FBI and GSA Studies of FBI Facility Requirements 

Consistent with our first two leading practices in capital decision making—

to conduct a comprehensive assessment of needs to meet an agency’s 

mission goals and objectives and to identify the current capabilities and 

condition of existing assets (i.e., facilities) to meet those needs—the FBI 

and GSA conducted facility condition and security assessments of the 

Hoover Building in 2001 and 200253 and identified recommendations in 

both areas. For example, the poor condition of the Hoover Building was 

identified as a gap in the FBI’s need for a functional headquarters. In 

addition, as noted, the FBI’s 2005 Asset Management Plan54 identified 

 

53As we discussed earlier in this report, the FBI updated its security assessment of the 

Hoover Building in 2011. 

54Executive Order 13327, Federal Real Property Asset Management, issued February 4, 

2004, required agencies to develop and implement an agency asset management plan 

that would identify actions to be taken to improve the operational and financial 

management of the agency’s real property inventory and give consideration to a number 

of real property issues. These issues include the (1) acquisition costs of real property 

assets; (2) operating, maintenance, and security costs at federal properties; (3) disposal of 

real property excess to agencies’ needs; (4) opportunities for cooperative arrangements 

with the commercial real estate community; and (5) enhancement of federal agency 

productivity through an improved working environment. 

GAO Capital Decision-Making 

Practices 1 and 2: Assess 

Requirements and Determine 

Gaps between Current and 

Needed Capabilities 

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

2002

Security assessment

2001

Condition assessment

2005

Headquarters housing strategy 

2006

Site study

2007

Space study

2010

Consolidation report (final draft)

2008

Real estate appraisal

2009

Relocation study

Source: GAO analysis.
 

Page 26 GAO-12-96 Federal Bureau of Investigation 

the need for a new headquarters facility to safeguard personnel and 

information within efficient and cost-effective workspace, and the FBI has 

worked with GSA to identify its strategic facility and space requirements. 

Also in 2005, the FBI Director and a Deputy FBI Director—with input from 

assistant directors—decided which FBI programs should be colocated in 

a headquarters facility to meet the agency’s strategic and mission 

requirements. According to their analysis, the FBI Director; the National 

Security Branch, including its counterterrorism and intelligence divisions; 

the Criminal, Cyber, Response, and Services Branch; and other FBI 

headquarters functions, such as the Information Technologies Branch, 

would need to be colocated. Throughout the decision-making process, 

FBI senior officials have consulted with senior GSA regional and national 

officials to discuss the FBI’s requirements and the range of alternatives to 

meet the FBI’s needs. In 2007, GSA and the FBI found that the need to 

colocate certain FBI programs—to better enable collaboration and 

facilitate information sharing55—could not be met in the Hoover Building 

and the annexes and that the FBI’s operations in the Hoover Building and 

21 of its annexes in the National Capital Region should be consolidated.56

This decision to consolidate is also consistent with a 2010 presidential 

memorandum directing federal agencies to eliminate lease arrangements 

that are not cost-effective, pursue consolidation opportunities, and identify 

reductions when new space is acquired, as the FBI pointed out in its 2010 

consolidation report.57

In the studies they conducted from 2005 through 2009, the FBI and GSA 

identified security requirements for a consolidated FBI headquarters facility. 

Our previously issued law enforcement sensitive report describes these 

security requirements. The 2005 through 2009 planning studies also 

identified space requirements for an FBI headquarters facility. For example, 

a formal space programming study performed by the FBI’s architectural 

consultant established space requirements for approximately 11,600 

personnel and for support headquarters spaces, such as conference rooms 

and SCIF space. This personnel figure was based on current staffing levels 

 

55According to the FBI, efforts to improve collaboration and communication also respond 

to recommendations—made to the nation’s intelligence community—by the National 

Commission on Terrorist Attacks Upon the United States and the Commission on the 

Intelligence Capabilities of the United States Regarding Weapons of Mass Destruction. 

56GSA, “Space study” (2007).

57Presidential Memorandum—Disposing of Unneeded Federal Real Estate (June 10, 2010).
 

Page 27 GAO-12-96 Federal Bureau of Investigation 

for the functions that the FBI had determined should be colocated in a 

headquarters facility, adjusted to allow for limited future growth. To further 

identify the FBI’s headquarters space requirements, the architectural 

consultant and staff from the FBI’s Facilities and Logistics Services Division 

met with representatives from the FBI’s branches and their divisions to 

assess their operational needs, such as access to SCIF space or proximity 

to another organization or function. In addition, the FBI Facilities and 

Logistics Services Division established space standards for staff after 

reviewing GSA and industry benchmarks.58 According to the FBI, it requires 

modern, open-plan office space for its operations and shared team spaces 

to promote collaboration and information sharing across mission teams59

and to permit easy reconfiguration to meet changing needs, such as space 

for newly formed internal and interagency task forces.60 The FBI also 

identified requirements for large SCIFs to fully support its divisions’ 

classified discussion and processing needs. 

 

58The FBI’s space standards call for an average workstation of 49 square feet (7 feet by 

7 feet). 

59Our review of FBI planning documents shows that the FBI considered using alternative 

workplace strategies—such as teleworking—to help address its space needs but 

determined that because most of its work is highly classified, teleworking is not a practical 

option and also does not support its mission need to bring teams together. 

60GSA’s federal workplace goals for the next decade call for open-space floor plans that 

promote collaboration and provide greater flexibility to reconfigure space to meet the 

changing needs of building occupants. 
 

Page 28 GAO-12-96 Federal Bureau of Investigation 

Consistent with our third leading practice in capital decision making—

decide how best to meet a gap by identifying and evaluating alternative 

approaches—the FBI and GSA, in their 2005 through 2009 planning 

studies, identified and analyzed a range of alternatives, together with their 

estimated costs and benefits, for meeting the gap between the FBI’s 

current and needed space. These alternatives fall into three categories: 

(1) modernizing the Hoover Building;61 (2) demolishing the building and 

constructing a new facility on the existing site;62 and (3) acquiring a new 

consolidated headquarters facility—through federal construction or lease—

on a new site.63 Figures 6 and 7 provide summary information about these 

three alternatives and the status quo, which we include because the Office 

of Management and Budget (OMB) requires agencies to submit baseline 

information when they propose a major capital acquisition.64

 

61GSA, “Site study” (unpublished study, 2006). 

62GSA, “Site study” (2006). 

63GSA, “FBI headquarters housing strategy” (unpublished study, 2005); FBI, “Relocation 

study” (unpublished study, 2009); and FBI, “Consolidation report” (unpublished, final draft 

report, 2010). 

64Some alternatives included variations. For example, the modernization alternative 

included four variations that ranged from vacating the entire building during the renovation 

to renovating the occupied building floor by floor. 

GAO Capital Decision-Making 

Practice 3: Identify Alternatives 

to Close Gaps 
 

Page 29 GAO-12-96 Federal Bureau of Investigation 

Figure 6: The Baseline Status Quo and Alternative 1 Consider Continued Use of the Hoover Building 

a

The U.S. Green Building Council’s Leadership in Energy and Environmental Design green building 

rating system defines sustainable features for buildings and includes a set of performance standards 

that can be incorporated into the design and construction of buildings. When the standards are met 

during facility design and construction, credits are earned to enable buildings to be certified in 

accordance with an established four-level scale—certified, silver, gold, and platinum. 
 

Page 30 GAO-12-96 Federal Bureau of Investigation 

Figure 7: Alternatives 2 and 3 Consider New Construction on the Existing Hoover Site or a New Site 

The cost estimates in figures 6 and 7 cannot be compared because the 

studies and estimates were completed at different times, for different 

purposes, by different consultants, using different methodologies and 

facility specifications. 
 

Page 31 GAO-12-96 Federal Bureau of Investigation 

As the FBI and GSA continue to advance through the capital planning 

process, our leading practices in capital decision making can help guide 

their efforts, as well as inform decision makers’ evaluations of any 

preferred alternative and other alternatives considered. Our fourth leading 

practice—establish a review and approval framework that is supported by 

analyses65—encourages management reviews and approvals, supported 

by the proper financial, technical, and risk analyses that are critical in 

making sound capital investment decisions. 

OMB’s guidance, together with GSA’s Capital Planning Program Guide, 

provides a capital asset review framework such as our fourth leading 

practice describes. OMB’s guidance requires GSA—if GSA constructs or 

leases a headquarters facility for the FBI’s use—to submit a capital asset 

business case in support of the project. According to OMB’s guidance, 

the FBI and GSA need to partner to develop the business case—

providing input on the estimated project costs and financing strategies66—

but the design and construction budget request would be part of GSA’s 

annual budget submission to OMB if the construction is to be funded 

through the FBF. (See app. III for information on the FBF.) This business 

case should include the total estimated life-cycle costs—for the preferred 

alternative and the other alternatives the agencies considered67—

including the costs of acquisition, operations, maintenance, and 

disposal.68 In addition, GSA’s guide directs GSA to conduct a variety of 

reviews, such as site feasibility studies and environmental analyses, 

designed to ensure that projects are feasible and in compliance with all 

federal construction requirements. 

 

65See GAO/AIMD-99-32. 

66The FBI would also need to identify its contributions to the other related project costs 

that are not part of the design and construction estimate—such as the costs of moving, 

systems furniture, and security equipment. Funding for these costs would be requested 

separately through the FBI’s budget submission. 

67OMB Circular A-11, Part 7, “Planning, Budgeting, Acquisition, and Management of 

Capital Assets” indicates that in selecting the best capital asset, agencies should identify 

at least three viable alternatives in addition to a baseline representing the status quo. In 

addition, agencies should identify specific qualitative benefits, as well as quantitative costs 

and benefits, to be realized. 

68GSA would need to consult with OMB as to whether the disposition or reuse of the 

Hoover Building and site should be factored into the business case analysis. 

GAO Capital Decision-Making 

Practice 4: Establish a Review 

and Approval Framework 
 

Page 32 GAO-12-96 Federal Bureau of Investigation 

As GSA develops a capital asset business case for OMB with input from 

the FBI, it will have to rank the alternatives the agencies considered and 

select a preferred alternative. This ranking, when weighed against other 

relative priorities that the FBI and GSA will have to evaluate, would be 

consistent with our fifth capital decision-making practice—rank and select 

projects based on established criteria. FBI officials have preliminarily 

concluded that their security and space requirements can be met only 

through the construction of a new headquarters facility on a new site. 

GSA officials have thus far generally concluded that the FBI has longterm space needs and that FBI operations should be consolidated to 

achieve greater security and efficiency, but have not finalized their 

construction cost estimates. According to GSA officials, the FBI and GSA 

will discuss the FBI’s needs with OMB, and a final decision will be based 

on the results of a more comprehensive analysis that GSA will complete 

with FBI input for OMB. For the preferred alternative, GSA officials said 

they will need to undertake a final due diligence process to revalidate the 

FBI’s program requirements, update costs, and initiate feasibility 

studies—such as an assessment of the likelihood that sites are available 

in the National Capital Region—so as to develop a detailed prospectus 

for formal OMB approval and congressional consideration.69

Our leading practices state that prudent decision makers also should 

consider various funding options available to them. In the case of real 

property, that means considering other funding alternatives in comparison 

to funding new construction or a modernization through the FBF. In 

separate interviews, both GSA’s Deputy Administrator and Director of the 

Office of Real Property Asset Management indicated that GSA will 

undertake a thorough analysis of a range of financing strategies as part 

its due diligence. (See app. III for a description of some of the financing 

strategies that GSA may consider.) According to GSA, it almost always 

recommends federal construction using the FBF because this is usually 

the lowest cost alternative. However, GSA reports that in the current 

budgetary environment, it believes that alternative strategies such as the 

ground lease and leaseback arrangement—providing for eventual 

 

69The prospectus shall include, among other things, a brief description of the space, the 

location of the space, an estimate of the maximum cost to the United States, and a 

statement of how much the government is already spending to accommodate the 

employees who will occupy the space. Prospectus requirements also apply to alterations 

of public buildings. For large federal construction projects, GSA typically submits an initial 

prospectus to request authorization for site acquisition and design funding and a second 

prospectus for construction funding. See 40 U.S.C. § 3307. 

GAO Capital Decision-Making 

Practice 5: Rank and Select an 

Alternative 
 

Page 33 GAO-12-96 Federal Bureau of Investigation 

ownership of the building by the government—may need to be 

considered.70

After GSA and the FBI identify a preferred alternative and financing 

strategy, and if the alternative entails constructing a new federal facility 

through the FBF, GSA will have to rank the need for any FBI 

headquarters capital project against other FBI and governmentwide 

facility needs. GSA ranks projects from all agencies that have identified 

requirements—first by GSA region and then nationally. The GSA 

Administrator decides which major prospectus projects to propose within 

GSA’s budget based on recommendations and input from the 

Commissioner of the Public Buildings Service, among others. While GSA 

has general criteria for prioritizing capital construction and major 

modernization needs, it does not specifically include security among its 

ranking criteria. Instead, according to a GSA official, the agency relies on 

its customers to convey their mission-critical needs in a way that reflects 

which issues, such as security, are critical to them. At this time, GSA 

officials could not indicate how a new FBI headquarters facility—or a 

major modernization of the Hoover Building—might be ranked in relation 

to other competing federal asset needs. FBI staff we spoke with indicated 

that a new headquarters project has the support of the FBI Director, but it 

is unclear whether a new headquarters is the most important facility need 

for the FBI or whether regional field office facility needs may be more 

important. 

The FBI and GSA plan to continue working together to reach a decision 

with OMB on how best to meet the FBI’s needs. GSA reports that fiscal 

year 2014 is likely the earliest that any budget request and prospectus 

might be put forth for congressional consideration. Based on that insight 

and our review of preliminary FBI and GSA schedules, we estimate that 

the earliest that any project could be completed would be fiscal year 

2020. 

 

70If a facility were constructed by a developer and leased for the FBI’s use, annual rent 

would be requested by the FBI in the appropriate budget year to coincide with its 

occupancy of the new facility. Rent is then paid to GSA and deposited into the FBF. GSA 

then pays the landlord from the FBF. 
 

Page 34 GAO-12-96 Federal Bureau of Investigation 

With its employees dispersed throughout the National Capital Region and 

many of them housed in the aging and inefficient Hoover Building—a 

facility constructed prior to current ISC standards governing security 

countermeasures—the FBI is under pressure to find an alternative that 

will meet its security, space, and building condition requirements. Any 

alternative will take years to implement and is likely to cost over a billion 

dollars. It is therefore important that the choice of an alternative be based 

on up-to-date assessments of the FBI’s security, space, and building 

condition needs. In the interim, the FBI and GSA may have opportunities 

to further enhance security and address condition deficiencies at the 

FBI’s current facilities. 

For the next several years or more, the FBI’s headquarters workforce will 

be dispersed between the Hoover Building and the headquarters 

annexes. During this time, it is important that the FBI and FPS conduct 

security assessments of the annexes, as required by the 2010 ISC 

standards, and that the FBI track the implementation status of 

recommended countermeasures for all its headquarters facilities. For the 

FBI, documentation of decisions to implement recommendations—

whether made in its 2011 security assessment of the Hoover Building or 

in future assessments of its headquarters annexes against the 2010 ISC 

standards—could inform decisions on how best to meet the FBI’s longterm headquarters facility needs. Complete, current information on 

security needs and the status of recommended countermeasures—some 

that have budget implications—at both the Hoover Building and the 

annexes could indicate to the FBI whether it is allocating its security 

resources as efficiently as possible to mitigate risks. Such information 

could also help the FBI and GSA evaluate alternatives to the FBI’s current 

dispersed headquarters structure and develop a business case to support 

a budget request for the alternative that they determine would best meet 

the FBI’s security needs. 

Given the likelihood that FBI employees will be housed in the Hoover 

Building for several more years no matter which alternative is ultimately 

selected, and that the building may remain in GSA’s portfolio whether it is 

occupied by the FBI or another federal tenant, it is important to ensure 

that GSA’s current strategy for maintaining the facility is appropriate. The 

deferred maintenance, repairs, and recapitalization projects that have 

accumulated under this strategy could lead to system or component 

failures and potentially disrupt FBI operations. Allowing the building to 

deteriorate further could also make it difficult to house another agency in 

the Hoover Building if the FBI moves to a different location. 

Conclusions 
 

Page 35 GAO-12-96 Federal Bureau of Investigation 

Ultimately, decisions about the future of the FBI’s headquarters facilities 

will require careful consideration of policy matters related to the FBI’s 

mission and security needs and competing budget priorities, as well as 

other factors, such as the availability of a suitably sized site in the 

National Capital Region where the FBI’s headquarters operations could 

be colocated. Currently, planning for a new FBI headquarters is ongoing, 

and GSA has yet to submit a business case for a preferred alternative to 

OMB, which is essential in the decision as to which specific alternative 

and financing strategy to pursue. 

To ensure that complete, current security information is being used to 

minimize risks to FBI facilities, operations, and personnel and to inform a 

final decision on how best to meet the FBI’s long-term facility 

requirements, we recommend that the Attorney General direct the FBI 

Director to take the following two actions: 

 Document whether any recommendations from the FBI’s 2011 

security assessment will be implemented at the Hoover Building. 

 Track the implementation status of all recommendations made in FPS 

or FBI security assessments—of both the Hoover Building and the 

FBI’s headquarters annexes—using the 2010 ISC standards. Where 

recommendations are not implemented, document the rationale for 

accepting risk, including any alternate strategies that are considered. 

Given that the FBI will likely remain in the Hoover Building for at least the 

next several years, we also recommend that the GSA Administrator direct 

the Commissioner of the Public Buildings Service to take the following 

action: 

 Evaluate GSA’s current strategy to minimize major repair and 

recapitalization investments and take action to address any facility 

condition issues that could put FBI operations at risk and lead to 

further deterioration of the building, potentially affecting continued use 

of the Hoover Building by the FBI or any future tenant. 

Recommendations for 

Executive Action 
 

Page 36 GAO-12-96 Federal Bureau of Investigation 

We provided a draft of the law enforcement sensitive version of this report 

to the Department of Justice, GSA, and DHS for review and comment. In 

that law enforcement sensitive report we also recommended that the 

Attorney General direct the FBI Director to update the Hoover Building’s 

security assessment using the 2010 ISC standards—to include 

undertaking an analysis of its building security requirements, 

documenting if threat scenarios exceed the ISC design-basis threat, and 

indicating whether recommendations would be implemented. Given that 

the FBI took action to address part of the recommendation—subsequent 

to our July 2011 law enforcement sensitive report but prior to this public 

version—we modified the recommendation to reflect the FBI’s recent 

security assessment. Specifically, the security assessment documents 

threats and analyzes building security requirements consistent with ISC 

security standards, but does not indicate whether recommended actions 

will be implemented. This is reasonable given the short period of time 

since our report and the FBI’s ensuing analysis. We therefore revised the 

first recommendation above to focus on the need for the FBI to document 

decisions on the 2011 security assessment’s recommendations. 

Our July 2011 law enforcement sensitive report also recommended that 

the FBI track the implementation status of all recommendations in FPS or 

FBI security assessments. We will continue to monitor the FBI’s decisions 

and actions related to its security assessment of the Hoover Building—

and the security assessments of the FBI headquarters annexes—as 

indicated in the recommendations above. 

For security reasons and for clarity, we made additional modifications to 

the language used in the above recommendations to the Attorney 

General compared to the language we used in our July 2011 law 

enforcement sensitive report. 

We received written comments from the FBI on our law enforcement 

sensitive report on behalf of the Department of Justice. We also received 

written comments from GSA and DHS on that report. The FBI concurred 

with our recommendations and said that its primary concern in finding a 

long-term solution for its headquarters facility needs is to mitigate the 

operational impact of a fragmented workforce located at multiple sites 

across a wide geographic area. The FBI also cited concerns that its 

current headquarters housing is inefficient and expensive, and stated that 

a new, consolidated headquarters facility is one of the FBI’s highest 

priorities. GSA indicated that it is currently taking appropriate action to 

implement our recommendation and remains committed to making all 

necessary investments in the Hoover Building to ensure ongoing 

Agency Comments 

and Our Evaluation 
 

Page 37 GAO-12-96 Federal Bureau of Investigation 

operations until a long-term solution for the FBI can be developed. Written 

comments—on our law enforcement sensitive report—from the FBI, GSA, 

and DHS are reprinted with sensitive information redacted in appendixes 

IV through VI, respectively. The FBI, GSA, and DHS provided additional 

clarifying and technical comments, which we incorporated throughout the 

report as appropriate in consideration of sensitivity concerns. 

In addition, we provided a draft of this public report to the FBI, GSA, and 

DHS for review. Those agencies provided no additional comments. 

We are providing copies of this report to appropriate congressional 

committees, the Attorney General, the Director of the Federal Bureau of 

Investigation, the Administrator of the General Services Administration, 

the Secretary of Homeland Security, and other interested parties. In 

addition, this report will also be available at no charge on the GAO Web 

site at http://www.gao.gov. 

If you or your staffs have any questions about this report, please contact 

David C. Maurer at (202) 512-9627, maurerd@gao.gov, or David J. Wise 

at (202) 512-2834, wised@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made key contributions to this report are 

listed in appendix VII. 

David C. Maurer 

Director, Homeland Security and Justice Issues 

David J. Wise 

Director, Physical Infrastructure Issues 
Appendix I: Objectives, Scope, and 

Methodology 

Page 38 GAO-12-96 Federal Bureau of Investigation 

Congress directed us, in the explanatory statement accompanying the 

2009 Omnibus Appropriations Act, to review the J. Edgar Hoover Building 

(Hoover Building)—the main headquarters building for the Federal 

Bureau of Investigation (FBI)—and the FBI’s off-site locations (annexes), 

which support headquarters and are dispersed throughout the National 

Capital Region.1

 We conducted our review to examine (1) the extent to 

which the Hoover Building and annexes support the FBI’s operational 

requirements for security, space, and building condition and (2) the extent 

to which the FBI and the General Services Administration (GSA) have 

followed leading capital decision-making practices in identifying 

alternatives for meeting the FBI’s operational requirements and the extent 

to which each alternative would address these requirements. 

To determine the extent to which the Hoover Building and annexes 

support the FBI’s operational requirements for security, space, and 

building condition, we visited the Hoover Building and five annexes. We 

selected the five annexes to represent different facility security levels 

(FSL); different FBI divisions, such as Cyber and Counterterrorism; and 

varying degrees of staff fragmentation. While visiting these annexes, we 

examined security, space, and building condition issues firsthand and 

interviewed on-site program and security officials about the FBI’s 

operational requirements and the extent to which the annexes do, or do 

not, meet those needs. 

For security-related issues at the five annexes, we reviewed site-specific 

facility security assessments (security assessments) that were conducted 

by either FBI security officials or the Department of Homeland Security’s 

Federal Protective Service (FPS) in relation to Interagency Security 

Committee (ISC) security standards that are applicable to owned and 

leased federal buildings. We also discussed with FBI officials the extent to 

which countermeasures recommended in those security assessments 

had been implemented. In our July 2011 law enforcement sensitive 

report, we recommended that the FBI conduct a new security assessment 

in accordance with updated security standards issued in 2010. In 

response to our recommendation, the FBI conducted such an 

assessment, which we also reviewed. 

 

1

Explanatory statement in the 2009 Committee Print of the House Committee on 

Appropriations on H.R. 1105, at 1764 accompanying the 2009 Omnibus Appropriations 

Act, Pub. L. No. 111-8, Div. B, Title II, 123 Stat. 524, 574 (2009). 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology 

Page 39 GAO-12-96 Federal Bureau of Investigation 

During our site visits, we interviewed FBI security officials about the 

security assessments, security risks and challenges, and actual security 

incidents or breaches at each facility. We also asked FBI officials whether 

any security challenges at the annexes were a direct result of operations 

not being colocated at the Hoover Building. To learn more about security 

issues at the Hoover Building, we toured the building while FBI officials 

reported on security vulnerabilities and some countermeasure 

improvements that had been implemented, and we interviewed FBI 

security, police, and facilities officials with knowledge of these 

improvements. 

In addition, we interviewed FBI security and facility officials about 

outstanding security projects to determine why they had not been 

implemented. To identify these projects, we reviewed FBI, FPS, GSA, 

and National Capital Planning Commission documents, including the 

FBI’s 2002 security assessment of the Hoover Building, as well as 

numerous FBI and GSA planning studies that identified security 

requirements for the building. We interviewed FPS security officials about 

the security standards for federal facilities, both past and present, and the 

FSL determination process. We reviewed FPS’s 2000 Policy Handbook 

and the ISC standards from 2004 and 2010. Furthermore, we reviewed 

and analyzed GSA’s design standards related to security.2

 In addition, we 

relied on internal security experts from GAO’s Office of Security and 

Forensic Audits and Investigative Service to verify security assumptions 

and requirements. 

For space-related issues, we reviewed the size and location of current 

facilities and programs; reviewed FBI and GSA reports that tracked annex 

leases, space use, and the Hoover Building’s efficiency (how much of its 

space is usable for mission needs) and how the existing space does, or 

does not, meet the FBI’s operational needs; and interviewed FBI program 

officials to understand the effects on operations of having different 

programs housed in several annexes. We reviewed FBI and GSA 

planning studies that identified which FBI programs or functions should be 

colocated. We compared attributes of the Hoover Building, such as its 

efficiency, to GSA standards and compared the Hoover Building to other 

agency headquarters in the National Capital Region. We asked FBI 

officials about the systems they use to manage their real property data 

 

2

GSA, Facilities Standards for the Public Buildings Service (November 2010). 
Appendix I: Objectives, Scope, and 

Methodology 

Page 40 GAO-12-96 Federal Bureau of Investigation 

and how frequently they update their leasing and space planning data. 

We used GSA’s asset business plans to cross check the real property 

data reported to us by the FBI to ensure reasonable consistency in the 

facility data, such as the ownership status and size (i.e., square footage) 

of facilities. Furthermore, we reviewed and analyzed GSA’s design 

standards related to building efficiency and space planning. 

For building condition issues, we analyzed assessments of the Hoover 

Building’s physical condition and compared this information to GSA 

policies for building condition. We also asked GSA how often it conducts 

facility condition assessments of owned buildings. We examined GSA’s 

asset business plan and other studies of the Hoover Building to identify 

completed maintenance projects, deferred maintenance, and planned 

major repair and recapitalization projects. We also asked FBI and GSA 

officials about their assessments of the Hoover Building’s condition. 

To determine the extent to which the FBI and GSA have followed leading 

capital decision-making practices in identifying alternatives for meeting 

the FBI’s operational requirements, we compared the FBI’s and GSA’s 

planning actions against leading practices we have reported on in this 

area.3

 In addition, we reviewed FBI and GSA studies of the FBI’s facilities 

and operational requirements, identified the alternatives discussed in 

these studies for meeting the requirements, and reviewed relevant laws 

relating to real property. We determined that the alternatives fell into three 

broad categories, each of which included a number of variations. For our 

analysis, we focused on the categories, since the appropriateness of the 

variations could not be determined without further study and would 

depend on site-specific conditions. We then assessed the extent to which 

each alternative would address the FBI’s security, space, and building 

condition requirements.4

We did not independently analyze the FBI’s requirements for security, 

which are based on its assessments of the threats it faces and their 

probability of occurrence; its requirements for space, which are based on 

its projections of each FBI program’s future staffing and space needs; or 

the FBI’s process for deciding which programs need to be colocated at a 

 

3

See GAO, Executive Guide: Leading Practices in Capital Decision-Making, 

GAO/AIMD-99-32 (Washington, D.C.: Dec. 1, 1998). 

4

See GAO-03-1011. 
Appendix I: Objectives, Scope, and 

Methodology 

Page 41 GAO-12-96 Federal Bureau of Investigation 

single location. In our view, such analyses were outside the scope of our 

review and would require extensive reviews of classified intelligence on 

threats and hostile groups, as well as of programmatic mission 

justifications for FBI branches and their associated staffing levels. We did, 

however, determine that the FBI senior leadership was involved in 

deciding which FBI programs should be colocated. Furthermore, because 

the FBI and GSA are still in the early stages of the facility planning 

process and have not yet prepared final cost estimates for the Office of 

Management and Budget (OMB), we did not validate preliminary cost 

estimates for new construction or past cost estimates for modernizing or 

redeveloping the Hoover Building and site. 

We conducted this performance audit from July 2010 to November 2011 

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. 
Appendix II: FBI and GSA Studies Related to 

FBI Headquarters Planning 

Page 42 GAO-12-96 Federal Bureau of Investigation 

This appendix provides summary information about eight studies that 

provide information on the condition of the Hoover Building and the FBI’s 

facility needs. The studies, issued from 2001 through 2010, are presented 

in chronological order. 

1. Condition assessment, 2001 

In 2001, a facility engineering consultant conducted a facility condition 

assessment for GSA of the Hoover Building and identified numerous 

building deficiencies including deferred maintenance and life-cycle 

replacement projects. The study concluded the building was in poor 

condition. The contractor prepared three funding scenarios to provide 

GSA with insight into how the condition of the building would be affected 

based on various investment assumptions over 20 years. One scenario 

included improving the building condition to an industry-acceptable level. 

2. Security assessment, 2002 

In 2002, the FBI conducted a security assessment of the building, and 

with the assistance of two consultants, identified recommendations to 

further improve the building’s security. 

3. Headquarters housing strategy, 2005 

In 2005, a real estate services consultant contracted by GSA studied the 

FBI’s facility needs. According to the consultant, the FBI’s mission was 

impaired by a fragmented headquarters organization that caused staff to 

be dispersed across the Hoover Building and 16 annexes at that time in 

the National Capital Region. In addition, the consultant documented 

space inefficiencies in the Hoover Building. To address these 

deficiencies, the consultant developed a strategic housing plan and 

facility requirements for FBI headquarters. These requirements included 

 meeting ISC security standards, 

 making maximum use of open-plan office space, 

 providing enough secure space for handling classified information, 

 planning building systems to support current and future information 

technology needs, and 

 providing extensive emergency backup power as well as state-of-theart air filtration systems. 

Appendix II: FBI and GSA Studies Related to 

FBI Headquarters Planning 
Appendix II: FBI and GSA Studies Related to 

FBI Headquarters Planning 

Page 43 GAO-12-96 Federal Bureau of Investigation 

The consultant developed three consolidation alternatives1 for addressing 

identified deficiencies and meeting the FBI’s headquarters facility needs 

based on projected 2011 staffing levels:2

 one-site consolidation with both headquarters national security and 

law enforcement located together; 

 two-site consolidation (option A) with national security functions at one 

site and law enforcement functions at a second site; and 

 two-site consolidation (option B) with a more even distribution of FBI 

headquarters elements (compared to option A) and no split between 

national security and law enforcement functions. 

A preliminary financial analysis, which estimated the net present value of 

savings for each alternative over 30 years, showed that each alternative 

was more economically beneficial than the status quo. The savings were 

largely due to the planned consolidation of 3.1 million rentable square feet 

into 2.3 million rentable square feet.3

According to a draft timeline, it would take nearly 3 years for GSA to 

complete its analysis, develop a project prospectus for congressional 

authorization, and identify a site. Another 3 years was estimated for 

design, construction, and move-in. 

Citing detailed cost estimates for a project of similar size for another 

intelligence agency, the consultant predicted a total project cost of over 

$1.5 billion. 

 

1

Each of the three consolidation alternatives would provide approximately 2.3 million 

rentable square feet of space. Each of the three consolidation alternatives also included a 

small downtown Washington, D.C., location for elements that need to coordinate closely 

with Congress, the Department of Justice, or the White House as well as an administrative 

annex outside the downtown area. 

2

Staffing projections assumed an annual growth rate of 5 percent during fiscal years 2005 

through 2011. The projected fiscal year 2011 staffing level was 9,500 personnel. In 

January 2011, the FBI reported that if a move to a consolidated campus occurred in 

January 2011, an estimated 10,000 staff—500 more than projected in 2005—would be 

relocated to the new headquarters. 

3

To provide an equal-size comparison, the status quo baseline in the plan considered that 

GSA would acquire an additional 610,000 rentable square feet of leased space to 

accommodate the FBI’s projected growth during fiscal years 2005 through 2011. 
Appendix II: FBI and GSA Studies Related to 

FBI Headquarters Planning 

Page 44 GAO-12-96 Federal Bureau of Investigation 

4. Site study, 2006 

In 2006, another real estate services consultant hired by GSA studied a 

range of scenarios for use of the Hoover Building and site. This study was 

intended to inform GSA management decisions on optimizing the value of 

the Hoover Building as a GSA real property asset and was not 

necessarily performed to identify alternatives for meeting the FBI’s 

headquarters facility needs. The study did, however, consider the impact 

on operations if the FBI remained as the building tenant. The consultant 

identified five scenarios: 

 maintain and operate the building “as is,” 

 vacate the building and sell the asset, 

 modernize the building,4

 vacate and demolish the building and redevelop the site,5 and 

 partially demolish the building to redevelop the front side facing 

Pennsylvania Avenue and renovate the back portion that faces E 

Street.6

Estimated costs to modernize the Hoover Building ranged from $850 

million to $1.1 billion. Estimated costs to demolish the Hoover Building 

and redevelop the site ranged from $853 million to $1.4 billion.7

The study concluded that no alternative was a definite best option for 

GSA. 

 

4

Four variations were considered, including (1) vacating the building and renovating it; 

(2) renovating by floor; (3) renovating by quadrant; and (4) renovating by floor and building 

out the open-air second floor and mezzanine. 

5

Two variations were considered, including (1) constructing a single secure building and 

(2) constructing three buildings. 

6

The front of the Hoover Building is triangular in shape and includes the building’s central 

courtyard. The concept envisioned a more efficient structure built on this portion of the 

site. 

7

The cost estimates do not include costs for swing space to house personnel while 

construction takes place. 
Appendix II: FBI and GSA Studies Related to 

FBI Headquarters Planning 

Page 45 GAO-12-96 Federal Bureau of Investigation 

The study reported that a modernization, in general, would not improve 

the building’s gross and rentable square footage. In addition, this 

alternative would create a demand for swing space and could adversely 

affect the FBI’s operations if the FBI remained as the building’s tenant 

during the modernization. According to the study, the modernization 

would be least costly if the FBI vacated the entire building to give the 

construction contractor unrestricted access. 

According to the study, redeveloping the site with a new building or 

buildings would not meet GSA’s required rate of return on investment, 

and constructing a new secure facility would sacrifice tremendous value 

associated with a highly marketable location. 

5. Space study, 2007 

In 2007, GSA hired an architectural design and planning consultant to 

assess the condition of the Hoover Building and determine the extent to 

which it supports the FBI’s mission. The consultant assessed the Hoover 

Building’s design and use of space against industry standards and 

compared the Hoover Building to facilities used by other intelligence 

agencies. 

According to the report, the FBI’s work process is dynamic, requiring 

intelligence gathered by one team to be shared with multiple teams for 

whom the intelligence may also be relevant. To respond to the FBI’s work 

process and mission, the consultant determined that the FBI’s workplace 

should promote collaboration and communication among staff and be 

easily reconfigured. The study found that the Hoover Building does not 

generally meet these criteria because of its structural characteristics and 

inherent inefficiencies. For example, the study found that aspects of the 

building—including the location of structural elements and hard wall 

partitions—result in an inherently inefficient use of space. According to 

the consultant, these characteristics limit the degree to which the FBI can 

reconfigure space to optimize its operations and respond to mission 

changes. The consultant concluded that the Hoover Building is a 

significant barrier to the FBI’s performance and operational effectiveness 

and no longer effectively supports the FBI’s mission. 

The consultant also indicated that the renovations necessary to make the 

Hoover Building viable, feasible, and desirable may be unjustifiable given 

the costs and disruption they would entail. The consultant concluded that 

relocating the FBI to a new facility would likely lead to a significant 

improvement in performance at a lower cost. 
Appendix II: FBI and GSA Studies Related to 

FBI Headquarters Planning 

Page 46 GAO-12-96 Federal Bureau of Investigation 

6. Real estate appraisal, 2008 

In 2008, GSA hired a real estate appraisal firm to develop a market-value 

opinion of the Hoover Building and site to inform GSA’s asset 

management strategy. The appraisal firm considered three valuation 

approaches: (1) a cost approach; (2) a sales comparison approach; and 

(3) an income capitalization approach.8

The appraisal firm described the construction quality of the existing 

building as average and the condition of the building as below average. It 

also found the building inferior to other office buildings constructed during 

the same period. In particular, the consultant reported the building 

windows are very small compared to modern office building windows and 

that larger windows are generally required to attract tenants to higherpriced leased space. The firm reported that GSA had estimated a cost of 

over $200 million to modify the structure and replace its windows. 

GSA provided the appraisal firm with a list of planned recapitalization 

projects totaling over $460 million, to be implemented over 10 years; 

however, the appraiser reported that GSA’s Property Manager had 

indicated that, for lack of funds, none of the planned capital expenditures 

would likely be made. Therefore, the appraiser did not consider the value 

of any planned recapitalization projects in the estimated value. However, 

the appraiser reported that even if the planned capital expenditures were 

made, the Hoover Building would not be considered a Class A office 

building.9

The appraiser reported that the site was zoned to permit retail, office, 

housing, mixed, and public uses, and the appraiser concluded that no 

reasonably probable use of the site would be likely to generate a higher 

 

8

The cost approach assumes a buyer would pay no more for a property than what it would 

cost to construct a like property with the same utility. The sales comparison approach 

assumes a buyer would pay no more than what it would cost to acquire a similar existing 

property. The income capitalization approach reflects the market’s perception of a 

relationship between a property's potential income and its market value. 

9

The Building Owners and Management Association International defines Class A office 

buildings as the most prestigious buildings that compete for premier office users with rents 

above average for the area. Such buildings have high-quality standard finishes, state-ofthe-art systems, exceptional accessibility, and a definite market presence. Class B office 

buildings compete for a wide range of users with rents in the average range for the area. 

Building finishes are fair to good for the area, and systems are adequate. 
Appendix II: FBI and GSA Studies Related to 

FBI Headquarters Planning 

Page 47 GAO-12-96 Federal Bureau of Investigation 

value than office use. Accordingly, the appraiser identified office use, 

developed to the level permitted by the zoning, as the highest and best 

use of the property. 

The appraiser reported that the site, if redeveloped, could accommodate 

a building area of approximately 2.5 million gross square feet based on 

the current zoning regulations. The appraiser also noted that the existing 

Hoover Building is 2.4 million gross square feet and therefore a building 

on the redevelopment site would likely be similar in size. The appraiser 

noted that the existing building is set back farther from Pennsylvania 

Avenue greater than is typical for a commercial office building downtown 

but not far enough where demolishing the building to capture the space 

would be cost-effective. Redevelopment would enable a developer to 

construct a new Class A office building. 

7. Relocation study, 2009 

In 2009, the FBI contracted with an architectural and planning firm to 

develop a housing plan, space requirements program, and conceptual 

site plans for consolidating its headquarters in a new facility onto a single 

site. While the 2005 GSA study examined space requirements at a macro 

level, it did not provide a detailed housing plan and space requirements 

program. Thus, to more fully define its requirements, the FBI established 

goals for the 2009 study. These goals were to 

 develop a housing plan that identified the FBI branches and divisions 

to be located on-site; 

 summarize staffing levels by branch and division, including both FBI 

personnel and contractors; 

 summarize future staffing growth factors; 

 develop space-planning standards and workspace types; 

 develop a space requirements program for branches and divisions 

based on those staffing and space standards; 

 identify required adjacencies; 

 outline common shared support spaces and special space 

requirements; 
Appendix II: FBI and GSA Studies Related to 

FBI Headquarters Planning 

Page 48 GAO-12-96 Federal Bureau of Investigation 

 recommend an ideal floor plate size for a new building that would 

maximize future flexibility; 

 identify circulation factors for the building; 

 calculate total gross and usable square footage of a new facility; 

 develop conceptual site plans; and 

 identify design criteria, including Leadership in Energy and 

Environmental Design, security, and building code requirements. 

The consultant collected data by walking through the FBI’s headquarters 

spaces, using a space requirements questionnaire, and interviewing FBI 

personnel in the facilities, security, and information technology groups to 

verify information from the questionnaire. Each FBI branch and division 

reviewed the consultant’s data. 

Using FBI personnel counts from 2008 with projections for future growth 

through 2013 and 2018, the consultant derived overall square footage 

tabulations. FBI’s Resource Planning Office provided the personnel 

counts and growth projections. 

Based on the space and security requirements for the main headquarters 

building, the consultant developed planning estimates for the site acreage 

required. 

The consultant developed two site concepts: (1) a suburban office 

campus and (2) a more urban site located near the Washington beltway. 

Preliminary cost estimates for a new headquarters were developed based 

on the consultant’s analyses of space and security requirements. FBI 

costs for special security equipment, communications and information 

systems, modular systems furniture, and moving were not included in the 

construction-related costs but were separately estimated and are not 

considered GSA project costs. 

Land costs were estimated on the basis of comparable land sales over 

the past several years in a variety of locations inside and outside the 

beltway. The suburban and beltway property costs were each averaged 

to determine average expected prices. The land costs were added to the 

GSA project cost summary and increased by 10 percent to reflect 

potential increases in land value, which may occur before a property is 

acquired. 
Appendix II: FBI and GSA Studies Related to 

FBI Headquarters Planning 

Page 49 GAO-12-96 Federal Bureau of Investigation 

The study identified a need for a headquarters facility containing an 

estimated 2.6 million gross square feet—including 2.1 million useable 

square feet—to house nearly 11,600 personnel. Required site sizes were 

estimated at between 55 and 65 acres based on zoning assumptions for 

suburban and more urban locations. 

8. Consolidation report (Final Draft), 2010 

In 2010, the FBI’s Facilities and Logistic Services Division prepared an 

executive-level report to summarize past FBI and GSA findings and 

conclusions about the Hoover Building and both agencies’ studies of the 

need for a new headquarters facility. The report was intended to update 

FBI leadership on the current headquarters planning, costs, and 

recommendations prior to discussions with GSA and OMB. The report 

outlines a range of acquisition strategies that GSA and the FBI could use 

to acquire a new consolidated headquarters and identifies the FBI’s 

preferred strategy. 

According to the report, the FBI’s mission-critical headquarters operations 

are dispersed in 22 separate locations including the Hoover Building, up 

from 17 when GSA first studied the issue in 2005. Citing space and 

staffing requirements, the report identifies the need for a facility with 2.5 

million gross square feet, 2.2 million rentable square feet, and 1.9 million 

usable square feet to house an estimated 11,500 personnel. The report 

further anticipates a reduction of approximately 873,400 rentable square 

feet when the 22 current locations are consolidated, as well as an 

estimated annual savings of at least $30 million in leased housing costs. 
Appendix III: Financing Strategies Available for 

Capital Projects 

Page 50 GAO-12-96 Federal Bureau of Investigation 

This appendix describes potential financing strategies that may be 

considered in acquiring a new headquarters for the FBI. 

 Construction or modernization is funded through GSA’s Federal 

Buildings Fund (FBF). 

 We have previously reported that although ownership through federal 

construction is often the most cost-effective option,1

 pursuant to 

budget scoring rules, the full cost of construction of a capital project is 

recorded up front in the budget. 

 The FBF is the primary means of financing the operating and capital 

costs associated with federal space owned or managed by GSA. 

GSA’s Public Buildings Service charges federal agencies rent, the 

receipts of which are deposited in the FBF. Congress exercises 

control over the FBF through the annual appropriations process, 

setting annual limits on how much of the fund can be used for various 

activities. In addition, Congress may appropriate additional amounts 

for the FBF. Among the activities the FBF is used for are new 

construction, building repairs and alterations, building operations, and 

rental of space. 

 GSA officials report that lease construction by a developer could be 

pursued using GSA real property authorities in 40 U.S.C. § 585(c) or 

Section 412 of Public Law 108-447 (hereafter referred to as Section 

412).2

 40 U.S.C. § 585(c) authorizes GSA to lease federal property—for not 

more than 30 years—to a developer who would build a facility on a 

site owned by the government and lease it back to GSA. The title to 

the parcel never leaves government ownership, and at the expiration 

of the lease, the title to the building passes to the United States. 

 

1

GAO, Federal Real Property: Reliance on Costly Leasing to Meet New Space Needs Is 

an Ongoing Problem, GAO-06-136T (Washington, D.C.: Oct. 6, 2005). 

2

Pub. L. No. 108-447, 118 Stat. 2809, 3259 (2004). 

Appendix III: Financing Strategies Available 

for Capital Projects 

Federal Construction 

Using the Federal 

Buildings Fund 

Lease of Federal Site 

to a Developer Who 

Constructs a Facility 

On-site and Leases It 

Back to the 

Government (i.e., 

Ground Lease and 

Leaseback) 
Appendix III: Financing Strategies Available for 

Capital Projects 

Page 51 GAO-12-96 Federal Bureau of Investigation 

 Section 412 provides GSA with new, additional authorities to dispose 

of and use its real property inventory by sale, lease, exchange, and 

leaseback arrangements. Section 412 does not specify any limit on 

the term of the lease. 

 According to GSA, it has attempted to use 40 U.S.C. § 585(c) only 

once as a development authority, and it ultimately did not complete 

the project using this authority. GSA has never used Section 412 as a 

development authority. 

 Section 412 also authorizes GSA to retain the net proceeds from its 

real property disposals. Section 412 might enable GSA to use the 

proceeds of a sale—if the existing Hoover Building or site were sold—

to pay for some of a new project’s costs. 

 How a leaseback is structured will determine how it is scored, and it 

may be treated as a capital lease with the amount equal to the asset 

cost recorded up front in the budget.3

 Given the current budgetary environment, this type of arrangement 

may be more feasible now than in the past. Furthermore, even though 

GSA told us that it almost always recommends the traditional funding 

strategy—federal construction—it has said that in the current 

budgetary environment, it believes that alternative strategies such as 

a ground lease and leaseback arrangement may need to be 

considered. 

 FBI officials believe that if a ground lease and leaseback arrangement 

were to be pursued, the agency may be able to move into a new 

consolidated facility 2 or 3 years earlier than it could with a direct 

federal appropriation for design and construction, given the demands 

on the FBF. 

 

3

For more information, see OMB Circular No. A-11, Appendix B, “Budgetary Treatment of 

Lease-Purchases and Leases of Capital Assets” (2010). 
Appendix III: Financing Strategies Available for 

Capital Projects 

Page 52 GAO-12-96 Federal Bureau of Investigation 

 The government acquires space through an operating lease. 

 The government has no ownership of the land or the facility at any 

time. 

 We have previously reported that operating leases tend to be the 

most expensive approach to meeting long-term federal space needs 

and that over the last decade, GSA has relied heavily on operating 

leases to meet new long-term needs because it lacks funds to pursue 

ownership.4

 GSA currently leases more space than it owns. 

Use of this approach has grown because only the annual lease payment 

needs to be recorded in GSA’s budget request, reducing the up-front 

funding commitment but generally costing the federal government more 

over time. 

 

4

GAO-06-136T. 

Lease Construction 

(i.e., Leasing) 
Appendix IV: Comments from the Federal 

Bureau of Investigation 

Page 53 GAO-12-96 Federal Bureau of Investigation 

Appendix IV: Comments from the Federal 

Bureau of Investigation 
Appendix IV: Comments from the Federal 

Bureau of Investigation 

Page 54 GAO-12-96 Federal Bureau of Investigation 
Appendix V: Comments from the General 

Services Administration 

Page 55 GAO-12-96 Federal Bureau of Investigation 

Appendix V: Comments from the General 

Services Administration 
Appendix V: Comments from the General 

Services Administration 

Page 56 GAO-12-96 Federal Bureau of Investigation 
Appendix VI: Comments from the Department 

of Homeland Security 

Page 57 GAO-12-96 Federal Bureau of Investigation 

Appendix VI: Comments from the 

Department of Homeland Security 
Appendix VI: Comments from the Department 

of Homeland Security 

Page 58 GAO-12-96 Federal Bureau of Investigation 
Appendix VII: GAO Contacts and Staff 

Acknowledgments 

Page 59 GAO-12-96 Federal Bureau of Investigation 

David C. Maurer, Director, Homeland Security and Justice Issues, 

(202) 512-9627 or maurerd@gao.gov

David J. Wise, Director, Physical Infrastructure Issues, (202) 512-2834 or 

wised@gao.gov

In addition to the individuals named above, Michael Armes, Assistant 

Director; Sandra Burrell, Assistant Director; John Bauckman, Analyst-inCharge; Kevin Craw; Daniel Hoy; Bess Eisenstadt; Susan Michal-Smith; 

Linda Miller; Sara Ann Moessbauer; Joshua Ormond; Thomas Predmore; 

and Janet Temko made key contributions to this report. 

Appendix VII: GAO Contacts and Staff 

Acknowledgments 

GAO Contacts 

Staff 

Acknowledgments 

(542189)
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