UNITED STATES DEPARTMENT OF COMMERCE 

The Inspector General 

Washington, D.C. 20230 

June 28, 2010 

The Honorable Maria Cantwell 

Chair 

Subcommittee on Oceans, Atmosphere, 

Fisheries and Coast Guard 

Committee on Commerce, Science, & Transportation 

United States Senate 

The Honorable Olympia J. Snowe 

Ranking Member 

Subcommittee on Oceans, Atmosphere, 

Fisheries and Coast Guard 

Committee on Commerce, Science, & Transportation 

United States Senate 

Dear Madam Chair and Senator Snowe: 

This letter responds to your March 5, 2010, request that we examine the National Oceanic and 

Atmospheric Administration's (NOAA) decision to award a lease to the Port ofNewport, 

Oregon, for facilities to house NOAA's Marine Operations Center-Pacific (MOC-P). In your 

letter, you expressed concern about the MOC-P lease acquisition specifically and NOAA's 

facilities acquisition management systems more generally. We have completed our review ofthe 

events, decisions, and processes that culminated in the decision to award the 20-year operating 

lease to the Port ofNewport, Oregon. 

Our review extended back to the final years ofthe previous lease for MOC-P facilities on Lake 

Union in Seattle, Washington, and NOAA's efforts to find alternatives in the event the lease 

could not be extended beyond 2003. We summarize our findings below and provide details in the 

enclosure that address the specific questions you posed in your March 5, 2010, correspondence. 

Based on our review, we are unable to provide assurance that NOAA's award ofthe lease to the 

Port ofNewport provided the most cost-effective solution for MOC-P, or more generally for the 

government. The principal reasons for this conclusion center around two issues: NOAA limited 

its options based on a preference for a consolidated facility without a documented analysis, and it 

did not, in our view, adequately consider the use of existing federal facilities. NOAA's decisions 

in these two areas took place well before the agency initiated the competitive lease acquisition 

process. 

As detailed below and in our enclosure, there were errors and weaknesses in NOAA's 

competitive lease acquisition source selection; however, the outcome ofthe competition (Le., the 

award to the Port ofNewport) is unlikely to have changed in the absence ofthe weaknesses and 

errors in the source selection process. 
We are sharing the results of our review with the Secretary and Under Secretary Lubchenco. The 

Office ofInspector General does not have a decision-making role in the Department's real 

property acquisition process; accordingly, our report is advisory in nature. We will, however, 

follow up to determine what, if any, action is taken as a result ofour review. We note that the 

Secretary has recently directed a comprehensive review ofthe acquisition process across the 

Department, based, in part, on concerns surrounding the MOC-P lease acquisition. 

NOAA's Consideration ofExisting Federal Facilities 

First, we found that NOAA limited its consideration to a solution that consolidated all ships and 

related facilities at one location, even though a dispersed model is feasible and would have given 

the agency more options for siting the facility. In 2000, in anticipation ofthe possibility ofnot 

being able to extend its Lake Union lease, NOAA had considered a dispersed configuration on 

the premise that it was the most efficient and economic solution. Moreover, NOAA has been 

operating in a dispersed mode since the 2006 fire at the Lake Union site. Yet NOAA did not 

assess this possibility in its planning for the new lease. 

Second, NOAA did not adequately, in our view, consider federal facilities, such as use of 

federally owned space at NOAA's Western Regional Center or space available at the Federal 

Center South, leading us to conclude that NOAA did not make "every reasonable effort to utilize 

Government-controlled space," as required by the Department's Real Property Management 

Manual. This is especially significant given the Administration's emphasis on containing costs 

associated with federal facilities. Our fmdings on this issue are discussed in detail in the 

enclosure. 

We alerted NOAA to our concerns in this regard on May 26 ofthis year, prior to its fmal 

determination about practicable alternatives, and advised that NOAA should address these 

concerns. In a June 1, 2010, memorandum, the Administrator stated that she had tasked her staff 

with reviewing the issue and ensuring appropriate actions were taken to address it as NOAA 

fmalizes its analysis ofpracticable alternatives. However, on June 2, NOAA issued its fmal 

decision on its practicable alternatives analysis. Although this document inserted a discussion of 

existing federal properties, it provided no discemable new information about NOAA's process 

for considering the use of existing federal facilities. 

Source Selection Process 

With respect to source selection, both we and the Department's independent review ofNOAA's 

process found weaknesses and errors with NOAA's lease acquisition process for MOC-P. These 

problems reflect the highly technical nature of the source selection process. Based on our 

concerns about the source selection process, NOAA requested that the Department's Senior 

Procurement Executive and Director ofAcquisition Management review the source selection 

documentation associated with the lease acquisition for MOC-P. The Senior Procurement 

Executive's review is documented in a June 3, 2010, memorandum to NOAA's Chief 

Administrative Officer. This review identified a dozen weaknesses including the addition of a 

new evaluation factor late in the process, an overly complex and convoluted rating scheme, and 

issues with how the evaluation criteria for the proposals were applied. 

2 
Despite the weaknesses and errors in the source selection process, the outcome is unlikely to 

have changed. Specifically, two ofthe four unsuccessful offerors were deemed to have leasing 

costs that exceeded NOAA's lease authority. They, therefore, could not legally receive the 

award. While the third was within NOAA's lease authority, its proposal was more expensive 

than that ofNewport, was also in a floodplain, 1 and received a lower technical rating. Notably, 

the Department's Senior Procurement Executive stated in her June 3,2010, memorandum that 

she had identified process deficiencies but concurred with the ultimate conclusion that was 

reached by the official responsible for the award decision. Based on our analysis, we also concur 

that the outcome is unlikely to have changed in the absence ofthese weaknesses and errors. 

In our view, the more fundamental problems pertain to NOAA's process prior to the competitive 

lease process. A primary cause ofthese problems is grounded in the fact that NOAA did not 

subject the MOC-P project to a rigorous capital investment planning and oversight process. 

Unfortunately, NOAA's policy and procedures for facility capital planning and investment are 

unclear in their scope and requirements. Consequently, the MOC-P lease acquisition was subject 

to few process requirements, lacked any meaningful oversight, and was permitted to be 

unnecessarily schedule-driven. While the Department has a clear real property policy, NOAA did 

not follow it. NOAA thus proceeded with requirements for its desired option of a consolidated 

MOC-P facility and an operating lease, based on justification and consideration of alternatives 

that on their face and without additional documentation were significantly lacking. 

NOAA's organizational structure places the real property contracting officers in the Office ofthe 

ChiefAdministrative Officer rather than in the Acquisition and Grants Office. Separation ofthe 

real property contracting staff from the leadership, supervision, and expertise ofsenior 

contracting professionals in NOAA's contracting office reduces the agency's ability to ensure 

that it is properly carrying out its responsibilities and that NOAA applies high-quality and 

consistent procurement methodologies. 

Finally, although it is within NOAA's discretion to define the scope ofthe practicable 

alternatives analysis conducted in response to the recommendation in GAO's protest decision, it 

is difficult for those unfamiliar with the technical rules offederal acquisition to understand how 

the scope that NOAA chose constitutes a true alternatives analysis. NOAA limited its analysis to 

the four offers received in response to the MOC-P solicitation and defined "practicable 

alternative" as one that did not involve development in a floodplain and otherwise presented an 

executable lease under the terms ofthe solicitation. Since NOAA did not expand its definition of 

practicable alternatives to permit consideration of other options, such as government-owned 

space, and since NOAA was willing to allow development for MOC-P in a floodplain, the result 

ofthe practicable alternatives analysis could have easily been predicted from the outset. 

The issues surrounding the MOC-P acquisition exemplify the importance ofeffective capital 

planning and investment processes. While offerors who do not win an award can protest 

irregularities with the source selection process, the confidentiality ofthat process limits the 

1 Executive Order No. 11988, "Floodplain Management," states that if an agency has plans to conduct, support, or 

allow an action to be located in a floodplain, the agency must consider alternatives to avoid adverse effects and 

incompatible development in the floodplain. The MOC-P solicitation stated that an award of contract would not be 

made for a property located within a base floodplain or wetland unless the government has detennined that there is 

no practicable alternative. Here, GAO found that the selected offeror was, indeed, located in a floodplain thus 

triggering the duty for NOAA to cure this deficiency by engaging in a practicable alternatives analysis many months 

after the award. 

3 
information available to them and therefore the opportunity to protest all source-selection 

missteps. And, as in this case, decisions made prior to publication of information about the 

solicitation are, for the most part, internal. Thus, requirements definition, decisions about 

whether to thoroughly investigate the suitability offederal facilities, and decision-making 

regarding lease versus purchase were not subject to external scrutiny. These factors make it 

imperative that the senior officials and staff responsible for an acquisition ensure that agency 

capital asset planning and investment processes are coherent, rigorous, and implemented as 

intended. Based on our review, we have concluded that this was not the case for MOC-P. 

As noted above, Secretary Locke has recently directed a comprehensive review ofthe acquisition 

processes across the Department based, in part, on the concerns surrounding the MOC-P lease 

acquisition. We will support this review in whatever manner the Secretary requests. Once that 

review is completed, we will consider whether there would be a benefit to a broader review of 

NOAA's facilities acquisition process by our office as you have also requested. Ifyou have 

any questions, or ifwe can be of further assistance, please do not hesitate to contact me at 

(202) 482-4661. 

Todd J. Zinser 

Enclosure 

cc: The Secretary 

Dr. Jane Lubchenco, Under Secretary ofCommerce for Oceans and Atmosphere 

4
 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

This enclosure addresses the specific issues that the Office of Inspector General was requested to 

review in the March 5, 2010, request from Chairwoman Cantwell and Senator Snowe. Each issue 

is stated below, followed by our assessment. 

Issue 1 

Whether the Department of Commerce improperly exempted the MOC-P lease acquisition 

from the policies and procedures set out in NOAA’s Facility Capital Planning and Project 

Management Manual. 

OIG Assessment 

We found that NOAA determined that the MOC-P lease acquisition was not subject to its 

policies and procedures for capital planning because it did not meet the applicable thresholds. 

This decision, which was not well-documented, permitted a diminished level of oversight and 

planning compared to construction and repair projects of comparable or even lesser cost. As 

discussed below, NOAA’s policy is ambiguous and convoluted but can reasonably be read as 

requiring categorization of MOC-P as a major investment, making it subject to the Facility 

Capital Planning and Project Management Manual. Our observations indicate that NOAA 

should revisit how it addresses lease acquisitions under its policies. 

NOAA’s policy on facility capital planning, which is set forth in NOAA Administrative Order 

(NAO) 217-104 (Facility Capital Planning and Project Management Policy) and the 

accompanying Facility Capital Planning and Project Management Manual, does not explicitly 

establish rigorous planning and oversight requirements for lease acquisitions below the General 

Services Administration (GSA) prospectus threshold. In addition, both documents fail to indicate 

clearly how such leases should be categorized and analyzed. NOAA has informed us that the 

NAO’s requirements, including a business case analysis, only apply to lease acquisitions above 

the prospectus threshold. Further, NOAA’s position throughout our fieldwork was that the 

accompanying manual sets forth procedures for construction and repair of NOAA-owned 

facilities and therefore does not apply to leases such as MOC-P. 

At our June 17, 2010, exit conference, NOAA’s Chief Administrative Officer (CAO) informed 

us that our reliance on the manual’s requirements is not appropriate because the manual was 

prepared to support the OCAO’s Project Planning and Management Division’s construction 

project planning and management process. This division is separate from the Business Analysis 

and Investment Planning staff, which is in the immediate office of the CAO and is responsible 

for the capital investment planning process under the NAO including its application to MOC-P. 

The CAO also informed us that the manual, which we found was publicly available on NOAA’s 

website without a designation as a draft document as recently as June 24, 2010, has not been 

reviewed, approved, or implemented by the NOAA CAO staff or by the capital investment 

planning staff. NOAA did not inform us of the status of this manual during the course of our 

discussions regarding its provisions and applicability to MOC-P. Nevertheless, our reliance on 

the manual was reasonable and correct. Issued in 2005, the NAO authorized development of the 

manual, stating, “The Manual will be issued, updated, and maintained by the OCAO.” The 

manual was published on a website maintained by a division of the OCAO. 

Our review of the NAO revealed apparent internal inconsistencies and ambiguous provisions. 

The NAO divides capital planning projects into two categories—major and minor investments. 

This classification is fundamental because major investments are subject to the requirements of 

the NAO, while minor investments are subject to the lesser requirements specified in the manual. 

E-1 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

The NAO categorizes investments as major or minor based on total project costs, which 

explicitly include “moving and relocation associated with occupancy of new or significantly 

renovated buildings, or for lease acquisitions covered under this Order.” 

According to NOAA’s CAO, leases of space are only subject to the NAO’s procedural 

requirements when the dollar value of the rental payments exceeds the GSA’s lease prospectus 

threshold. However, the NAO does not state that leases are exempted from the total project costs 

measure. Likewise, the manual states: “NAO 217-104 requires a Total Project Cost estimate to 

determine the classification of a project as Major or Minor.” NOAA may have intended to tie the 

threshold for major lease investments directly to the lease prospectus threshold, but the policy’s 

language is unclear. 

This inconsistency illustrates the complexity of the policy, which does not provide clear direction 

on evaluating and planning for lease acquisitions. Several critical threshold provisions are 

ambiguous and convoluted. NOAA’s responses to our inquiries did not clarify how the policy, 

read on its own, supported NOAA’s decision not to subject this project to the NAO’s 

requirements, including a business case analysis. 

NOAA’s assertion that the manual was not intended to address lease acquisitions for space, but 

instead was developed for construction and repair projects in government-owned space, 

highlights another apparent contradiction. The NAO authorized the development of the manual 

and states that the manual sets forth procedures for minor investments. But NOAA’s position is 

that leases do not follow this decision-making path and only receive the oversight described in 

the NAO and manual when they exceed the prospectus level. It is worth noting that such leases 

would also be subject to oversight by the Department and GSA in any event. This position lacks 

clear support in the text of the policies. Had the MOC-P project been subjected to the total 

project costs measure, it would have been designated a major investment requiring greater 

NOAA oversight. 

The various ambiguities and internal inconsistencies in the NAO and the manual suggest that 

leases did not receive detailed consideration when the policy was developed, or alternatively that 

the policy was developed to provide these strictures only when the leases would simultaneously 

be subject to Department and GSA oversight through the prospectus process. NOAA should 

revise the policy to provide rigorous planning and oversight procedures for significant leases 

whose annual lease rate falls below the prospectus threshold. 

NOAA had discretion under the NAO and the manual to subject the MOC-P lease acquisition to 

the more stringent requirements of a major investment. After defining the dollar thresholds for 

major investments, the NAO goes on to state, 

Major Investment thresholds may be modified downward at the 

discretion of the NOAA CAO or the CAO’s designee. Such 

adjustments might be appropriate in situations involving the 

relocation of significant numbers of employees, projects with 

significant political or environmental sensitivity, or projects of great 

importance to the agency’s mission. 

These factors would have been relevant for MOC-P. The CAO has informed us that resource 

levels dictated the decision not to exercise this discretion. 

E-2 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

Ultimately, the language in the policies provides conflicting answers on whether this project 

should have been subject to a stringent set of planning and oversight requirements. NOAA’s 

position on how the project was classified as minor and subject to none of the specific 

requirements in the policies lacks clear support in the text. However, NOAA missed an 

opportunity to exercise its discretion to invoke the requirements based on the characteristics of 

the project. Such a decision would have required greater rigor and more deliberate planning for 

MOC-P. In addition, taking steps such as preparing a business case analysis would have 

produced clearer documentation to explain how NOAA reached its key decisions. Whatever the 

status of the manual, NOAA has affirmed that the immediate office of the CAO, through the 

Business Analysis and Investment Planning staff, has the responsibility for the facility capital 

investment planning process as outlined in the NAO. 

Considering the total project cost of MOC-P, the NAO itself could reasonably be interpreted to 

classify this project as a major investment, requiring a business case analysis, and it also gives 

the CAO discretion to treat such projects as major. The uncertain status of the manual only 

highlights the difficulty in determining the content and application of these key policies. 

Finally, chapter 5 of the Department’s Real Property Management Manual provides policies and 

procedures applicable to real property lease acquisitions. NOAA did not follow a number of 

these key policies and procedures, most notably those involving: 

o	 adequately surveying and periodically inventorying government-controlled facilities 

with the intent of relocating programs from leased space (Sections 5.1.3(b)(1) and 

5.4.1. (d)); 

o	 conducting lease versus purchase analyses (Section 5.4.16); 

o	 providing due consideration to maintenance and operational efficiency (Section 

5.1.3(b)(10)); and 

o	 ensuring all justifications and background information for all major decisions and all 

documentation is contained in the official lease file (Section 5.6.4). 

The first listed requirement is discussed in greater detail in Issue 4; the second and third 

requirements are further addressed in Issue 11. The fourth requirement is discussed throughout 

the enclosure. 

Issue 2 

Whether the MOC-P lease acquisition inappropriately bypassed internal agency oversight 

from the NOAA Facilities Investment Management Board (FIMB) and Department of 

Commerce Real Property Review Board. 

OIG Assessment 

The MOC-P lease was below the FY 2009 GSA prospectus threshold for lease of space, and in 

NOAA’s interpretation of its real property policy, the total project cost did not have to be 

considered in the determination of whether it was a major or minor investment. NOAA therefore 

did not deem MOC-P a major investment, and the project did not receive review by NOAA’s 

Facilities Investment Management Board or the Department of Commerce Real Property Review 

Board. However, as discussed in Issue 1, NOAA’s policy is ambiguous at best in its treatment of 

lease acquisitions. 

E-3 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

As was also noted previously, NOAA’s Facility Capital Planning and Project Management 

Policy and the accompanying manual provide the agency the discretion to apply the same 

stringent oversight requirements (including review by FIMB) to projects that fall below the 

prospectus threshold, but NOAA chose not to exercise this option. 

Also, as we reported in Issue 1, NOAA’s CAO has recently informed us the manual is an 

unapproved draft. In any event, given the total project cost of MOC-P, we reiterate our 

observation that NAO 217-104 could reasonably be read to treat it as a major investment, and 

further that NOAA’s CAO had discretion under the NAO to revise the relevant threshold to treat 

it as major. This point stands despite the unclear status of the manual. 

Issue 3 

Whether the MOC-P lease competition’s evaluation of technical factors and subfactors meet 

FAR 15.304(b)(2) requirement to “support meaningful comparison and discrimination 

between and among competing proposals.” 

OIG Assessment 

We found weaknesses and errors with NOAA’s application of the technical factors and 

subfactors. NOAA’s decision to award the MOC-P lease to an offeror located in a base flood 

plain, without consideration of practicable alternatives, was contrary to the solicitation and led to 

a successful protest of the MOC-P award. Upon learning that we had identified source selection 

issues, NOAA’s CAO requested that the Department’s Senior Procurement Executive and 

Director of Acquisition Management review the MOC-P source selection documentation. In a 

June 3, 2010, memorandum in response to this request, the Senior Procurement Executive raised 

significant concerns about the source evaluation process. The Senior Procurement Executive’s 

memorandum identified a dozen process deficiencies, but also pointed out the great disparity in 

pricing (i.e., low annual rental cost of the Port of Newport) and indicated her concurrence with 

the ultimate decision that was reached, based on review of the documentation provided. 

Our review similarly indicates that the outcome is unlikely to have changed in the absence of the 

weaknesses and errors, given that two of the four unsuccessful offerors were deemed to have 

proposals that were not under the prospectus threshold, as required by the solicitation, and the 

remaining offer, although below the threshold, received a lower technical rating. Nonetheless, 

the missteps that were identified are sufficiently numerous and serious to raise questions about 

the quality, integrity, and oversight of NOAA’s real property procurement processes. 

Examples of weaknesses identified by our analysis or that of the Department’s Senior 

Procurement Executive include the following: 

o	 A new evaluation factor, “Quality of Building and Pier,” was added late in the source 

selection process, after the initial evaluation of offers and request for best and final 

offers. As the Senior Procurement Executive noted, this was a questionable action 

that can give the appearance that “the Government is trying to ‘gear’ the award 

decision to a specific offeror.” She also noted that it raises the question of whether 

NOAA’s requirements were adequately defined in the solicitation and whether the 

competition should have been reopened for other potential offerors. 

o	 An overly complex and convoluted rating method was established. The method was 

difficult to understand and use in the evaluation, and it appears to have been only 

loosely applied as described in the solicitation. 

E-4 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

o	 The narrative evaluations did not always clearly support the ratings that were given. 

For example, the adjectival rating scale (Outstanding, Acceptable, Marginal) did not 

include a category for an unacceptable rating in any evaluation factor or subfactor, 

yet—in some instances and as would be expected in most source selections— 

deficiencies were identified by Source Evaluation Board members that should have 

led to an unacceptable rating in a certain factor or subfactor. 

o	 The narrative evaluations indicate that the Source Evaluation Board members did not 

have all their questions answered in preparing their final evaluations. This appeared 

to cause evaluators to make assumptions and inferences about the proposals rather 

than getting their questions answered in the appropriate manner. The real property 

contracting officer should have ensured that all questions and clarifications were 

addressed through discussions and negotiations with the offerors. To the extent that 

this may have been done, the information should have been reflected in the final 

Source Evaluation Board report. 

Issue 4 

NOAA’s failure to formally evaluate the potential use of existing federal properties, including 

the NOAA Western Regional Center (WRC) at Sandpoint, and whether utilizing such federal 

properties could have saved taxpayer dollars, increased efficiencies, and provided more ideal 

operations. 

OIG Assessment 

Federal and Department policy state that leasing may only be considered in the event that there is 

no government-controlled facility available to meet space requirements. Although the 

Department’s Real Property Management Manual requires agencies to make “every reasonable 

effort to utilize Government-controlled space that meets or can be economically altered to meet 

DOC’s requirements,” in our view, NOAA did not do this. This is especially significant given 

the Administration’s emphasis on containing costs associated with federal facilities. 

In its June 16, 2010, legal opinion regarding certain MOC-P issues, the Office of General 

Counsel (OGC) concludes that NOAA’s various unrelated efforts to consider other homeporting 

sites spanning nearly a decade constitute compliance with this requirement. While we recognize 

that the relevant regulation does not provide clear criteria for compliance, NOAA’s failure to 

systematically review and update information related to federal sites suggests that a reasonable 

effort was not made. Furthermore, the opinion’s recent citation of various documents that 

purportedly support NOAA’s compliance with this requirement is at odds with NOAA’s 

December 2009 response to the Committee’s inquiry in which NOAA indicated that it had “no 

responsive documents” on the issue of analyzing the feasibility of utilizing existing federal 

properties. 

Our review uncovered some evidence that NOAA considered other federal facilities. However, 

NOAA was not able to provide evidence that other federal facilities were systematically 

inventoried, analyzed, and rejected before initiating efforts to acquire a follow-on lease from 

other sources for MOC-P, nor was the decision to reject other federal facilities well-documented. 

Without any evidence of a systematic and documented approach, NOAA cannot demonstrate that 

there are no government-controlled facilities that meet its requirements and that it has fully 

complied with federal and Departmental requirements. 

E-5 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

For example, according to NOAA officials, NOAA had considered collocating with select Coast 

Guard and Navy facilities, but its consideration was not documented. In preparation for the lease 

acquisition, NOAA awarded a contract to Fraser & Fogle Architects, who subcontracted with 

MAKERS architecture and urban design to conduct an alternative site analysis to (1) investigate 

the most functional, efficient, and cost-effective options for reconsolidating MOC-P and (2) 

provide an indication of how each site might perform during the subsequent lease solicitation 

process. That study was completed in September 2008. Of the 32 ports, cities, and economic 

development councils contacted, 11 responded, offering a total of 22 potential site options for 

further analysis. The 22 were narrowed to a total of 15, only 3 of which were federally-owned: 

GSA’s Federal Center South, the Department of Labor’s Tongue Point, and NOAA’s Western 

Regional Center. In November 2008, in an apparent—but undocumented—rejection of those 

federal sites, NOAA issued the Solicitation for Offers. 

Prior to extending the lease at Lake Union in 2003, NOAA awarded a contract to SRI 

International to identify and evaluate potential facilities should the lease not be extended beyond 

2003. The study, released in June 2000, reviewed potential sites in select areas of Alaska and the 

greater Puget Sound in Washington State. In its legal opinion, OGC has argued that the review of 

potential sites in this study should be considered as part of its review of available federal 

facilities for the current MOC-P effort. However, in our view, the results of the study are too 

outdated to be considered relevant to the current procurement. SRI anticipated this, stating that 

the conditions for the facilities could “change rapidly” and that to effectively use the analysis 

further, study of the recommended sites should be performed “at the earliest possible time.” 

There is no indication that NOAA followed up on most of the federal facilities identified in the 

SRI study to determine their current status. In particular, as discussed below, NOAA did not 

adequately consider other opportunities to consolidate MOC-P operations at GSA’s Federal 

Center South or NOAA’s Western Regional Center (WRC) or support its contention that those 

facilities could not reasonably meet MOC-P requirements. 

Discussion of Federal Center South 

GSA made a specific offer of Federal Center South (FCS) in May 2008 prior to the solicitation 

being issued for the lease acquisition. The feasibility of FCS was brought up again in mid-July 

2009, prior to the award of the lease. In the latter instance, the Commanding Officer, NOAA 

Pacific Fleet, MOC-P, viewed the GSA offer as worthy, at least, of greater consideration and 

specifically asked that it be further explored. This request was based on the Commander’s 

operating experience at FCS since the 2006 fire and new developments, including American 

Recovery and Reinvestment Act (ARRA) funding, which would have made more space available 

since GSA’s previous offer. The Commander was suggesting that NOAA may want to determine 

what GSA could offer under these changed circumstances, whether NOAA could make it work, 

and if there would be a cost savings to NOAA, GSA, and the taxpayer. 

In a July 24, 2009, e-mail responding to the MOC-P Commander’s request to reconsider FCS, 

the Chief of NOAA’s Real Property Management Division, Western Region noted concerns 

about the narrow waterway under federal control and need for construction at a Superfund site. 

The e-mail also stated, 

In my opinion, even if GSA represented that they could develop the facility to meet 

your needs with ARRA funds, it is highly unlikely they could do so in any 

predictable time frame, if at all. In short, if the current procurement is canceled 

E-6 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

in the hopes of relocating to FCS, OMAO [Office of Marine and Aviation 

Operations] runs a substantial risk of having a dispersed fleet for the foreseeable 

future. 

Unless directed otherwise by my chain of command, my staff will remain focused 

on preparing to award a lease under the current procurement after a decision by 

the SSO [Source Selection Official]. 

After receiving this e-mail, the Commanding Officer immediately sent an e-mail to the Director 

of the Office of Marine and Aviation Operations and other OMAO staff stating, 

1) We know that since power improvements have been made and sewage hookups 

added, we can get three vessels into FCS. XO has confirmed that. 

2) We have also upgraded power at WRC since. Providing us more moorage 

options than we had a yr ago. 

3) The river front development part of FCS could be held as a longer term 

development opportunity, that would not require immediate implementation. FCS 

is not required to meet the SFO. 

4) The new development there may change things since a yr ago. 

5) We successfully worked two ships there last yr and had no trouble with getting 

one ship by the other (MCII and DY). We know a third could be moored there 

without any further waterfront development of the site. 

Things have changed since our first look, but [Chief, NOAA’s Real Property 

Management Division, Western Region] was not approachable about this last 

night. 

The real question is what could they offer and could we make it work and is there 

a cost savings to NOAA GSA and the taxpayer to look at that option? Is there risk 

in looking at it at this late date? 

I don't know if we'd have to cancel the solicitation process or just do a parallel 

look at FCS to see what is possible and flesh out the FCS option. It could save us 

and the taxpayer a lot of money. 

On August 7, 2009, NOAA awarded the lease to the Port of Newport. NOAA’s focus was clearly 

to place MOC-P in a consolidated facility by the June 30, 2011, termination date for the current 

lease. It is unclear why the project was so schedule driven. Given the apparent importance of the 

schedule to NOAA, it is also unclear why availability/timeline was made significantly less 

important in evaluating proposals than a variety of other factors. In essence, under the 

solicitation, NOAA considered proposals that involved occupying interim facilities to be 

acceptable for the lease acquisition, but did not consider use of interim facilities in order to take 

the time to thoroughly investigate existing federal properties. 

Discussion of Western Regional Center 

NOAA’s Western Regional Center was developed in the 1970s as a consolidated facility to 

house all of NOAA’s West Coast and Pacific operations, including MOC-P’s predecessor 

agency. The facility was dredged in anticipation of providing moorage for up to 17 vessels, and 

infrastructure was installed for two additional buildings before development was halted in the 

E-7 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

early 1980s due to budgetary issues. Currently MOC-P has a fleet of 10 vessels, only four of 

which are officially homeported in Seattle. None of the 10 are the large Class I vessels of the 

type in the Pacific fleet in the 1970s and 1980s. In fact, the Ronald H. Brown, which is 

homeported in Charleston, SC, is the only Class I vessel in the entire NOAA fleet. 

Despite WRC’s capacity, NOAA rejected it as a long-term, owned solution for MOC-P because 

of what NOAA characterized as litigation risk. NOAA’s assumptions regarding community 

opinion and litigation risk were based on actions from the 1970s and early 1980s, when public 

controversy arose around GSA’s disposition of the former Puget Sound Naval Air Station. 

NOAA wanted 100 acres for its Western Regional Center, the City of Seattle wanted a portion 

for a park, and another group sought to retain the former airstrip for use as a small airport. After 

considerable public controversy, haggling, and finally the intervention of U.S. Senator Warren 

G. Magnuson, NOAA and the City of Seattle prevailed. 

In 1976, NOAA published a final environmental impact statement (EIS) that concluded that 

location of all facilities at WRC would represent the most cost effective alternative to the various 

sites that had been under consideration. In December 1977, a local community group and 

numerous private citizens filed a lawsuit seeking injunctive and declaratory relief against the 

construction of ocean vessel berths at Sand Point. A preliminary injunction was granted in March 

1978 on the grounds that NOAA’s final EIS was deficient in its failure to adequately discuss 

alternative sites and for failing to discuss increased navigational hazards that would result from 

passage of large vessels through Montlake Cut to Lake Washington. 

NOAA subsequently prepared a supplemental EIS and issued a decision memorandum approving 

the consolidation of Seattle facilities at Sand Point. In response to NOAA’s request, the district 

court vacated the preliminary injunction. The plaintiffs then appealed, and in 1981, a federal 

appeals court decision affirmed the judgment of the lower court in NOAA’s favor and lifted the 

injunction on further construction at WRC. While the appeal was pending, NOAA scaled back its 

plans due to budgetary constraints. In 1983, NOAA entered into a second 20-year lease at Lake 

Union. While NOAA contends that it has since been operating under a commitment to the 

community to not homeport its fleet at WRC, it cannot provide any documentation of a 

formalized agreement to support its contention. 

NOAA has not done any recent work to reassess the feasibility of locating at WRC, including 

canvassing its Sand Point neighbors regarding their current views, documenting its litigation risk 

assessment, or even identifying what litigation risk it contemplated. In fact, the questions and 

answers document from NOAA’s December 2009 all-hands meeting with MOC-P employees 

states that NOAA is not certain of where the community’s views currently are on this issue. Our 

discussions with personnel from the City of Seattle’s Office of Economic Development and 

February 2010 letters from the City of Seattle and several key neighborhood associations 

adjacent to WRC show considerable local support for relocating MOC-P to WRC. 

NOAA has argued that moving the homeport to the WRC site would “pose unresolved hazards to 

recreational boating and navigation hazards to the fleet.” These issues surfaced during the 

litigation discussed above when there were a number of Class I vessels in NOAA’s fleet. As 

noted, no Class I vessels would need to be accommodated at MOC-P now. Further, NOAA has 

not demonstrated that hazards have posed problems while using the WRC pier since the 2006 

fire. 

E-8 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

NOAA has argued that moving the homeport to either the FCS or WRC would require funds to 

build new or expand existing pier facilities. Since the fire in 2006, MOC-P has used a 

combination of both facilities while only occupying office space at the Lake Union site. NOAA 

has not demonstrated why continued use of both facilities, in addition to other governmentcontrolled or leased office space, is not a viable solution either in the long-term or in the shortterm to allow for additional time to determine if a government-controlled facility can be used in 

the long-term. 

We recognize an agency’s discretion to define its requirements, and contrary to OGC’s June 

2010 legal opinion, we do not suggest that an ill-suited solution should drive the requirements. 

However, our review has indicated that the requirements were not clearly and systematically 

defined, and available options were not fully pursued. Regardless of what conclusion a more 

thorough and carefully planned process may have produced, NOAA should have treated the 

possible use of existing federal properties in a more systematic and comprehensive manner. 

Issue 5 

Whether the MOC-P lease was executed under proper authorities, including whether the lease 

signed with Newport exceeded the leasing authority delegated to the Department of Commerce 

by the General Services Administration. 

OIG Assessment 

In 2008, NOAA applied for and received special GSA lease delegation authority covering all 

aspects of the MOC-P lease prior to commencing the acquisition. NOAA was aware that if the 

MOC-P lease could not be accomplished under the GSA FY 2009 annual prospectus threshold 

($2.66 million), it would have to turn the lease acquisition over to GSA. Although all of the 

initial offers were in excess of the prospectus, NOAA was able to negotiate with the offerors, 

resulting in two that were below the threshold. NOAA, with necessary delegated lease authority, 

awarded the lease to the Port of Newport. 

Issue 6 

The appropriateness of the Department of Commerce’s decision to not include a termination 

for convenience clause in the MOC-P lease, and any negative consequences of that omission. 

OIG Assessment 

NOAA uses GSA’s standard lease for its lease awards for build-to-suit leases. NOAA stated that 

GSA does not include a termination for convenience clause in such leases because lessors must 

generally secure financing for such ventures and inclusion of a termination clause in the lease 

could cause lessors problems in securing financing if it were possible to break a lease for 

convenience. We reviewed both the lease and NOAA’s rationale and confirmed that omitting a 

termination for convenience clause was in keeping with GSA’s practice and the rationale given 

was supported by the relevant legal literature. 

Commerce’s General Counsel opined that if the government broke the lease in the absence of a 

cancellation clause, it could be responsible for damages. The GAO’s bid protest decision did not 

recommend that the Port of Newport suspend its work in delivering the site and buildings to the 

government, and the lease does not include a suspension of work clause that would authorize the 

government to issue a stop-work order. The Port of Newport continued to incur development 

E-9 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

costs under the lease, and NOAA did not mitigate potential damages while conducting the 

required practicable alternatives analysis. 

Issue 7 

The Department’s handling of the GSA prospectus threshold during the MOC-P competition, 

including whether bidders were misled or ill-informed as to the actual role and importance of 

the prospectus threshold in the evaluation of their bids. 

OIG Assessment 

The MAKERS site selection analysis, which was completed in 2008, estimated the probable 

range of bids as compared to the prospectus threshold and concluded that the MOC-P solicitation 

was likely to produce offers under the threshold. Based on this analysis, NOAA expected to 

complete the lease acquisition within the special delegated lease authority granted to it by GSA. 

NOAA did not include a provision regarding the prospectus threshold in the Solicitation for 

Offers, and all of the initial offers exceeded the threshold. After receiving the proposals, NOAA 

advised all four offerors of the prospectus threshold three times: 

o	 First, letters of clarification were sent to each offeror, which stated, 

“The annual rental rate (base rate + tenant improvements) offered is above the 

fiscal year 2009 threshold annual rental rate for leases, known as the prospectus 

 threshold (see www.gsa.gov/annualprospectusthreshold ). NOAA’s real estate 

broker, Public Properties LLC, and the Contracting Officer would like to schedule 

a conference call or meeting to clarify the rental rate.” 

o	 Second, the significance of the prospectus was explained during meetings held prior to 

the best and final offers 

o	 Third, letters were sent to each offeror requesting best and final offers, which said, 

“The lease rate is currently over the annual rent per year approved for this project. 

The Government may not award a lease for an amount that exceeds the prospectus 

level approved by Congress.” 

Two offerors researched the prospectus threshold on their own or with the assistance of their 

consultants and understood its significance clearly. One read the letter requesting the best and 

final offer, misinterpreting the term “may,” to mean that NOAA had the option of awarding a 

lease in excess of the prospectus by requesting congressional approval. 

A fourth explained that upon learning of the prospectus threshold during the meeting with 

NOAA procurement officials, it informed NOAA that it could not comply with the threshold and 

would not submit a best and final offer. Instead, it offered to sell the facility to NOAA. The same 

offeror advised that NOAA did not acknowledge the sales offer but encouraged it to submit a 

best and final offer anyway, stating that selection of the successful offer would be decided by a 

combination of technical evaluations and price, not on price alone. Ultimately the offeror 

submitted a two-lease best and final offer, one lease for the ground and another for the facilities, 

each of which was priced under the prospectus threshold but which in combination exceeded the 

threshold. 

Including the prospectus threshold in the solicitation is permitted but agencies are not required to 

do so. GSA has not historically included this information in its standard solicitation format. 

E-10 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

Going forward, it is our opinion that bidders should be apprised of such a limitation on an 

agency’s spending authority. Publishing this information would have aided NOAA in obtaining 

best value. It would have given potential offerors critical information for determining whether to 

bid and if so, for structuring their proposals to best suit NOAA’s requirements while maintaining 

the incentive to offer a fair and reasonable price through use of the competitive process. 

According to an attorney in GSA’s real property division, GSA occasionally does include the 

prospectus threshold in solicitations and is currently considering including this information in its 

standard solicitation template as part of an effort to re-engineer its lease acquisition process. 

Issue 8 

The significant disparities between initial estimates provided by a third-party contractor for the 

MOC-P lease and the bids ultimately received by NOAA. 

OIG Assessment 

The initial estimates reported by the MAKERS market assessment were developed for 11 sites 

from September 2007 through September 2008. The MOC-P Solicitation for Offers was issued in 

November 2008 and initial offers were due February 2009. Of the four initial offers received, all 

were in excess of the FY 2009 prospectus threshold for leased space. In their June 2009 best and 

final offers, two of four offers exceeded the prospectus threshold. 

NOAA did not prepare a contemporaneous analysis of the differences between the government 

estimates developed as part of the MAKERS study and the initial offers. However, in documents 

prepared in response to congressional inquiries and in discussions with us, NOAA attributed the 

disparity between the September 2008 MAKERS’ study estimates and the February 2009 initial 

offers to the effects of the financial system crisis on financial/credit markets—writing that “...the 

cost and availability for credit were likely directly impacted by this change in the financial/credit 

market. To the extent an offeror was impacted by the rate and availability of securing financing, 

this could have impacted their price proposal.” NOAA maintained that since two of the four best 

and final offers came in under the GSA prospectus, “NOAA’s determination that the lease could 

be executed below the prospectus level was validated.” 

We contacted the two offerors who submitted offers in excess of the prospectus threshold. Both 

stated that their estimates of costs associated with NOAA’s MOC-P requirements, rather than 

financing issues, caused them to exceed the prospectus threshold. 

Issue 9 

Whether the Department of Commerce sufficiently analyzed, understood, and incorporated 

long-term and indirect life-cycle costs for the MOC-P facility, as well as the operational and 

logistical implications of the proposed relocation. 

OIG Assessment 

NOAA’s financial analysis of the four offers submitted in response to the solicitation did not 

assess the total cost to the government, and NOAA provided no evidence that it had thoroughly 

considered the operational and logistical implications of the relocation. NOAA did make an 

adjustment to each offer during its evaluation of proposals to account for initial moving-related 

costs for locations beyond a 50-mile radius of the current Lake Union site. Intended to represent 

average move-related costs, the same cost ($7.3 million) was applied to the analysis for all 

E-11 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

applicable sites. According to NOAA, a complete life-cycle cost analysis could not be conducted 

because future travel, fuel, and support service contract costs were too speculative. 

Yet months after awarding the lease to the Port of Newport—as a result of questions raised 

concerning the total NOAA cost associated with the Newport award relative to the other offerors 

and to ensure that future year budget implications were addressed—NOAA developed a cost 

analysis with the objective of more fully forecasting and comparing the cost impact of the four 

offers that included estimated ship maintenance costs and associated contractual labor. We have 

not examined this analysis and cannot draw conclusions as to its adequacy. The analysis had no 

role in the source selection. 

A more extensive cost analysis than the analysis done later for source selection had been 

completed in 2008 as part of the MAKERS study of alternative sites. The MAKERS analysis was 

conducted primarily to compare prospective sites and determine whether they could potentially 

offer leases within the prospectus threshold. The cost analysis included some life-cycle costs 

such as operations and maintenance, cost of travel for MOC-P and NOAA personnel, cost to 

transport equipment to ships from customer locations, and the cost to relocate families to a new 

site. However, this analysis also omitted some life-cycle costs, stating that those such as 

additional travel for contract labor and additional cost of ship refueling due to the distance to 

government fuel sites, were too unpredictable to include. MAKERS claimed that the costs 

associated with these activities were not expected to significantly alter the relative life-cycle 

costs between potential sites. 

According to the “Capital Programming Guide,” Supplement to Office of Management and 

Budget (OMB) Circular A-11, consideration of full life-cycle costs is a key tenet of capital asset 

planning; thus, it should have been considered in NOAA’s lease award decision. In reviewing the 

MOC-P solicitation and source selection process, the Department’s Senior Procurement 

Executive also questioned NOAA’s failure to include total cost in its MOC-P evaluation and 

decision to relocate the operation and noted that the financial analysis would have been 

strengthened by inclusion of other costs to NOAA, although given the great disparity in pricing, 

such an analysis would not have been likely to change the outcome. 

Issue 10 

Whether the Department of Commerce sufficiently analyzed and considered the impacts on 

NOAA’s current employees and future workforce needs. 

OIG Assessment 

The MAKERS site selection analysis included factors assessing (1) the availability of skilled 

labor for each of the sites considered, noting that it was important that the appropriate type and 

variety of skilled labor be accessible and (2) a number of quality of life factors. NOAA also 

included a factor in the Solicitation for Offers that provided a qualitative assessment of the 

effects on NOAA’s future workforce needs and current employees. Access to labor was one of 

the most critical subfactors. However the subfactors making up the quality of life consideration, 

including—housing availability; schools; proximity to hotels, motels, food and recreational 

facilities; and proximity to a business district—were assigned the least weight in the overall 

technical evaluation process. To date there has been no formal assessment of whether current 

MOC-P staff would make the move to Newport and if not, what immediate and long-term 

E-12 
 

   

 

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

impacts may be anticipated on MOC-P’s ability to fulfill its mission subsequent to the impending 

relocation. 

Issue 11 

Whether key decisions in the MOC-P acquisition, such as the decision to pursue only leasebased solutions for the MOC-P facility, and the selection of the geographic scope of the 

agency’s initial Market Analysis, were sufficiently documented and based on proper analyses 

and procedures. 

OIG Assessment 

As discussed below, key decisions such as to pursue only leased-based solutions for MOC-P and 

the choice of delineated geographic area were not sufficiently documented, and the requirements 

and alternatives analyses that would help support such decisions were not performed. 

Pursuit of Leased-Based Solution Only 

Although Department of Commerce policy states that leasing is not a long-term solution for 

space needs, NOAA did not consider a purchase solution for MOC-P facilities requirements. It 

did not conduct a lease versus purchase analysis as is required by OMB Circular A-94, or 

otherwise analyze the relative merits of continuing its over 60-year history of a leased solution to 

MOC-P space requirements for another 20 years. Nor did it attempt to obtain funding for an 

owned solution at any time since 2000. 

In the past 10 years, the matter of purchasing the present Lake Union site for MOC-P was briefly 

discussed several times; however, no evidence was provided showing this approach was 

seriously explored. NOAA could provide no evidence of systematic efforts to assess the 

feasibility of purchasing or constructing facilities elsewhere except in the early consolidation 

efforts associated with the development of its Western Regional Center in the late 1970s and 

early 1980s. According to NOAA management, leasing was preferred because acquiring funding 

for an owned solution would have required considerable lead time and because funding of 

facilities has historically received lower priority than other funding requirements. NOAA 

management also cited MOC-P’s historical use of leased sites and its limited resources for 

conducting lease versus purchase analysis. 

NOAA emphasizes that it lacks general legal authority to purchase land and has failed in 

previous efforts to secure budget authority to proceed with federal-construction solutions to its 

real property needs. However, the fact remains that MOC-P and its predecessor agency have 

occupied leased space for decades despite a Department policy that leased facilities are not to be 

considered a permanent solution to space needs. Furthermore the Department clearly requires 

that a lease versus purchase analysis be accomplished in every instance where the asset 

considered for lease has a total fair market value in excess of $1 million. Accordingly, the 

expectation is that NOAA would prepare the required lease versus purchase analysis and if the 

analysis supported a purchase decision, would make an attempt to secure funding for the project. 

Had NOAA done so and documented its efforts, it would not only have complied with basic 

Department policies but also would have had a more convincing argument for its subsequent 

actions to secure yet another lease solution for MOC-P. 

E-13 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

Choice of Delineated Geographic Area 

NOAA’s choice of a delineated geographic area for the lease competition was not well 

supported. The area was expanded from Washington to Oregon—specifically to Portland and 

Astoria—based on an e-mail request from OMAO, which believed that the expansion would 

enhance competition. The subsequent study performed by MAKERS was designed to determine 

whether competition within the area was likely. NOAA provided no evidence that it had assessed 

the decision factors described in the Department’s Real Property Management Manual such as 

the desirability of a consolidated location over split locations, program client accessibility, 

environmental impact, personnel hiring and retention, travel time, transportation costs, and 

program needs that may require close proximity to other entities and agencies. NOAA also did 

not analyze the potential long-term or ancillary costs of various locations as a way to determine 

the appropriate geographic scope for the competition. 

The rationale for extending the delineated geographic area down the Oregon coast to Newport, is 

unclear. Consistent with the OMAO e-mail, the statement of work for the MAKERS study called 

for a study area consisting of the greater Puget Sound area, including U.S. waterside properties 

north to Bellingham, west to Port Angeles, south to the Columbia River, including Astoria, 

Oregon and southeast to Portland, Oregon on the Willamette River. This definition of the area 

persisted from MAKERS’ initial proposal through page 1 of the final report. However, page 2 of 

the final report included a study area map and states that NOAA and MOC-P identified a study 

area as “the Northwest coast and the Puget Sound region from Bellingham, Washington to 

Newport, Oregon.” NOAA and MAKERS’ management were unable to provide an explanation or 

documentation supporting the change in the study area. 

Analysis of Requirements and Alternatives 

Because NOAA did not follow a rigorous facilities capital investment planning process, 

requirements were not thoroughly assessed and documented, and acquisition alternatives were 

not systematically considered. This resulted in a requirement for a solution that consolidated all 

ships and related facilities in one location, an approach that reduced the locations available for 

consideration. By limiting its options, NOAA may have missed an opportunity to reduce costs. It 

also resulted in insufficient assessment of federal facilities and the lack of adequate consideration 

to the purchase of a facility. 

In November 2008, NOAA published its Solicitation for Offers, which presented requirements 

for a consolidated MOC-P facility. A dispersed solution had been considered by NOAA as the 

basis for the 2000 SRI study mentioned in Issue 4. At that time, SRI International was tasked 

with studying a dispersed model on the premise that it was the most efficient and economic 

solution for MOC-P. In addition, NOAA has been operating in a dispersed configuration since 

the 2006 fire at Lake Union site, which housed all MOC-P operations before the 2006 fire. 

In its June 2, 2010, Practicable Alternatives Analysis, NOAA asserts that the centralized solution 

was presented by senior program officials in NOAA’s Office of Marine and Aviation Operations 

and that it is NOAA’s preferred business model for conducting its MOC-P operations, based on 

consideration of operational efficiencies NOAA has experienced over the last several decades. 

NOAA maintains that the SRI study is no longer relevant to its requirements because at the time 

it was conducted, the NOAA Corps was significantly declining in size. Specifically, according to 

NOAA, at the time of the SRI study, “Saving money in the context of a shrinking requirement 

was a central theme.” We note that at the same time that NOAA maintains the SRI study is not 

E-14 
 

   

Enclosure Assessment of Issues Posed in March 5, 2010, Request 

relevant, OGC’s legal opinion cites the SRI study as a key part of its position that NOAA 

adequately considered existing federal facilities. 

In our view, consideration of a dispersed facility is still relevant. At the time of the SRI study, 

NOAA homeported four vessels at the Lake Union facility, the same number as are homeported 

at Lake Union today. Similarly, there has been little or no change in MOC-P shoreside staffing 

since the SRI report was issued. It is thus unclear why NOAA now contends that dispersed 

operations are not worthy of consideration and why it would not continue to seek efficiencies 

through alternative operating approaches. 

Finally, while the Department’s Real Property Management Manual provides for the operating 

unit head to determine space or facilities to meet authorized program needs, agencies should 

have a process in place to ensure that appropriate alternatives have been considered and that the 

most cost-effective solution to meeting the agency’s mission will be obtained. No such process 

appears to have existed for the MOC-P project. 

E-15