GAO

United States General Accounting Office

Report to Senator Byron L. Dorgan

U.S. Senate

July 2001 FACILITIES 

LOCATION

Agencies Should Pay 

More Attention to 

Costs and Rural 

Development Act

GAO-01-805

Page 1 GAO-01-805 Facilities Location

Contents

Letter 3

Results in Brief 5

Background 10

Recently Selected Federal Sites Were Mostly in Urban Areas 13

The Rural Development Act and Other Federal Policies on Location 21

Lessons From Private Sector Relocations That Relate to the Federal 

Government 26

Some Functions Can Potentially Locate in Rural Areas 31

Conclusions 35

Matters for Congressional Consideration 37

Recommendations for Executive Action 37

Agency Comments and Our Evaluation 37

Appendixes Appendix I: Objectives, Scope, and Methodology 44

Appendix II: List of Surveyed Federal Agencies That Recently 

Selected Site Locations 51

Appendix III: Location of the 32 Rural Sites (Areas With Populations 

of 25,000 or Less) in Our Survey 53

Appendix IV: Location Factors Considered by Private Sector 

Organizations 54

Appendix V: Federal Executive Branch Agencies With Some Level 

of Independent Authority to Acquire Real Property, 

Calendar Year 2000 55

Appendix VI: Survey of Federal Facilities’ Locations 57

Appendix VII: Comments From the General Services Administration 66

Appendix VIII:Comments From the Department of the Interior 70

Appendix IX: Comments From the U.S. Customs Service 72

Appendix X: GAO Contacts and Staff Acknowledgments 74

Tables Table 1: Commercial Rental Rates for Washington, D.C., and the 

10 Federal Cities, Calendar Year 1999 11

Table 2: Federal Executive Branch Full-Time Employees in MSAs

and Non-MSAs 12

Table 3: Established Locations for Sites in Survey: Urban or Rural 14

Table 4: Factors Agencies Used to Select the Delineated Area for

Federal Facilities in the Survey 16
Contents

Page 2 GAO-01-805 Facilities Location

Table 5: List of Primary Functions Performed at the Sites in the

Survey 20

Table 6: Definitions of Rural Used by Federal Agencies and Selected 

Private Sector Organizations 25

Table 7: Functions That Might be Located in Rural Areas 31

Table 8: Benefits and Challenges Associated With Rural Areas for Nine 

Functions 32

Table 9: Executive Branch Agencies With Some Level of Independent 

Authority to Acquire Real Property 55

Abbreviations

APHIS Animal and Plant Health Inspection Service

CBA Central Business Area

CICA Competition in Contracting Act of 1984

DOD Department of Defense

GSA General Services Administration

MSA Metropolitan Statistical Area

NARA National Archives and Records Administration

NCR National Capital Region

OMB Office of Management and Budget

OPM Office of Personnel Management

RDA Rural Development Act of 1972

USDA United States Department of Agriculture

USMS United States Marshals Service

USPS United States Postal Service
Page 3 GAO-01-805 Facilities Location

United States General Accounting Office

Washington, D.C. 20548 Letr

July 31, 2001

The Honorable Byron L. Dorgan

United States Senate

Dear Senator Dorgan:

This report responds to your request that we develop information on the 

types of federal functions that lend themselves to being performed at 

locations other than Washington, D.C., and federal regional cities.1

 You 

were concerned that federal agencies may not have been considering 

locating facilities in rural areas, as required by the Rural Development Act 

of 1972 (RDA),2

 particularly in light of recent advances in 

telecommunication technology. You specifically asked that we report on 

(1) What executive branch civilian non-Department of Defense functions 

have recently selected urban locations other than Washington, D.C., and 

the federal cities, compared to rural locations, and what factors, benefits, 

and problems were associated with such site selections?

(2) What federal laws and policies govern facility location and to what 

extent have agencies implemented this guidance? 

(3) What lessons can be learned from private sector site selections? 

(4) What functions lend themselves to being located in rural areas?

1

Prior to 1995, the Office of Management and Budget (OMB) established in Circular A-105 

the following 10 cities as the standard federal cities for federal regional headquarters: 

Atlanta, Boston, Chicago, Dallas, Denver, Kansas City, New York, Philadelphia, San 

Francisco, and Seattle. On June 8, 1995, OMB rescinded the Circular, stating that the way 

the federal government manages resources, agency efforts to reduce duplicative levels of 

oversight, and the expanded use of technology made a strict regional structure inefficient 

and unnecessary.

2

7 U.S.C. § 2204b-1.
Page 4 GAO-01-805 Facilities Location

To answer the first question, we used a questionnaire and follow-up 

interviews to survey agency officials regarding 115 sites acquired during 

fiscal years 1998 though 2000 by the General Services Administration 

(GSA) or other agencies that exercised their independent statutory 

authority to acquire sites. At your request, we excluded moves to 

Washington, D.C., and the 10 federal cities. We chose space of 25,000 

square feet or larger in order to review decisions with more significant 

economic importance.3

 To determine what federal laws and policies 

govern facility location, we interviewed GSA and other agency officials and 

reviewed relevant laws and policies. We contracted with a consultant4

 who 

surveyed 52 private sector companies and reviewed real estate-related 

literature discussing private sector site selections to determine what 

lessons the public sector could learn from private sector site selections. To 

determine which functions lend themselves to locations in rural areas, we 

used results from our questionnaire survey, interviews with real estate and 

other officials at 13 cabinet agencies, and observations from the 

consultant’s survey. 

3

By using a threshold of 25,000 square feet, we started with 166 sites that were acquired by 

federal agencies with the assistance of GSA in fiscal years 1998 through 2000. If we had 

used a threshold of 10,000 square feet, we would have initially considered 430 sites. The 

inclusion of sites under a smaller threshold size may have led to more rural sites being 

included in our survey, but the acquisitions of smaller sites probably would have been less 

important for considerations of economic impact.

4

John D. Dorchester Jr., of The Dorchester Group, L.L.C., Scottsdale, AZ. The study was 

entitled Office Location Considerations of Large U.S. Corporations: U.S. Government 

Potentials, March 31, 2001. Mr. Dorchester has an M.A (Economics), Specialization in Urban 

and Regional Planning and Land Economics. In 1990, Mr. Dorchester also did contract work 

for us on private sector locations, which was included in our 1990 report that dealt with 

location policies, Facilities Location Policy: GSA Should Propose a More Consistent and 

Businesslike Approach (GAO/GGD-90-109, Sept. 28, 1990).
Page 5 GAO-01-805 Facilities Location

For this survey, we defined rural area as an area having a population of 

25,000 and under. We had to select a threshold because RDA is unclear as 

to which population size to use for facility siting. The prior threshold, 

which was eliminated in 1996, used a population threshold of 50,000 and 

included a population density requirement. Population density data were 

not readily available; therefore, it was not feasible for us to use this 

definition.5

 We chose 25,000 or less because it was used to define rural 

areas by several federal agencies for purposes other than federal siting 

under RDA and private sector organizations that we identified. The 25,000 

population threshold resulted in the identification of 32 of the 115 sites in 

our survey as rural sites.6

 

We did our work from August 2000 to May 2001 in accordance with 

generally accepted government auditing standards. Although we obtained 

GSA’s and other agencies’ comments on factors they considered for site 

selections, we did not attempt to determine the appropriateness of 

agencies’ siting decisions. A more complete description of our scope and 

methodology is included in appendix I.

Results in Brief Since our 1990 study on this issue, federal agencies continue to locate for 

the most part in higher cost, urban areas. Eight of the 13 cabinet agencies 

surveyed had no formal RDA siting policy, and there was little evidence 

that agencies considered RDA’s requirements when siting new federal 

facilities. Further, GSA has not developed for congressional consideration 

a cost-conscious, governmentwide location policy, as we recommended in 

1990. 

Agencies chose urban areas for the majority (72 percent) of the 115 

recently acquired federal sites in our survey. Agencies said they selected 

urban areas primarily because of the need to be near agency clients and 

5

The information on population density for areas outside of cities was not readily available 

and is subject to change, pending the results of the 2000 census. Additionally, when the U.S. 

Department of Agriculture needs to determine whether a city that has applied for a grant is 

rural or not, and may have a population of close to 50,000, it has experts who survey the 

population density of the city’s surrounding area to determine whether the density meets the 

criteria for rural area. We did not use 50,000 as a population threshold because many of the 

definitions of rural used by federal agencies for purposes other than federal siting under 

RDA and private sector organizations we identified used thresholds of 25,000 or less.

6

See appendix III for a listing of the 32 rural sites.
Page 6 GAO-01-805 Facilities Location

related government and private sector facilities to accomplish their 

missions. Agencies that selected rural areas (areas with a population of 

25,000 or less) said they did so primarily to be close to existing support 

facilities and because of lower real estate costs. Agencies that relocated 

operations tended to relocate within the same areas where they were 

originally located, which were mainly in urban areas, while newly 

established locations were almost equally divided among urban and rural 

sites. The private sector companies our consultant surveyed reported that 

they select urban areas over rural areas largely because of the need to be 

near a skilled labor force.

The functions that were recently located predominately at urban sites were 

loans/grants/benefits administration processing, inspection and auditing, 

and health and medical services. The functions that were recently located 

predominately in rural areas were research and development, supply and 

storage, automatic data processing, and finance and accounting. Some 

functions were placed in both urban and rural areas, such as law 

enforcement, which was the most prevalent function located in both areas, 

although it was located more often at urban sites.

Agencies said the benefits experienced by sites in urban areas were 

efficiency in agency performance due to the ability to share existing 

facilities, close proximity to other agency facilities and employees, and 

accessibility to public transportation for both employees and clients. 

Agencies that chose rural sites said that benefits included close proximity 

to agency support facilities, improved building and data security, and better 

access to major transportation arteries. Among the problems reported for 

urban sites were lack of building security and expansion space. For rural 

sites, problems included the lack of public transportation, location far from 

other agency facilities, and insufficient infrastructure for high-speed 

telecommunications.

RDA and the Competition in Contracting Act of 1984 (CICA),7

 a federal 

procurement law, as well as executive orders, provide guidance on site 

location decisions. When considering the areas in which to locate, RDA 

requires all executive departments and agencies to establish policies and 

procedures giving first priority to the location of new offices and other 

facilities in rural areas. However, we also observed that the definition of 

"rural" used in RDA for federal facilities siting is unclear because the 

7

41 U.S.C. §253.
Page 7 GAO-01-805 Facilities Location

previous definition used by RDA for locating federal facilities was 

eliminated by amendment in 1996. Furthermore, only 5 of the 13 cabinet 

departments we contacted had a policy to implement RDA. Also, our 

survey of federal facilities showed that for about 73 percent of 113 

responding sites, respondents said either they did not use RDA in site 

acquisitions or they did not know whether it was used. We recognize that 

consideration of RDA may not have led agencies to make different location 

decisions.

Once agencies have selected their respective geographic areas for possible 

locations, CICA generally requires agencies to obtain full and open 

competition for the facility acquisitions within the areas selected. 

Moreover, when agency mission requirements lead agencies to urban areas, 

other federal policies apply. These are (1) Executive Order 12072, which 

requires that central business areas (CBA) be given first preference for the 

location of federal facilities that need to be in urban areas and (2) 

Executive Order 13006,8

 which requires the federal government to utilize 

historic properties and districts to the extent possible, especially those 

located in CBAs.

Lessons that the public sector can learn from the private sector in locating 

facilities involve factors that contribute to minimizing acquisition costs. 

These factors are (1) taking advantage, where possible, of certain 

incentives offered by localities to attract new employers, such as free land, 

and (2) the lower real estate and labor costs available in some areas. The 

private sector cited these two factors as having influenced their decisions 

more frequently than did the federal agencies in our survey. We recognize 

that federal agencies’ missions and socioeconomic goals associated with 

the government’s siting policy may sometimes preclude them from taking 

advantage of the potential savings represented by these factors; however, 

those agencies that have flexibility in determining the location of a function 

may be able to take advantage of one or both of these factors so long as 

they are not offset by other higher operations costs. Existing policy, as 

stated in Executive Order 12072 or RDA, which emphasizes locating federal 

facilities in either urban or rural areas to promote economic development, 

does not recognize costs to the government as a factor to be considered in 

8

The National Historic Preservation Act Amendments of 2000 (P.L. 106-208, 114 Stat-318 

(2000), amends section 110(a)(1) of the National Historic Preservation Act, 16 U.S.C.§ 470h2, to codify Executive Order 13006, issued May 21, 1996, which encourages federal agencies 

to use historic properties prior to acquiring, constructing or leasing buildings for offices and 

facilities. 
Page 8 GAO-01-805 Facilities Location

the selection of geographic areas for sites. In our survey of 115 sites 

acquired by federal agencies, agencies reported that for only 15 sites did 

any agency perform cost analyses of alternative geographical areas, to 

compare costs of different areas in which a site could ultimately be 

selected. In 1990, we recommended that GSA develop for congressional 

consideration a more cost-conscious, governmentwide location policy. In 

1991, GSA required agencies to consider real estate and labor costs as part 

of a temporary regulation that subsequently expired; however, its 1997 

replacement did not contain the requirement. In 2001, GSA officials could 

not explain to us why the requirement was deleted.

According to our review and the study done by our consultant, certain 

functions have potential for rural area locations. In fact, some are already 

in rural areas, such as research and development, finance and accounting, 

law enforcement, and data processing. Other potential functions for rural 

areas include records archiving and teleservicing.9

 Locating offices in rural 

areas depends primarily on the following factors: (1) whether the agency 

has flexibility in determining the location of a function (i.e., the function’s 

mission does not require close proximity to a specified population); (2) 

whether the function can be efficiently and effectively performed in a 

location remote from the agency’s main offices; and (3) whether the 

function can be performed without a large, technical workforce often 

associated with urban areas. 

We are suggesting, as matters for consideration, that Congress (1) enact 

legislation to require agencies to consider, along with their missions and 

program requirements, real estate, labor, and other operational costs and 

applicable local incentives when deciding whether to relocate or establish 

a new site in a rural area or urban area and (2) amend RDA to clarify the 

definition of “rural area” for facility siting purposes to facilitate its 

implementation.

We are recommending that the Administrator of GSA, in GSA’s role as the 

federal government’s central property management agency, revise its 

guidance on federal facility siting to (1) advise customer agencies that they 

should consider, along with their missions and program requirements, real 

estate, labor, and other operational costs and applicable local incentives 

9

As an example of teleservicing, the American Teleservices Association represents call 

centers, trainers, and consultants that facilitate telephone, Internet, and E-mail service and 

support. 
Page 9 GAO-01-805 Facilities Location

when deciding whether to relocate or establish a new site in a rural or 

urban area; (2) require that each federal agency subject to GSA’s authority 

provide a written statement to GSA demonstrating that, in selecting a new 

facility location, the agency, as required by RDA, had given first priority to 

locating in a rural area, and if a rural area was not selected, the agency’s 

justification for the decision; and (3) define the term “rural area” to provide 

its customer agencies with a single definition for purposes of federal siting 

under RDA until Congress amends RDA to define the term.

Seventeen of the 21 agencies commenting on a draft of this report 

responded that they either had no comments, agreed with the information 

in the report, or suggested technical changes, which we considered and 

incorporated within this report where appropriate. GSA, the Department 

of the Interior, the Internal Revenue Service, and the U.S. Customs Service 

had more extensive comments.

In response to our recommendation that GSA provide agencies with a 

single definition of a rural area for the purpose of RDA until Congress, as 

we suggested, defines the term, GSA agreed to develop a definition for 

agencies subject to its authority. Also, while GSA agreed to issue a bulletin 

to make other agencies aware of the definition of rural, it responded that it 

had no authority to establish or require the use of a definition for all federal 

agencies. The Internal Revenue Service (IRS) responded that the definition 

should be based on terms other than population alone. We clarified our 

report to reflect GSA’s authority to develop a definition only for its 

customer agencies and noted that Congress may want to consider factors 

in addition to population in defining a rural area.

Regarding our recommendation that GSA require agencies to submit a 

written statement demonstrating the agency had given first priority to 

locating in a rural area and if a rural area was not selected, to include a 

justification, GSA agreed to require the written statement but said that 

requiring a justification would put GSA in the position of second-guessing 

the agencies. IRS also questioned the need for the justification. The 

Department of the Interior commented that the requirement should be 

limited to a minimum dollar threshold, exempt operations that are being 

expanded in the same local area, and be required only if the agency does 

not select a rural area. We emphasized in the report that we are not 

recommending that GSA evaluate the justifications, but we remain 

convinced that a justification is needed to help document that agencies 

gave first priority to rural areas, but only when a rural area was not 

selected. We also believe that expansions of existing operations should be 
Page 10 GAO-01-805 Facilities Location

subject to this requirement if they might involve a relocation. Although we 

agree that a minimum dollar threshold may be reasonable conceptually, we 

noted that RDA does not include a dollar threshold.

In response to our recommendation that agencies be required to consider 

certain cost factors along with agency mission when determining whether 

to locate a site in a rural or urban area, the Department of the Interior said 

that the recommendation should be limited to the establishment of new 

offices. The Internal Revenue Service commented that if Congress 

supports a location policy that is economically based rather than socially 

based, Congress should repeal and replace the RDA. We clarified our 

recommendation to consider only relocations and new offices. Also, we 

noted that we are not suggesting that Congress establish a location policy 

based solely on economics but rather that cost should be one of the factors 

considered in siting decisions.

The U.S. Customs Services responded that it generally agreed with the 

information in the report and provided additional information on the 

uniqueness of its facilities.

Background GSA is the central management agency for acquiring real estate for federal 

agencies. According to a GSA policy official, GSA is responsible for 

managing the acquisition of about 40 percent of the federal government’s 

office space and 10 percent of all government space. Other agencies, such 

as DOD, have their own authority to acquire space. To acquire real estate, 

an agency must either go through GSA using GSA’s statutory authority, use 

its own statutory authority, or obtain delegated authority from GSA. If it is 

using GSA, the agency must provide GSA with a "delineated area," the 

geographic area where the agency wants to be located. GSA’s policy 

requires its staff to review each delineated area to confirm its compliance 

with all applicable laws and regulations. Once an agency has selected a 

delineated area, GSA, under CICA, is to acquire the site within the selected 

area through the use of full and open competitive procedures. If an agency 

acquires property independently of GSA using its own statutory authority, it 

is responsible for compliance with all relevant laws and regulations but is 

not subject to GSA regulations.

In 1990, we were asked by Senator Kent Conrad to look at policies that 

guide civilian agencies in selecting facility locations and determine whether 

any changes in federal location policies were warranted. We reported that 

GSA needed to develop a more consistent and cost-conscious 
Page 11 GAO-01-805 Facilities Location

governmentwide location policy that required agencies, in meeting their 

needs, to maximize competition and select sites that offer the best overall 

value, considering such factors as real estate and labor costs. Since 1990, 

at least two matters raised in that report have remained unchanged. First, 

GSA has not developed for congressional consideration the cost-conscious 

and consistent governmentwide location policy that we recommended. 

The second item that remains unchanged is that rents in the CBAs of 

federal regional cities and Washington, D.C., are generally higher than the 

rents in non-CBA sections of those same cities—an average of $4.03 per 

square foot higher within calendar year 1999, as shown in table 1. 

Table 1: Commercial Rental Rates for Washington, D.C., and the 10 Federal Cities, 

Calendar Year 1999

a

Class A buildings are in excellent locations and are either new buildings or old buildings that are 

competitive with new buildings.

b

Population for these cities ranged from 402,000 to 7,381,000.

c

Data obtained from Trammell Crow Company, a commercial real estate firm. All other rental rates 

were obtained from the Society of Industrial and Office Realtors.

Source: Society of Industrial and Office Realtors, the Bureau of the Census, and Trammell Crow 

Company.

According to an April 2001 GSA congressional testimony, high rents for 

class A commercial space in San Francisco, CA, caused three federal 

Average commercial rents for class A buildings ($/sq.ft)a

Cityb

Central business

area

Noncentral business

area

Difference (Non-CBA

compared to CBA

Atlanta $22.36 $23.45 (1.09)

Boston 40.50 31.20 9.30

Chicago 33.23 26.00 7.23

Dallas 23.07 24.10 (1.03)

Denver 24.58c 23.98c .60

Kansas City 20.00 20.50 (0.50)

New York 47.90 39.05 8.85

Philadelphia 24.22 22.24 1.98

San Francisco 47.76 36.36 11.40

Seattle 33.27 27.74 5.53

Washington, D.C. 36.57c 34.51c 2.06

Average $32.13 $28.10 $4.03
Page 12 GAO-01-805 Facilities Location

agencies to move from leased space in San Francisco to leased space in 

Oakland, CA, where rates were 25 percent to 30 percent lower.

One change that occurred since our 1990 report that affected the 

workplace is the surge in telecommunications services, including 

widespread access to the Internet. One result of telecommunications 

services is the practice of “telecommuting,” whereby employees can work 

from home or remote offices for all or part of their work week. 

Telecommuting increased significantly, rising from a level of 4 million U.S. 

workers in 1992, according to the Department of Transportation, to 16.5 

million in 2000, according to the International Telework Association and 

Council.10

Despite the continuing relative higher cost of urban commercial rents, 

federal employment generally remains focused in Metropolitan Statistical 

Areas (MSA),11 as shown in table 2. 

Table 2: Federal Executive Branch Full-Time Employees in MSAs and Non-MSAs 

Note: Numbers include DOD civilian employees, but not DOD uniformed personnel, Postal Service 

employees, or intelligence agency employees.

a

Total includes 57,476 employees for whom there were no MSA/Non-MSA data.

b

For about 4 percent of federal employees, there were no MSA/Non-MSA data. Total does not add to 

100 percent because of rounding.

Source: Office of Personnel Management.

10The International Telework Association and Council is a nonprofit organization 

specializing in telework. 

11An MSA is an area having 1 or more counties containing a city of 50,000 or more or a 

Census Bureau-defined urbanized area and a total population of at least 100,000 (or 75,000 in 

New England).

Number and percent of federal full-time employees in fiscal 

years 1990 and 2000

1990 2000

Location Number Percent Number Percent

MSA 1,686,959 85 1,371,381 85

Non-MSA 295,556 15 191,057 12

Total 1,982,515 100 1,619,914a 97b
Page 13 GAO-01-805 Facilities Location

Recently Selected 

Federal Sites Were 

Mostly in Urban Areas 

During fiscal years 1998 through 2000, agencies chose urban areas for 

about 72 percent of the 11512 acquired federal sites in our survey and 

selected rural areas (those with a population of 25,000 or less)13 for about 

28 percent of the sites. Agencies reported that mission was the primary 

factor used to determine the location for over one-half of the sites and that 

the mission dictated the need to be in close proximity to clients, other 

agency facilities, and related organizations. GSA conducted the 

acquisitions for 79 of the sites using GSA authority, and agencies using their 

own statutory authority conducted the acquisitions for the other 36 sites. 

Agencies selecting urban sites reported that close proximity to other 

agency facilities and organizations contributed to cost savings resulting 

from less travel, more prompt on-site support, and ease in technology 

sharing. Other benefits reported for urban sites included the availability of 

a skilled labor pool and accessibility to public transportation for both 

employees and agency clients. Agencies that chose rural sites reported 

some similar benefits, stating that close proximity to related or support 

agency facilities and proximity to industries with which the agency is 

connected resulted in more efficient use of agency resources and less 

travel. Other benefits reported for rural sites included better building and 

data security and improved access to major transportation arteries.

Officials reporting for about 66 percent of the sites either said no problems 

existed at the sites (45 percent), or they did not respond to the survey 

question (21 percent). For the remaining sites, agencies selecting urban 

areas reported problems such as lack of secure buildings, lack of 

expandable space, and high rental rates. Agencies selecting rural areas 

reported problems such as lack of infrastructure for high-speed 

telecommunications and a lack of access to public transportation.

Functions performed at the sites varied, and some functions were 

performed in both urban and rural areas.

12The 115 sites involved 32 different agencies (25 of which were either components of 

cabinet departments or the cabinet departments themselves, and 7 were independent 

agencies). See appendix II for a list of the agencies that selected the locations.

13As noted in the objectives, scope, and methodology section in appendix I, 26 of the rural 

sites that fell within the 25,000 population threshold were located in MSAs in which large 

cities were located. A list of the rural sites is in appendix III.
Page 14 GAO-01-805 Facilities Location

Most of the Sites Were 

Located in Urban Areas

Eighty-three (or 72 percent) of the sites in our survey were located in urban 

communities (areas with a population above 25,000), and 32 (or 28 percent) 

were located in rural areas (areas with a population of 25,000 or below). 

Most of the 115 site selections involved relocations within existing 

communities (56) or expansions of existing sites (14). As table 3 shows, 

the number of newly established locations (locations for agency functions 

for which the agency neither relocated nor expanded an existing site) was 

almost evenly distributed between rural and urban areas. Functions at the 

six rural sites selected for newly established locations included 

storage/inventory (mainly Census Bureau material for the 2000 Census), air 

traffic control, and law enforcement. The seven urban areas selected for 

the newly established locations included functions such as document 

archiving, passport production, law enforcement, and inspection of 

diseased plants near plant quarantine areas. 

Table 3: Established Locations for Sites in Survey: Urban or Rural 

Note: The 83 sites in urban areas were in areas with populations of over 25,000, and the 32 sites in 

rural areas were in areas with populations of 25,000 or fewer.

Source: GAO analysis of survey data.

As table 3 shows, of the 32 sites that were relocated from one community 

to another community, 18 were in urban areas and 14 were in rural areas. 

Among these relocated sites, law enforcement and administrative program 

management were the most prevalent functions; and the two functions 

were about evenly divided between urban and rural sites. However, the 

finance and accounting and research and development functions were 

found only at rural sites. Functions at the urban relocated sites included 

inspecting/auditing, tax administration, and aviation operations. 

Type of move

Sites in

rural area

Sites in

urban

area Total sites

Percent of

total sites

Relocated within same community 7 49 56 48.7

Relocated from one community to 

another community

14 18 32 27.8

Newly established location 6 7 13 11.3

Expansion of same site 5 9 14 12.2

Total sites 32 83 115 100
Page 15 GAO-01-805 Facilities Location

An agency can use GSA to acquire property on its behalf or acquire the 

property independently, using either statutory authority or authority 

delegated by GSA. No major difference existed in the percentage of urban 

sites selected, regardless of whether the site decisions were made by 

agencies working with GSA or made independently of GSA. About 71 

percent of the sites that GSA procured on behalf of agencies were in urban 

areas, and about 75 percent of the sites agencies selected independently of 

GSA were in urban areas.

Agencies Reported That 

Agency Mission 

Requirements Determined 

Site Location

From a list of 12 factors (and an overall “others” category) in our survey, 

agencies reported that they considered numerous factors to determine the 

delineated area14 for the sites in our survey. As shown in table 4, agencies 

considered mission in making location decisions for 82 of the sites in our 

survey. The next most-cited factors were transportation efficiencies, which 

was considered for 46 sites; and particular space needs, such as specialized 

floor layouts, which was considered for 45 sites.

14GSA defines the delineated area as the specific boundaries within which space will be 

obtained to satisfy an agency’s space requirements.
Page 16 GAO-01-805 Facilities Location

Table 4: Factors Agencies Used to Select the Delineated Area for Federal Facilities in the Survey

Note: The number of sites we surveyed totaled 115. Eighty-three were in urban areas (areas with 

population of over 25,000), and 32 were in rural areas (areas with population of 25,000 or less). The 

number of sites will not total to these numbers because agencies cited more than one factor as the 

reason for selecting the delineated area for some of the sites.

Source: GAO analysis of survey data.

In their discussion as to why agency mission was the primary factor for site 

selections, agencies most often cited the need for the site to be in close 

proximity either to the mission service area, other agency facilities, other 

government agencies, or related private sector organizations. For example:

• The U.S. Customs Service (Customs) reported that it chose the 

delineated area for its international mail inspection function in Carson, 

CA, because the U.S. Postal Service (USPS) had relocated its 

international mail operations to Carson, CA, and Customs needed its 

inspection function to be near the international mail site. Customs also 

reported that its cybersmuggling center needed to be located within the 

concentration of private computer-based industries in Fairfax, VA.

• U.S. Attorney offices reported that their policy is to be within four 

blocks of federal courthouses because, as the principal litigators for the 

U.S. government, U.S. Attorneys need to be available for courtroom 

Number of sites where each factor was 

considered during the location decision

Factors agencies used to determine where to locate federal facilities

Number of

rural sites

Number of

urban sites

Total

number of

sites

Percent of

total sites

Agency mission requirements (e.g., need to be near customers) 19 63 82 71.3

Transportation efficiencies (proximity to interstate highways, airports, rail lines) 14 32 46 40.0

Particular space needs (size or nature of facility) 14 31 45 39.1

Public transportation (proximity to mass transit, such as subways and buses) 10 23 33 28.7

Low real estate costs 14 11 25 21.7

Use of existing infrastructure investment 13 9 22 19.1

Employees must be located near coworkers at another site 11 10 21 18.3

Needed sufficient competition to meet the Competition in Contracting Act 

requirements

8 9 17 14.8

Recruitment and/or retention issues (e.g., quality of life, available applicant pool, 

and local economic conditions)

5 11 16 13.9

Personnel cost considerations 6 9 15 13.0

Political considerations/congressionally directed 1 8 9 7.8

Low labor costs 1 2 3 2.6
Page 17 GAO-01-805 Facilities Location

activities on a regular basis. U.S. Marshals Service (USMS) offices also 

reported that USMS offices need to be colocated with the courts 

because the agency’s primary concern is the safety and security of the 

judiciary, the judicial process, and its participants.

• The Department of Agriculture’s Animal and Plant Health Inspection 

Service (APHIS) reported that the delineated areas of its sites in our 

survey were selected because they needed to be in close proximity to 

diseased plant quarantine areas. The Federal Emergency Management 

Agency also reported that its Pasadena, CA, site in our survey needed to 

be in close proximity to a disaster area.

• The Immigration and Naturalization Service reported that its national 

records center had to be located as close as possible to a National 

Archives and Records Administration (NARA) center in Lees Summit, 

MO, to reduce the costs associated with a high-volume records transfer 

to NARA. 

• Agencies providing services to the public, such as the Social Security 

Administration (SSA), IRS, and the Department of Veterans Affairs, 

reported that the delineated areas for their offices/clinics were selected 

because the agencies needed to be as close as possible to the 

client/patient population that the agencies service.

Agencies did not select rural areas for 83 of the 115 sites in our survey. For 

about 75 percent of the 83 sites, agencies cited mission requirements as the 

reason for not selecting rural areas. They again cited proximity 

considerations and said that locating the sites in rural areas would have 

placed them too far from their clients, other supporting agency facilities, 

related research facilities, or the function they had to monitor. For 

example, GSA’s Federal Technology Service reported that it did not 

consider a rural area for its site because the function needed to remain in 

the Washington, D.C., area to have access to its major customers and 

telecommunications providers. 

Other reasons for not selecting rural areas included the need to be near 

public transportation and rural areas’ lack of the necessary labor pool and 

sufficient space. Some respondents also said that rural areas can have high 

costs, such as for transportation to airports. The Bureau of Reclamation 

stated that a water resources management operation was not located in a 

rural area because of the unavailability of a building to meet space needs. 

The IRS said it did not place a telephone−based customer service site in a 

rural area because of the need for a large number of recruitment candidates 

who were available only in a more heavily populated area. Similarly, the 

SSA said that when one of its teleservicing centers needed additional 
Page 18 GAO-01-805 Facilities Location

space, it did not move the center to a rural area because of the difficulty of 

locating sufficient space and personnel in rural areas.

In addition to agency mission, lower real estate cost was one of three main 

factors that contributed to the selection of the 32 rural sites. Respondents 

representing almost one-half of the rural sites identified (1) lower real 

estate costs; (2) particular space needs (e.g., specialized space for security 

reasons); and (3) transportation efficiencies, such as access to major 

arteries, as factors considered in the site selection decisions. 

Agencies Reported Benefits 

and Problems With Selected 

Sites

In response to our survey’s request to list three chief benefits and 

problems, if any, associated with the selected location for sites in our 

survey, agencies reported numerous benefits and few problems for both 

urban and rural locations. The benefits of urban areas included close 

proximity to other agency resources, such as support facilities and related 

government agencies, and related private sector organizations. Agencies 

said proximity was a benefit because it contributed to more prompt on-site 

support and cost savings resulting from less travel and transportation of 

material over distances and eased technology sharing and daily interaction 

among related organizations. For example, both the Forest Service and 

APHIS reported that their sites’ close accessibility to universities allowed 

for sharing of advanced technologies and improved collaboration between 

the agency and university researchers. Also, the Department of Veterans 

Affairs reported that the urban location of one of its clinics was a benefit 

because it was in close proximity to the city’s medical center complex. 

Other benefits cited for sites in urban areas included the availability of a 

skilled labor force, the ability to use existing infrastructure, and the 

accessibility of public transportation for both employees and clients.

Agencies that located sites in rural areas reported some similar benefits, 

such as close proximity to related or support facilities, other program 

employees, and the industry to which the agency was connected. They said 

proximity resulted in more efficient use of agency resources and less 

travel. Other benefits reported for rural sites included improved building 

and data security and accessibility to major transportation arteries.

Agencies reported they had no problems with about 45 percent of the sites, 

either urban or rural. They provided no response to this survey question 

for another 21 percent of the sites. For the remaining sites, agencies 

selecting urban areas reported problems such as lack of secure buildings 

and expandable space, traffic problems, high rental rates, and specific 
Page 19 GAO-01-805 Facilities Location

problems with buildings needing repairs. Agencies selecting rural areas 

reported problems such as a lack of proximity to other agency facilities and 

public transportation, great distance from major airports, and a lack of 

necessary infrastructure for telecommunications and city waste 

management services.

Functions Located at 

Established Sites Varied 

Widely

As table 5 shows, agencies reported that the three most common functions 

located in rural areas included law enforcement, research and 

development, and supply storage and inventory control. Three functions, 

automated data processing, finance and accounting, and social services, 

were located only in rural areas.
Page 20 GAO-01-805 Facilities Location

Table 5: List of Primary Functions Performed at the Sites in the Survey

Note: The number of sites we surveyed totaled 115. Eighty-three were in urban areas (areas with 

population of over 25,000), and 32 were in rural areas (areas with population of 25,000 or less). The 

total number of sites in this table is 114, because 1 agency reported that although it obtained the 

space, none of the agency’s functions were performed at the site; other agencies use the site. The 

total percentage does not add to 100 due to rounding.

Source: GAO analysis of survey data.

The three most common functions located in urban areas were law 

enforcement, administration of loans/grants/benefits and processing of 

applications and claims, and administration/program management. Law 

enforcement was the most prevalent function in both urban and rural 

areas, although it was more prevalent in urban areas. Also, although 

research and development and supply storage and inventory functions 

Primary functions

Sites in

rural area

Sites in

urban

area

Total

sites

Percent of

total sites

Law enforcement, security, border patrol 7 24 31 27.2

Loans/grants/benefits administration/application and claims processing 1 11 12 10.5

Administration/program management 2 8 10 8.8

Supply storage and/or inventory control 5 3 8 7.0

Research and development 5 3 8 7.0

Health and medical services 1 5 6 5.3

General support services 2 2 4 3.5

Document archiving and storage/records management 1 3 4 3.5

Plant health inspection/quarantine areas/disaster operations 0 4 4 3.5

Aviation and space operations 2 2 4 3.5

Parks, natural resources, environment management/water resources management 0 3 3 2.6

Telephone-based customer service (teleservicing) 1 2 3 2.6

Inspecting/auditing/examining/monitoring 0 4 4 3.5

Automated data processing and/or electronic storage 2 0 2 1.8

Finance and accounting 2 0 2 1.8

Equally combined functions (enforcement/benefits/medical services) 0 2 2 1.8

Passport operations 0 2 2 1.8

Tax administration 0 1 1 0.9

Social Services 1 0 1 0.9

Communications 0 1 1 0.9

Insurance operations 0 1 1 0.9

Morale, well-being, and recreation 0 1 1 0.9

Total sites 32 82 114 100.2
Page 21 GAO-01-805 Facilities Location

were more prevalent in rural areas, sometimes they were also located in 

urban areas. 

The Rural 

Development Act and 

Other Federal Policies 

on Location

Several laws and executive orders affect the location of federal facilities. 

The laws, which take priority over the executive orders, include RDA, the 

primary law on rural siting; and CICA, a law governing federal acquisition 

generally. When considering areas in which to locate, RDA "directs the 

heads of all executive departments and agencies of the Government to 

establish and maintain departmental policies and procedures giving first 

priority to the location of new offices and other facilities in rural areas.” 

Any move by an agency to new office space in another location would be 

considered a new office or facility covered by RDA. Once agencies have 

selected their respective areas for possible locations, CICA generally 

requires that agencies obtain full and open competition for facilities 

acquisitions within the areas selected. 

The two primary executive orders on federal facility location decisions are 

Executive Order 12072 of August 16, 1978; and Executive Order 13006 of 

May 21, 1996. Executive Order 12072 specifies that when the agency 

mission and program requirements call for facilities to be located in urban 

areas, federal agencies must give first consideration to locating in a CBA 

and adjacent areas of similar character. Executive Order 13006 requires 

the federal government to utilize and maintain, wherever operationally 

appropriate and economically prudent, historic properties and districts, 

especially those located in the CBA.
Page 22 GAO-01-805 Facilities Location

Agencies acquiring real estate are responsible for complying with federal 

laws and executive orders. If GSA is acquiring the real estate for an agency, 

then GSA regulations state15 that GSA is responsible for ensuring 

compliance with “all applicable laws, regulations, and Executive orders." 

However, if the agency is making the acquisition under its independent 

statutory authority, or through a delegation from GSA, the agency is 

responsible for compliance with relevant laws and regulations. Some 

agencies also have been provided statutory authority to acquire real estate 

for different purposes. Some agencies such as the Tennessee Valley 

Authority (TVA) have been provided broad authority. TVA is authorized to 

purchase or lease real property that it deems necessary or convenient in 

transacting its business.16 Other agencies’ statutory authority is for more 

limited purposes. For example, the Secretary of the Interior is authorized 

to lease buildings and associated property for use as part of the National 

Park System17 and the Secretary of the Treasury is authorized to lease 

space for the storage of unclaimed or other imported merchandise that the 

government is required to store.18

Limited Consideration of 

RDA 

RDA states that executive departments and agencies must establish 

policies and procedures to give first priority to the location of new offices 

and other facilities in rural areas. However, among the 13 cabinet 

departments, only the departments of Agriculture (USDA), Commerce, 

Labor, Transportation, and the Treasury had written policies specifically 

addressing RDA. The other departments (Justice, Health and Human 

Services, the Interior, Housing and Urban Development, State, and 

Education) said they did not have policies on RDA; and two (Energy and 

Veterans Affairs) said they expect all employees to abide by all policies on 

facility acquisitions, but they also had no written policies regarding RDA.

In addition, many agency real estate specialists in field offices also said 

either their agencies did not have RDA policies or they did not know if their 

agencies had such policies. Among the 113 sites for which we received 

responses, 61 sites involved agencies that did not have RDA policies, and 24 

15Interim Rule D-1, 41 C.F.R. 101-21, appendix to subchapter D § 101-17.205(h).

1616 U.S.C. § 831c.

1716 U.S.C. § 1a-2.

1819 U.S.C. § 1560.
Page 23 GAO-01-805 Facilities Location

involved agencies that had policies. Respondents for 28 sites also said that 

they did not know if their agencies had RDA policies.

Our survey also requested respondents to report which of the four 

applicable laws and executive orders were considered in the acquisition of 

the surveyed sites. Agencies reported that 

• CICA was considered for 73 percent of the 113 sites for which a 

response was received,

• Executive Order 12072 (on locating in CBAs) was considered for 50 

percent of the 113 sites for which a response was received,

• Executive Order 13006 (on historic districts) was considered for 43

percent of the 112 sites for which a response was received, and 

• RDA was considered for about 27 percent of the 113 sites for which a 

response was received.

Agencies reported that they considered RDA for 8 of the 36 sites that were 

acquired independently of GSA. Agencies also reported that RDA was 

considered for 21 of the 79 sites acquired by GSA. Conversely, for about 73 

percent of 113 sites for which a response was received, respondents said 

they either did not use RDA in site acquisitions or did not know whether it 

was used.

To determine if GSA was requiring agencies to apply RDA, we looked at 

GSA regulations and examined 33 GSA lease files. GSA regulations state 

that federal agencies using GSA are responsible for identifying their 

delineated areas,19 consistent with their missions and program 

requirements in accordance with applicable regulations and statutes, 

including RDA. The agencies must also submit to GSA a written statement 

explaining the basis for their delineated areas, and GSA is responsible for 

reviewing these delineated areas to confirm their compliance with laws and 

regulations. We looked at 33 files involving GSA leases made from 1989 

through 2000 in 3 GSA regions, including the Rocky Mountain Region, 

based in Denver; the Greater Southwest Region, based in Ft. Worth, TX; 

and the Mid-Atlantic Region, based in Philadelphia. We found no mention 

of RDA in any of the 33 acquisition files. In the files we examined, we did 

find cases where GSA requested modification of the delineated area in 

19Interim Rule D-1, 41 C.F.R 101-21, appendix to subchapter D (101-17.205(a). GSA defines 

the delineated area as the specific boundaries within which space will be obtained to satisfy 

an agency’s space requirements (101-17.205(p).
Page 24 GAO-01-805 Facilities Location

response to other criteria, such as CICA. Additionally, a GSA official in the 

National Capital Region (NCR) provided us with a checklist of documents 

that are expected to be in each NCR lease file. Neither the 1999 checklist 

nor the 2000 update of that list mentioned RDA, although both mentioned 

Executive Orders 12072 and 13006.

What Constitutes Rural or 

Rural Area Is Unclear

In addition to agencies’ limited consideration of RDA, the act’s definition of 

"rural" is unclear. RDA provides that rural areas, for the purpose of federal 

facilities location decisions, are defined in the private business enterprise 

exception in section 1926(a)(7) of title 7 of the U.S. Code. Prior to 1996, 

this exception in 7 U.S.C. § 1926(a)(7) defined rural as “all territory of a 

State that is not within the outer boundary of any city having a population 

of fifty thousand or more and its immediately adjacent urbanized and 

urbanizing areas with a population density of more than one hundred 

persons per square mile, as determined by the Secretary of Agriculture 

according to the latest decennial census of the United States: Provided, that 

special consideration for such loans and grants shall be given to areas other 

than cities having a population of more than twenty five thousand.”

However, in 1996, 7 U.S.C. § 1926(a)(7) was repealed and replaced with a 

new section 1926(a)(7) that defines “rural” and “rural areas” but no longer 

contains a provision or even a reference relating to the private business 

enterprise exception.20 The new section 7 U.S.C. § 1926(a)(7) defines 

rural—but only for water and waste disposal grants and direct and 

guaranteed loans—as "a city, town, or unincorporated area that has a 

population of no more than 10,000 inhabitants."

Different Agencies Use 

Different Rural Definitions

Government agencies have different definitions of what constitutes a rural 

area. For example, GSA uses two different population thresholds to define 

rural area for purposes of RDA. According to GSA Interim Rule D-1, a rural 

area is any area "that (i) is within a city or town if the city or town has a 

population of less than 10,000 or (ii) is not within the outer boundaries of a 

city or town if the city or town has a population of 50,000 or more and if the 

adjacent urbanized and urbanizing areas have a population density of more 

than 100 per square mile."

20Public Law No. 104-127, 110 Stat. 888, 1123 (1996).
Page 25 GAO-01-805 Facilities Location

Meanwhile, as table 6 shows, other federal agencies use other definitions of 

rural to implement various federal programs; and private organizations use 

other definitions as well.

Table 6: Definitions of Rural Used by Federal Agencies and Selected Private Sector Organizations

a

A nongovernmental organization.

Source: Department of Agriculture, the Bureau of the Census, Department of Housing and Urban 

Development, OMB and private sector organizations.

Agency/organization Population thresholds and definitions for rural area

Census Bureau Under 2,500 or open country

Department of Agriculture’s Economic 

Research Service

Under 2,500

(Metro or nonmetro area)

Department of Agriculture’s Rural Business 

Opportunity Grant Program

Under 10,000 

(Open country not associated with urban area) USDA defines open country as open 

space separated from any adjacent densely populated urban area.

Department of Agriculture’s Rural Housing 

Programs

10,000 and under

Department of Housing and Urban 

Development’s Rural Housing and Economic 

Development Program

One of five ways: 

(1) Under 2,500 population (metro or nonmetro area).

(2) Counties with no urban population of 20,000 or more.

(3) Rural portions of "extended cities,” as defined by the Census Bureau.

(4) Open country that is not part of or associated with an urban area.

(5) Not over 20,000 and not in MSA.

Plants, Sites and Parks Magazinea 20,000 and under

(50 miles or more from major city or MSA)

Department of Agriculture’s Intermediary 

Relending Program

Under 25,000

National Middle School Associationa Under 25,000

Housing Assistance Councila 25,000 or fewer

General Services Administration (Rural 

Development Act implementation)

Under 10,000 or under 50,000

Department of Agriculture’s Rural Business 

Enterprise Grants

Under 50,000

Department of Agriculture’s Rural Business 

Cooperative Service

Under 50,000

OMB Nonmetropolitan areas (areas other than "core counties” containing one or more central 

cities with at least 50,000 residents or an urbanized area and a total population of at 

least 100,000 (75,000 in New England) and adjacent communities that have a high 

degree of social and economic integration with the core counties).
Page 26 GAO-01-805 Facilities Location

Lessons From Private 

Sector Relocations 

That Relate to the 

Federal Government

According to our study and our consultant’s review, location factors 

considered important by the private sector for minimizing costs might 

benefit the public sector. These factors are (1) incentives offered by 

localities to attract new employers, such as free land; and (2) the lower real 

estate, labor, and operational costs available in some areas. The private 

sector cited these two factors as having influenced their location decisions 

more frequently than did the federal agencies in our survey. We recognize 

that federal agencies’ missions may sometimes preclude them from taking 

advantage of the savings represented by these factors. However, in 

instances where an agency has flexibility in locating a function, the agency 

may be able to take advantage of one or both of these factors, so long as 

they are not offset by other higher operational costs.

Location Factors Important 

to the Private Sector

According to our consultant, there are two broad steps involved in office 

location decisions made by the private sector. The first step is to determine 

whether a given location is functionally suited to achieve the purposes of 

the office that is to be located. The second step is to test the location for its 

ability to meet a range of factors that have been shown to be important in 

meeting required goals. Our consultant found that corporations strongly 

preferred urban locations over rural ones. The determining location factor 

for most companies, he said, derives from a specific location’s 

characteristics.21 The private sector considers numerous factors in making 

location decisions, and the relative importance of the factors appears to be 

company specific.22 However, our consultant’s literature search and survey 

of 52 private sector companies identified several factors as the main areas 

of consideration in the private sector location decisionmaking process. 

They were (1) transportation and logistics, (2) labor availability and cost, 

(3) real estate costs, and (4) business climate and business incentives. Of 

these factors, some were location factors considered by the federal sites 

we surveyed and some were not.

21According to our consultant, the inclusion of manufacturing firms in his study did not 

skew the results because the study focused only on office locations and not on the location 

of manufacturing facilities. 

22See appendix IV for location factors the private sector considered.
Page 27 GAO-01-805 Facilities Location

Transportation: Access to 

Highways, Trains, and Airports 

Access to highways and major thoroughfares is important for employees 

who commute and essential to maintaining connections to companies’ 

suppliers and customers. When asked to rate the importance of 

transportation and logistics, 17 of the 52 respondents in our consultant’s 

survey gave it the highest rating for headquarters offices, and over one-half 

gave it the highest rating for satellite (field) offices.23 With the increasing 

globalization of markets, easy access to airports is also very important in 

corporate location decisions. Professional services, such as those of 

accountants and lawyers, also increasingly require access to airports, our 

consultant said. 

Transportation factors were also important to the public sector. In our 

survey of federal agency sites, officials for 40 percent of the sites said 

access to transportation, such as airports, trains, and highways, was an 

important factor in their location decisions. Examples cited by the agencies 

included easy access to airports for trainees from around the nation and 

access to highways for service centers.

Availability and Cost of Labor According to our consultant, the availability and cost of labor are among 

the most important location factors for the private sector. Most of the 

corporations responding to our consultant’s survey rated these among the 

top location factors considered when locating either their headquarters or 

field offices. Asked to rate the importance of "availability and cost of labor 

supply,” of the 52 survey respondents 30 gave it the highest rating for 

headquarters offices and 32 gave it the highest rating for satellite (field) 

offices. Our consultant emphasized that the availability of sufficient and 

qualified labor is crucial to any business location decision because, even in 

a low-wage area, the need to train a qualified workforce can wipe out 

savings from lower labor costs. Our consultant also stated that while many 

small towns on the fringes of metropolitan areas have experienced rapid 

growth, their small populations suggest that they will remain small, which 

can be a liability to attracting companies.

Labor costs include not only wage rates but also benefits, unemployment 

insurance, and workmen’s compensation requirements. Labor costs also 

include costs associated with recruitment and training and the competition 

for labor within the same area. Some companies try to avoid areas where 

23Our consultant’s report indicated that satellite (field) offices are similar to federal regional 

offices in that they are located apart from the principal office, are smaller, and serve a 

particular function.
Page 28 GAO-01-805 Facilities Location

they have to compete with major competitors for the same labor pool 

because of the possibility that skilled labor would be unavailable or that 

competitors would drive up the wage rate. According to our consultant, 

these factors are particularly important when considering rural areas 

where educational qualifications, in some cases, are not so readily 

available.

Availability and cost of labor were not location factors considered by 

federal agencies for most of the sites in our survey. Respondents reported 

that they considered personnel costs, including lower labor costs and 

recruitment and retention costs, in location decisions for no more than 23 

of the 115 sites in our survey. Whether the federal government can adopt 

the private sector’s practice in this area is open to question because, as 

previously mentioned, the primary location factor cited by federal agencies 

for the sites in our survey was agency mission. If agency mission dictates 

where most of the federal facilities have to be located, specifically in close 

proximity to clients, then the agency may have little flexibility to realize 

costs savings from low-wage areas.

Lower Real Estate and Operating 

Costs

Since at least 1990, real estate costs have consistently ranked among the 

top 10 factors influencing private sector location decisions. Real estate 

costs include direct costs (i.e., land, building, and occupancy costs such as 

rent and utilities), and indirect costs (costs such as shipping, 

transportation, and storage). When direct costs are higher in one 

community than another, the addition of lower indirect costs may result in 

a lower overall real estate cost in the community with higher direct costs. 

When asked to rate the importance of real estate costs, 31 percent of the 

corporate survey respondents gave this factor the highest rating for 

corporate headquarters offices, and 63 percent did the same for corporate 

field offices. 

Real estate cost was cited less frequently by federal agencies in our survey 

than by the private sector in making site location decisions. Agencies 

reported that for about 22 percent of the sites in our survey, lower real 

estate cost was a factor in the decision. If the public sector adopted this 

private sector practice, specifically for functions where agencies have 

flexibility as to where they may be located, potential savings could be 

offered by lower real estate costs, so long as the savings are not offset by 

other higher operating costs. 

Business Climate and Business 

Incentives 

The business climate of an area, including its business incentives, is a cost 

factor highly important to the private sector. When asked to rate the 
Page 29 GAO-01-805 Facilities Location

importance of an area’s business climate, 54 percent of respondents in our 

consultant’s survey gave it the highest rating. Business climate factors 

include the general business potential and receptivity of a community to 

the corporate purpose. This includes the community’s economic health, its 

organization and preparedness for growth, and the capacity of the 

community to support future growth of the locating company. For 

example, zoning issues are critical. Similarly, business incentives, such as 

tax abatements, free land, or infrastructure improvements offered by a 

community, are indicative of the business climate and are highly important 

location decision factors. According to our consultant, while incentives do 

not replace the need for a company’s location to make good business sense, 

incentives become a means of distinguishing among otherwise acceptable 

alternatives.

Business incentives were mentioned by only 2 agencies in our survey of 115 

sites. USDA said it chose a site at a local university for wildlife research 

because Colorado State University made land available at no cost. In 

return, USDA agreed to work in cooperation with university students on 

wildlife research. The Environmental Protection Agency (EPA) said when 

the lease expired for its regional office in Kansas City, KS, it relocated to 

another location within the city because the city provided free land. EPA 

reported that this was a “win-win” situation for both the agency and the city 

because the agency saved on its real estate costs, and the office benefited 

the economically depressed area where it is located. 

The limited use of local incentives by agencies in our survey contrasts with 

the emphasis the private sector places on incentives to save costs. For 

example, functions that need not be in proximity to the public or other 

facilities—such as training, data processing, document distribution, or 

telephone-based servicing—have the potential to take advantage of local 

incentives. While federal agencies cannot take advantage of all local 

incentives, such as tax relief, they might make use of other local incentives. 

For example, our 1990 report, referred to earlier, noted that the Bureau of 

Engraving and Printing chose a site in Ft. Worth, TX, in the late 1980s in 

part because of incentives offered by the locality. The incentives included 

the donation of 100 acres of land and construction of a building, a total 

package valued at between $12.5 million and $15 million.

Public policy may have an impact on the extent to which federal agencies 

may seek incentives provided by local communities. The public sector 

sometimes seeks to provide economic assistance to certain areas, rather 

than the reverse—consider how the government may benefit from an area. 
Page 30 GAO-01-805 Facilities Location

RDA and executive orders, such as Executive Order 12072, promote 

locating federal agencies in rural areas or in the central business districts of 

urban areas to foster their economic development. In contrast, according 

to our consultant, the private sector seeks the reverse—consider how the 

corporation may benefit from the community.

Government Lacks 

Cohesive Location Policy 

The government lacks a cohesive overall location policy that requires 

agencies to consider costs when initially deciding whether to locate a site 

in a rural or an urban area. In 1990, we reported that the government was 

not as cognizant of cost considerations as was the private sector and that 

government policy was aimed at improving the economic development of 

either rural areas through RDA or urban areas through the executive 

orders. We recommended that GSA develop for congressional 

consideration a more consistent and cost-conscious govermentwide 

location policy that considers such factors as maximizing competition and 

taking advantage of lower real estate and labor costs in order for the 

government to lower its acquisition and operating costs. In 1991, GSA 

issued a temporary regulation requiring agencies to consider the 

availability of local labor pools, pay differentials for employees, local 

incentives offered, and real estate costs for prospectus-level projects24

whose missions did not dictate a geographic area. However, the 

requirement was eliminated in 1997 when GSA revised its location 

regulations. GSA officials could not explain why the requirement was 

deleted when we asked them in May 2001.

On the basis of our latest survey of 115 sites, we found that little 

consideration in the site acquisition process was given to the differing costs 

of alternative areas. Besides finding little interest in lower real estate costs 

or in the use of certain local incentives, our survey also found that only 15 

sites were acquired using cost analyses of alternative geographic areas, 

which compared costs of different areas in which a site could ultimately be 

selected. However, no regulation presently calls for such an analysis.

In 1990, we reported that GSA, as a central management agency, had not 

provided leadership to assist agencies in implementing and complying with 

24GSA is required to prepare project descriptions called prospectuses for space acquisitions 

that are expected to exceed specified dollar thresholds, which can be adjusted annually. In 

fiscal year 2000, for example, a prospectus was required for any lease exceeding an average 

annual rent of $1.93 million. The prospectuses are to be submitted to GSA’s Senate and 

House authorizing committees. 
Page 31 GAO-01-805 Facilities Location

RDA. We noted that GSA had not assisted agencies in developing 

procedures and guidelines to implement the various location policies. 

Therefore, we recommended in our 1990 report that GSA develop for 

congressional consideration a more consistent governmentwide location 

policy. In our recent survey of agency sites, we found most agencies, 

whether they obtained the sites independently or through GSA, did not use 

RDA or did not know whether it was used in choosing their sites.

Some Functions Can 

Potentially Locate in 

Rural Areas 

On the basis of our survey of 115 federal facilities, the report of our 

consultant, and our interviews with high-ranking officials in human 

resources and information technology at 13 cabinet agencies, we were able 

to identify several federal functions that could be performed in rural areas. 

These included printing, archiving, accounting and finance, training, 

passport application processing, automatic data processing, research and 

development, storage, and law enforcement. 

Private Sector Functions 

That Might Locate in Rural 

Areas

Our consultant identified 21 functions that the private sector might locate 

in rural areas, as shown in table 7. 

Table 7: Functions That Might be Located in Rural Areas

Source: Office Location Considerations of Large U.S. Corporations: U.S. Government Potentials, The 

Dorchester Group, L.L.C., March 31, 2001.

Functions that might be located in rural areas

Accounting Legal support

Account representative Logistical support

Appraisal/market research Manufacturing and assembly offices

Clerical/secretarial Operations centers

Data processing Printing and publishing

Distribution/warehousing Records archiving

Education/training Repairs and servicing

Enforcement and quality control Scientific studies, and research and development

Field service operations Technical functions and support

Human resources and social services Telemarketing, order processing, and communications

Information technologies services
Page 32 GAO-01-805 Facilities Location

According to our consultant, these functions lend themselves to being 

performed in rural areas because (1) some of them do not demand the large 

and technical, sophisticated labor pool often found in urban areas; (2) 

some functions may be performed in a location remote from the principal 

office’s day-to-day operations; and (3) some support functions can be 

performed by telephone. He also emphasized that rural areas are 

sometimes suitable for functions where security is important, such as 

research and development and law enforcement activities.

We reviewed the 21 functions to see if they were represented in the federal 

sector and whether any of the federal agencies we contacted identified 

them as being found in rural areas or potential for rural areas. Nine of the 

21 functions met these criteria. They were (1) accounting, (2) distribution 

and warehousing, (3) education and training, (4) enforcement and quality 

control, (5) printing and publishing, (6) records archiving, (7) data 

processing, (8) scientific studies and research and development, and (9) 

telemarketing/teleservicing. 

Table 8 shows the potential benefits and challenges that would result from 

situating the function in a rural area for the nine selected functions.

Table 8: Benefits and Challenges Associated With Rural Areas for Nine Functions

Source: Office Location Considerations of Large U.S. Corporations: U.S. Government Potentials. The 

Dorchester Group, L.L.C., March 31, 2001.

Function Benefits Challenges

Accounting Lower wages and operating costs Data security and quality control

Data processing Reduced costs of office and labor Needs skills more often found in 

metropolitan areas

Distribution and warehousing Savings on labor and real estate Needs good transportation links

Education and training Fewer distractions and recreation opportunities None identified

Enforcement/quality control None identified Needs good regional access

Printing and publishing None identified Needs good transportation links

Records archiving Lower costs for real estate and wages Limited access to records 

Scientific studies/research and 

development

Better security; in some cases, access to universities Specialized employees may have to be 

recruited nationally

Telemarketing, order processing, 

communications

Operating cost efficiencies Sufficient and sustainable labor pool
Page 33 GAO-01-805 Facilities Location

Functions Performed by 

Federal Agencies in Rural 

Areas

Some of the federal functions in our survey were more often located at 

rural sites than at urban ones. These were automated data processing, 

finance and accounting, social services, research and development, and 

storage and inventory.

Special space needs and low real estate cost were key factors for research 

and development and storage sites. The survey also asked respondents to 

pick 1 or more of 12 named reasons why they had chosen their locations. 

Survey responses regarding research and development and 

storage/inventory facilities that were in rural areas pointed to two factors: 

low real estate costs and unique space needs. For instance, officials 

representing four of the eight research and development sites cited their 

unique space needs as a reason for their sites’ selection. Of these sites, 

three were in rural areas. Officials representing five of the eight 

storage/inventory facilities also gave this reason, and four were in rural 

areas. Similarly, all three of the research and development sites for which 

officials cited low real estate costs as a reason for their site choices were 

located in rural areas. All five of the storage and inventory sites for which 

respondents cited low real estate costs as a factor were in rural areas.

Information from cabinet agency officials showed that functions that had 

been decentralized within the agency were more likely to be found in rural 

areas than were centralized functions. We asked these officials, who 

worked in information technology or human resources, about five 

functions—printing, training, personnel benefits administration, 

procurement, and finance/payroll—and whether these or other functions 

could be relocated to rural areas.25 Officials from 11 of the 13 cabinet 

agencies said they had decentralized 1 or more of the 5 functions by placing 

it in regional or even local operating units, including those in rural areas. 

For instance, USDA said its training and procurement functions were 

decentralized to local offices, which are "in a majority of rural counties.” 

The Interior Department said that, except for finance and payroll, the other 

functions were decentralized “to the installation level,” and it has hundreds 

of rural installations. Four agencies reported that they had placed training 

in rural areas, and one, the Department of Energy, said it also had 

decentralized the procurement and personnel functions to local offices, 

half of which are in nonurban areas. 

25Experts in government management and personnel management had identified these 

functions as functions that could be conducted in nonurban areas.
Page 34 GAO-01-805 Facilities Location

However, if an administrative function was centralized it was more likely to 

be in an urban area. For instance, of the seven agencies that said they had 

centralized payroll, five said they located that function in cities, including 

New Orleans. The remaining two agencies placed the function in suburbs. 

The five agencies that centralized printing said they were doing it at an 

urban location—Washington, D.C. One agency that centralized its training 

and benefits administration said it had achieved economies of scale that it 

feared would be lost if any part of that centralized operation was relocated 

to a rural area. 

At least six agencies represented in these interviews identified one or more 

problems with rural areas. One official cited difficulty in recruiting 

minority employees because some rural areas tend to lack minorities. Such 

areas, this official said, also may pose sufficient cultural adjustments for 

minorities and minority employees may not wish to relocate to these areas. 

Other officials cited cost concerns. Officials for five agencies, for instance, 

said rural areas can involve personnel-related costs, such as the cost of 

relocating employees or of recruiting and training replacement workers. 

Officials from three agencies also expressed concern over the relatively 

higher cost of travel to rural areas, with one asserting that this made such 

areas poor choices for training sites. Three agencies also raised concerns 

about facility costs, stating that the lack of available office space in rural 

areas would force them to build new facilities and lose agency 

infrastructure investments at current locations. Three agency officials also 

told us that their urban operations were in those areas because of factors 

intrinsic to urban areas, such as the availability of public transportation 

and proximity to the operations of other agencies or private sector 

organizations.

The full impact of telecommunications advancements in office location 

decisions is still uncertain. A widespread notion is that 

telecommunications advances have made the use of rural areas more 

viable. However, of the 11 cabinet agencies that discussed the benefits and 

drawbacks of rural telecommunications, only 2 agencies said 

telecommunications advances had made rural locations more viable. The 

other nine agencies expressed concern about telecommunications service 

in rural areas, with five saying that sophisticated telecommunications 

services are not always available or can be costly when they are available. 

Three agencies also said telecommunications is of less importance to siting 

decisions than other factors, and one of these expressed concern that rural 

telecommunications networks are inherently less secure than urban ones. 

On a positive note, five agencies saw telecommunications benefiting 
Page 35 GAO-01-805 Facilities Location

employees by, for instance, allowing benefits data and training to be 

offered on-line or by allowing employees to work from home or from the 

sites where they are conducting inspections. 

The private sector offered similar views. According to our consultant, 

although telecommunications is an increasingly important factor in 

location decisionmaking, its full impact has not become clear. Advanced 

telecommunications services are touted as leveling the playing field 

between small towns and metropolitan areas; however, broadband (highspeed) telecommunications facilities26 are not available in all areas, as 

noted by our consultant.27 He also emphasized that many small towns and 

rural areas lack the capital and infrastructure to facilitate these broadband 

services. 

Conclusions Since our 1990 report on this issue, federal agencies continue to locate for 

the most part in higher cost, urban areas. Eight of the 13 cabinet agencies 

surveyed had no formal RDA siting policy, and there was little evidence 

that agencies considered RDA’s requirements when siting new federal 

facilities. Further, GSA has not developed for congressional consideration 

a cost-conscious, governmentwide location policy, as we recommended in 

1990.

In our survey, the sites that involved relocated operations still largely 

remained in urban areas, while the sites that involved newly established 

operations were more evenly spread over rural and urban areas. Federal 

agencies’ mission requirements, such as the need to be near clients or other 

organizations, apparently have led them to select urban areas. Other 

26The Federal Communications Commission defines services with a transmission speed of at 

least 200 kilobits per second (kbps) in one direction as “high speed.” A broadband 

connection, such as that provided by a cable modem service or by a telephone technology, 

known as digital subscriber line (DSL), has a greater capacity, giving the user faster data 

transmission rates than a narrowband connection, such as that provided by a conventional 

telephone line.

27We also reported in February 2001 that the availability of broadband technology was more 

prevalent in large metropolitan areas than in rural areas, on the basis of a survey of Internet 

users who were age 18 and older. For example, in a metropolitan area with a population of 

at least 2.5 million, more than 32 percent (plus or minus 8 percent) of the survey 

respondents reported having DSL and cable modem capability where they lived; in rural 

areas, the corresponding figure was less than 8 percent (plus or minus 6 percent). 

Telecommunications: Characteristics and Choices of Internet Users, (GAO-01-345, Feb. 16, 

2001). 
Page 36 GAO-01-805 Facilities Location

factors that led them to select urban areas are the availability of public 

transportation and particular space needs. A major factor that influences 

private sector site selection for urban areas was the availability and cost of 

skilled labor. Other private sector factors included real estate cost, access 

to transportation, and business incentives. In choosing the geographic area 

for a facility, the private sector more often cites cost considerations and 

incentives offered by states and local areas than did the federal agencies in 

our survey. 

Several government functions, such as research and development, data 

processing, accounting and finance, and teleservice centers, can be located 

in rural areas. Although it is not clear from the information we collected 

whether any of the federal agencies that located sites in urban areas could 

have located them in rural areas, one matter that is clear is that RDA has 

not had the influence on federal siting practices that the Congress appears 

to have intended when RDA was enacted. Many agencies had no RDA 

policy, as required by the act, and many agency personnel in our survey 

either did not consider RDA or did not know whether the act was used in 

making their site selection decisions. If agencies had RDA policies and 

agency personnel were aware of and considered them, certain constraints 

would still exist that impede efforts to locate in rural areas, such as 

inadequate infrastructure for high-speed telecommunications, limited 

public transportation, and a limited labor force.

In the future, some of these constraints may be mitigated for a number of 

rural areas, but for the federal government to cost effectively consider rural 

as well as urban areas, we believe the following must occur:

• The government needs to have a cohesive, governmentwide site location 

policy that considers costs to the government as well as the goal of 

enhancing the socioeconomic status of urban areas and rural areas. We 

do not believe that the public policy objectives of assisting either urban 

or rural areas in a way that will allow agencies to fully and effectively 

achieve their missions preclude agencies from considering other factors 

such as the availability and cost of labor, real estate costs, operational 

costs, and certain local incentives. In fact, a more cost-conscious 

federal siting policy may even increase agencies’ consideration of rural 

areas, since rural areas may have lower overall costs. However, we also 

recognize that in making siting decisions, the agency’s ability to achieve 

its mission can be a more important consideration than costs.

• Federal agencies need to have clearly stated and documented policies 

on site location that conform to governmentwide policy, including RDA; 
Page 37 GAO-01-805 Facilities Location

and GSA and other agencies need to document their consideration of 

RDA to ensure consistent policy application. As a central management 

agency, GSA could require any agency subject to its authority to do this.

• Federal agencies need one, clear definition of “rural area” for the 

purposes of implementing facility siting under RDA.

Matters for 

Congressional 

Consideration

We suggest that Congress consider (1) enacting legislation to require 

agencies to consider, along with their missions and program requirements, 

real estate, labor, and other operational costs and applicable local 

incentives when deciding whether to relocate or establish a new a site in a 

rural area or urban area, and (2) amending RDA to clarify the definition of 

“rural area” for facility siting purposes to facilitate its implementation.

Recommendations for 

Executive Action

We recommend that the Administrator of GSA, in GSA’s role as the federal 

government’s central property management agency, revise its guidance on 

federal facility siting to (1) advise customer agencies that they should 

consider, along with their missions and program requirements, real estate, 

labor, and other operational costs and applicable local incentives when 

deciding whether to relocate or establish a new site in a rural or urban 

area; (2) require that each federal agency subject to GSA’s authority provide 

a written statement to GSA demonstrating that, in selecting a new facility 

location, the agency, as required by RDA, had given first priority to locating 

in a rural area, and if a rural area was not selected, the agency’s justification 

for the decision; and (3) define the term “rural area” to provide its customer 

agencies with a single definition for purposes of federal siting under RDA, 

until the Congress amends RDA to define the term.

Agency Comments and 

Our Evaluation

We provided copies of a draft of this report for comment to the heads of 21 

federal agencies.28 The agencies included both the agencies in our survey 

and departmental agencies from which we obtained additional site location 

information. We received written comments from 14 of the agencies and 

oral comments from 7 of the agencies.

28The 21 agencies include the Department of Education and all of the departmental agencies 

and independent agencies listed in appendix II.
Page 38 GAO-01-805 Facilities Location

Seventeen of the agencies responded that they either had no comments on 

the draft report, agreed with the information in the report, or suggested 

technical changes, which we considered and incorporated within this 

report where appropriate. The remaining four agencies provided more 

extensive comments, which are discussed below.

The GSA Administrator provided written comments dated July 16, 2001, 

which are reprinted in appendix VII. The Administrator stated that 

references in our report to GSA as the government’s central real property 

management agency were somewhat misleading, since GSA administers 

only about 10 percent of the total federal real property inventory and, 

therefore, GSA has no authority to establish governmentwide policy. 

However, we note that GSA’s mission statement identifies it as one of three 

central management agencies in the federal government. According to 

GSA, its inventory includes 40 percent of all federal office space, which is 

occupied by 1 million civilian federal employees, approximately half of the 

total federal civilian workforce. Thus, GSA’s policies would affect almost 

half of the federal government’s civilian office space, the type of space that 

was included in our survey. 

We agreed with the Administrator’s statement in his comments that 

agencies acquiring property independently of GSA are not subject to GSA 

regulations, and we have revised this report accordingly. 

The Administrator also said that our 1990 report, which we referred to in 

our draft report, called for GSA to develop a governmentwide location 

policy, and he added that GSA could not have done so since it lacked the 

authority. Our 1990 report did not call on GSA to develop this policy under 

its authority, but instead recommended that GSA propose a policy to 

Congress as a matter for consideration. The Administrator also said GSA 

had no mechanism for implementing a governmentwide leadership role in 

1990, while that might be possible now through its Office of 

Governmentwide Policy. As previously mentioned, we recommended in 

1990 that GSA develop such a policy for congressional consideration.

The Administrator also said our draft report implied that GSA selected the 

geographic area for agencies’ site acquisitions. We did not intend that 

implication, and we have revised this report to clarify that issue.

In addition, the Administrator pointed to GSA’s efforts to make its customer 

agencies aware of RDA requirements. In our report, we noted GSA’s 

regulations require RDA compliance by customer agencies. Nonetheless, 
Page 39 GAO-01-805 Facilities Location

RDA was not often used in the site acquisitions we surveyed, and some 

agencies said they were not aware of RDA requirements.

The Administrator also responded to our recommendation that GSA 

require written statements from each customer agency demonstrating that 

the agency had given first priority to locating in a rural area and, if a rural 

area was not selected, the agency also include a justification for the 

decision to GSA. He agreed to require a written statement from customer 

agencies regarding use of RDA in site acquisitions. However, he did not 

agree to asking for a justification because he said this would put GSA into 

the position of second-guessing the agencies because he believes that the 

agencies have authority to decide where to locate their facilities. While we 

agree with GSA on the latter point, we remain convinced that a justification 

is needed to help document that agencies gave first priority to rural areas 

when they did not choose a rural area. We are not recommending that GSA 

be required to evaluate these justifications.

The Administrator also responded to our recommendation that GSA define 

“rural area” to provide agencies with a single definition for the purpose of 

federal siting under RDA until the Congress amends RDA to define the 

term. He said GSA will develop a definition for use by its customer 

agencies, but it has no authority to establish a definition for all federal 

agencies. We clarified our report to reflect GSA’s authority to develop a 

definition only for its customers. GSA did agree, however, to issue a 

bulletin to make other agencies aware of this definition. We believe that 

GSA’s definition should be useful to other agencies until Congress amends 

RDA to set forth a statutory definition.

We also received written comments from the Department of the Interior’s 

Acting Assistant Secretary of Policy, Management and Budget dated July 3, 

2001, which are reprinted in appendix VIII. The Acting Assistant Secretary 

responded that the agency generally agreed with the findings and agreed in 

part with the matters for congressional consideration and the 

recommendations for executive action. Our report suggested that 

Congress consider enacting legislation to require agencies to consider 

certain costs along with agency mission when deciding whether to locate a 

site in a rural or urban area. He responded that our suggestion should be 

limited to the establishment of new offices because agencies have different 

considerations, for example, relocation costs, when expanding operations 

at an existing location, as compared to establishing a new office. We did 

not intend our recommendation to apply to situations in which an agency 

expands an operation at an existing site that does not involve a relocation 
Page 40 GAO-01-805 Facilities Location

or establishment of a new site. We clarified our recommendation in this 

regard.

The Acting Assistant Secretary also commented that our recommendation 

that GSA require customer agencies to provide a written statement to GSA 

demonstrating that the agency had given first priority to a rural area should 

(1) be required only if the agency does not select a rural area, (2) be limited 

to a minimum dollar threshold that would exempt certain locations from 

the documentation requirement, and (3) exempt operations that are being

expanded in the same local area. Our recommendation, as noted in the 

draft report, states that all site decisions should include a written statement 

to GSA and a justification only should be provided if a rural area was not 

selected. Although we agree that the establishment of a minimum dollar 

threshold may be reasonable conceptually, we note that RDA does not 

include a dollar threshold for application of the act’s requirements. We also 

believe that expansions of existing operations should be subject to this 

requirement if they might involve a relocation.

The two Department of the Treasury components in our survey also 

provided written comments. We received comments from IRS’ Director of 

the Office of Real Estate and Facilities Management dated June 26, 2001. 

IRS’s comments on this report covered four areas: (1) the use of RDA, (2) 

compliance with RDA requirements, (3) agencies’ ability to consider costs 

when selecting new sites, and (4) technical considerations. 

With respect to the first point—use of RDA, IRS said that 

• the RDA’s encouragement of locating in rural areas needs to be balanced 

against other legal requirements that sometimes contradict RDA 

requirements, such as those of CICA, and OMB and congressional 

budget requirements and limitations, and short-term and long-term cost 

considerations;

• a “rural area” should be defined in a way that achieves the intent of the 

RDA and be based on terms other than population alone; and

• if Congress supports a location policy that is economically rather than 

socially based, then Congress should repeal RDA and replace it with 

legislation that would require agencies to meet specific threshold terms 

specified in the legislation.

We agree that agencies need to consider a variety of legal requirements 

when selecting a new site for their facilities as well as costs. However, the 

statutory requirement imposed by RDA must be given priority. We also 
Page 41 GAO-01-805 Facilities Location

believe that if Congress defines “rural area” for purposes of RDA, it may 

want to consider factors in addition to population. By stating in our report 

that cost factors should be considered in the location process, we are not 

suggesting that Congress enact a location policy based solely on 

economics. Rather we are saying that cost should be one of the factors 

considered in the decisionmaking process.

With respect to its second point, on compliance, IRS said that agencies 

selecting their own sites without GSA assistance are to be held directly 

accountable for compliance with RDA and, therefore, GSA should not be 

required to evaluate or enforce compliance with the RDA. Additionally, IRS 

said that if an agency is using GSA to acquire a site, a simple statement that 

the agency considered the RDA should be sufficient. We recommended 

that GSA require a written statement only for federal agencies subject to its 

authority. We are not recommending that GSA enforce compliance with 

RDA for agencies that have and use their own authority to acquire space. 

In those cases where GSA acquires space for other agencies, we believe 

that providing GSA with a justification for a site selection that includes the 

reasons for not choosing a rural area under the RDA will help document 

that the agency gave consideration to RDA.

Regarding IRS’s third point, IRS said that, in considering costs, most 

agencies have no means to assess project costs, such as real estate or labor 

costs, across geographic areas. The agency added that market data on rural 

areas are not readily available or readily accessible to compare them with 

alternative geographic areas. We believe that GSA and OPM can provide 

much of the information needed to do cost analyses. Furthermore, private 

sector companies are able to make such analyses and gain access to them. 

Finally, several agencies in our survey said their site selection process 

included cost analyses of alternative geographic areas as well as cost 

analysis of sites within a geographic area. 

Regarding IRS’s fourth point, its technical comments, IRS thought we 

should make distinctions between leased occupancies and new federal 

construction because of the greater time commitment for continued 

occupancy in new construction. We do not agree with IRS on this point. 

RDA does not distinguish between leased and owned space, and in our 

view, it is as important to consider costs and other factors regardless of 

whether space is leased or owned, particularly considering that many 

leases are for long time periods.
Page 42 GAO-01-805 Facilities Location

On July 3, 2001, we received written comments from the U.S. Customs’ 

Director, Office of Planning, which are reprinted in appendix IX. The 

Director responded that Customs concurred with the report’s 

recommendation to GSA to revise its guidance on federal facilities and 

stated that information in the report about Customs’ facility acquisition 

process and factors used by Customs to select the sites in our survey was 

correct. He also stated that when Customs acquires property under its 

existing statutory authority, it utilizes the same process as GSA; and, 

although not mentioned in our draft report, Customs applies GSA’s basic 

policy to house agencies in existing federally owned and leased space 

before acquiring additional space. The Director of Planning also stated that 

many of Customs’ facilities are unique because the operation requires 

proximity to the border, an airport, or a seaport, and difficulties sometimes 

arise in complying with RDA and the pertinent executive orders because 

many of the land border crossings, airports, and seaports are not located in 

the central business area of either a rural area or an urban area. We agree 

and acknowledged in this report that agency mission requirements 

primarily dictated the location of the sites in our survey.

As agreed with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 21 days after its 

issue date. At that time, we will send copies of this report to the Chairman 

and Ranking Minority Member, Senate Committee on Governmental 

Affairs; the Chairman and Ranking Minority Member, House Committee on 

Government Reform; the Chairman and Ranking Minority Member, Senate 

Committee on Environment and Public Works; the Chairman and Ranking 

Minority Member, House Committee on Transportation and Infrastructure; 

the Chairman and Ranking Minority Member, Senate Committee on 

Agriculture, Nutrition and Forestry; the Chairman and Ranking Minority 

Member, House Committee on Agriculture; the House and Senate 

Appropriations Committees; Representative Ernest J. Istook; the Director 

of the Office of Management and Budget; and the Administrator of GSA. 

We will also make copies available to others upon request. 
Page 43 GAO-01-805 Facilities Location

If you have any questions about this report, please call me on (202) 512-

8387. Key contributors to this report are acknowledged in appendix X. 

Sincerely yours,

Bernard L. Ungar

Director, Physical Infrastructure Issues
Page 44 GAO-01-805 Facilities Location

Appendix I

Objectives, Scope, and Methodology AAppenednxidxeiIs

Objectives Our objectives were to determine (1) what executive branch civilian nonDepartment of Defense (DOD) functions have recently selected urban 

locations other than Washington, D.C., and the federal cities,1

 compared to 

rural locations; and what factors, benefits, and problems were associated 

with such site selections; (2) what federal laws and policies govern facility 

location and to what extent have agencies implemented this guidance; (3) 

what lessons can be learned from private sector site selections; and (4) 

what functions lend themselves to being located in rural areas.

Scope and 

Methodology

To address the first objective, we looked at (1) sites selected by the General 

Services Administration (GSA), the government agency that has authority 

to acquire space on behalf of executive branch agencies and (2) sites 

selected by executive branch agencies using their independent statutory 

authority. We chose to look at sites acquired independently of GSA to 

determine whether agencies, when acting independently, engaged in 

practices that were different from those of agencies that used GSA for their 

acquisitions. We looked at those sites that were acquired from fiscal years 

1998 to 2000. In establishing an appropriate site size to study, we wanted to 

choose sites that were large enough to have some economic impact on the 

community in which they were located, that were sufficient in number to 

provide useful information, and for which sufficient information was 

available. 

Accordingly, we decided to consider only those sites with space of 25,000 

square feet or more.2

 Regarding manageability, GSA advised us that spaces 

of this size were small enough that they would be found on GSA’s inventory 

in all of its 11 regions. Concerning economic impact, GSA advised us that 

1

Prior to 1995, the Office of Management and Budget (OMB) established in Circular A-105 

the following 10 cities as the standard federal cities for federal regional headquarters: 

Atlanta, Boston, Chicago, Dallas, Denver, Kansas City, New York, Philadelphia, San 

Francisco, and Seattle. On June 8, 1995, OMB rescinded the Circular stating that the way the 

federal government manages resources, agency efforts to reduce duplicative levels of 

oversight, and the expanded use of technology make a strict regional structure inefficient 

and unnecessary.

2

At sites involving multitenant federal office buildings, we did not aggregate the holdings of 

any one agency. For instance, if an agency such as the Department of Justice had entities, 

such as Drug Enforcement Administration and Immigration and Naturalization Service, that 

each occupied less than 25,000 square feet at that site, the individual entities' holdings were 

not combined. We recognize that each entity within an agency can have a unique mission 

that affects its location decision.
Appendix I

Objectives, Scope, and Methodology

Page 45 GAO-01-805 Facilities Location

spaces of 25,000 square feet or more would tend to be associated with a 

relatively larger number of employees than spaces of less than 25,000 

square feet and would consequently have a greater economic impact.3

 

Finally, in considering the availability of information, we discovered that if 

a space has 25,000 or more square feet, the agency requesting that site can 

officially appeal any GSA revision of the delineated area in which that 

agency wishes to search for a site. As a result, we thought the appeals 

process would make information on such sites more readily available.4

We selected fiscal years 1998 through 2000 to obtain the most recent 

complete data available. As agreed with your office, we excluded 

Washington, D.C., and the 10 agency regional cities because of your request 

to see site acquisitions made outside of those cities.

We focused exclusively on new sites, rather than locations where leases 

had been renewed. In addition, we excluded spaces acquired by the 

judicial and legislative branches of the federal government because these 

branches are not subject to the Rural Development Act (RDA), which is 

applicable to executive departments and agencies. We also excluded sites 

acquired by DOD because DOD informed us that it has so much vacant 

space available at its bases nationally that it has no choice but to consider 

its existing vacant space when locating new or existing operations. We 

excluded the sites acquired by the United States Postal Service (USPS) 

because USPS advised us that it had little or no discretion in deciding 

where to locate most of its facilities, in that they needed to be in specific 

locations to serve customers or near airports. In addition, the Postal 

Reorganization Act of 1970 exempts USPS from federal laws relating to 

contracts and property. Further, USPS has authority to acquire space 

independently of GSA.

3

By using a threshold of 25,000 square feet, we started with 166 sites that were acquired by 

federal agencies with the assistance of GSA in fiscal years 1998 through 2000. If we had 

used a threshold of 10,000 square feet, we would have initially considered 430 sites. The 

inclusion of sites under a smaller threshold size may have led to more rural sites being 

included in our survey, but the acquisitions of smaller sites probably would have been less 

important for considerations of economic impact.

4

Our results are not generalized to sites with space of less than 25,000 square feet. The type 

of functions and reasons for locating in rural areas might be different if we had included 

sites of less than 25,000 square feet.
Appendix I

Objectives, Scope, and Methodology

Page 46 GAO-01-805 Facilities Location

Identifying Sites Recently 

Acquired Through GSA and 

Independently of GSA

GSA provided us with a list of 166 sites it had recently acquired for 

agencies. After excluding sites on the basis of the previously discussed 

criteria, the total number of GSA-acquired qualifying sites was reduced to 

81, representing 29 agencies. We did not independently verify the 

completeness or accuracy of the site data provided by GSA. 

GSA also provided us with a list of 52 agencies, including cabinet 

departments and their components, that have some level of statutory 

authority to acquire space independently of GSA. After excluding agencies 

from the list on the basis of the previously discussed criteria, we reduced 

the total number of agencies to 33. We subsequently contacted the 33 

agencies, asking each whether it had, independently of GSA, used its 

statutory authority to acquire, during fiscal years 1998 through 2000, sites 

that met our criteria.5

 All 33 agencies responded, and 12 agencies identified 

37 sites6 meeting these criteria. Of the 12 agencies, 5 were not among the 

29 agencies represented by the 81 sites GSA helped agencies to acquire. 

Therefore, our total universe was 118 sites (81+37) represented by 34 

agencies (29+5). Using a 28-question, mail-out survey form, 7

 we surveyed 

agency officials at the 118 sites. As of May 3, 2001, we had received 

responses for 115 of the 118 sites, for a response rate of 97.5 percent.

The practical difficulties of conducting any survey may introduce errors, 

commonly referred to as nonsampling errors. For example, differences in 

how a particular question is interpreted by the survey respondents could 

introduce unwanted variability in the survey's results. We took steps in the 

development of the questionnaire, the data collection, and the data editing 

and analysis to minimize nonsampling errors. These steps included 

pretesting the questionnaire with officials of the Department of Veterans 

Affairs and the National Institutes of Health, prompting potential 

respondents in order to increase our survey's response rate, and editing the 

questionnaires for completeness and accuracy.

5

See appendix V for a list of agencies that have independent site authority.

6

GSA does not track sites acquired by agencies independently of GSA. We therefore relied 

upon officials at each agency that acquired sites using their independent authority to report 

that all sites meeting our criteria have been included. We did not independently verify the 

completeness or accuracy of the site data provided by agencies with independent authority 

to acquire space.

7

See survey form in appendix VI.
Appendix I

Objectives, Scope, and Methodology

Page 47 GAO-01-805 Facilities Location

Identifying Sites in Rural 

Areas—Defining “Rural”

To determine whether any of the sites were in rural areas, we reviewed 

RDA to obtain a definition for rural. However, RDA’s definition for rural 

was unclear, and we found application of it would be impractical. For the 

purpose of locating federal facilities, RDA states that rural areas shall be 

defined as those areas identified by the private business enterprise 

exception in 7 U.S.C. § 1926(a)(7). Prior to 1996, the private business 

enterprise exception in 7 U.S.C. § 1926(a)(7) defined rural areas as 

including all territory of a state that is not within the outer boundary of any 

city having a population of 50,000 or more and its immediately adjacent 

urbanized and urbanizing areas with a population density of more than 100 

persons per square mile, as determined by the Secretary of Agriculture, 

according to the latest decennial census of the United States. In 1996, 

7 U.S.C. § 1926(a)(7) was amended and no longer includes the private 

business enterprise exception. Therefore, the appropriate definition of 

rural area under RDA is unclear. Furthermore, we identified two problems 

with the pre-1996 definition. First, determining the population density for 

communities adjacent to these federal sites was not feasible within the 

scope of this job. Second, the term “outer boundary” in this definition lacks 

specificity. 

The current definition of rural in 7 U.S.C. § 1926(a)(7) is for purposes of 

water and waste disposal grants and loans and defines rural as a city, town, 

or unincorporated area that has a population of no more than 10,000 

inhabitants. We are not certain that this is the appropriate definition since 

it refers to water and sewer grants and not the private business enterprise 

exception. The prior threshold, which was eliminated in 1996, used a 

population threshold of 50,000 and included a population density 

requirement. Population density data were not readily available; therefore, 

it was not feasible for us to use this definition.8

For this survey, we chose a threshold of 25,000 or less because it was used 

to define rural areas by several other federal agencies and private sector 

organizations that we identified. When we applied this population 

8

The information on population density for areas outside of cities was not readily available 

and is subject to change, pending the results of the 2000 census. Additionally, when the U.S. 

Department of Agriculture needs to determine whether a city that has applied for a grant is 

rural or not, and may have a population of close to 50,000, it has experts who survey the 

population density of the city's surrounding area to determine whether the density meets 

the criteria for rural area. We did not use 50,000 as a population threshold because many of 

the definitions of rural used by other federal agencies and private sector organizations we 

identified used thresholds of 25,000 or less.
Appendix I

Objectives, Scope, and Methodology

Page 48 GAO-01-805 Facilities Location

threshold of 25,000 to the sites on the list of 81 GSA-acquired federal sites, 

we determined that 23 were located in rural communities; and of the 37 

sites that agencies acquired independently of GSA, 9 were located in rural 

communities. Thus, our survey included a total of 32 rural sites.9

 We note 

that 26 of the “rural” sites in our survey that fall within the 25,000 

population threshold were actually located in metropolitan statistical areas 

in which large cities are located.

Determining Laws, 

Regulations, and Policy That 

Affect Site Selections

To address the second objective, which concerned federal laws and 

policies that affect the selection of sites, we reviewed federal laws, 

executive orders, and policies that relate to the location of federal facilities. 

We also conducted interviews with officials of GSA’s Office of 

Governmentwide Policy, the chief realty officers of 13 of the 14 cabinet 

agencies, 10 and an Office of Personnel Management official on federal 

employee compensation and relocation benefits. Furthermore, we asked 

survey respondents to identify whether they had applied the relevant laws 

and policies when making a site acquisition. We also examined GSA lease 

files created between 1989 and 2000 in three GSA regions—the Rocky 

Mountain Region in Denver, CO; the Greater Southwest Region in Ft. 

Worth, TX; and the Mid-Atlantic Region in Philadelphia, PA—where we 

were already conducting an examination of GSA files for another 

assignment. We examined the files for documentation regarding 

application of RDA. However, we did not attempt to verify whether GSA or 

other agencies were in compliance with RDA.

Private Sector Lessons for 

the Public Sector

To address our third objective, we contracted with a private sector 

consultant11 to (1) perform a literature search, interview experts in 

corporate real estate consulting, and survey corporations that had made 

recent site selection decisions; (2) determine the factors and criteria the 

private sector uses to select urban, suburban, or rural office locations; (3) 

9

See appendix III for a listing of the 32 rural sites.

10As previously mentioned, DOD was not included in our review because DOD informed us 

that because of the amount of vacant space at its bases, it generally considers its existing 

vacant space when locating new operations.

11John D. Dorchester, Jr., of The Dorchester Group, L.L.C. His report was entitled Office 

Location Considerations of Large Corporations: U.S. Government Potentials, March 31, 

2001.
Appendix I

Objectives, Scope, and Methodology

Page 49 GAO-01-805 Facilities Location

identify types of office functions (such as claims processing) that lend 

themselves to being performed in more rural areas; (4) identify, to the 

extent possible, similar federal functions; and (5) identify and explain how 

technological advances in the last decade have reduced the disadvantages 

previously associated with rural areas and what impact U.S. economic 

changes have had on facility location decisions. 

Our consultant reviewed relevant professional literature, surveyed a 

judgmental sample of private sector firms, and analyzed selected economic 

data for indicators of private sector location practices. Our consultant's 

results are not statistically representative of private sector locations 

practices because of the following factors: (1) a judgmental sample rather 

than a random sample was used, (2) 17 percent of those surveyed 

responded, and (3) no evidence was provided that those who responded 

were distributed proportionately across industry-type and geographic 

region to the proportions corresponding to these factors in the population 

of the 1,000 largest U.S. companies. Our consultant also did not empirically 

determine whether the same factors that influence private sector location 

decisions are applicable to location decisions of federal facilities. 

Information obtained from our consultant was still very useful for our 

review because the information included data from both survey 

respondents and an extensive literature search on factors involved in 

corporate location decisions. Also, although our consultant's study 

included various types of companies, the study's focus was on the location 

of offices of those companies. Offices in the consultant's survey performed 

such functions as professional services, management, computing, 

secretarial, clerical, and administrative, functions that are similar to 

government functions. 

Identifying Functions That 

May Relocate

To accomplish the fourth objective, which concerned the potential of 

certain federal functions to relocate to rural areas, we used the agency 

survey described above and interviewed officials at 13 of the 14 cabinet 

agencies about the location of functions—such as printing, personnel 

benefits administration, and procurement—that are often conducted on an 

agencywide basis. Experts in government management and personnel 

management had identified such functions as those that could be 

conducted in nonurban areas. At these agencies, we contacted the chief 

technology and human resources officials to inquire whether each of these 

agencywide functions was being conducted in an urban or a nonurban area 

and why. These officials were also asked to report the impact of 
Appendix I

Objectives, Scope, and Methodology

Page 50 GAO-01-805 Facilities Location

telecommunications technology on the location of these agency functions 

and whether technology had made rural areas more viable as site locations. 

We also reviewed several of our reports, which provided background 

information on all four of our objectives.12

We did our review between August 2000 and May 2001 in Washington, D.C., 

and in the cities of Philadelphia, PA; Denver, CO; and Fort Worth, TX, cities 

where we were already conducting an examination of GSA files for another 

assignment. Our review was conducted in accordance with generally 

accepted government auditing standards.

12Facilities Location Policy: GSA Should Propose a More Consistent and Businesslike 

Approach (GAO/GGD-90-109, Sept. 28, 1990); Federal Statutes and Executive Orders 

Applicable to Public Buildings Service's Leasing Program (GAO/GGD-00-27R, Oct. 18, 1999); 

and Facility Relocation: NRC Based Its Decision to Move Its Technical Training Center on 

Perceived Benefits--Not Costs (GAO/GGD-01-54, Oct. 19, 2000).
Page 51 GAO-01-805 Facilities Location

Appendix II

List of Surveyed Federal Agencies That 

Recently Selected Site Locations ApendxiI

Agencies that recently selected site locations

Department of Agriculture:

 Animal and Plant Health Inspection Service

 Natural Resources Conservation Service

 Forest Service

Department of Commerce

 Bureau of the Census

 National Oceanic and Atmospheric Administration

Department of Energy

Department of Health and Human Services

 Centers for Disease Control and Prevention

 National Institutes of Health

 Agency for Health Care Research and Quality

Department of Housing and Urban Development

Department of the Interior

 National Park Service

 Bureau of Reclamation

Department of Justice

 U. S. Attorney

 Bureau of Prisons

 Drug Enforcement Administration

 Federal Bureau of Investigation

 Immigration and Naturalization Service

 U.S. Marshals Service

Department of Labor

Department of State

Department of Transportation

 U. S. Coast Guard

 Federal Aviation Administration

Department of the Treasury

 U.S. Customs Service

 Internal Revenue Service

Department of Veterans Affairs

Environmental Protection Agency

Equal Employment Opportunity Commission

Federal Emergency Management Agency
Appendix II

List of Surveyed Federal Agencies That 

Recently Selected Site Locations

Page 52 GAO-01-805 Facilities Location

a

The Smithsonian Institution is an independent trust instrumentality of the United States.

Source: Survey data.

Agencies that recently selected site locations

General Services Administration

National Aeronautics and Space Administration

Smithsonian Institutiona

Social Security Administration
Page 53 GAO-01-805 Facilities Location

Appendix III

Location of the 32 Rural Sites (Areas With 

Populations of 25,000 or Less) in Our Survey ApendxiI

Note: Twenty six of the 32 rural sites (located in areas with populations of 25,000 or less) were actually 

located in metropolitan statistical areas (MSA), in which large cities are located.

a

MSA is an area having 1 or more counties containing a city of 50,000 or more or a Census Bureau 

defined urbanized area and a total population of at least 100,000 (or 75,000 in New England).

b

Two sites were located in Decatur, GA.

c

Three sites were located in Jeffersonville, IN.

Source: Survey data and the Bureau of the Census.

City/town State Name of MSAa

Beckley WV (Not in MSA)

Cape Canaveral FL Melbourne-Titusville-Palm Bay

Capitol Heights MD Washington, D.C.

Chamblee GA Atlanta

Clarksburg WV (Not in MSA)

Clarksville IN Louisville

Decaturb GA Atlanta

Eagle Pass TX (Not in MSA)

Fairfax VA Washington, D.C.

Ft. Meade (Odenton) MD Baltimore

Greenbelt MD Washington, D.C.

Herndon VA Washington, D.C.

Jeffersonvillec IN Louisville

Key West FL (Not in MSA)

Lanham MD Washington, D.C.

Martinsburg WV Washington, D.C.

Mineola NY Naussau-Suffolk

Newtown Square PA Philadelphia

Norcross GA Atlanta

Opa-Locka FL Miami

Oxford MS( (Not in MSA)

Peachtree City GA Atlanta

Pomona NJ Atlantic-Cape May

New Port Richey FL Tampa-St. Petersburg

Quantico VA Washington, D.C.

Springfield VA Washington, D.C.

Williamsburg KY (Not in MSA)

Williston VT Burlington

Wilmington MA Boston

Total locations—32 
Page 54 GAO-01-805 Facilities Location

Appendix IV

Location Factors Considered by Private 

Sector Organizations ApendxIVi

Source: Office Location Considerations of Large U.S. Corporations: U.S. Government Potentials, The 

Dorchester Group, L.L.C., March 31, 2001.

Categories of overall factors and factors within the categories

Overall category of factors Factors within overall categories

Workforce issues Availability: skilled and unskilled labor

Costs

Worker/technical training

Productivity

Retention considerations

Recruitment possibilities

Quality of life

Transportation and utilities Transportation

 Highway accessibility

 Proximity to a major airport

 Water and port accessibility

Energy availability and cost 

Electricity availability and cost

Water availability

Adequacy of sewage facilities

Technology Infrastructure for business

Infrastructure for residential use

State and local incentives Tax abatements

Educational incentives

Others

Business climate Responsiveness

Permitting

Attitudes toward growth and business

Environmental considerations

Tax policy

Costs Operations

Occupancy

Construction

Land

Room for expansion

Proximity to markets/suppliers/raw materials/competitors

Consistency with corporate Image
Page 55 GAO-01-805 Facilities Location

Appendix V

Federal Executive Branch Agencies With 

Some Level of Independent Authority to 

Acquire Real Property, Calendar Year 2000 ApendxVi

As table 9 shows, some agencies have been provided independent statutory 

authority to acquire real estate, and some agencies have broad authority. 

For example, the Tennessee Valley Authority is authorized to purchase or 

lease real estate property that it deems necessary or convenient in 

transacting its business;1

 and the Securities and Exchange Commission is 

authorized to enter into real property leases for office, meeting, storage, 

and other space as is necessary to carry out its functions.2

 Other agencies' 

statutory authority to acquire space is for more limited purposes. For 

example, the Secretary of the Interior is authorized to lease buildings and 

associated property for use as part of the National Park System,3 while the 

Secretary of the Treasury is authorized to lease space for the storage of 

unclaimed or other imported merchandise that the government is required 

to store.4

Table 9: Executive Branch Agencies With Some Level of Independent Authority to 

Acquire Real Property

1

16 U.S.C. § 831c.

2

15 U.S.C. § 78d.

3

16 U.S.C. § 1a-2.

4

19 U.S.C. § 1560.

Executive branch agencies with some level of authority to acquire real property

Agency for International Development

American Battle Monuments Commission

Appalachian Regional Commission

Bonneville Power Administration

Central Intelligence Agency

Department of Agriculture

Department of Commerce

Department of Defense

Department of Education

Department of Energy

Department of Health and Human Services

Department of Housing and Urban Development

Department of the Interior
Appendix V

Federal Executive Branch Agencies With 

Some Level of Independent Authority to 

Acquire Real Property, Calendar Year 2000

Page 56 GAO-01-805 Facilities Location

a

The Smithsonian Institution is an independent trust instrumentality of the United States.

Source: GSA.

Executive branch agencies with some level of authority to acquire real property

Department of Justice

Department of Labor

Department of State

Department of Transportation

Department of the Treasury

Department of Veterans Affairs

Environmental Protection Agency

Federal Emergency Management Agency

General Services Administration

National Aeronautics and Space Administration

National Archives and Records Administration

National Science Foundation

National Transportation Safety Board

Panama Canal Commission

Pennsylvania Avenue Development Corporation

Securities and Exchange Commission

Smithsonian Institutiona

Tennessee Valley Authority

Broadcasting Board of Governors

U.S. Parole Commission

U.S. Postal Service

U.S. Sentencing Commission

U.S. Trade Representative
Page 57 GAO-01-805 Facilities Location

Appendix VI

Survey of Federal Facilities’ Locations ApendxViI
Appendix VI

Survey of Federal Facilities’ Locations

Page 58 GAO-01-805 Facilities Location
Appendix VI

Survey of Federal Facilities’ Locations

Page 59 GAO-01-805 Facilities Location
Appendix VI

Survey of Federal Facilities’ Locations

Page 60 GAO-01-805 Facilities Location
Appendix VI

Survey of Federal Facilities’ Locations

Page 61 GAO-01-805 Facilities Location
Appendix VI

Survey of Federal Facilities’ Locations

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Appendix VI

Survey of Federal Facilities’ Locations

Page 63 GAO-01-805 Facilities Location
Appendix VI

Survey of Federal Facilities’ Locations

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Appendix VI

Survey of Federal Facilities’ Locations

Page 65 GAO-01-805 Facilities Location
Page 66 GAO-01-805 Facilities Location

Appendix VII

Comments From the General Services 

Administration ApendxiVI
Appendix VII

Comments From the General Services 

Administration

Page 67 GAO-01-805 Facilities Location
Appendix VII

Comments From the General Services 

Administration

Page 68 GAO-01-805 Facilities Location
Appendix VII

Comments From the General Services 

Administration

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Page 70 GAO-01-805 Facilities Location

Appendix VIII

Comments From the Department of the 

Interior ApendxiVI
Appendix VIII

Comments From the Department of the 

Interior

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Page 72 GAO-01-805 Facilities Location

Appendix IX

Comments From the U.S. Customs Service ApendxiIX
Appendix IX

Comments From the U.S. Customs Service

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Page 74 GAO-01-805 Facilities Location

Appendix X

GAO Contacts and Staff Acknowledgments ApendxiX

GAO Contacts Bernard Ungar (202) 512-8387

John Baldwin (202) 512-8387

Acknowledgments In addition to those named above Alan Belkin, Lucy Hall, Brandon Haller, 

Stuart Kaufman, Thomas Keightley, Gary Lawson, Susan Michal-Smith, 

Edward Warner, and Greg Wilmoth all made key contributions to this 

report.

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