FEDERAL REAL 

PROPERTY

GSA Should Better 

Target Its Use of 

Swap-Construct 

Exchanges

Report to Congressional Requesters

July 2014

GAO-14-586

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-586, a report to 

congressional requesters

July 2014

FEDERAL REAL PROPERTY

GSA Should Better Target Its Use of Swap-Construct 

Exchanges

Why GAO Did This Study

To help address challenges in federal 

real-property management, including 

the growing need to replace and 

modernize federal buildings, GSA has 

proposed expanding its use of swapconstruct exchanges. GSA has 

proposed this approach for some 

potentially large projects, including 

replacing the FBI’s headquarters.

GAO was asked to review issues 

related to these exchanges. This report 

addresses: (1) GSA’s experience with 

completed swap-construct exchanges; 

(2) the status of GSA’s proposed 

swap-construct exchanges; and (3) the 

potential benefits of these exchanges

and factors that can influence their 

future use. GAO reviewed documents, 

including GSA’s solicitations for swapconstruct exchanges, appraisals of 

completed exchanges, and OMB and 

GAO guidance. GAO conducted site 

visits to the completed swap-construct 

sites and three proposed swapconstruct sites, selected based on 

location, number of responses to 

GSA’s solicitation, and stage in the 

swap-construct process, and 

interviewed GSA officials and

nonfederal participants in the 

exchanges. 

What GAO Recommends

GAO recommends that GSA (1) 

include, to the extent possible, details

on what GSA is seeking in exchange 

for federal property in these 

solicitations and (2) develop criteria for 

determining when to solicit market 

interest in swap-construct exchanges. 

GSA agreed with GAO’s 

recommendations.

What GAO Found

Since 2000, the General Services Administration (GSA) has completed two 

“swap-construct” exchanges—transactions in which the agency exchanges title to 

federal property for constructed assets or construction services, such as renovation 

work—in response to private sector interest in specific federal properties. In both 

completed exchanges, GSA used the value of federal properties it determined 

were underutilized to acquire new parking garages. The recipients of the federal 

properties told us that the exchanges took longer than expected (about 3 years 

for one of the exchanges and 5 years for the other). In response, GSA noted its 

lack of experience with swap-construct exchanges at the time.

Since 2012, GSA has proposed six swap-construct exchanges. After reviewing 

responses to its solicitations, GSA is actively pursuing three, including a potential 

exchange of the existing Federal Bureau of Investigation’s (FBI) headquarters for 

construction of a new FBI headquarters building. Respondents to the three 

solicitations that GSA is not actively pursuing noted concerns, including the 

amount of investment needed in the federal properties and the lack of detail 

regarding GSA’s construction needs in an exchange. Swap-construct can result 

in an exchange of equally valued assets or services or can result in the 

government or a property recipient paying for a difference in value. 

Proposed Swap-Construct Exchanges That GSA is No Longer Actively Pursuing

The swap-construct approach can help GSA address the challenges of disposing 

of unneeded property and modernizing or replacing federal buildings, but various 

factors could affect future use of the approach. For example, swap-construct can 

require developers to spend large sums on GSA’s construction needs before 

receiving title to the federal property used in the exchanges. GSA’s solicitations 

have not always specified these construction needs. Consequently, developers 

may be unable to provide meaningful input, and GSA could miss swap-construct

opportunities. Further, the viability of swap-construct exchanges may be affected 

by specific market factors, such as the availability of alternative properties. 

However, GSA lacks criteria to help determine if the agency should solicit interest 

in a swap-construct exchange. As a result, GSA could miss opportunities to use 

swap-construct or select properties and construction projects better suited to 

traditional disposal and funding processes. Office of Management and Budget 

(OMB) and GAO guidance emphasize the importance of criteria in making 

capital-planning decisions and providing clarity on construction needs. View GAO-14-586. For more information, 

contact Dave Wise at (202) 512-2834 or 

wised@gao.gov.
Page i GAO-14-586 Federal Real Property

Letter 1 

Background 3

GSA’s Experience with Swap-Construct Is Limited to Two 

Exchanges for Parking Garages That Were Initiated by Private 

Sector 7

GSA Is Pursuing Half of Its Six Swap-Construct Proposals 12

Swap-Construct Can Help Address GSA’s Needs, but Level of 

Detail in GSA’s Solicitations and Market Interest May Affect 

Future Use 18

Conclusions 23

Recommendations 24

Agency Comments 24

Appendix I Objectives, Scope, and Methodology 26

Appendix II Comments from the General Services Administration 29

Appendix III GAO Contact and Staff Acknowledgments 31

Related GAO Products 32

Figures

Figure 1: GSA’s Decision Making Process for Swap-Construct 

Exchanges and Three Exchange Scenarios 6

Figure 2: Map and Images of Parking Garage Disposed (top) and 

Parking Garage Received (bottom) by GSA in Atlanta 

Swap-Construct Exchange 9

Figure 3: Map and Images of Parking Garage Received (top) and 

Federal Property Disposed (bottom) by GSA in San 

Antonio Swap-Construct Exchange 11

Figure 4: Swap-Construct Exchanges for Which GSA Solicited 

Market Interest, 2012–2013 14

Figure 5: Location of Properties Being Considered for Exchange 

by Swap-Construct in Washington, D.C. 17

Contents
Page ii GAO-14-586 Federal Real Property

Abbreviations

ADA Americans with Disabilities Act 

FBF Federal Buildings Fund 

FBI Federal Bureau of Investigation 

GSA General Services Administration 

HEBSPC H. E. Butt Store Property Company No. One 

HEB HEB Grocery Company 

MARTA Metropolitan Atlanta Rapid Transit Authority 

OMB Office of Management and Budget 

RFI request for information 

RFP request for proposals 

RFQ request for qualifications

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

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

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

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necessary if you wish to reproduce this material separately.
Page 1 GAO-14-586 Federal Real Property

441 G St. N.W.

Washington, DC 20548

July 24, 2014

Congressional Requesters:

The General Services Administration (GSA), which manages federal real 

property on behalf of other federal agencies, including real property 

acquisition, maintenance, and disposal, has faced long-standing 

challenges with underutilized properties and with securing funding for new 

construction and disposing of excess federal properties in a timely 

manner.1 GSA also faces challenges replacing and maintaining aging 

federal properties due to the current fiscal environment of shrinking 

budgets throughout the federal government.2 To help address these 

challenges, GSA has proposed expanding its use of “swap-construct” 

exchanges, whereby GSA receives either a constructed asset, such as a 

new building, or construction services, such as renovation work on an

existing federal building, from a nonfederal entity in return for title to 

different federally owned property. GSA has proposed using swapconstruct for several potentially large projects, including the consolidation 

of the Federal Bureau of Investigation’s (FBI) headquarters operations 

into a new location, in exchange for the existing FBI headquarters 

building and its underlying land, and the relocation and consolidation of 

federal workers in the Federal Triangle South area of Washington, D.C., 

in exchange for federal buildings and their underlying lands.

Given the potential importance of swap-construct exchanges to 

addressing federal real property challenges, you asked us to review 

issues related these exchanges. This report addresses:

• GSA’s experiences with completed swap-construct exchanges;

 

1

We have previously found challenges with funding new construction, disposing of excess 

federal properties, and managing underutilized properties. See, GAO, High-Risk Series: 

An Update, GAO-13-283 (Washington, D.C.: February 2013); GAO, Capital Financing: 

Alternative Approaches to Budgeting for Federal Real Property, GAO-14-239 

(Washington, D.C.: March 2014), and GAO, Federal Real Property: The Government 

Faces Challenges to Disposing of Unneeded Buildings, GAO-11-370T (Washington, D.C.: 

February 2011).

2

Statement of the Honorable Daniel Tangherlini, Administrator for General Services 

Administration before the Subcommittee on Financial Services and General Government, 

Committee on Appropriations, House of Representatives (Apr. 8, 2014: Washington, 

D.C.).
 

Page 2 GAO-14-586 Federal Real Property

• the status of GSA’s proposed swap-construct exchanges; and

• the potential benefits of swap-construct exchanges and factors that 

can influence their future use.

To determine GSA’s experience with swap-construct exchanges, we 

identified and reviewed the two completed swap-construct exchanges by 

reviewing GSA’s exchange agreement documentation, appraisal reports, 

and related GSA guidance,3 and interviewing GSA officials. To further 

understand these swap-construct exchanges, we conducted site visits to 

the locations of the exchanges (Atlanta, GA, and San Antonio, TX), 

examined the properties, and interviewed GSA and nonfederal 

participants in the exchanges. To determine the status of GSA’s proposed 

swap-construct exchanges, we identified and reviewed the six exchanges 

proposed by GSA (two in Washington, D.C., and one each in Miami, FL; 

Los Angeles, CA; Baltimore, MD, and Lakewood, CO) using GSA 

documentation, including solicitations for market interest and ideas for 

addressing agency needs, called requests for information (RFI), and 

interviews with GSA officials. We visited three of the properties (two in 

Washington, D.C., and one in Baltimore, MD), which we selected based 

on proximity to GAO, number of RFI responses, and the stage at which 

the property was in GSA’s swap-construct process. To understand GSA’s 

authority to complete swap-construct exchanges, we reviewed relevant 

statutes and related GSA guidance. To further understand these 

proposed exchanges, we reviewed responses to the RFIs that GSA 

issued and conducted interviews with four of the seven respondents to 

two of the three proposed exchanges that GSA was no longer pursuing to 

further understand their experience with the proposals.4 We selected the 

sample of respondents to include a variety of respondents, including a 

developer, a firm that advises developers, a university, and a company 

that provides property management services to the government.5 To 

 

3

General Services Administration, Guidance for Real Property Exchanges of Non-Excess 

Property (Washington, D.C.: 1997). 

4

The two proposed exchanges from which we interviewed respondents were in Los 

Angeles, CA and Baltimore, MD. We did not conduct interviews with RFI respondents to 

the two proposed exchanges in Washington, D.C. since GSA is still actively in discussions 

or negotiations with these respondents. 

5

The views of these respondents cannot be generalized to make conclusions about all of 

the views of all respondents to GSA’s proposed swap-construct exchanges. However, 

they illustrate the views of a diverse set of respondents with experience related to these 

exchanges.
 

Page 3 GAO-14-586 Federal Real Property

understand the possible exchange in Lakewood, CO, we analyzed GSA

documents, including agency property descriptions and tentative plans for 

the swap-construct exchange, and interviewed GSA officials and a local 

government official involved in the negotiations with GSA. To identify the 

potential benefits of swap-construct exchanges and factors that can 

influence their future use, we evaluated GSA’s approach to identifying 

potentially successful swap-construct exchanges to propose for market 

interest against guidance from the Office of Management and Budget 

(OMB)6 and GAO’s Executive Guide on leading practices in capital 

decision-making,7 and interviewed GSA officials, nonfederal participants 

in the two completed exchanges, affected stakeholders, and 

representatives of nongovernmental organizations familiar with GSA’s 

real property projects. A full description of our scope and methodology 

can be found in appendix I.

We conducted this performance audit from September 2013 to July 2014 

in accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

GSA follows a prescribed process for the disposal of federal properties 

that are reported as excess by federal agencies8

—a process that can 

take years to complete. GSA first offers excess property to other federal 

agencies. If no federal agency needs it or homeless provider expresses 

an interest in it, the property becomes surplus and may be made 

available for other uses through a public benefit conveyance, when state 

and local governments, and certain nonprofits, can obtain the property at 

 

6

Office of Management and Budget, Supplement to Circular No. A-11: Capital 

Programming Guide (Washington, D.C.: July 2012). 

7

GAO, Executive Guide: Leading Practices in Capital Decision-Making, GAO/AIMD-99-32 

(Washington, D.C., December 1998). GAO identified leading practices by interviewing and 

reviewing documentation from government and private sector organizations identified 

through consultation with experts in the fields of capital planning and decision-making.

8

According to GSA, if a federal agency no longer needs property it is considered excess 

property. 

Background
 

Page 4 GAO-14-586 Federal Real Property

up to 100 discount of fair market value when it is used for public 

purposes, such as an educational facility. Ultimately, the property may be 

disposed of by a negotiated sale for public use or public sale based on 

GSA’s determination of the property’s highest and best use.

GSA collects rent from tenant agencies, which is deposited in the Federal 

Buildings Fund (FBF) and serves as GSA’s primary source of funding for 

operating and capital costs associated with federal real property. 

Congress exercises control over the FBF through the appropriations 

process, which designates how much of the fund can be obligated for 

new construction and maintenance each fiscal year.9 According to GSA, 

capital funding has not kept pace with GSA’s need to replace and 

modernize buildings in its federal real property portfolio, which includes 

about 1,500 buildings. We have recently found that GSA and other 

federal agencies have pursued alternative approaches to address 

challenges with funding federal real property projects.10 One alternative 

approach is a swap-construct exchange between the federal government 

and a nonfederal entity, such as a private developer. GSA has several 

authorities to exchange federal property for constructed assets and, in 

2005, was specifically authorized to exchange federal property for 

construction services.11

Swap-construct exchanges can be proposed by a nonfederal entity, such 

as a private developer or local government, or by GSA. GSA’s process for 

proposing and conducting a swap-construct exchange includes either 

proposing a swap-construct exchange to a nonfederal entity that has 

expressed an interest in acquiring a specific federal property or soliciting 

market interest through an initial proposal, often an RFI, followed by more 

detailed proposals. These more detailed proposals include requests for 

qualifications (RFQ) to identify qualified developers and requests for 

proposals (RFP). In a swap-construct exchange, the federal government 

transfers the title of the federal property to a developer or other property 

recipient after receiving a constructed asset or the completion of 

 

9

GAO has previously reported on the Federal Buildings Fund. See GAO, Federal 

Buildings Fund: Improved Transparency and Long-term Plan Needed to Clarify Capital 

Funding Priorities, GAO-12-646 (Washington, D.C.: August 2012). 

10GAO-14-239. 

11See 40 U.S.C. § 3304(a); 40 U.S.C. § 3305(a)(1); 40 U.S.C. § 3305(a)(2); 40 U.S.C. § 

581(c)(1); 40 U.S.C. § 543; and Pub. L. No. 108-447, § 412 (Dec. 8, 2004). 
 

Page 5 GAO-14-586 Federal Real Property

construction services at a different location. Swap-construct exchanges 

can involve swapping property and constructed assets or construction 

services that are of equal value or can include cash to compensate for a 

difference in value between the federal property and the asset or services 

to be received by the government. According to GSA, highest priority is 

assigned to swap-construct exchanges that involve exchanges of federal 

property of equal or greater value than the asset or services provided by 

the property recipient because these scenarios do not require 

appropriation of federal funding. Figure 1 describes GSA’s decisionmaking process for proposing swap-construct exchanges and the three 

scenarios that can result from an agreement for a swap-construct 

exchange.
 

Page 6 GAO-14-586 Federal Real Property

Figure 1: GSA’s Decision Making Process for Swap-Construct Exchanges and Three Exchange Scenarios
 

Page 7 GAO-14-586 Federal Real Property

According to GSA, once the agency has decided to pursue an exchange 

for a newly constructed asset or services, it follows GSA’s 1997 guidance 

for real property exchanges of non-excess property.12 The guidance lays 

out a number of steps, including:

• obtaining a property appraisal;

• using, if possible, one appraiser for all properties involved in an 

exchange; and

• analysis and documentation of all benefits and costs of the exchange 

to show why the exchange is in the best interest of the government.

In November 2013, the GSA Inspector General issued a memo noting 

that GSA’s 1997 guidance is not specifically applicable to exchanges of 

real property for services.13 In responding to the memo, GSA stated that it 

was in the process of preparing guidance specific to exchanges for 

services. 

Since 2000, GSA has completed two swap-construct exchanges initiated 

by companies—Emory University Hospital Midtown (then called Emory 

Crawford Long Hospital) and H. E. Butt Store Property Company No. One 

(HEBSPC)—that were interested in acquiring specific federal properties in 

Atlanta, GA and San Antonio, TX, respectively. A now-retired 

representative of Emory University Hospital Midtown and representatives 

of HEBSPC told us that they were satisfied with the end result of the 

exchanges, but added that there were challenges in the process that may 

affect future swap-construct exchanges. Specifically, the representatives 

told us that the exchanges took longer than anticipated, about 3 years in 

Atlanta and over 5 years in San Antonio, and that, consequently, less 

motivated parties may avoid or withdraw from future exchanges. GSA 

officials told us that both exchanges were a good value for the 

government because the properties and services received by the 

government were of equal or greater value than the federal properties 

disposed of in the exchanges. GSA officials added that the exchanges 

 

12General Services Administration, Guidance for Real Property Exchanges of Non-Excess 

Property (Washington, D.C.: 1997). As previously discussed, properties declared excess 

follow a prescribed disposal process.

13General Services Administration, Office of Inspector General, PBS Needs to Develop 

Policies and Procedures for Use of Section 412 Authorities, Audit Memorandum A130132 

(Washington, D.C.: November 2013).

GSA’s Experience 

with Swap-Construct 

Is Limited to Two 

Exchanges for 

Parking Garages That 

Were Initiated by 

Private Sector
 

Page 8 GAO-14-586 Federal Real Property

were a good value for the government because both of the assets 

disposed of were underutilized. However, these officials noted their lack 

of experience with swap-construct exchanges at the time.

Atlanta Swap-Construct—In 2001, GSA exchanged a federal parking 

garage (the Summit Garage) in Atlanta with 1,829 spaces on a 1.53-acre 

parcel with Emory University Hospital Midtown for a newly constructed 

parking garage (the Pine Street Garage) with 1,150 spaces on .92 acres 

(see fig. 2). GSA also received a commitment from the hospital to lease 

and manage the operations and maintenance of the Pine Street Garage 

for 16 years and to lease spaces in it to federal employees. According to 

GSA, at the time of the exchange, the Summit Garage was underutilized 

because it included more parking spaces than GSA needed.14 Although 

GSA utilized some of the extra spaces through a lease agreement with 

the hospital, which is located nearby, the garage was, GSA added, in 

deteriorating condition and was not it compliance with the Americans with 

Disabilities Act (ADA). According to GSA, the swap-construct exchange 

was in the best interest of the government because GSA received a new 

ADA-compliant garage with a direct covered connection to both the 

Peachtree Summit Federal building and a Metropolitan Atlanta Rapid 

Transit Authority (MARTA) subway station in exchange for a garage that 

was underutilized and in deteriorating condition. GSA added that the 

exchange was beneficial to the government because it included the 

hospital’s commitment to lease spaces not needed by the government for 

16 years, with proceeds deposited into the FBF, and to cover operations 

and maintenance work typically covered by GSA.15

 

14The Summit building and garage were built for a private sector company and later 

acquired by the federal government. The Summit Garage was originally intended to 

accommodate two office towers, only one of which, the current Peachtree Summit Federal 

Building, was constructed. 

15According to GSA, at the end of lease, GSA can extend the lease with the hospital or 

issue another solicitation for prospective bidders.
 

Page 9 GAO-14-586 Federal Real Property

Figure 2: Map and Images of Parking Garage Disposed (top) and Parking Garage Received (bottom) by GSA in Atlanta SwapConstruct Exchange

According to the now-retired representative of Emory University Hospital 

Midtown who was involved with the swap-construct exchange, the 

acquisition of the Summit Garage was crucial to accommodating a 

hospital renovation and expansion project. However, the hospital was 

aware that GSA needed parking spaces to accommodate federal tenants 

in the Peachtree Summit Federal Building, so it proposed the swapconstruct approach to GSA. The representative added that, although the 

hospital was pleased with the end result of the transaction, the exchange 

took about 3 years to complete, a time that was longer than anticipated 

for the hospital and that may lead less motivated parties to avoid or 
 

Page 10 GAO-14-586 Federal Real Property

withdraw from future exchanges. GSA officials noted that the agency had 

limited experience with this type of exchange, which may have 

contributed to the length of time required to complete it. The 

representative added that the exchange was also complicated in that the 

appraised value of the new garage and any additional services had to be

equal to the appraised value of the Summit Garage.16 The now-retired 

representative added that to address concern that the new and smaller 

garage might appraise for less than the Summit Garage, the hospital 

agreed with GSA to continue leasing spaces in the new garage and cover 

operations and maintenance costs. As a result, the two parts of the 

exchange—the garages and lease agreements—were equally appraised 

at $6.6 million. According to GSA, although the hospital’s lease in the new 

garage expires in 2017, the size of the garage allows the agency to meet 

continued demand for federal parking in the vicinity of the Peachtree 

Summit Federal Building.

San Antonio Swap-Construct—In 2012, GSA exchanged an 

approximately 5-acre federal property (the Federal Arsenal site) in San 

Antonio, TX, with HEBSPC for construction of a parking garage on 

existing federal land for the recently renovated Hipolito F. Garcia Federal 

Building and U.S. Courthouse (see fig. 3). According to GSA, at the time 

of the exchange, the Federal Arsenal site was an underutilized asset 

because of historical covenants limiting the ability to redevelop the land 

and its buildings and because it was located on the periphery of the city 

away from other federal assets. Although the property was partly utilized 

by GSA’s Fleet Management and through a lease agreement with HEB 

Grocery Company (HEB)17 for parking spaces, GSA officials told us that 

there was no anticipated long-term government need for it. According to 

GSA officials, the swap-construct exchange was in the best interests of 

the federal government because the government received a new federal 

parking garage for the Hipolito F. Garcia Federal Building and U.S. 

Courthouse in exchange for a property that was underutilized.

 

16According to GSA officials, GSA’s policy goal is for the government to receive equal or 

better than fair market value for swap-construct exchanges. 

17According to an HEBSPC representative, HEB is a retail grocery store with whom 

HEBSPC engages in business transactions. The two companies are separate and neither 

is a subsidiary of the other.
 

Page 11 GAO-14-586 Federal Real Property

Figure 3: Map and Images of Parking Garage Received (top) and Federal Property Disposed (bottom) by GSA in San Antonio 

Swap-Construct Exchange

HEBSPC representatives told us that the company was interested in 

acquiring the Federal Arsenal site to accommodate existing space needs 

and potential expansion of HEB’s corporate headquarters, near the site 

and expressed this interest to GSA. The representatives added that 

although the historic covenants on the property presented some potential 

challenges, the company had prior experience renovating and utilizing 

historic properties on HEB’s headquarters property. The representatives 

also told us that the company had a long-standing interest in acquiring the 

Federal Arsenal site prior to 2005, but during that time, the property could 

not be sold because it was being partly used by GSA’s Fleet 

Management. In 2005, however, GSA told HEBSPC about the need for 

an additional parking for the Hipolito Garcia Federal Building and U.S. 
 

Page 12 GAO-14-586 Federal Real Property

Courthouse and, subsequently, proposed the swap-construct exchange to 

HEBSPC, which had experience building parking garages. An official from 

one of the tenant agencies in the federal building and courthouse told us 

that the increased availability of parking with the new garage (150 new 

spaces compared with 35 existing spaces) was one of the reasons the 

agency decided to locate in the building. GSA officials told us that the 

availability of the new parking spaces is critical to further attracting 

tenants to the building, which is not fully occupied.

HEBSPC representatives told us the company was pleased with the 

transaction and GSA’s management of the transaction. However, they 

added that they would have preferred it to have been completed quicker 

than the 5-plus years between the proposal and exchange of properties, 

and noted that the time it took to complete the transaction may lead less 

motivated parties to avoid or withdraw from such exchanges. According to 

GSA officials, the transaction took longer than anticipated because GSA 

did not have significant experience to use as a basis for completing the 

transaction and because of fluctuations in real estate values due to the 

economic recession that required additional property appraisals to be 

completed. After four property appraisals between 2007 and 2009, GSA 

and HEBSPC ultimately valued the Federal Arsenal site at $5.6 million. 

According to GSA, the new parking garage was constructed to fully utilize 

the $5.6 million value of the property that HEBSPC received.

Since August 2012, GSA has proposed six swap-construct exchanges—

one that the agency proposed directly to the City of Lakewood, CO, and 

five in which GSA solicited market interest in exchanging federal property, 

totaling almost 8-million square feet, for construction services or newly 

constructed assets. After reviewing responses to these six proposals, 

GSA is actively pursuing three, including: (1) a potential exchange of 

undeveloped federal land in Denver with the City of Lakewood for 

construction services at the Denver Federal Center; (2) a potential 

exchange of the existing FBI headquarters building for a new FBI 

headquarters building; and (3) a potential exchange of two federal 

buildings in the Federal Triangle South area of Washington, D.C., for 

construction services to accommodate federal workers elsewhere in the 

city. According to GSA officials, although the agency has had authority to 

exchange property for construction services since fiscal year 2005 and 

had authority to exchange property for newly constructed assets prior to 

that, until recently there has been limited agency interest using nontraditional property disposal and acquisition approaches, such as swapconstruct exchanges. The officials added that since 2012 the agency has 

GSA Is Pursuing Half 

of Its Six SwapConstruct Proposals
 

Page 13 GAO-14-586 Federal Real Property

more widely pursued swap-construct exchanges to address challenges 

such as a rising number of agency needs and limited budgetary 

resources. According to GSA officials, although the projects could involve 

exchanges of equal value, similar to the Atlanta and San Antonio 

exchanges, they could result in the government either receiving a 

payment or paying to cover any difference in value between the property 

to be exchanged and its construction projects.

GSA decided to propose a swap-construct exchange to the City of 

Lakewood because the city had previously expressed interest in the 

undeveloped federal land, totaling about 60 acres, and because GSA had 

need for construction services at the nearby Denver Federal Center. A 

representative of the City of Lakewood told us that the city was supportive 

of the swap-construct approach because the services provided to GSA 

would support employment for the local population, whereas if the city 

were to purchase the property through a sale, the proceeds would not 

necessarily be spent locally. GSA told us that negotiations for a possible 

swap-construct exchange are ongoing.

We found that respondents expressed openness or interest in the swapconstruct approach regarding four of the five exchanges for which GSA 

solicited market interest, but generally this openness or interest was 

limited to the proposed consolidation of the FBI’s headquarters operations 

into a new location in exchange for the existing FBI headquarters building 

and land. Several responses to GSA’s RFIs did not address swapconstruct and instead provided other information, such as the credentials 

of a particular developer and statements that GSA should ensure that 

affordable housing is included in the redevelopment of federal properties 

to be exchanged. Figure 4 describes swap-construct exchanges for which 

GSA solicited market interest and responses to its RFIs. 
 

Page 14 GAO-14-586 Federal Real Property

Figure 4: Swap-Construct Exchanges for Which GSA Solicited Market Interest, 2012–2013

a

An RFI is a solicitation for market interest and ideas in addressing an agency’s needs.
 

Page 15 GAO-14-586 Federal Real Property

For the proposed FBI headquarters swap-construct exchange, GSA 

officials told us that the agency anticipates identifying qualified developers 

by fall 2014 and awarding a contract to a developer for the transaction in 

summer 2015. For the proposed swap-construct exchange involving 

Federal Triangle South properties, GSA narrowed the scope of its 

proposed exchange after reviewing responses to its RFI. Specifically, in 

April 2014, the agency issued an RFQ to identify qualified developers for 

a potential exchange involving two of the five properties included in the 

RFI—the Cotton Annex and the GSA Regional Office Building—for 

renovations to GSA’s headquarters building and construction services to 

support the Department of Homeland Security’s headquarters 

consolidation in Washington, D.C.

GSA officials told us that there was little or no market interest in potential 

swap-construct exchanges in Baltimore, MD (the Metro West building) 

and Miami, FL (the David W. Dyer Courthouse18), and that different 

approaches were now being considered to address them. In addition, 

although GSA received some interest in a swap-construct exchange 

involving another property, the U.S. Courthouse at 312 N. Spring Street in 

Los Angeles (hereafter referred to as “the Spring Street Courthouse”), 

GSA officials said the agency may need to pursue other approaches for 

this property as well. The respondents to these potential exchanges 

expressed various concerns. For example, 4 of 9 respondents expressed 

concerns about the lack of detail regarding what GSA would expect in 

return for the federal property and 4 of 9 respondents expressed 

concerns about the amount of investment needed in the federal 

properties to make the exchange profitable for the property’s recipient. 

Three RFI respondents and representatives of one nongovernmental 

organization familiar with GSA’s real property projects added that swapconstruct may be a less viable approach in markets with a large number 

of alternative real estate options.

According to developers and organizations familiar with GSA’s swapconstruct proposals, the two exchanges for which GSA solicited market 

interest and is still pursuing generally benefit from the inclusion of federal 

properties located in an area with high real-estate values and, thus, 

profitable redevelopment potential. Specifically, both properties are 

 

18A swap-construct exchange was one of several options listed in GSA’s RFI for the David 

W. Dyer Courthouse. These options included an exchange, exchange for services, lease, 

or sale of the property. 
 

Page 16 GAO-14-586 Federal Real Property

located in areas of Washington, D.C., near mass transit and prominent 

landmarks (see fig. 5). In addition, one of the potential projects—the 

consolidation of the FBI headquarters operations into a new location—

benefits from a well defined scope with GSA’s expectations for the 

construction priority being sought by the agency in exchange for the 

federal property considered for exchange in the proposal—the J. Edgar 

Hoover Building. In 2011, GSA estimated that a new FBI headquarters 

built on federal land would cost about $1.9 billion.19 According to GSA, 

this estimate is out of date.

 

19According to GSA, this figure represents the cost of initial development and long-term 

ownership, including recurring operations, maintenance, and repair expenses over a 30-

year period, discounted to 2011.
 

Page 17 GAO-14-586 Federal Real Property

Figure 5: Location of Properties Being Considered for Exchange by Swap-Construct in Washington, D.C.
 

Page 18 GAO-14-586 Federal Real Property

GSA officials told us that swap-construct exchanges can help GSA 

facilitate construction projects given a growing need to modernize and 

replace federal properties, shrinking federal budgets, and challenges 

getting funding appropriated from the FBF.20 Specifically, GSA officials 

noted that swap-construct exchanges allow GSA to immediately apply the 

value of a federal property to be used in the exchange to construction 

needs, rather than wait for funds to be made available from the FBF. GSA 

officials and a representative of a nongovernmental organization familiar 

with GSA’s real property projects added that the exchanges can be 

attractive for GSA because the agency can get construction projects 

accomplished without having to request full upfront funding for them from 

Congress. In addition, because swap-construct exchanges require 

developers or other property recipients to address GSA’s construction 

projects prior to the transfer of the title to the exchange property, federal 

agencies can continue to occupy the federal property during the 

construction process, eliminating the need for agencies to lease or 

acquire other space to occupy during the construction process. GSA 

officials also told us that swap-construct exchanges can help advance a 

government-wide goal to consolidate agencies out of leased space into 

federally owned space. For example, according to GSA, about half of the

FBI’s headquarters staff are located in the existing headquarters building 

and the potential swap-construct exchange for a new FBI headquarters 

could allow the agency to consolidate into one federally owned building. 

 

20We have previously reported that, historically, the FBF has been challenged to provide 

sufficient revenue to support GSA’s real property portfolio. In recent years, budgeting and 

appropriations decisions made by the executive branch and Congress, respectively, have 

limited the amount of resources made available to GSA to fund its real property 

operations. See GAO-12-646 and GAO-14-239. 

Swap-Construct Can 

Help Address GSA’s 

Needs, but Level of 

Detail in GSA’s 

Solicitations and 

Market Interest May 

Affect Future Use

Swap-Construct Can Help 

Facilitate New 

Construction and 

Developer Access to 

Federal Properties, but at 

Potentially Greater Cost to 

Some Stakeholders Than 

the Traditional Disposal 

Approach
 

Page 19 GAO-14-586 Federal Real Property

The retired Emory University Hospital Midtown representative and 

HEBSPC representatives added that swap-construct exchanges can help 

the private sector acquire federal property that it otherwise may not be 

able to acquire.

While swap-construct can facilitate GSA’s construction needs, it could 

come at a greater cost to some stakeholders than the traditional disposal 

approach. Specifically, because federal properties disposed of through 

swap-construct are not declared excess or surplus (often because they 

are still in use by federal tenants when the swap-construct is proposed 

and during the exchange process), they do not go through the traditional 

disposal process. Thus, the swap-construct approach may limit the 

participation of nonfederal entities that would have been interested in 

acquiring the properties through public benefit conveyance or other 

means. For example, in a typical property disposal, eligible public and 

nonprofit entities, such as institutions of higher education or homeless 

organizations, can receive the federal property at up to a 100 percent 

discount of fair market value when it is used for a variety of qualified 

purposes, such as education and assistance for the homeless. Two 

institutions of higher education that responded to GSA’s solicitations for a 

swap-construct exchange expressed a preference for GSA to use the 

traditional disposal process because the universities could then obtain it 

by public benefit conveyance. A representative of a national advocacy 

group for the homeless expressed concern that swap-construct could 

serve as a way around the traditional disposal process and believes GSA 

should offer public benefit conveyances prior to proposing swap-construct 

exchanges.

Swap-construct exchanges require developers to make potentially large 

investments in federal construction projects prior to receiving title to 

federal property used in the exchanges. GSA’s solicitations for market 

interest in swap-construct projects do not always clearly identify what 

projects the agency is seeking in exchange for the federal property. For 

example, the RFIs for the potential Dyer Courthouse and Metro West 

swap-construct exchanges did not specify what GSA was seeking as part 

of an exchange. Two respondents to the Metro West RFI told us that 

additional details regarding what GSA expects in return for the property 

would be key to future consideration of a swap-construct exchange. In 

addition, one developer we spoke to told us that the lack of detail 

regarding what GSA expected in return for the Metro West property 

influenced his company’s decision not to respond to the RFI. One of the 

four respondents to the Spring Street Courthouse RFI added that 

GSA Does Not Always 

Clearly Identify Its Needs 

in Its Solicitations for 

Market Interest in SwapConstruct Exchanges
 

Page 20 GAO-14-586 Federal Real Property

although GSA specified a need for a new building in exchange for the 

Spring Street Courthouse, it was not clear that the new building was a 

GSA priority. Specifically, the respondent noted that future swapconstruct exchanges may benefit from additional information on GSA’s 

needs, such as a strategic plan for a region where GSA is proposing a 

swap-construct exchange.

GSA officials also told us that the agency does not always identify its 

needs prior to releasing its RFIs for swap-construct exchanges. OMB 

guidance notes that although federal agencies should not specify 

requirements too narrowly in RFIs, agencies should identify clear agency 

needs in the documents.21 Leading practices also note the importance of 

identifying an agency’s needs22 and being transparent about these 

needs.23 GSA officials acknowledged that while details were not always 

specified in RFIs for swap-construct exchanges, details would be 

specified in subsequent solicitations if GSA determines there is enough 

market interest based on the RFI responses. GSA officials also stated 

that fewer details were included in the RFIs because the agency wanted 

to gauge market interest in the swap-construct transaction structure and 

did not want to limit the creativity of potential RFI respondents. However, 

by not providing some detail on the agency’s needs in its RFIs, GSA risks 

limiting respondents’ ability to provide meaningful input and could miss 

potential swap-construct opportunities for the properties.

GSA has generated interest in swap-construct for some projects, as 

previously discussed, but several factors may limit the applicability of the 

agency’s approach. Three of the four RFI respondents and one of the two 

nongovernmental organizations we spoke to noted that the federal 

property to be exchanged should have high redevelopment potential to 

offset the developers’ risk of delayed access to the property until 

providing GSA with its needed asset or construction services. Specifically, 

a developer may have to expend significant time and money addressing 

GSA’s needs for a new building or renovating an existing federal building 

before receiving, redeveloping, and generating revenue from the 

 

21OMB, Capital Programming Guide. 

22GAO/AIMD-99-32. 

23GAO 12-646. 

Various Factors May Affect 

the Applicability of SwapConstruct Exchanges, and 

GSA Lacks Criteria for 

Identifying Good 

Exchange Candidates
 

Page 21 GAO-14-586 Federal Real Property

swapped federal property. GSA officials told us that it might be possible to 

negotiate some early rights of access to the federal property before the 

transfer of the property title to conduct activities such as site preparation 

and demolition work, but at a developer’s risk. According to 

representatives of the two nongovernmental organizations we spoke to, 

GSA should also consider local market conditions in deciding if a property 

is suitable for swap-construct because developers can often purchase or 

lease similar properties they need from the private sector and quickly 

access them for redevelopment. For example, a representative of a firm 

that advises developers noted that the FBI headquarters building is 

located in an area of Washington, D.C., with high potential for profitable 

redevelopment and that there are few other similar properties available to 

developers. In contrast, a Metro West RFI respondent and a Spring Street 

Courthouse RFI respondent expressed concern that the federal 

properties included in those exchanges, in Baltimore and Los Angeles, 

respectively, may not have sufficient redevelopment potential to offset the 

risks associated with delayed transfer of title under a swap-construct 

approach.

Potential complications with exchanging property in one region for a 

constructed asset or construction services in another region may also 

limit the applicability of swap-construct exchanges. Specifically, GSA 

officials told us that the pool of potential bidders is smaller and community 

and political opposition can be higher when removing federal assets from 

one region for a constructed asset or construction services in another. In 

addition, the officials said project management can be more difficult for 

GSA when an exchange is executed across different regions. 

Consequently, the officials told us they try to locate the desired 

constructed asset or construction services in the same region as the 

federal property to be exchanged. GSA officials added that many 

underutilized federal properties are not suitable for swap-construct 

because they are in locations where GSA has limited needs for new 

assets or construction services or because the federal properties are not 

sufficiently desirable or would require too much investment from a 

developer.

A representative of the firm that advises developers added that while the 

swap-construct approach gives GSA greater control over the proceeds 

from a property disposal, the federal government may get a better deal for 

a new asset or construction services and potentially larger proceeds for 

the disposed federal property if it were to use traditional acquisition and 

disposal methods. In particular, the representative noted that developers 

may be willing to pay more for federal property through a sale because 
 

Page 22 GAO-14-586 Federal Real Property

the developers could gain immediate access to the property for 

redevelopment purposes. Similarly, the representative told us that GSA 

may get a better deal on a new asset or construction services it if were to 

pursue them through a traditional acquisition process because it would 

invite more developer competition into the process, unlike in a swapconstruct approach where a developer would also need to be willing to 

receive federal property as consideration.

While GSA has guidance for determining if it should continue to pursue 

an exchange that has already been proposed, it does not have criteria to 

help determine when the agency should solicit interest in a swapconstruct exchange. According to GSA officials, the agency considers 

possible swap-construct exchanges on a case-by-case basis during its 

annual review of its entire federal real property portfolio, but it lacks 

guidance on how that case-by-case analysis should be conducted. GSA 

officials added that because the agency only recently started using the 

swap-construct approach, it does not have screening criteria for 

determining when a swap-construct exchange should be proposed. 

Moreover, we found that some proposed swap-construct exchanges have 

been driven by GSA’s need to dispose of specific federal properties and 

that, as previously discussed, GSA has not given the same amount of 

consideration to construction projects to include in its proposed 

exchanges. For example, in the Metro West and Dyer Courthouse swapconstruct proposals, GSA identified federal properties to be exchanged, 

but little or no information on construction projects it needed in a potential 

exchange. 

GSA has proposed swap-construct exchanges since 2012 to a mixed 

reception, as previously noted, with little or no interest in exchanges 

involving the Dyer Courthouse in Miami, the Spring Street Courthouse in 

Los Angeles, and the Metro West building Baltimore, and high level 

interest in an exchange only for the FBI headquarters consolidation 

project. Both OMB and GAO guidance emphasize the importance of 

using criteria to make capital-planning decisions.24 By not using screening 

criteria to identify potentially successful swap-construct exchanges, the 

agency may miss the best opportunities to leverage swap-construct 

 

24OMB, Capital Programming Guide, Supplement to Office of Management and Budget 

Circular A-11: Planning, Budgeting, and Acquisition of Capital Assets (Washington, D.C.: 

July 2013), and GAO, Executive Guide: Leading Practices in Capital Decision-Making, 

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

Page 23 GAO-14-586 Federal Real Property

exchange or select properties for exchange that are better suited to the 

traditional property disposal process and construction projects that are 

better suited to traditional funding processes. GSA may also waste time 

and money pursuing a potential swap-construct exchange that could be

better spent pursuing these traditional approaches.

GSA faces some key challenges in managing its federal real property 

portfolio, especially in disposing of unneeded federal property and 

financing the replacement or modernization of aging and underutilized 

properties. In some cases, the swap-construct approach discussed in this 

report might be a useful means through which GSA can more readily 

achieve these property-related goals. However, GSA’s recent solicitations 

for market interest in swap-construct have not always been well received 

by potential bidders. Specifically, of the five swap-construct exchanges 

GSA for which GSA solicited market interest since 2012, only two are 

being actively pursued; the others generated little market interest. One 

concern for potential bidders was the lack of detail regarding the 

construction services that GSA hoped to gain in return for an asset it 

would cede to the bidder. We found that in developing initial proposals for 

a swap-construct exchange GSA often focused on identifying assets to 

dispose of and gave less attention to what it needed in exchange for 

those assets. Construction services or a newly constructed asset are fully 

half of any swap-construct exchange, yet GSA has not always clearly 

identified its needs when requesting feedback from potential bidders. The 

agency’s intent may be to provide greater details at later stages of the 

proposal process, but this approach may limit the ability of respondents to 

provide meaningful input and lead to missed swap-construct opportunities 

for GSA.

At present GSA does not have criteria for identifying viable exchanges in 

the sense that both sides of the potential transaction are fully defined and 

communicated to potential interested parties. OMB and GAO have 

previously identified the importance of criteria in making agency 

decisions. By not using screening criteria to make its choices, GSA may 

be pursuing swap-construct exchanges with less potential for success, 

and potentially delaying time that it could be spending on traditional 

disposal and appropriation processes. Similarly, GSA may also miss 

opportunities to leverage swap-construct more widely moving forward, 

which could be crucial given ongoing budgetary challenges.

Conclusions
 

Page 24 GAO-14-586 Federal Real Property

In order to identify potentially successful swap-construct exchanges 

during GSA’s review of its federal real property portfolio and reduce 

uncertainty for those responding to GSA’s solicitations for possible swapconstruct exchanges, we recommend that the Administrator of GSA take 

the following two actions:

1. include, to the extent possible, details on what GSA is seeking in 

exchange for federal property in its solicitations, including requests for 

information, for potential swap-construct exchanges and

2. develop criteria for determining when to solicit market interest in a 

swap-construct exchange.

We provided a draft of this report for review and comment to GSA. GSA 

concurred with the report’s recommendations and provided additional 

information on the proposed swap-construct exchange with the City of 

Lakewood, Colorado, which we incorporated. GSA’s letter is reprinted in 

appendix II.

As arranged with your offices, unless you publicly disclose the contents 

earlier, we plan no further distribution of this report until 30 days after the 

date of this letter. At that time, we will send copies of the report to the 

Administrator of GSA. Additional copies will be sent to interested 

congressional committees. We will also make copies available to others 

upon request, and the report is available at no charge on the GAO 

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

If you have any questions about this report, please contact me at (202) 

512-2834 or wised@gao.gov. Contact points for our Offices of 

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

of this report. Major contributors to this report are listed in appendix III.

David Wise

Director

Physical Infrastructure Issues

Recommendations

Agency Comments
 

Page 25 GAO-14-586 Federal Real Property

List of Congressional Requesters

The Honorable Thomas R. Carper

Chairman

The Honorable Tom Coburn, M.D.

Ranking Member

Committee on Homeland Security and Governmental Affairs

United States Senate

The Honorable Darrell Issa

Chairman

The Honorable Elijah E. Cummings

Ranking Member

Committee on Oversight and Government Reform

House of Representatives

The Honorable John L. Mica

Chairman

Subcommittee on Government Operations,

Committee on Oversight and Government Reform

House of Representatives
Appendix I: Objectives, Scope, and 

Methodology

Page 26 GAO-14-586 Federal Real Property

Our objectives were to determine (1) GSA’s experiences with completed 

swap-construct exchanges; (2) the status of GSA’s proposed swapconstruct exchanges; and (3) the potential benefits of swap-construct 

exchanges and the factors that can influence their future use. We 

described GSA’s swap-construct process using information gathered from 

GSA guidance1 and interviews with GSA officials. In addition, we 

reviewed related laws that facilitate GSA’s swap-construct exchanges.2

To determine GSA’s experience with swap-construct exchanges, we 

identified and reviewed the two swap-construct exchanges (Atlanta, GA, 

and San Antonio, TX) completed by GSA since 2000 through GSA 

exchange agreement documentation, appraisal reports, and property 

descriptions, and through interviews with GSA officials. We conducted 

site visits to Atlanta and San Antonio, examined the properties involved in 

the exchanges, and interviewed GSA officials and nonfederal 

participants—H. E. Butt Store Property Company No. One (HEBSPC) and 

Emory University Hospital Midtown—about their experience with the 

transactions.

To determine the status of GSA’s proposed swap-construct exchanges, 

we identified and reviewed the six proposed swap–construct 

exchanges—two in Washington, D.C., and one each in Miami, FL; Los 

Angeles, CA; Baltimore, MD; and Lakewood, CO—using GSA 

documentation, including GSA solicitations for possible exchanges, 

known as requests for information (RFI), and through interviews with GSA 

officials. We conducted site visits to three of the properties involved in the 

proposed exchanges (the Cotton Annex and Regional Office Building in 

Washington, D.C and the Metro West building in Baltimore, MD), 

examined the properties, and spoke with GSA officials about the RFIs 

that included these properties. We selected these properties based on 

nearby proximity (within a 50-mile radius) and to include a site visit to 

both a location where the property or properties in the RFI generated 10 

or more responses and to a location were the property or properties in the 

RFI generated fewer than 10 responses. To further identify a property or 

 

1

General Services Administration, Guidance for Real Property Exchanges of Non-Excess 

Property (Washington, D.C.: 1997). 

2

40 U.S.C. § 3304(a); 40 U.S.C. § 3305(a)(1); 40 U.S.C. § 3305(a)(2); 40 U.S.C. § 

581(c)(1); 40 U.S.C. § 543; and Pub. L. No. 108-447, § 412. 

 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 27 GAO-14-586 Federal Real Property

properties to visit, we then limited our selection to property or properties 

that were furthest along in GSA’s proposed swap-construct process. In 

addition, to better understand the status of these proposed exchanges, 

we analyzed the responses GSA received to its solicitations for these 

swap-construct exchanges and discussed the proposed exchanges with 

four of the seven respondents to the Metro West and Spring Street 

Courthouse RFIs. We did not interview RFI respondents to the proposed 

swap-construct exchanges that involved the FBI headquarters and 

Federal Triangle South properties since GSA is actively in discussions or 

negotiations with these respondents. We selected our sample of the 

respondents to include a variety of respondents, including a development 

company, firm that advises developers, a university, and a company that 

provides property management services to the government. Because the 

RFI respondents were selected as a nonprobability sample, the 

information gained in these interviews cannot be generalized to make 

conclusions about all of GSA’s swap-construct exchanges. However, they 

illustrate the views of a diverse set of respondents with experience related 

to these exchanges. To understand the possible exchange in Lakewood, 

CO, we analyzed GSA documents, including agency property 

descriptions and tentative plans for the swap-construct exchange, and 

interviewed GSA officials and a local government official involved with the 

negotiations with GSA.

To identify the potential benefits of swap-construct exchanges and factors 

that can influence GSA’s future use these exchanges, we evaluated 

GSA’s approach to identifying potentially successful swap-construct 

exchanges to propose against the OMB Capital Programming Guide3 and 

the GAO Executive Guide on Leading Practices in Capital DecisionMaking,

4 and interviewed GSA officials; nonfederal participants in 

completed swap-construct exchanges (HEBSPC and Emory University 

Hospital Midtown); stakeholders in federal property acquisition and 

disposal processes (the National Capital Planning Commission and the 

National Law Center for Homelessness and Poverty, respectively); and 

nongovernmental organizations familiar with GSA’s swap-construct 

exchanges (the National Council for Public-Private Partnerships and the 

 

3

OMB, Supplement to Circular No. A-11: Capital Programming Guide (Washington, D.C.: 

July 2012). 

4

GAO, Executive Guide: Leading Practices in Capital Decision-Making, GAO/AIMD-99-32 

(Washington, D.C., December 1998).
Appendix I: Objectives, Scope, and 

Methodology

Page 28 GAO-14-586 Federal Real Property

Urban Land Institute). In addition, we analyzed written responses GSA 

received to its solicitations for proposed swap-constructs exchanges and 

information from interviews we conducted with the four respondents, 

described above, to identify any factors that may affect GSA’s future use 

of swap-construct exchanges.

We conducted this performance audit from September 2013 to July 2014 

in accordance with generally accepted government auditing standards. 

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

sufficient, appropriate evidence to provide a reasonable basis for our 

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.
Appendix II: Comments from the General 

Services Administration

Page 29 GAO-14-586 Federal Real Property

Appendix II: Comments from the General 

Services Administration
Appendix II: Comments from the General 

Services Administration

Page 30 GAO-14-586 Federal Real Property
Appendix III: GAO Contact and Staff 

Acknowledgments

Page 31 GAO-14-586 Federal Real Property

Dave J. Wise at (202) 512-2834 or at wised@gao.gov

In addition to the contact named above, Keith Cunningham, Assistant 

Director; Amy Abramowitz; Dawn Bidne; Timothy Guinane; James 

Leonard; Sara Ann Moessbauer; Josh Ormond; and Crystal Wesco made 

key contributions to this report.

Appendix III: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments
Related GAO Products

Page 32 GAO-14-586 Federal Real Property

Capital Financing: Alternative Approaches to Budgeting for Federal Real 

Property. GAO-14-239. Washington, D.C.: March 12, 2014.

Federal Real Property: Excess and Underutilized Property Is an Ongoing 

Challenge. GAO-13-573T. Washington, D.C.: April 25, 2013.

High-Risk Series: An Update. GAO-13-283. Washington, D.C.: February 

14, 2013.

Federal Courthouses: Recommended Construction Projects Should Be 

Evaluated under New Capital-Planning Process. GAO-13-263. 

Washington, D.C.: April 11, 2013.

Federal Buildings Fund: Improved Transparency and Long-term Plan 

Needed to Clarify Capital Funding Priorities. GAO-12-646. Washington, 

D.C.: July 12, 2012.

Federal Real Property: National Strategy and Better Data Needed to 

Improve Management of Excess and Underutilized Property. 

GAO-12-645. Washington, D.C.: June 20, 2012.

Federal Real Property: The Government Faces Challenges to Disposing 

of Unneeded Buildings. GAO-11-370T. Washington, D.C.: February 10, 

2011.

Federal Courthouse Construction: Estimated Costs to House the L.A. 

District Court Have Tripled and There Is No Consensus on How to 

Proceed. GAO-08-889. Washington, D.C.: September 12, 2008.

Federal Real Property: Most Public Benefit Conveyances Used as 

Intended, but Opportunities Exist to Enhance Federal Oversight. 

GAO-06-511. Washington, D.C.: June 21, 2006.

Executive Guide: Leading Practices in Capital Decision-Making. 

GAO/AIMD 99-32. Washington, D.C.: December 1, 1998.

Related GAO Products

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