U.S. ENVIRONMENTAL PROTECTION AGENCY

OFFICE OF INSPECTOR GENERAL

EPA Can Further 

Reduce Space in 

Under-Utilized Facilities 

Report No. 13-P-0162 February 20, 2013 

Scan this mobile 

code to learn more 

about the EPA OIG. 
 

 

Report Contributors: Marcia Hirt-Reigeluth

 Jennifer Hutkoff 

 Yeon Kim 

Heather Layne 

Mike Davis 

Abbreviations 

CFR Code of Federal Regulations 

EPA U.S. Environmental Protection Agency 

FMSD Facilities Management and Services Division 

GSA U.S. General Services Administration 

HQ Headquarters 

OARM Office of Administration and Resources Management 

OIG Office of Inspector General 

SLATE Strategic Lease and Asset Tracking Enterprise 

USF Usable Square Feet 

Cover photos:	 EPA facilities, from left: the EPA Region 5 Ralph H. Metcalfe Federal 

Building, Chicago, Illinois; and the EPA Region 1 John W. McCormack 

Federal Building, Boston, Massachusetts. (EPA photos) 

Hotline 

To report fraud, waste, or abuse, contact us through one of the following methods: 

e-mail: OIG_Hotline@epa.gov write: EPA Inspector General Hotline 

phone: 

fax: 

1-888-546-8740 

202-566-2599 

1200 Pennsylvania Avenue, NW 

Mailcode 2431T 

online: http://www.epa.gov/oig/hotline.htm Washington, DC 20460 
 

 

U.S. Environmental Protection Agency 13-P-0162 

February 20, 2013 Office of Inspector General 

At a Glance
 

Why We Did This Review 

We sought to determine to what 

extent the U.S. Environmental 

Protection Agency’s (EPA’s) 

efforts to reduce under-utilized or 

unneeded property resulted in cost 

savings. The February 2004 

Executive Order 13327, Federal 

Real Property Asset Management, 

promotes efficient and economical 

use of federal real property assets 

and assures management 

accountability for implementing 

federal real property management 

reforms such as the development 

and implementation of agency 

asset management plans. Federal 

real property is defined as any real 

property owned, leased, or 

otherwise managed by the federal 

government. The June 2010 

Presidential Memorandum, 

Disposing of Unneeded Federal 

Real Estate, requires federal 

agencies to eliminate excess 

properties and lease 

arrangements that are not cost 

effective. 

This report addresses the 

following EPA Goal or 

Cross-Cutting Strategy: 

• Strengthening EPA’s Workforce 

and Capabilities 

For further information, contact 

our Office of Congressional and 

Public Affairs at (202) 566-2391. 

The full report is at: 

www.epa.gov/oig/reports/2013/ 

20130220-13-P-0162.pdf 

EPA Can Further Reduce Space in 

Under-Utilized Facilities 

What We Found 

Although EPA has been releasing unneeded space since 2007, it continues to 

have under-utilized space. The U.S. General Services Administration (GSA) 

owns or leases facilities for EPA use. At 13 of the 16 facilities reviewed, we 

estimated that EPA had 433,336 square feet of under-utilized space as of 

February 2012. EPA is limited in what type of space it can release back to 

GSA before a lease expires. Space can only be released if it is marketable; 

configuration issues and the cost to relocate employees can pose problems. 

If all under-utilized space in our sample was marketable, we estimate EPA 

could save up to $21.6 million annually by releasing under-utilized space. 

Also, EPA does not have a policy for determining when it should be housing 

contractors on-site in its facilities. Contractors occupied an estimated 197,000 

square feet in the sampled facilities. We estimated that EPA spent up to 

$9.9 million annually in housing contractors on-site at the sampled facilities. 

EPA lacks accurate, current, and complete information on the number of 

personnel and usable square feet (USF) in its Strategic Lease and Asset 

Tracking Enterprise (SLATE) system for its GSA-owned/leased offices. As of 

April 2012, SLATE had incorrect personnel information for 13 of the 16 

facilities sampled (81 percent), and 5 of 16 facilities sampled (31 percent) had 

incorrect information on USF. SLATE recorded a net 548 more personnel than 

what EPA facility managers had provided for the sampled facilities and a net 

235,918 less USF than the sampled facilities had. Additionally, the entire USF 

of 325,128 for the Region 5 Ralph H. Metcalfe building was not reported in 

SLATE. This occurred because updates to SLATE are sporadic and 

inconsistent. Inaccurate data in SLATE hamper EPA’s ability to make 

informed decisions about managing its facilities. 

Recommendations and Planned Agency Corrective Actions 

We recommend that the Assistant Administrator for Administration and 

Resources Management assess utilization of space and relocate staff where 

warranted. We also recommend that the Assistant Administrator develop and 

enforce a policy that requires contracting staff ensure that approval for 

on-site contractor performance is obtained from the responsible office, and 

require that personnel information for each facility be consistently tracked and 

updated in the appropriate EPA systems. The Agency concurred with all of the 

recommendations and proposed revised language, which we incorporated 

where appropriate. 

 Noteworthy Achievements 

Since fiscal year 2007, EPA has saved nearly $12.9 million by reducing space 

and plans to save an additional $1.8 million by fiscal year 2014, for a total of 

$14.7 million in savings. 
 

 

 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

THE INSPECTOR GENERAL 

February 20, 2013 

MEMORANDUM 

SUBJECT:	 EPA Can Further Reduce Space in Under-Utilized Facilities

 Report No. 13-P-0162 

FROM: Arthur A. Elkins, Jr. 

TO: Craig E. Hooks 

Assistant Administrator for Administration and Resources Management 

This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the 

U.S. Environmental Protection Agency (EPA). This report contains findings that describe the 

problems the OIG has identified and corrective actions the OIG recommends. This report 

represents the opinion of the OIG and does not necessarily represent the final EPA position. 

Final determinations on matters in this report will be made by EPA managers in accordance with 

established audit resolution procedures. 

Action Required 

In accordance with EPA Manual 2750, you are required to provide a written response to this 

report within 60 calendar days. Your response will be posted on the OIG’s public website, along 

with our comments on your response. Your response should be provided in an Adobe PDF file 

that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of 

1973, as amended. If your response contains data that you do not want to be released to the 

public, you should identify the data for redaction. You should include a corrective actions plan 

for agreed-upon actions, including milestone dates. We have no objections to the further release 

of this report to the public. This report will be available at http://www.epa.gov/oig. 

If you or your staff have any questions regarding this report, please contact Melissa Heist, 

Assistant Inspector General for Audit, at (202) 566-0899 heist.melissa@epa.gov; or Mike Davis, 

Director for Efficiency Audits, at (513) 487-2363 or davis.michaeld@epa.gov. 
 

 

 

 

 

 

 

 

 

 

 

 

 

EPA Can Further Reduce Space	 13-P-0162 

in Under-Utilized Facilities 

Table of Contents 

Chapters 

1 Introduction ........................................................................................................ 1

 Purpose ....................................................................................................... 1 

Background ................................................................................................. 1 

 Noteworthy Achievements ........................................................................... 3 

 Scope and Methodology .............................................................................. 3 

2 EPA Can Further Strive for Space Reduction.................................................. 6
 

Federal Policies Seek to Reduce Space ..................................................... 6 

EPA Has Under-Utilized Space .................................................................. 7 

EPA Does Not Have a Policy for Determining When Contractors 

 Should Be On-Site ............................................................................... 9 

Conclusion................................................................................................... 11 

 Recommendations ...................................................................................... 12 

Agency Response and OIG Evaluation ....................................................... 12 

3 Personnel and Usable Square Feet Data in SLATE Not Updated Timely...... 14 

SLATE and Its Data Quality and Integrity Important.................................... 14 

Personnel Information in SLATE Not Accurate ........................................... 15 

USF Information in SLATE Not Accurate .................................................... 16 

Number of Facilities in SLATE Not Accurate............................................... 17
 

Conclusion ................................................................................................... 17 

 Recommendations ...................................................................................... 17 

Agency Response and OIG Evaluation ....................................................... 17 

Status of Recommendations and Potential Monetary Benefits.............................. 19
 

Appendices 

A Details on Scope and Methodology.................................................................. 20
 

B Calculations for Under-Utilized Space and Excess Cost 

for 16 Sampled Facilities ................................................................................... 22
 

C Cost of Housing Contractors On-Site at 16 Sampled Facilities..................... 24
 

D Agency Response to Draft Report ................................................................... 25 

E Distribution ........................................................................................................ 29
 
 

 

   

 

 

 

 

 

Chapter 1

Introduction 

Purpose 

The June 2010 Presidential Memorandum, Disposing of Unneeded Federal Real 

Estate, required federal agencies to accelerate efforts to identify and eliminate 

excess properties. Agencies were to dispose of surplus assets, consolidate 

facilities, and eliminate lease arrangements that were not cost effective. 

Accordingly, we sought to determine to what extent the U.S. Environmental 

Protection Agency’s (EPA’s) efforts to reduce under-utilized or unneeded 

property resulted in cost savings. 

Background 

EPA facilities are comprised mostly of offices and laboratories in space owned or 

leased by either EPA or the U.S. General Services Administration (GSA). As of 

November 2011, the data in EPA’s Strategic Lease and Asset Tracking Enterprise 

(SLATE) system showed that EPA occupied 170 facilities with approximately 

10 million usable square feet (USF) of space at an annual operating cost of 

approximately $279 million. USF is the net space occupied by a tenant for its 

personnel and equipment use and does not include fire corridors, toilets, 

mechanical rooms, and common building areas. SLATE also reported that these 

facilities housed 23,498 personnel; that number includes not only EPA staff but 

contractors, grantees, Senior Environmental Employment enrollees, and interns. 

Details are in table 1. 

Table 1: EPA facilities by legal interest 

Legal interest 

No. of 

facilities Percent Personnel USF3 Annual cost 

EPA owned/leased 24 14.12% 5,536 4,224,479 $45,530,093 

EPA special use agreement 1 10 5.88% 46 30,475 519,697 

GSA-owned/leased 2 134 78.82% 17,909 5,793,357 232,607,245 

State government owned 

Total 

2 

170 

1.18%

100.00%

 7 

23,498 

2,050 

10,050,361 

-

$278,657,035 

Source: Office of Inspector General (OIG) analysis of EPA’s data in SLATE as of November 2011. 

1 Facilities where EPA personnel are co-located with other federal agencies or have special use arrangements 

with state or local entities. 

2 Includes offices, laboratories, warehouses, storage, child care, and parking lots.
 

3 Includes rentable square feet for one facility that did not record usable square feet. 

EPA facilities are spread throughout the United States and Puerto Rico. Of the 

170 facilities, approximately 59 are large facilities—greater than 20,000 USF. 

13-P-0162
 

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The remainder of EPA’s facilities are smaller, special-purpose buildings and 

project offices. Each of EPA’s 10 regions has a regional office and at least one 

laboratory. Figure 1 shows details. 

Figure 1: EPA regions and major facilities 

EPA national headquarters – Washington, DC 

 Regional headquarters 

Central regional laboratories 

 Program laboratories 

Source: EPA’s 2009 Nationwide Facilities Guide 

Initiatives to Reduce Federal Property 

The February 2004 Executive Order 13327, Federal Real Property Asset 

Management, promotes efficient and economical use of federal real property 

assets and assures management accountability for implementing federal real 

property management reforms such as the development and implementation of 

agency asset management plans. For the purpose of this executive order, federal 

real property is defined as any real property owned, leased, or otherwise managed 

by the federal government. 

The June 2010 Presidential Memorandum, Disposing of Unneeded Federal Real 

Estate, directed agencies to take immediate steps to make better use of remaining 

real property assets as measured by utilization and occupancy rates, annual 

operating costs, energy efficiency, and sustainability. Agencies were to dispose of 

surplus assets, consolidate facilities, and eliminate lease arrangements that were 

not cost effective. Agencies were directed to use innovative approaches to space 

management and alternative workplace arrangements such as telework. 

To carry out the requirements of the June 2010 memorandum, the Office of 

Management and Budget, in consultation with the GSA Administrator and the 

Federal Real Property Council, developed guidance in July 2010 for actions that 

agencies should take. The memo included agency-developed targets to achieve 

$3 billion in cost savings by the end of fiscal year 2012. These savings included 

proceeds from the sale of assets; reduced operating, maintenance, and energy 

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expenses from disposals; and other space consolidation efforts, including ending 

of leases. EPA planned to contribute approximately $7.8 million as part of the 

$3 billion in savings. 

EPA’s July 2010 initial and April 2011 updated Real Property and Innovation 

Plan stated the Agency’s commitment to reducing its environmental footprint 

through efficient management of its real property portfolio. The plan stated that 

the Agency would continue to monitor and assess its facilities’ space utilization 

and take steps to reduce under-utilized space. Additionally, the Agency would 

continue to implement sustainable design, construction, alterations, and 

operations and maintenance. 

The June 2011 Presidential Executive Order 13576, Delivering an Efficient, 

Effective, and Accountable Government, calls for a government that cuts waste 

and is fully accountable to the American public. As part of this executive order, 

the President charged federal chief financial officers with increasing efforts to 

identify, execute, and report on cost savings within federal agencies. 

Noteworthy Achievements 

Since fiscal year 2007, EPA has released more than 380,000 square feet of space 

with cost savings of nearly $12.9 million. EPA plans to save an additional 

$1.8 million in fiscal years 2012 through 2014 by releasing additional space, for a 

total of $14.7 million in savings (table 2). 

Table 2: EPA space released 

Year Square feet released Cost savings 

Fiscal years 2007–2011 380,756 $12,864,283 

Planned for fiscal years 2012–2014 71,157 $1,843,112 

Total 451,913 $14,707,395 

Source: OIG analysis of EPA’s data. 

Scope and Methodology 

We conducted this performance audit 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 review objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objective. 

We performed the audit from November 2011 to October 2012. We visited the 

Facilities Management and Services Division (FMSD) and Office of Acquisition 

Management in the Office of Administration and Resources Management, 

Washington, DC. We interviewed FMSD officials in headquarters (HQ) and regional 

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facility managers for 16 sampled facilities to determine their roles and 

responsibilities and to verify information on personnel head counts and USF in 

SLATE. We interviewed the Office of Acquisition Management Special Assistant 

and Region 9’s contracting personnel to gain a better understanding of EPA’s 

policies and procedures regarding allocation of space to on-site contractors. 

We selected 16 GSA-owned/leased facilities for review, as shown in table 3. 

Table 3: Sixteen Sampled Facilities 

Region State City Building Name 

Usable 

Square Feet 

No. of 

Personnel 

HQ District of Columbia Washington Ariel Rios Federal Building 446,324 1,649 

HQ District of Columbia Washington 1310 L Street 135,901 570 

HQ District of Columbia Washington Ronald Reagan Building 230,664 1,137 

HQ District of Columbia Washington Colorado Building 9,667 20 

1 Massachusetts Boston John W. McCormack Building 224,261 845 

2 New York New York Ted Weiss Federal Office Building 269,834 851 

2 Puerto Rico Guaynabo City View Plaza 19,700 60 

3 Pennsylvania Philadelphia 1650 Arch Street 268,968 1,133 

5 Illinois Chicago Ralph H. Metcalfe Federal Building 0 1,558 

5 Michigan Ann Arbor National Vehicle & Fuel Emissions 

Laboratory - Office Building 

59,100 235 

5 Ohio Norwood Norwood Professional Building 28,594 85 

6 Texas Dallas Fountain Place 239,130 1,052 

7 Kansas Kansas City 901 North 5th Street 182,554 700 

9 California San Francisco 75 Hawthorne Street 253,919 1,160 

9 California Los Angeles Los Angeles Field Office 13,813 25 

10 Washington Seattle Park Place Building 154,006 669 

Total 2,536,435 11,749 

Source: OIG analysis of EPA data in SLATE as of November 2011 (further details on OIG methodology in appendix A). 

To determine applicable criteria, we reviewed the following: 

 Code of Federal Regulations (CFR), 41 CFR Part 102-79, Assignment and 

Utilization of Space 

 Executive Order 13327, Federal Real Property Asset Management, 

February 2004 

 GSA’s July 2011 report, Workspace Utilization and Allocation Benchmark 

 Federal Real Property Council’s Guidance for Improved Asset 

Management, December 2004 

 Presidential Memorandum, Disposing of Unneeded Federal Real Estate, 

June 2010 

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	 Office of Management and Budget’s July 2010 Management Procedures 

Memorandum No. 2010-07, Development of a Real Property Cost Savings 

and Innovation Plan 

	 Executive Order 13576, Delivering an Efficient, Effective, and 

Accountable Government, June 2011
 

Further details on the scope and methodology used—including the methodology 

to select our sample, calculate under-utilized space, and calculate cost savings— 

are in appendix A. 

13-P-0162
 

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Chapter 2

EPA Can Further Strive for Space Reduction 

Although EPA has been releasing unneeded space since 2007, EPA continues to 

have under-utilized space. At 13 of the 16 GSA-owned/leased EPA facilities 

reviewed, we estimated that EPA had 433,336 square feet of under-utilized space 

as of February 2012. EPA is limited in what type of space it can release back to 

GSA before a lease expires. Space can only be released if it is marketable; 

configuration issues and the cost of relocating employees can pose additional 

problems. If all the under-utilized space in our sample were marketable, we 

estimate EPA could save up to $21.6 million annually by releasing under-utilized 

space. Also, EPA does not have a policy for determining when it should be 

housing contractors on-site in its facilities. Contractors occupied an estimated 

197,000 usable square feet in the sampled facilities. We estimated that EPA spent 

at least $5.8 million and up to $9.9 million annually in housing contractors on-site 

at the sampled facilities. 

Federal Policies Seek to Reduce Space 

The June 2010 Presidential Memorandum, Disposing of Unneeded Federal Real 

Estate, required: 

	 Federal agencies to take immediate steps to make better use of remaining 

real property assets, as measured by utilization and occupancy rates and 

annual operating costs. 

	 To the extent permitted by law, agencies dispose of surplus assets, 

eliminate lease arrangements that are not cost effective, pursue 

consolidation opportunities within and across agencies in common asset 

types, increase occupancy rates in current facilities through innovative 

approaches to space management and alternative workplace arrangements 

such as telework, and identify offsetting reductions in inventory when new 

space is acquired. 

Assignment and Utilization of Space, 41 CFR Part 102-79, states: 

An Executive agency must promote maximum utilization of 

Federal workspace, consistent with mission requirements, to 

maximize its value to the Government. 41 CFR §102-79.10. 

Executive agencies must promote the optimum use of space for 

each assignment at an economical cost to the Government, provide 

quality workspace that is delivered and occupied in a timely 

13-P-0162
 

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manner, and assign space based on mission requirements. 41 CFR 

§102-79.20. 

EPA Has Under-Utilized Space 

EPA planned to save $7.8 million as part of the federal government’s efforts to 

reduce space to comply with the June 2010 Presidential Memorandum. Since 

fiscal year 2007, EPA has released over 380,000 square feet of space with a 

savings of nearly $13 million, and plans to save an additional $1.8 million in 

fiscal years 2012 through 2014 (see table 2, chapter 1). Nonetheless, despite 

EPA’s efforts, at 13 of the 16 EPA facilities in our sample of GSA-owned/leased 

facilities, we estimated that EPA had 433,336 square feet of under-utilized space 

as of February 2012. We estimated the annual operating cost of this under-utilized 

space to be approximately $21.6 million annually. A breakdown is in table 4 and 

further details are in appendix B. 

Table 4: Under-utilized space and annual costs for 13 facilities using 210 USF per 

person 

Location and building name 

Total under-utilized 

space 

Excess annual 

operating cost 

HQ-Ariel Rios Federal Building 100,589 $5,664,167 

R 2-Ted Weiss Federal Building 64,676 5,274,975 

R 1-John W. McCormack Building 78,064 4,350,507 

R 7-901 North 5th Street 49,849 1,941,619 

R 5-Ralph H. Metcalfe Federal Building 33,360 1,336,402 

R 3-1650 Arch Street 41,192 1,112,184 

R 10-Park Place Building 10,275 448,812 

R 2-City View Plaza, Puerto Rico 6,489 393,169 

HQ-Colorado Building 6,103 345,674 

R 6-Fountain Place 11,924 245,754 

R 9-Los Angeles Field Office 7,830 183,770 

HQ-310 L Street 18,500 182,595 

R 5-Norwood Professional Building 4,485 96,966 

Total 433,336 $21,576,594 

Source: OIG analysis of EPA data provided by FMSD and regional facility managers as of 

February 2012. 

GSA’s July 2011 report, Workspace Utilization and Allocation Benchmark, 

recommended a federal benchmark of 190 USF per person. GSA staff stated that, 

in determining the benchmark, they included only office or cubicle areas and a 

portion of shared space such as conference rooms and hall space. Also, GSA’s 

July 2011 report further states that the average space allocated could be reduced 

to only 60 square feet in the next 5 years. In response to our draft report, the 

Agency stated that “the GSA document hypothesises (sic) that the 60 square feet 

could be achieved only through extensive use of alternative workspace 

arrangements, such as hoteling, home office and teleworking on a fulltime basis. 

The EPA’s current policy limits telework to no more than two days per week and 

13-P-0162
 

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would therefore have to be modified. Such a significant change has already been 

the subject of extensive negotiation and delay. Hence, at this time, the EPA does 

not recognize that the average office space can be reduced to 60 square feet in 

upcoming years.” We recognize that the 60 square feet relates to alternative 

workspace arrangements for teleworking employees. However, as the Agency has 

already started to move toward enhanced telework in Regions 7 and 9 that allows 

employees to telework more than 2 days per week, this option could become a 

viable option. 

In determining EPA’s under-utilized space, we used EPA’s internal standard of 

210 USF per person as opposed to GSA’s 190 USF because EPA office spaces 

include a variety of support spaces that GSA does not include in its 190 USF 

benchmark. These support spaces include areas for conferences, copying, public 

information, computers, library, filing, storage, mail and stock, and an employee 

lounge. We decided to use 210 USF since EPA tracks all of the support space that 

GSA excludes from its benchmark when computing USF, and since FMSD does 

not readily track the excluded GSA support space. We believe that applying 

210 USF per person for calculating space utilization is the generalized and 

conservative workspace average and demonstrates whether EPA’s facilities are 

under-utilized. EPA’s 2011 draft New Mobile Work Space Design Guidelines 

require a typical work station to be up to 60 USF and a telework station up to 

30 USF per person not including support spaces. In response to the draft report, 

the Agency stated that the guideline numbers of 60 and 30 USF are not considered 

reductions from the 210 square feet per person number, which incorporates 

required space outside the actual workstation for circulation, filing, conferencing, 

collaboration, and small meeting rooms. The Agency stated a reasonable design 

reduction from 210 square feet would be 175 square feet per person. 

EPA had conducted space assessments in 2005 and 2007. Given the under-utilized 

space disclosed by the OIG, the Agency needs to further assess utilization of 

GSA-owned and leased facilities and consider relocating staff to reduce underutilized space. 

EPA Needs to Establish Space Guidelines for Support Spaces 

EPA’s normal practice is to make a determination 5 years before a lease expires 

whether the Agency will stay in its current location or put out a request for 

proposals for new space. As part of this process, EPA performs a space 

assessment to determine space requirements. However, EPA’s draft 2011 space 

guidelines do not include specific guidelines for support spaces. 

In a 2005 rent analysis conducted by an EPA contractor, the contractor 

recommended that EPA define and allocate support spaces (training, conference, 

filing rooms, etc.) based on the actual requirements for these spaces. However, 

FMSD performs an overall assessment of space on a case-by-case basis when a 

lease is up for renewal. The Chief of FMSD’s Architecture, Engineering and 

13-P-0162
 

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Asset Management Branch explained that during the assessment, support space is 

determined by need at the individual facility. EPA’s July 2004 Space Acquisition 

and Planning Guidelines describe the approximate size and frequency of special 

spaces typically found in EPA facilities. However, EPA’s October 2011 draft 

New Mobile Work Space Design Guidelines focus on workstations and offices. 

It generally describes what should be in the support space but does not include 

specific space allowance guidelines for these spaces. Establishing guidelines, 

analyzing the support space specifically based on need, and determining that it is 

within the established guidelines are essential in determining whether an office is 

sized correctly and fully utilized. 

Limitations on Returning Space to GSA 

EPA is limited in returning marketable space to GSA. EPA’s occupancy 

agreement with GSA allows EPA to return marketable space or terminate a lease 

with 120 days notice. EPA is locked into long-term lease agreements (10 years) 

with GSA unless it can return a marketable space to GSA during the lease. 

Otherwise, EPA must remain in place until the lease expires. 

Other factors related to space configuration impact the ability of EPA to return 

under-utilized space to GSA. For example, EPA Region 3 planned to return an 

entire floor and portions of two others to GSA before abandoning such plans for 

security reasons. The original GSA lease for the EPA Region 3 building required 

space where only government employees could use an elevator bank with access 

to its space. Returning the space would potentially have allowed the general 

public to have access to the elevator bank and EPA space. In addition, FMSD’s 

Chief of the Architecture, Engineering and Asset Management Branch said that 

the Ariel Rios building and the Colorado building in Washington, DC, along with 

the John W. McCormack building in Region 1 (Boston, Massachusetts) are 

historic buildings that have corridors and hallways that cannot be reduced. 

FMSD’s Chief of the Architecture, Engineering and Asset Management Branch 

also stated that there is substantial cost involved when the Agency relocates 

employees for space reduction; if the cost outweighs the benefits, the Agency will 

not implement the space reduction. 

EPA Does Not Have a Policy for Determining When Contractors Should 

Be On-Site 

EPA houses contractors on-site without determining in advance if they should be 

housed on-site. Our review of 16 GSA-owned/leased facilities determined that 

contractors occupied space in 14 facilities totaling an estimated 197,000 square 

feet of EPA space. However, there is no Agency policy outlining what contractor 

functions are essential to the Agency and require contractors working on-site, and 

program officers are not required to justify the need to house contractors on-site. 

EPA spends at least $5.8 million and up to $9.9 million annually housing 

13-P-0162
 

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contractors and a policy is needed to ensure contractors are only housed in EPA 

space when justified. 

EPA Studies and Guidance Address Contractors Being Off-Site 

EPA’s 2009 Rent Efficiencies Report recommended that EPA explore options to 

have contractors located at contractor-provided locations if those contractors are 

deemed “non-mission critical” or not meeting on-site qualifying criteria. Also, the 

EPA Support Service Contracting Guide states that efforts should be taken to 

ensure that contractor employees do not occupy the same space with federal 

employees unless it is required. 

EPA’s Contracts Management Manual, Section 3.2.5, states that program and 

regional offices must identify all contracts where the contractor is working at a 

government facility and evaluate whether this is appropriate and necessary and, 

if not, relocate the place of performance to an off-site location. 

No Policy for Determining On-Site Contractors 

There is no overarching EPA policy regarding housing contractors on-site in EPA 

space. Each region has its own way of determining which contract personnel need 

to be housed in EPA space. Often, it is decided on a contract-by-contract basis. 

The Special Assistant to the Director of the Office of Acquisition Management 

and a senior Region 9 contracting officer confirmed that there is no official EPA 

policy regarding contractor personnel being assigned space within EPA 

owned/leased facilities. The Special Assistant to the Director of the Office of 

Acquisition Management also stated that program officers were not required to 

justify the need to house contractors on-site. Without a policy on what contractors 

should be provided space in EPA facilities, upfront determinations are not made 

on the space that contractors need and EPA may pay for unnecessary contractor 

space. 

13-P-0162
 

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As of February 2012, EPA spent approximately $9.9 million annually housing 

contractors on-site for the 16 sampled facilities (table 5 and appendix C). 

Table 5: Cost of housing contactors on-site at 16 sampled facilities 

Location and building name 

No. of 

contractors 

Annual cost for 

contractor space 

R 1-John W. McCormack Building 53 $951,081 

R 2-City View Plaza, Puerto Rico - -

R 2-Ted Weiss Federal Building 79 1,843,653 

R 3-1650 Arch Street 82 549,007 

R 5-National Vehicle & Fuel Emissions 36 300,026 

R 5-Norwood Professional Building 7 37,716 

R 5-Ralph H. Metcalfe Federal Building 58 543,097 

R 6-Fountain Place 77 350,906 

R 7-901 North 5th Street 11 123,723 

R 9-75 Hawthorne Street 59 640,458 

R 9-Los Angeles Field Office 3 33,786 

R 10-Park Place Building 40 392,863 

 Subtotal – contractors only 505 $5,766,316 

HQ-Ronald Reagan Building 1351 2,193,470 

HQ-Ariel Rios Federal Building 1171 1,784,260 

HQ-1310 L Street 511 124,330 

HQ-Colorado Building - -

Subtotal – contractors and 

nonfederal personnel 

303 $4,102,060 

Total 808 $9,868,376 

Source: OIG analysis of data in SLATE and from EPA sampled office facility managers as of 

February 2012: 

1 Calculation includes contractors as well as Senior Environmental Employment enrollees, 

and others as FMSD was unable to provide breakdowns. 

Conclusion 

EPA can potentially achieve up to $21.6 million in cost savings annually by 

releasing all under-utilized office space for 13 of the 16 sampled facilities 

reviewed. EPA can also potentially save at least $5.8 million and up to 

$9.9 million annually by not housing contractors on-site in 14 of the 16 sampled 

facilities that housed contractors. EPA’s occupancy agreement with GSA allows 

EPA to return space or terminate a lease with 120 days notice if it is marketable. 

However, EPA is locked into 10-year, long-term lease agreements with GSA for 

these office spaces unless it can return a marketable space to GSA during the 

lease, and also faces other obstacles in eliminating under-utilized space. 

Nonetheless, EPA has the potential to achieve savings when office space is 

renovated or relocated, and EPA should continue to pursue reducing underutilized space. 

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Recommendations 

We recommend that the Assistant Administrator for Administration and Resources 

Management: 

1. Assess utilization of GSA-owned and leased facilities and relocate staff as 

warranted to reduce under-utilized space. 

2. Develop space guidelines for support spaces and assess the number and size 

of support spaces needed at the time of a new or renewal lease. 

3. Require the Office of Acquisition Management, in conjunction with the 

Office of Administration, to develop and enforce a policy that requires 

contracting staff ensure approval for on-site contractor personnel is 

obtained from the responsible office and documented in the contract file. 

Agency Response and OIG Evaluation 

The Agency concurred with the findings and recommendations and provided 

milestone dates for the recommendations. The Agency also proposed some 

revised language, which we incorporated where appropriate in the report. The 

Agency’s full response is in appendix D. 

The Agency concurred with recommendation 1 and stated that the Office of 

Administration and Resources Management (OARM) continues to identify 

options throughout program offi.ces and the regions to do work differently in 

support of the June 2010 Presidential Memorandum, Disposing of Unneeded 

Federal Real Estate. To further this initiative and at the direction of the 

Administrator and Chief Financial Officer, OARM is implementing a plan to 

reduce the EPA’s office space by 20 percent at its leased facilities. In 

subsequent discussions, the Agency stated that given the breadth of the 

Agency’s space consolidation project and the unknowns involved, it is difficult 

to provide a meaningful completion date. However, Office of Administration’s 

projected completion date, based on the availability of sufficient funding, is 

December 2022. On December 17, 2012, Craig E. Hooks, Assistant 

Administrator issued a memo to EPA's senior leadership on EPA’s Space 

Redesign Effort. The memo stated that, "To further this effort and at the 

direction of the Administrator and Chief Financial Officer, OARM is 

implementing a plan to reduce the EPA’s office space by 20 percent at our 

leased facilities. The plan is to transform agency work space so that it is more 

efficient, collaborative and technologically sophisticated, and will reduce the 

agency’s physical and environmental footprints. ...This is an ambitious, 

multiyear, agencywide effort for which I am seeking your support as the EPA’s 

senior leaders. It will position the agency to better achieve our mission through 

greater openness and collaboration; enhance the quality of work life in our 

workplace; support the government wide mobile/flexible workplace initiative 

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and reduce our energy and greenhouse gas emissions." We agree with the 

Agency’s corrective action for recommendation 1. 

The Agency concurred with recommendation 2 and stated that OARM will 

revise the October 2011 draft New Mobile Work Space Design Guidelines to 

include support space guidance that will be used for new and renewal leases. 

The corrective action is expected to be completed by December 2013. We agree 

with the Agency’s corrective action for recommendation 2. 

The Agency initially did not concur with recommendation 3 to require the Office 

of Acquisition Management, in conjunction with the Office of Administration, to 

develop and enforce a policy that requires justification for contractor personnel 

to utilize on-site work space at EPA facilities and confirmation of the 

justification by FMSD and regional facility managers. The Agency stated that 

decisions regarding on-site contractors are strictly based on the work being 

performed. Rather than developing and enforcing a policy, OARM believes 

that a more prudent approach would be to require EPA’s contracting staff to 

ensure that approval for on-site contractor performance is obtained from the 

responsible office and documented in the contract file. We agree with the 

Agency’s proposed language for recommendation 3 and have revised it 

accordingly. However, our position remains unchanged for development of a 

policy. During the exit conference, OAM stated that it will establish a work 

group to develop an agency-wide process with associated guidance, for 

consideration for contractor personnel to be housed in on-site, EPA occupied 

work space. EPA expects to have this process in place by September 2013. We 

agree with the Agency’s corrective action for recommendation 3. 

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Chapter 3

Personnel and Usable Square Feet Data in SLATE 

Not Updated Timely 

EPA lacks accurate, current, and complete information on the number of 

personnel and usable square feet (USF) in SLATE for its GSA-owned/leased 

offices. As of April 2012, SLATE had incorrect personnel information for 13 of 

the 16 facilities sampled (81 percent), and 5 of 16 facilities sampled (31 percent) 

had incorrect information on USF. SLATE recorded a net 548 more personnel 

than what EPA had working in the sampled facilities and listed a net 235,918 

fewer USF than the sampled facilities had. Additionally, the entire USF of 

325,128 for the Region 5 Ralph H. Metcalfe building was not reported in SLATE; 

it only reported rental square feet in SLATE. This occurred because updates to 

SLATE are sporadic and inconsistent. Inaccurate data in SLATE hamper EPA’s 

ability to make informed decisions for managing its facilities. 

SLATE and Its Data Quality and Integrity Important 

The SLATE system describes SLATE as follows: 

SLATE is a Web-based, comprehensive management and strategic 

planning system developed for use by those responsible for real 

property management at EPA. SLATE is designed to maintain and 

allow viewing of all EPA facilities, including building plans, lease 

information, photographs, personnel, space and energy usage, 

budget requests, cost, and construction project tracking. 

SLATE allows a user to submit and maintain facility level data as well as to view, 

create reports on, and print a wide range of facility information. The system tracks 

construction projects from their planning stages through the budget process and 

supports design, construction, and commissioning by maintaining drawings, 

photographs, contracts, work plans, and other supporting project data. SLATE 

also provides space use analyses of EPA buildings and allows EPA to do longterm planning for buildings and facilities budgets. 

FMSD’s Standards of Behavior for Strategic Lease and Asset Tracking Enterprise 

(SLATE), Section 2.5, Integrity, states, “Employees shall protect the integrity and 

quality of information.” Section 2.5.1 requires employees to “[r]eview the quality 

of information as it is collected, generated, and used to make sure it is accurate, 

complete and up-to-date.” 

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Personnel Information in SLATE Not Accurate 

As of April 2012, SLATE had incorrect personnel information for 13 of the 16 

facilities sampled, or 81 percent (table 6). Personnel information is the number of 

employees and other non-federal staff in each facility. Personnel numbers include 

full-time EPA employees, Stay-in-Schools, Senior Environmental Employment 

enrollees, and on-site contractor personnel. 

Table 6: Comparison of personnel information for 16 sampled facilities 

Location and building name 

Per facility 

managers 

Per 

SLATE 

Personnel 

over/(under) 

in SLATE % 

HQ–Ariel Rios Federal Building 1,649 1,649 - -

HQ–1310 L Street 500 570 70 14% 

HQ–Ronald Reagan Building 1,137 1,137 - -

HQ–Colorado Building 17 20 3 18% 

R 1–John W. McCormack Building 697 845 148 21% 

R 2–Ted Weiss Federal Building 851 851 - -

R 2–City View Plaza, Puerto Rico 63 60 (3) (5%) 

R 3–1650 Arch Street 1,084 1,133 49 5% 

R 5–Ralph H. Metcalfe Federal Building 1,390 1,558 168 12% 

R 5–National Vehicle & Fuel Emissions 282 235 (47) (17%) 

R 5–Norwood Professional Building 115 85 (30) (26%) 

R 6–Fountain Place 1,084 1,052 (32) (3%) 

R 7–901 North 5th Street 631 700 69 11% 

R 9–75 Hawthorne Street 987 1,160 173 18% 

R 9–Los Angeles Field Office 29 25 (4) (14%) 

R 10–Park Place Building 685 669 (16) (2%) 

Total 11,201 11,749 548 4.89% 

% of facilities not updated in SLATE 81.25% 

Source: Data from SLATE and facility managers as of April 13, 2012. 

FMSD does not require facility managers to update personnel information on a 

systematic or regular basis and there is no quality assurance or verification of this 

data in SLATE. The Chief of FMSD’s Architecture, Engineering and Asset 

Management Branch stated that personnel information is entered into SLATE at 

the time the Occupancy Agreement/Lease is signed with GSA, and it is only 

updated when an office is realigned or is in the process of being moved or 

relocated. In addition, the FMSD SLATE project manager said that FMSD does 

not track personnel numbers in SLATE because it is a “moving target.” Further, 

facility managers determine personnel numbers in a variety of different ways, 

including: 

 Information Services Information System–regionally developed system 

 Systematic basis when in the process of a move 

 Employee directory database 

 Roster database 

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USF Information in SLATE Not Accurate 

As of April 2012, SLATE had incorrect USF information for 5 of the 16 facilities 

sampled, or 31 percent (table 7). 

Table 7: Comparison of USF information for 16 sampled facilities 

Location and building name 

USF per 

FMSD 

USF per 

SLATE 

USF over/(under) 

in 

SLATE % 

HQ–Ariel Rios Federal Building 446,324 446,324 - -

HQ–1310 L Street 123,279 135,901 12,622 10% 

HQ–Ronald Reagan Building 230,664 230,664 - -

HQ–Colorado Building 9,667 9,667 - -

R 1–John W. McCormack Building 224,261 224,261 - -

R 2–Ted Weiss Federal Building 243,057 269,834 26,777 11% 

R 2–City View Plaza, Puerto Rico 19,700 19,700 - -

R 3–1650 Arch Street 268,968 268,968 - -

R 5–Ralph H. Metcalfe Federal Building 325,128 - (325,128) (100%) 

R 5–National Vehicle & Fuel Emissions 59,100 59,100 - -

R 5–Norwood Professional Building 28,594 28,594 - -

R 6–Fountain Place 239,130 239,130 - -

R 7–901 North 5th Street 182,554 182,554 - -

R 9–75 Hawthorne Street 204,014 253,919 49,905 24% 

R 9–Los Angeles Field Office 13,907 13,813 (94) (1%) 

R 10–Park Place Building 154,006 154,006 - -

Total 2,772,353 2,536,435 (235,918) (8.51%) 

% of facilities not updated in SLATE 31.25%

 Source: FMSD and SLATE as of April 13, 2012. 

Similar to SLATE’s personnel information, the Chief of FMSD’s Architecture, 

Engineering and Asset Management Branch said that USF information is entered 

into SLATE at the time the Occupancy Agreement/Lease is signed with GSA, and 

there is no quality assurance or verification of this data in SLATE. In addition, 

this information is updated only when the lease is renewed or when EPA gives up 

space. FMSD provided the following examples of where USF was not updated in 

SLATE: 

 San Francisco office—It was under a third lease extension due to the 

design/construction for a succeeding lease. 

 Los Angeles field office—A reduction in space is planned, and the realty 

specialist was waiting for information on the reduction’s scope. 

 New York office—It was not updated as GSA re-measured the building. 

 1310 L Street building at HQ, and Chicago facilities—It was not timely 

updated due to an inadvertent oversight. 

Accurate information on personnel and USF is a key component in determining 

under-utilized office space and in determining office requirements when an office 

space is realigned or relocated. For our calculation of under-utilized space for our 

16 sampled offices, we had to obtain the updated personnel information for the 

16
 

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audit from the regional facility managers of the 16 sampled facilities and updated 

information on USF from the Chief of FMSD’s Architecture, Engineering and 

Asset Management Branch. Inaccurate personnel and USF data in SLATE on 

GSA-owned/leased offices hampers EPA’s ability to make informed decisions for 

managing its facilities. 

Number of Facilities in SLATE Not Accurate 

As of April 2012, information in SLATE showed 172 EPA facilities but showed 

one of those facilities as a “Nationwide” facility with no data. This should not be 

considered a facility for listing purposes. Another line item, “La Plaza Building 

(Off Campus Facilities),” in Region 9, was a duplicate entry; it was a summary of 

five offices also listed. These two line items should not be listed in SLATE, and 

the total number of facilities in SLATE should have only been 170. 

Conclusion 

EPA lacks sufficiently accurate, complete, and up-to-date information on the 

number of personnel and USF in SLATE for its GSA-owned/leased offices. If this 

information is not updated on a systematic basis, EPA’s ability to make informed 

decisions for managing its facilities is hampered. 

Recommendations 

We recommend that the Assistant Administrator for Administration and Resources 

Management: 

4. Require that personnel information be consistently tracked and updated in 

EPA’s designated real property management system on an annual basis or 

more often if needed. 

5.	 Require FMSD to update USF information whenever a change in office 

space is made. 

Agency Response and OIG Evaluation 

The Agency concurred with the findings and recommendations, and provided 

milestone dates for the proposed corrective actions. The Agency’s full response is 

in appendix D. 

The Agency concurred with recommendation 4 and stated that OARM is 

developing a process whereby facility mangers will be required to update 

personnel data in the designated real property asset management system. 

SLATE is no longer an active system. FMSD staff will provide oversight to 

ensure updates are provided. T h e corrective action is expected to be 

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completed by December 2013. We agree with the Agency’s corrective action 

for recommendation 4. 

The Agency concurred with recommendation 5 and stated that OARM has an 

internal policy to update the usable square feet of any agency facility once the 

EPA assumes or releases occupancy of space. F acility managers will update 

the usable square feet which will be audited by FMSD staff. The corrective 

action is expected to be completed by December 2013. We agree with the 

Agency’s corrective action for recommendation 5. 

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Status of Recommendations and 

Potential Monetary Benefits 

POTENTIAL MONETARY 

RECOMMENDATIONS BENEFITS (in $000s) 

Planned 

Rec. 

No. 

Page 

No. Subject Status1 Action Official 

Completion 

Date 

Claimed 

Amount 

Agreed-To 

Amount 

1 12 Assess utilization of GSA-owned and leased O Assistant Administrator for December 

facilities and relocate staff as warranted to reduce Administration and 2022 

under-utilized space. Resources Management 

2 12 Develop space guidelines for support spaces and 

assess the number and size of support spaces 

needed at the time of a new or renewal lease. 

O Assistant Administrator for 

Administration and 

Resources Management 

December 

2013 

3 12 Require the Office of Acquisition Management, in 

conjunction with the Office of Administration, to 

develop and enforce a policy that requires 

contracting staff ensure approval for on-site 

contractor personnel is obtained from the 

responsible office and documented in the contract 

file. 

O Assistant Administrator for 

Administration and 

Resources Management 

September 

2013 

4 17 Require that personnel information be consistently 

tracked and updated in EPA’s designated real 

property management system on an annual basis 

or more often if needed. 

O Assistant Administrator for 

Administration and 

Resources Management 

December 

2013 

5 17 Require FMSD to update USF information 

whenever a change in office space is made. 

O Assistant Administrator for 

Administration and 

Resources Management 

December 

2013 

O = recommendation is open with agreed-to corrective actions pending 

C = recommendation is closed with all agreed-to actions completed 

U = recommendation is unresolved with resolution efforts in progress 

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1 
 

 

Appendix A 

Details on Scope and Methodology 

We reviewed EPA’s Metropolitan Architects and Planners contract for information on EPA 

contract space reduction activities. We also reviewed EPA’s Asset Management Plan, EPA’s 

Real Property Cost Savings and Innovation Plan, EPA’s Space Acquisition and Planning 

Guidelines, and draft Mobile Work Space Design Guidelines, to determine EPA’s criteria and 

methodology for managing space and identifying and realizing real property cost savings. 

We reviewed space consolidation efforts such as the 2009 EPA Rent Efficiencies Report, EPA’s 

master rent avoidance charts, and the Metropolitan Architects and Planners’ October 2005 final 

report US EPA Nationwide Rent Analysis. We verified EPA’s rental space and cost reduction 

accomplished to its records. We verified GSA’s Rent-On-Web annual operating costs in SLATE 

to billings in GSA’s Rent-On-Web website. We also obtained updated head counts from regional 

facility managers and USF from FMSD. 

We reviewed fiscal years 2010 and 2011 Integrity Act Annual Assurance Letters for EPA’s 

OARM and Office of the Administrator to determine whether those letters identified any 

weaknesses related to property and space reduction. The letters did not identify such weaknesses. 

Methodology to Select Sample and Calculate Cost Savings 

To select a sample of EPA facilities for review, we: 

	 Obtained a listing of facilities in SLATE. We determined that there were 170 facilities 

that EPA used as of November 2011 at an annual operating cost of approximately 

$279 million. 

	 Analyzed the 170 EPA facilities. We excluded laboratories because, in July 2011, the 

U.S. Government Accountability Office reviewed laboratories that mainly consisted of 

EPA-owned facilities. We also excluded warehouses, parking spaces, storage rooms, and 

child care facilities because they had low annual costs. We used the remaining 92 

owned/leased and EPA special use offices for the audit universe. These facilities have 

total annual operating costs of approximately $206 million, which is approximately 

74 percent of the annual operating cost of the 170 facilities. 

	 Using GSA’s recommended federal benchmark of 190 USF per person, selected sample 

offices for review that had a potential annual cost savings of over $225,000. This came to 

16 offices with total operating costs of approximately $135 million and potential annual 

savings of $31.8 million. 

	 Calculated under/over-utilized space for the 16 sampled offices based on EPA’s internal 

standard of 210 USF per person and GSA’s federal benchmark of 190 USF per person 

(appendix B). 

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20 
 

 

 

To calculate potential cost savings, we: 

 Divided office USF by number of personnel and compared it to the EPA rate of 210 per 

person, thus arriving at under-utilized USF per person. 

 Multiplied under-utilized USF per person by number of personnel to arrive at total underutilized USF for the building. 

 Divided annual operating cost by office USF to arrive at operating cost per USF. 

 Multiplied total under-utilized USF for the building by annual operating cost per USF to 

arrive at potential cost savings. 

Prior Reports 

In January 2009, the OIG issued Report No. 09-P-0080, Congressionally Requested Report on 

EPA Staffing Levels and Total Costs for EPA Facilities. This report provided Congress with 

information on staffing levels, rental/lease fees, and utility and security costs for all EPA 

facilities and locations where EPA incurred employee-associated costs. 

We reviewed the U.S. Government Accountability Office’s July 2011 Report No. GAO-11-347, 

To Better Fulfill Its Mission, EPA Needs a More Coordinated Approach to Managing its 

Laboratories, to determine whether EPA laboratories should be included in our audit. As a result 

of that report, we decided to exclude laboratories. 

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Appendix B 

Calculations for Under-Utilized Space and 

Excess Cost for 16 Sampled Facilities 

Using EPA’s 210 USF per person 

Location and 

building name USF Personnel 

Current 

Underutilized 

Total 

underutilized 

USF 

Annual operating 

Excess 

annual 

operating 

USF per person cost cost 

 cost 

per USF 

HQ-Ariel Rios Building 446,324 1,649 271 61 100,589 $25,130,427 $56.31 $5,664,167 

R 2-Ted Weiss Building 243,057 851 286 76 64,676 19,824,229 81.56 5,274,975 

R 1-John W. McCormack 224,261 697 322 112 78,064 12,497,786 55.73 4,350,507 

R 7-901 North 5th Street 182,554 631 289 79 49,849 7,110,492 38.95 1,941,619 

R 5-Ralph H. Metcalfe 325,128 1390 234 24 33,360 13,023,915 40.06 1,336,402 

R 3-1650 Arch Street 268,968 1,084 248 38 41,192 7,262,002 27.00 1,112,184 

R 10-Park Place Building 154,006 685 225 15 10,275 6,727,108 43.68 448,812 

R 2-City View Plaza, PR 19,700 63 313 103 6,489 1,193,687 60.59 393,169 

HQ-Colorado Building 9,667 17 569 359 6,103 547,545 56.64 345,674 

R 6-Fountain Place 239,130 1,084 221 11 11,924 4,928,459 20.61 245,754 

R 9-Los Angeles Field Off 13,907 29 480 270 7,830 326,437 23.47 183,770 

HQ-310 L Street 123,279 500 247 37 18,500 1,216,534 9.87 182,595 

R 5-Norwood Prof. Building 28,594 115 249 39 4,485 618,300 21.62 96,966 

R 5-Nat'l Vehicle & Fuel 1 59,100 282 210 Utilized - 2,345,783 39.69 -

R 9-75 Hawthorne Street 2 204,014 987 207 Utilized - 10,692,122 52.41 -

HQ-Reagan Building 3 230,664 1,137 203 Utilized - 18,463,553 80.05 -

 Total 2,772,353 11,201 433,336 $31,908,379 $21,576,594 

Source: Source: OIG analysis of EPA data provided by FMSD and regional facility managers. 

1 Due to using 210 USF and increased personnel head count, the audit result disclosed that it is utilized. 

2 Due to using 210 USF and decreased USF and personnel head count, the audit result disclosed that it is utilized. 

3 Due to using 210 USF, the audit result disclosed that it is utilized.
 

Descriptions for above table 

Column description Calculation formula 

Usable square feet (USF) Provided by FMSD 

Personnel Provided by regional facility managers 

Current USF per person Usable square feet divided by personnel 

Under-utilized USF per person Current USF per person minus 210 USF 

Total under-utilized USF Under-utilized USF per person times personnel 

Annual operating cost Obtained from SLATE as of 2/1/2012 

Annual operating cost per USF Annual cost divided by USF 

Excess annual operating cost due to total under-utilized USF Annual operating cost per USF times total under-utilized USF 

22 

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Using 190 USF per person 

Location and building name USF 

Net usable 

plus 

circulation 

square feet Personnel 

USF 

Under/(over) 

utilized

 Per person 

HQ–Colorado Building 9,667 6,434 17 378 188 

R 2–Ted Weiss Federal Building 243,057 187,542 851 220 30 

HQ–Ariel Rios Federal Building 446,324 330,888 1,649 201 11 

R 1–John W. McCormack Building 224,261 128,250 697 184 (6) 

R 5–Ralph H. Metcalfe Federal Building 325,128 224,855 1,390 162 (28) 

R 7–901 North 5th Street 182,554 110,668 631 175 (15) 

HQ–1310 L Street 123,279 87,635 500 175 (15) 

R 3–650 Arch Street 268,968 185,282 1,084 171 (19) 

R 9–75 Hawthorne Street 204,014 146,321 987 148 (42) 

R 6–Fountain Place 239,130 155,253 1,084 143 (47) 

HQ–Ronald Reagan Building 230,664 167,536 1,137 147 (43) 

R 10–Park Place Building 154,006 93,788 685 137 (53) 

R 2–City View Plaza, Puerto Rico 19,700 Information not 

provided 63 N/A N/A 

R 5–National Vehicle & Fuel Emissions 59,100 Information not 

provided 282 N/A N/A 

R 5–Norwood Professional Building 28,594 Information not 

provided 115 N/A N/A 

R 9–Los Angeles Field Office 13,907 Information not 

provided 29 N/A N/A 

Total 2,772,353 11,201 

 Source: Data provide by FMSD and facility managers as of February 2012. 

 Descriptions for above table 

Column description Calculation and Source 

Usable square feet Provided by FMSD 

Net usable plus circulation square feet Offices, cubicles, conference rooms, and hallways 

Personnel Provided by facility managers 

USF per person Net use plus circulation square feet divided by personnel 

Under/(over) utilized at 190 USF per person USF per person minus 190 

23 

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 Appendix C 

Cost of Housing Contractors On-Site 

at 16 Sampled Facilities 

Location and building 

name USF Personnel 

Current 

USF per 

person 

No of USF for 

% of 

USF for Annual operating 

contractors cost 

cost for 

contractors 

R 1-John W. McCormack 224,261 697 322 53 17,066 7.61% 12,497,786 951,081 

R 2-Ted Weiss Building 243,057 851 286 79 22,594 9.30% 19,824,229 1,843,653 

R 2-City View Plaza, PR 19,700 63 313 - - 0.00% 1,193,687 -

R 3-1650 Arch Street 268,968 1,084 248 82 20,336 7.56% 7,262,002 549,007 

R 5-Ralph H. Metcalfe 325,128 1390 234 58 13,572 4.17% 13,023,915 543,097 

R 5-Nat'l Vehicle & Fuel 59,100 282 210 36 7,560 12.79% 2,345,783 300,026 

R 5-Norwood Prof. Building 28,594 115 249 7 1,743 6.10% 618,300 37,716 

R 6-Fountain Place 239,130 1,084 221 77 17,017 7.12% 4,928,459 350,906 

R 7-901 North 5th Street 182,554 631 289 11 3,179 1.74% 7,110,492 123,723 

R 9-75 Hawthorne Street 204,014 987 207 59 12,213 5.99% 10,692,122 640,458 

R 9-Los Angeles Field Off 13,907 29 480 3 1,440 10.35% 326,437 33,786 

R 10-Park Place Building 154,006 685 225 40 9,000 5.84% 6,727,108 392,863 

Subtotal - contractors 

only 

1,962,419 7,898 505 125,720 86,550,320 5,766,316 

HQ-Reagan Building* 230,664 1,137 203 135 1 27,405 11.88% 18,463,553 2,193,470 

HQ-Ariel Rios Building 446,324 1,649 271 117 1 31,707 7.10% $ 25,130,427 1,784,260 

HQ-1310 L Street* 123,279 500 247 51 1 12,597 10.22% 1,216,534 124,330 

HQ-Colorado Building 9,667 17 569 - - 0.00% 547,545 -

 Subtotal – contractors & 

nonfederal personnel 

809,934 3,303 303 71,709 45,358,059 $ 4,102,060 

Total 2,772,353 11,201 808 197,429 $131,908,379 $ 9,868,376 

Source: OIG analysis of data in SLATE and from EPA sampled office facility managers as of February 2012. 

1 Calculation includes contractors as well as Senior Environmental Employment enrollees and others as FMSD was unable to 

provide breakdowns. 

 Descriptions for above table 

Column description Calculation formula 

Current USF per person USF divided by personnel 

No. of contractors Provided by facility managers 

USF for contractors Current USF per person times number of contractors 

% of USF for contractors USF for contractors divided by USF 

Annual operating cost Obtained from SLATE as of 2/1/2012 

Annual cost for contractors Annual operating cost times percentage of contractors 

24 

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Appendix D 

Agency Response to Draft Report 

Thank you for the opportunity to review and comment on the draft report (Project No. OAFY12-0056), dated October 4, 2012. In the attachment we are providing clarification of three 

issues pertaining to factual accuracy and a discussion regarding our concurrence or 

nonconcurrence with your five proposed recommendations. 

If you have any questions pertaining to this response, please contact Renee Page, Director, 

Office of Administration, at (202) 564-8400. 

Attachment 

cc: Renee Page 

25
 

13-P-0162
 
 

 

Office of Administration and R esources Management
 

Response to Draft R eport: Project No. OA-FY12-0056
 

EPA Can Further Reduce Space in Under-Utilized Facilities 

Issues pertaining to factual accuracy 

Report language in Executive Summary and on page 12: ''EPA omitted reporting in SLATE 

an entire Region 5 building (325,128 USF)." 

According to the methodology on page 17, you obtained a listing of facilities in 

SLATE as of November 2011, and determined that the Ralph H. Metcalfe Federal 

Building was not included. This is an incorrect conclusion. An April28, 2011, 

SLATE report already included the building in the inventory. 

Report language on page 11: "Both GSA and EPA recognize that the average office 

space can be reduced to 60 square feet in upcoming years." 

The referenced document containing the GSA's 60 square foot number is the 

GSA'sJuly 2011 report, Workspace Utilizationand Allocation Benchmark,as indicated 

on page 4 of the draft. This GSA document hypothesises that the 60 square feet 

could be achieved only through extensive use of alternative workspace 

arrangements, such as hoteling, home office and teleworking on a fulltime basis. 

The EPA's current policy limits telework to no more than two days per week and 

would therefore have to be modified. Such a significant change has already been 

the subject of extensive negotiation and delay. Hence, at this time, the EPA does 

not recognize that the average office space can be reduced to 60 square feet in 

upcoming years.” 

Report language on page 8: “Also, EPA's 2011 draft New Mobile Work Space Design Guidelines 

require a typical work station to be up to 60 USF and a telework station up to 30 USF per 

person; both are substantial space reductions from the 210 USF per person used in our 

analysis.” 

The guideline numbers of 60 and 30 USF are not considered reductions from the 

210 square feet per person number, which incorporates required space outside the 

actual workstation for circulation, filing, conferencing, collaboration and small 

meeting rooms. A reasonable design reduction from 210 square feet would be 175 

square feet per person. 

Comments pertaining to concurrence or nonconcurrence with proposed recommendations 

Chapter 2 -"EPA Can Further Strive for Space Reduction" 

1. Assess utilization of GSA-owned and leased facilities and relocate staff as 

warranted to reduce under-utilized space.
 

OARM response: Concur Anticipated completion - ongoing 

The EPA's space consolidation efforts have been ongoing since 2007. OARM 

continues to identify options throughout program offi.ces and the regions to do 

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work differently in support of the June 2010 Presidential Memorandum, Disposing 

of Unneeded Federal Real Estate. To further this initiative and at the direction of the 

Administrator and Chief Financial Officer, OARM is implementing a plan to 

reduce the EPA's office space by 20 percent at its leased facilities. The redesign 

plan has already been implemented in the new Kansas City Regional Office and 

plans are underway to incorporate collaboration, greater mobility and advanced 

technology into the design of the new Region 9 offices. In Headquarters, several 

pilot projects are in development that will also demonstrate open design principles. 

In addition, we are in the process of relocating two offices within the Office of the 

Administrator that will release more than 19,000 square feet of leased office space 

and realize almost $1M in annual rent avoidance beginning in FY2013. 

2. Develop space guidelines for support spaces and assess the number and size of 

support spaces needed at the time of a new or renewal lease. 

OARM response: Concur Anticipated completion - December 2013 

The agency has guidance per the July 2004 Space Acquisition and Planning 

Guidelines that describe the approximate size and frequency of special spaces 

typically found at EPA facilities. OARM will revise the October 2011 draft New 

Mobile Work Space Design Guidelines to include support space guidance that will be 

used for new and renewal leases. 

3. Require the Office of Acquisition Management, in conjunction with the Office of 

Administration, to develop and enforce a policy that requires justification for 

contractor personnel to utilize on-site work space at EPA facilities and 

confirmation of the justification by FMSD and regional facility managers. 

OARM response: Does Not Concur 

Decisions regarding on-site contractors are strictly based on the work being 

performed. Rather than developing and enforcing a policy, OARM believes that a 

more prudent approach would be to require the EPA's contracting staff to ensure that 

approval for on-site contractor performance is obtained from the responsible office 

and documented in the contract file. 

Chapter 3 "Personnel and Usable Square Feet Data in SLATE Not Updated Timely" 

4. Require that personnel information be consistently tracked and updated in 

EPA's designated real property management system and SLATE on an 

annual basis or more often if needed. 

OARM response: Concur Anticipated completion - December 2013 

OARM is developing a process whereby facility mangers will be required to 

update personnel data in the designated real asset management system. Facilities 

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Management and Services Division staff will provide oversight to ensure updates 

are provided. SLATE is no longer an active system. 

5. Require FMSD to update USF information whenever a change in the office 

space is made. 

OARM response: Concur Anticipated completion - December 2013 

OARM has an internal policy to update the usable square feet of any agency facility 

once the EPA assumes or releases occupancy of space. As noted in the response to 

recommendation 4 above, facility managers will update the usable square feet which 

will be audited by FMSD staff. 

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Appendix E 

Distribution 

Office of the Administrator 

Assistant Administrator for Administration and Resources Management 

Director, Office of Acquisition Management, Office of Administration and Resources Management 

Director Office of Administration, Office of Administration and Resources Management 

Agency Follow-Up Official (the CFO) 

Agency Follow-Up Coordinator 

General Counsel 

Associate Administrator for Congressional and Intergovernmental Relations 

Associate Administrator for External Affairs and Environmental Education 

Audit Follow-Up Coordinator, Office of Administration and Resources Management 

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