FEDERAL REAL 

PROPERTY

Actions Needed to 

Enhance Information 

on and Coordination 

among Federal 

Entities with Leasing 

Authority

Report to Congressional Requesters

July 2016

GAO-16-648

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-16-648, a report to 

congressional requesters

July 2016

FEDERAL REAL PROPERTY

Actions Needed to Enhance Information on 

and Coordination among Federal Entities with 

Leasing Authority

What GAO Found

There is no comprehensive list of federal entities with independent leasing 

authority. The Federal Real Property Council (FRPC), chaired by the Office of 

Management and Budget (OMB), was established in 2004 through executive 

order to coordinate and share leading practices in real property management 

among federal agencies covered by the Chief Financial Officers Act of 1990. The 

General Services Administration (GSA) was directed to create a database 

intended to be a comprehensive inventory of federal facilities, which resulted in 

the Federal Real Property Profile (FRPP). However, federal entities that are not 

members of the FRPC are not required to submit data to the FRPP and few do 

so. Of the 103 federal entities that GAO surveyed, 52 reported having

independent authority to lease office and warehouse space. As of October 1, 

2015, these 52 entities leased 944 domestic offices and 164 warehouses. 

Twenty-five of those entities are not members of the FRPC and therefore not 

required to submit their real property data to the FRPP despite leasing 243 

offices and warehouses. As such, the FRPP’s incomplete data set reduces its 

effectiveness as an oversight and accountability mechanism for entities with 

independent leasing authority.

Offices and Warehouses Leased by Entities That Are Not Members of the Federal Real 

Property Council 

Number of federal 

entities

Number of offices and 

warehouses

Rentable square 

feet

Approximate 

annual rent

25 243 8,321,232 $303.4 million

Source: Information reported by federal entities in a GAO survey as of October 1, 2015. | GAO-16-648

GAO’s review of the costs of 37 selected independent leases found that the rates 

of most were less costly or comparable to matched GSA leases. When 

independent leases have lower costs, it may be attributed in part to: (1) GSA’s

using standardized lease documents that include clauses with higher energy 

conservation, security, and seismic requirements, and (2) independent leases’ 

having fewer space modifications, more periods of free rent, and private sector 

real-estate professionals negotiating with potential owners. Most of the 

independent leases were also less costly or comparable to matched private 

sector leases, particularly in the National Capital Region.

GAO reviewed the extent to which eight selected federal entities had policies that 

incorporated leading government leasing practices and found that six had 

policies that generally conformed to these practices. However, none of the lease 

files contained evidence that the practices were consistently followed. For 

example, 88 percent of the entities’ lease files lacked evidence of ensuring best 

value by documenting advertisements to seek bids to fill their space needs, and 

77 percent lacked evidence that entities effectively planned ahead by 

documenting the factors they used to evaluate lease offers. In addition, the 

average of all leases we analyzed for space-use more than doubled GSA’s 

recommended target of 150 rentable square feet per employee for office space. 

It may help federal entities conform to leading practices and meet utilization 

targets for the space they lease if they can benefit from the coordination and 

leading real-property management practices shared at the FRPC. 

View GAO-16-648. For more information, 

contact David J. Wise at (202) 512-2834 or 

wised@gao.gov.

Why GAO Did This Study

GSA leases real property on behalf 

of many federal tenants, but some 

federal entities have statutory

independent leasing authority. 

GAO was asked to review federal 

entities with independent leasing 

authority. This report examines (1) 

what is known about which federal 

entities have independent leasing 

authority and their use of this 

authority; (2) how selected 

independent leases compare to GSA 

and private sector leases in terms of 

cost; and (3) to what extent selected 

entities have leasing policies and 

practices that align with leading 

government practices. GAO 

conducted a survey of 103 federal 

entities identified in previous GAO 

work; selected eight entities for their 

diversity in size and mission, and

visited 37 leased office and 

warehouse locations; analyzed 

leases and lease files for the 37 

locations; reviewed applicable laws, 

policies, and guidance; and 

interviewed GSA, OMB, and officials 

from the selected entities. 

What GAO Recommends

GAO recommends that OMB should 

establish efficient methods to:

include data from non-FRPC 

members to the FRPP and increase

collaboration between FRPC and 

non-FRPC entities. OMB concurred 

with both recommendations.
Page i GAO-16-648 Federal Real Property

Letter 1

Background 5

Twenty-five Federal Entities That Reported Having Independent 

Leasing Authority Are Not Members of FRPC or Consistently 

Tracked in FRPP 9

For Various Reasons, the 37 Selected Independent Lease Rates 

Were Often Comparable to or Lower Than Matched GSA and 

Private Sector Rates 16

Most Selected Entities’ Leasing Policies Generally Align with 

Leading Practices but Lack Documentation, and Space 

Allocations Exceed the GSA Target 24

Conclusions 35

Recommendations for Executive Action 36

Agency Comments and Our Evaluation 36

Appendix I Objectives, Scope, and Methodology 39

Appendix II Federal Entities That Reported Having Independent Leasing Authority 

for Domestic Offices and Warehouses, as of September 30, 2015 48

Appendix III Comments from the National Credit Union Administration 53

Appendix IV Comments from the United States Patent and Trademark Office within

the Department of Commerce 55

Appendix V GAO Contact and Staff Acknowledgments 58

Tables

Table 1: Selected Data about Federal Entities That Reported 

Having Independent Statutory Leasing Authority for 

Domestic Offices and Warehouses and Are Not Part of 

the Federal Real Property Council 13

Contents
Page ii GAO-16-648 Federal Real Property

Table 2: Selected Independent Real Property Lease Rates 

Compared to Matched General Services Administration 

(GSA) Real Property Lease Rates, National Capital 

Region versus Other Metropolitan Areas 17

Table 3: Selected Independent Real Property Lease Rates 

Compared to Matched General Services Administration 

(GSA) Real Property Lease Rates, by Federal Entity 17

Table 4: Selected Independent Real Property Lease Rates 

Compared to Matched Private Sector Real Property 

Market Rates, National Capital Region versus Other 

Metropolitan Areas 23

Table 5: Percentage of Selected Lease Files GAO Analyzed That 

Documented Alignment with Leading Government 

Leasing Practices, by Selected Entity 31

Table 6: Federal Real Property Council Member Agencies that 

Reported Having Independent Leasing Authority for 

Domestic Offices and Warehouses 48

Table 7: Federal Entities Not Part of the Federal Real Property 

Council That Reported Having Independent Leasing 

Authority for Domestic Offices and Warehouses 51

Figures

Figure 1: Examples of the Types of Spaces Federal Entities Lease 

from Private Owners 6

Figure 2: Selected Independent Real Property Lease Rates 

Compared to Matched General Services Administration 

(GSA) Real Property Lease Rates, by Federal Entity 18

Figure 3: Selected Independent Real Property Lease Rates 

Compared to Matched Private Sector Real Property 

Market Rates, by Federal Entity 22

Figure 4: Leading Government Practices for Leasing Federal Real 

Property 25

Figure 5: Percentage of Selected Entities’ Lease Files GAO 

Analyzed That Documented Alignment with Applicable 

Leading Government Practices for Leasing Federal Real 

Property 30

Figure 6: Selected Federal Entities’ Per-Employee Office Space 

Allocation Averages and GSA’s Recommended Target 33

Figure 7: Examples of Unoccupied Office Spaces 34
Page iii GAO-16-648 Federal Real Property

Abbreviations

CFO Act Chief Financial Officers Act of 1990 

FAA Federal Aviation Administration 

FDIC Federal Deposit Insurance Corporation 

FRPC Federal Real Property Council 

FRPP Federal Real Property Profile 

GSA General Services Administration 

NASA National Aeronautics and Space 

Administration 

NCUA National Credit Union Administration 

NOAA National Oceanic and Atmospheric 

Administration 

National Strategy National Strategy for the Efficient Use of 

Real Property

OMB Office of Management and Budget 

PBGC Pension Benefit Guaranty Corporation 

USCG United States Coast Guard

USPTO United States Patent and Trademark Office 

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

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

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

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

necessary if you wish to reproduce this material separately.
Page 1 GAO-16-648 Federal Real Property

441 G St. N.W.

Washington, DC 20548

July 6, 2016

The Honorable Bill Shuster

Chairman

The Honorable Peter A. DeFazio

Ranking Member

Committee on Transportation and Infrastructure

House of Representatives

The Honorable Lou Barletta

Chairman

The Honorable André Carson

Ranking Member

Subcommittee on Economic Development,

 Public Buildings, and Emergency Management

Committee on Transportation and Infrastructure

House of Representatives

The federal government’s real property portfolio of over 275,000 buildings 

held or leased by civilian and defense agencies is vast and diverse. GAO 

has identified federal real-property management as a high-risk area due 

in part to an overreliance on leasing from the private sector in cases 

where ownership would be less expensive in the long run.1 As the federal 

government’s principal civilian landlord, the General Services 

Administration (GSA) leases real property on behalf of many federal 

tenants. In fiscal year 2014, GSA leased 6,859 office and warehouse 

spaces from the private sector (approximately 187.6-million rentable 

square feet).2 However, independent leasing authority can be provided to 

federal entities either through their enabling legislation or through an 

appropriations act.3 As such, the basis for such authority is unique to the 

 1

GAO, High-Risk Series: An Update, GAO-15-290 (Washington, D.C.: Feb. 11, 2015). 

Other reasons for the designation included unreliable data, excess and underutilized 

property, and challenges associated with protecting the physical security of federal 

facilities. 

2

GSA Public Buildings Service, FY2014 State of the Portfolio (Washington, D.C.: 2014). 

3

A provision in an annual appropriations act is presumed to be effective only for the 

covered fiscal year unless language in the act or the nature of the provision makes it clear 

that Congress intended for the provision to be permanent. 

Letter
Page 2 GAO-16-648 Federal Real Property

federal entity. Generally, without such authority, federal entities rely on 

GSA for their space needs. While GSA tracks and reports on its tenants’ 

real property holdings, less is known about the holdings of federal entities 

that independently lease real property.

You asked us to review federal entities’ use of independent leasing 

authority. This report examines: (1) what is known about which federal 

entities have independent leasing authority and their use of this authority 

to lease office and warehouse space; (2) how selected independent 

leases compare to GSA and private sector leases in terms of cost;4 and 

(3) to what extent selected federal entities with independent leasing 

authority have leasing policies and practices that align with leading 

government leasing practices.

To determine what is known about which federal entities have 

independent leasing authority and use this authority to lease office and 

warehouse space, we administered a survey to 103 civilian federal 

entities. Our survey universe included all federal entities identified in a 

prior GAO report on federally created entities such as executive 

departments,5 other executive branch entities, government corporations, 

and other federally established organizations in the executive branch that 

received an average of over $20 million in annual appropriations from 

fiscal years 2005 through 2008.6 The survey’s responses indicate which 

federal entities report having independent leasing authority and the 

statute which provided them the authority. For the entities using their 

authority, additional questions asked how much office and warehouse 

space they leased and the annual rental cost, as of October 1, 2015. We 

achieved a 100 percent response rate to our survey.

To assess how selected independent leases compare with GSA and 

private sector lease costs, we contracted with a real-estate consulting firm 

to perform analyses of lease costs. With the consulting firm, we collected 

 4

Independent leases are leases executed by federal entities using their independent 

leasing authority. 

5

We also surveyed the federal entities within executive departments that we either 

identified or the executive department identified as having independent leasing authority 

(e.g., Federal Aviation Administration (FAA) within the Department of Transportation). 

6

GAO, Federally Created Entities: An Overview of Key Attributes, GAO-10-97 

(Washington, D.C.: Oct. 29, 2009). 
Page 3 GAO-16-648 Federal Real Property

location, cost, and size information for 43 leases, commencing from 

calendar years 2001 through 2015, from eight selected federal entities, 

with offices and warehouses located in four different U.S. metropolitan 

regions: Atlanta, Georgia; Los Angeles, California; Miami, Florida; and 

Washington, D.C. We selected these four metropolitan regions because 

of the availability of independently leased office and warehouse spaces. 

The eight civilian federal entities were the Federal Aviation Administration 

(FAA) within the Department of Transportation, the Federal Deposit 

Insurance Corporation (FDIC), the National Aeronautics and Space 

Administration (NASA), the National Credit Union Association (NCUA), 

the National Oceanic and Atmospheric Administration (NOAA) within the 

Department of Commerce, the Pension Benefit Guaranty Corporation 

(PBGC), the U.S. Coast Guard (USCG) within the Department of 

Homeland Security, and the U.S. Patent and Trademark Office (USPTO) 

within the Department of Commerce. We used information on these 

selected independent leases, such as location, initial year, size, and other 

cost-affecting factors, to match the leases to similar GSA and private 

sector leases during this time period. For the GSA matches, we assessed 

how the leases’ net present value per square foot compared with one 

another, while for the private sector matches we assessed how the 

leases’ first years’ rents compared with one another.7 While our selection 

of 43 leases from eight federal entities is non-generalizable to the 

universe of all independent leases, this selection provides examples of 

how independent leases compare with GSA and private sector leases. 

When an independent lease’s net present value was within 10 percent 

above or 10 percent below its matched GSA or private sector lease, we 

considered the two leases comparable in rate. We allowed this range to 

account for variations caused by the specific circumstances and unique 

features of each lease transaction. Otherwise, we considered an 

independent lease beyond the 10 percent comparable range to be either 

more costly or less costly than its matched lease.

To evaluate the extent that selected entities’ leasing policies and 

practices aligned with leading government practices for leasing federal 

real property, we identified a broad set of applicable federal lease 

acquisition leading practices from a variety of federal sources including 

 7

Of the 43 independent leases collected from the eight entities, we excluded four leases 

on the basis that they did not require the tenant to pay any rent, and excluded two 

additional leases because leases of comparable building finish quality could not be 

identified in their respective market.
Page 4 GAO-16-648 Federal Real Property

the General Services Acquisition Regulation, the GSA’s Leasing Desk 

Guide,

8 the Federal Management Regulation, Office of Management and 

Budget’s (OMB) Circular A-11,

9 and prior GAO reports.10 To determine 

the extent that our eight selected entities’ policies aligned with our list of 

leading practices, we reviewed the real property policies provided to us by 

each entity. To determine the extent that the entities’ leasing practices 

aligned with leading government practices, we reviewed all 

documentation in individual lease files provided by the entities for 

selected 30 leases. In reviewing the lease files, we evaluated whether 

there was documentary evidence that the leading practices were used. To 

determine how these selected entities’ utilization of office spaces 

compared with the GSA’s recommended target of 150 rentable square 

feet per employee, we determined the space utilization rate for each 

leased office space by collecting data on the number of employees 

working at each leased office space. We divided the total rentable square 

footage of each leased office by the number of employees working at the 

office. We then compared these rates with the GSA’s recommended 

target. We also interviewed relevant officials from the GSA, OMB, and the 

Small Agency Council. For more information on our scope and 

methodology, see appendix I.

We conducted this performance audit from June 2015 to July 2016 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.

 8

GSA, Leasing Desk Guide, (Washington, D.C.: 2015).

9

OMB, Preparation, Submission and Execution of the Budget, OMB Circular No. A-11

(revised 2015).

10GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sept. 10, 2014); GAO, Acquisition Planning: Opportunities to Build 

Strong Foundations for Better Services Contracts, GAO-11-672 (Washington, D.C.: Aug. 

9, 2011); GAO, Framework for Assessing the Acquisition Function at Federal Agencies,

GAO-05-218G (Washington, D.C.: Sept. 1, 2005); and GAO, Federal Office Space: More 

Businesslike Leasing Approach Could Reduce Costs and Improve Performance, 

GAO/GGD-95-48 (Washington, D.C.: Feb. 27, 1995).
Page 5 GAO-16-648 Federal Real Property

The federal government’s civilian real-property holdings include 

thousands of leased office buildings and warehouses across the country 

that cost billions of dollars annually to rent, operate, and maintain. As the 

federal government’s principal landlord, GSA acquires, manages, and 

disposes of real property on behalf of many civilian federal tenants. In this 

role, GSA is responsible for executing, renewing, and terminating 

contracts for leased properties. As of fiscal year 2014, GSA leased 6,444 

office and 415 warehouse spaces (totaling 187.6-million rentable square 

feet) from the private sector.11 However, there are some federal entities 

that have independent statutory leasing authority, which refers to the 

authority to lease space independently of GSA. Congress provides this 

authority in law through a federal entity’s enabling legislation or through 

annual appropriations acts. Figure 1 illustrates examples of the types of 

spaces that federal entities lease directly from private owners.

 11GSA, Public Buildings Service, FY2014 State of the Portfolio (Washington, D.C.: 2014). 

Approximately 97 percent of the space GSA leases is for office and warehouse space. 

The other 3 percent were categorized as courthouses, land ports of entry, laboratories, 

and other. Government-owned properties constitute 183.5-million rentable square feet in 

GSA’s Public Buildings Service portfolio. 

Background
Page 6 GAO-16-648 Federal Real Property

Figure 1: Examples of the Types of Spaces Federal Entities Lease from Private Owners

Within the executive branch, the OMB and GSA provide leadership for the 

management of federal real property. As the chief management office for 

the executive branch, OMB is responsible for oversight of how agencies 

devise, implement, manage, and evaluate programs and policies. For real 

property management, OMB develops and provides direction to executive 

branch agencies and is responsible for reviewing their progress. GSA has 

two key leadership responsibilities related to real property management 

for the federal government. First, GSA’s Public Buildings Service 

functions as the federal government’s landlord, as described above. 

Second, GSA’s Office of Government-wide Policy is tasked, among other 

things, to identify, evaluate, and promote best practices to improve the 

efficiency of management processes.
Page 7 GAO-16-648 Federal Real Property

To promote the efficient and economical use of federal government real 

property, in 2004 the President issued Executive Order 13327 

establishing the Federal Real Property Council (FRPC) composed of 

senior management officials from specified executive branch departments 

and agencies covered by the Chief Financial Officers Act of 1990 (CFO 

Act), including GSA, and chaired by OMB.12 The executive order 

established FRPC with the goals of developing guidance, facilitating the 

implementation of agencies’ asset-management plans, and serving as a 

clearinghouse for leading practices.

The executive order also directed GSA, in consultation with the FRPC, to 

establish and maintain a single, comprehensive database describing the 

nature, use, and extent of all real property under the custody and control 

of executive branch agencies.13 To meet this directive, GSA’s Office of 

Government-wide Policy established the Federal Real Property Profile 

(FRPP) to be a government-wide real property inventory database. It also 

provided guidance to the FRPC member agencies about how to annually 

report data on real property under their custody and control for inclusion 

in the FRPP. Since the formation of the FRPP, only the FRPC member 

agencies have been required to annually submit their real property 

information to the database. According to GSA officials and OMB staff, 

other unspecified federal entities may voluntarily submit data to the 

FRPP.

In recent years, OMB has also undertaken several initiatives and issued 

guidance to federal entities to improve federal real-property management, 

specifically targeting offices and warehouses. In May 2012, OMB issued a 

 12Federal Real Property Asset Management, Exec. Order No. 13327, 69 Fed. Reg. 5897 

(Feb. 6, 2004). Certain provisions of the executive order apply to executive branch 

departments and agencies listed in section 901 of title 31, United States Code: the 

Departments of Agriculture, Commerce, Defense, Education, Energy, Health and Human 

Services, Homeland Security, Housing and Urban Development, the Interior, Justice, 

Labor, State, Transportation, the Treasury, and Veterans Affairs; the Environmental 

Protection Agency; GSA; NASA; the National Science Foundation; the Nuclear Regulatory 

Commission; the Office of Personnel Management; the Small Business Administration; the 

Social Security Administration; and the U.S. Agency for International Development. For 

the purposes of our report, we will be referring to this group of executive branch 

departments (including federal entities within the departments) and agencies included in 

the FRPC as “FRPC member agencies.” 

13Some properties are withheld from being reported to the FRPP database by agency 

heads for reasons of national security, foreign policy, or public safety, among other 

reasons.
Page 8 GAO-16-648 Federal Real Property

memorandum directing FRPC member agencies not to increase the size 

of their civilian real-estate inventory, stating that any increases in an 

agency’s total square footage of civilian real property must be offset 

through consolidation, co-location, or disposal of space from the inventory 

of that agency.14 In March 2013, OMB issued another memorandum 

establishing implementation procedures for this policy, called Freeze the 

Footprint. This memorandum clarified that agencies were not to increase 

the total square footage of their domestic office and warehouse inventory 

compared to a fiscal year 2012 FRPP baseline.15 Most recently, in March 

2015, OMB issued its National Strategy for the Efficient Use of Real 

Property (National Strategy). The National Strategy employs a three-step 

policy framework to improve the cost effectiveness and efficiency of the 

federal real property portfolio: (1) freeze growth in the portfolio; (2) 

measure the cost and utilization of real property assets to provide 

performance information and support more efficient use; and (3) reduce 

the size of the portfolio through asset consolidation, co-location, and 

disposal.16 To assist with the third step, OMB issued the Reduce the 

Footprint policy that requires agencies to develop a Real Property 

Efficiency Plan, which among other things, describes an agency’s overall 

approach to managing real property and establishes reduction targets for 

office and warehouse space, disposal of owned buildings, and the 

adoption of design standards to optimize owned and leased domestic 

office space usage.17 Only FRPC members are required to participate in 

these government-wide real property reform efforts.

As a result of these efforts, we acknowledged in the February 2015 

update to our High-Risk Series that the federal government has 

demonstrated a high level of leadership commitment to improving realproperty data to support decision making, and has made some progress 

in increasing its capacity to improve data reliability. In our previous 

 14OMB, Memorandum to the Heads of Executive Departments and Agencies: Promoting 

Efficient Spending to Support Agency Operations (Washington, D.C.: May 11, 2012). 

15OMB, Management Procedures Memorandum No. 2013-02 (Washington, D.C.: Mar. 14, 

2013). 

16OMB, National Strategy for the Efficient Use of Real Property: Reducing the Federal 

Portfolio through Improved Space Utilization, Consolidation, and Disposal (2015–2020)

(Washington, D.C.: Mar. 25, 2015). 

17OMB, Implementation of OMB Memorandum M-12-12 Section 3: Reduce the Footprint 

(Washington, D.C.: Mar. 25, 2015). 
Page 9 GAO-16-648 Federal Real Property

assessment of the FRPP, we found that FRPP’s data can be used in a 

general sense to track assets to provide an overall perspective on FRPC 

members’ real property portfolios. However, we raised concerns about 

the quality of the FRPP data specifically for some of the key variables, 

including utilization, condition, and annual operating costs. As such, we 

recommended that GSA develop and implement a plan to improve the 

FRPP, so that the data collected are sufficiently complete, accurate, and 

consistent. Most recently, we found that certain key FRPP data elements, 

such as utilization and status, continue to be inconsistently collected and 

reported by agencies. We recommended that GSA make transparent 

through its FRPP documents how its mission to provide space to federal 

agencies affects the reporting of the utilization and status data elements 

in the FRPP.18 GSA has taken steps to improve the reliability of FRPP 

data, but those efforts are ongoing.19

 18GAO, Federal Real Property: Strategic Focus Needed to Help Manage Vast and Diverse 

Warehouse Portfolio, GAO-15-41 (Washington, D.C.: Nov. 12, 2014). 

19GAO-15-290. 

Twenty-five Federal 

Entities That 

Reported Having 

Independent Leasing 

Authority Are Not 

Members of FRPC or

Consistently Tracked 

in FRPP
Page 10 GAO-16-648 Federal Real Property

According to GSA officials and OMB staff, neither GSA nor OMB 

maintains a comprehensive list of federal government entities with 

independent leasing authority and neither is required to do so. GSA 

prepared a partial list of 33 federal entities with independent leasing 

authority for its own purposes in 2009, but this list, according to GSA, was 

not intended to be a complete list of all entities.20

FRPP offers a possible way for determining which federal entities have 

independent leasing authority as it has a data field that indicates if a 

federal entity uses its own authority to lease real property. However, this 

information is incomplete as only agencies covered by the CFO Act, 

which are FRPC members, are required to annually submit their real 

property information to the FRPP. Federal entities outside FRPC 

membership can voluntarily submit real property data annually to FRPP, 

according to GSA officials and OMB staff, but few do. We found that three 

non-FRPC member entities reported to the FRPP in fiscal year 2014 that 

they independently leased office and warehouse spaces. Other nonFRPC member entities have submitted data to the FRPP inconsistently. 

For example, the U.S. Postal Service had previously chosen to submit 

some data to FRPP, but no longer does.

The population of federal entities with independent leasing authority can 

vary over time. As such, any list that is not regularly updated may not be 

comprehensive because it captures a snapshot in time. Some changes 

that may have taken place are, for example, federal entities that may 

have acquired leasing authority since the list was initially compiled. Also, 

individual leasing authority is specific to each federal entity and may 

change over time. For example, legislation may be enacted to create a 

new federal entity or change the nature of an existing entity’s leasing 

authority—laws may place conditions on the leasing authority, such as 

specifying the location, type of space, or terms under which the entities 

can exercise this authority. A federal entity’s leasing authority can range 

from an agency-wide, general authority to acquire real property (e.g., U.S. 

Postal Service, Tennessee Valley Authority), to authority given to specific 

components of a department or an agency (e.g., FAA within the 

 20GAO, Federal Real Property: Overreliance on Leasing Contributed to High-Risk 

Designation, GAO-11-879T (Washington, D.C.: Aug. 4, 2011). GAO added 2 agencies to 

the original list GSA prepared in 2009, for a total of 33 identified federal entities with 

independent leasing authority. However, this update was not part of a major effort to 

update the list. 

There Is No 

Comprehensive List of 

Federal Entities with 

Independent Leasing 

Authority
Page 11 GAO-16-648 Federal Real Property

Department of Transportation), or for types of property (e.g., Commodity 

Credit Corporation within the Department of Agriculture has leasing 

authority for office space and storage space), or for a specific time frame.

To obtain more complete and reliable information on federal entities with 

leasing authority, we administered a survey to 103 civilian executive 

branch agencies and other federal entities that met our selection 

criteria.21 Sixty of the entities self-identified as having independent 

authority to lease real property of which 52 reported having the authority 

to lease domestic office or warehouse space.22 Of these, 37 federal 

entities reported that they are using their authority to lease 944 offices 

(approximately 16.6-million rentable square feet of space and an annual 

rent of $556 million) and 164 warehouses (approximately 3.3-million 

rentable square feet of space and an annual rent of $39.8 million) as of 

October 1, 2015.23 The FAA alone leases 341 offices and 70 warehouses, 

which accounts for 36 percent and 43 percent of the total number of 

independently leased offices and warehouses. The remaining 36 entities 

use their authority to lease up to 91 offices and 36 warehouses. See table 

6 and table 7 in appendix II for a full listing of the 52 federal entities that 

reported having independent leasing authority to lease office and 

warehouse space, legal citations for their authority, and summary 

statistics about the offices and warehouses they leased.

 21GAO-10-97. Our survey universe included all federal entities identified in a prior GAO 

report on federally created entities such as executive departments, other executive branch 

entities, government corporations, and other federally established organizations in the 

executive branch that received an average of over $20 million in annual appropriations 

from fiscal years 2005 through 2008.

22Federal entities may have independent leasing authority to lease other types of real 

property other than buildings (e.g., offices and warehouses), mainly land and structures. 

There are also different types of building classifications that these entities may have 

authority to independently lease such as hospitals, laboratories, and prisons. However, for 

the purposes of our review, we focused on domestic offices and warehouses, which are 

the two primary types of federal real property that GSA generally leases and would be the 

most practical to try to compare across federal entities. For more information about the 

scope and methodology of our survey, see appendix I. 

23The aggregate numbers are provided to illustrate, based on our survey, the size of the 

federal government’s real estate portfolio comprised of independently leased offices and 

warehouses. We did not independently verify their accuracy. 

Fifty-two Surveyed 

Federal Entities Reported 

Having Leasing Authority 

Independent from GSA for 

Office and Warehouse 

Space
Page 12 GAO-16-648 Federal Real Property

Of the 37 federal entities that reported using their leasing authority to 

lease office or warehouse space, 18 also reported using GSA to lease a 

portion of their space. There are a variety of reasons why federal entities 

use GSA to lease on their behalf in certain circumstances and use their 

independent leasing authority in other situations. For example, NASA 

officials told us NASA is legally required to use GSA to lease office and 

warehouse space inside the National Capital Region, but may choose to 

use its own authority elsewhere.24 In contrast, according to FAA officials, 

the majority of FAA’s office spaces are leased independently, though they 

may use GSA when FAA does not have the staff resources available to 

administer the lease process or if private sector availability is limited in 

certain markets. They said that obtaining a lease using independent 

leasing authority can generally be completed more quickly than acquiring 

space through GSA. According to FAA officials, when faced with tighter 

timeframes, FAA can fulfill space needs in as little as 4 months, whereas 

it can take over a year to lease through GSA.

In our survey, 25 federal entities that are not members of the FRPC 

reported having independent authority to lease offices and warehouses. 

Of those entities, 19 reported using their authority to lease domestic 

offices and warehouses. Combined, these 19 non-FRPC member entities 

reported that they leased 243 offices and warehouses (approximately 8.3-

million rentable square feet of space and an annual rent of $303.4 million) 

as of October 1, 2015.25 Table 1 provides a listing of the 25 federal 

entities that reported having independent leasing authority and are not 

members of the FRPC, along with the amounts of domestic offices and 

warehouses they lease. To see more detailed information about these 

entities, see table 7 in appendix II.

 24The National Capital Region includes Washington, D.C., and local jurisdictions in the 

state of Maryland and in the Commonwealth of Virginia. 

25The aggregate numbers are provided to illustrate, based on our survey, the size of the 

federal government’s real estate portfolio comprised of independently leased offices and 

warehouses by non-FRPC member entities. We did not independently verify their 

accuracy. 

Twenty-five Federal 

Entities That Reported 

Having Leasing Authority 

Are not Members of the 

FRPC, Creating Gaps in 

Data
Page 13 GAO-16-648 Federal Real Property

Table 1: Selected Data about Federal Entities That Reported Having Independent Statutory Leasing Authority for Domestic 

Offices and Warehouses and Are Not Part of the Federal Real Property Council 

Federal Entity Offices and Warehouses

Number Rentable square feet Annual rent ($)

Federal Deposit Insurance Corporation 91 1,912,379 $47,161,467

Smithsonian Institution 50 1,487,394 $52,009,858

United States Postal Service 35a 701,613 $11,888,432

Tennessee Valley Authority 21 223,500 $2,973,000

Pension Benefit Guaranty Corporation 9 564,703 $28,222,074

Securities and Exchange Commission 8 1,882,484 $90,854,696

National Credit Union Administration 7 73,741 $1,456,317

United States Commodity Futures Trading Commission 4 434,679 $20,066,000

United States Holocaust Memorial Museum 4 10,528 $403,376

Federal Reserve Board 3 545,170 $21,689,150

Millennium Challenge Corporation 2 129,206 $8,300,000

National Transportation Safety Board 2 84,681 $2,715,075

Appalachian Regional Commission 1 21,626 $858,629

Farm Credit Insurance System Corporation 1 4,325 $155,813

Federal Retirement Thrift Investment Board 1 92,179 $5,236,601

Inter-American Foundation 1 14,332 $713,000

Overseas Private Investment Corporation 1 116,487 $7,504,813

Peace Corps 1 6,500 $348,281

United States African Development Foundation 1 15,705 $803,502

American Battle Monuments Commission — — —

Farm Credit Administration — — —

National Endowment for the Arts — — —

National Endowment for the Humanities — — —

Railroad Retirement Board — — —

United States Tax Court — — —

Total 243 8,321,232 $303,360,084

Source: Information reported by the respective federal entities in a GAO survey. | GAO-16-648

Note: This list of selected civilian federal entities with independent leasing authority was compiled 

from responses to a survey. These federal entities are those with independent leasing authority that 

are not part of the Federal Real Property Council. All reported figures were as of October 1, 2015.

a

According to a United States Postal Service (USPS) official, USPS does not categorize its buildings 

as “offices.” For the purposes of our review, we are using as a proxy, USPS’s independently leased 

spaces where over 50 percent of the total square footage was used for administrative functions. 

These spaces may include office buildings, as well as small offices or administrative space located in 

non-office buildings. USPS does not lease warehouse space.
Page 14 GAO-16-648 Federal Real Property

According to GSA’s Office of Government-wide Policy, the FRPC’s goals 

are that the FRPP database:

• leads to an increased level of agency accountability for asset 

management;

• allows comparing and benchmarking across various types of real 

property assets; and

• gives decision makers, including Congress, OMB, and federal entities, 

accurate and reliable data needed to make asset management 

decisions, including disposing of unneeded properties, in one 

comprehensive database.

However, the FRPP’s incomplete data set reduces its effectiveness as an 

oversight and accountability mechanism for entities with independent 

leasing authority. It is not a comprehensive database of all federal real 

property because, as noted previously, only the specified entities that are 

covered under the CFO Act and that are also the member agencies of the 

FRPC have been required to annually submit their real property data. 

Other entities with independent leasing authority may voluntarily report 

their data, according to GSA officials and OMB staff, but as discussed, 

few do. As a result, the scope of the real property portfolios of all other 

entities with independent leasing authority is largely unknown. For 

example, only two of the above identified 19 entities that reported using 

their authority to lease domestic offices and warehouses—the 

Smithsonian Institution and the Tennessee Valley Authority—voluntarily 

reported data on their independently leased offices and warehouses to 

the FRPP in fiscal year 2014. As such, the remaining 17 entities’ 172 

independently leased offices and warehouses (approximately 6.6-million 

rentable square feet of space and an annual rent of $248.4 million) were 

not accounted for in the FRPP.

The Standards for Internal Control in the Federal Government state that 

management should use quality information to achieve the entity’s 

objectives. To do so, management should design a process to identify the 

information requirements needed to achieve its objectives. One key step 

is to ensure that quality information is obtained. Quality information is 

appropriate, current, complete, accurate, accessible, and provided on a 
Page 15 GAO-16-648 Federal Real Property

timely basis. Management should use quality information to make 

informed decisions and evaluate the entity’s performance in addressing 

key objectives and assessing risks.26 The gaps in FRPP’s data limit the 

effectiveness of FRPP as a decision-making tool for policy leaders 

because the data are not a complete and accurate representation of the 

entirety of the federal government’s real property holdings. According to 

OMB staff, the inclusion of data by federal entities not required by the 

CFO Act would help the FRPP to be more of a comprehensive database, 

but the staff also noted that the majority of real property is owned or 

leased by CFO Act agencies. According to these staff, the federal 

government has limited resources to provide technical assistance and 

training to entities regarding submitting data to the FRPP, therefore, 

including them would need to be accomplished in an efficient way. For 

example, GSA officials and OMB staff said that if more federal entities 

started submitting data to FRPP, it may require GSA to divert some 

attention from its current efforts to train those entities that have not 

contributed to the FRPP before.

In our review, most of the federal entities that reported having

independent leasing authority, outside the entities that are covered under 

the CFO Act, are members of the Small Agency Council. The Small 

Agency Council is a voluntary association of about 80 independent 

federal entities with generally fewer than 6,000 employees that represents 

the entities’ collective management interests. The Small Agency Council 

provides these smaller federal entities a line of communication with key 

decision makers, including OMB. GSA officials who manage the FRPP 

said that the Small Agency Council may be able to help coordinate its 

members’ involvement in the FRPP. For example, the Small Agency 

Council could provide technical assistance to help its members collect 

and submit their real-property data to the FRPP and facilitate the process 

on behalf of GSA and OMB.

 26GAO-14-704G. 
Page 16 GAO-16-648 Federal Real Property

In our sample, the lease rates of most of the 37 independent leases we 

selected for review were less costly or comparable to matched GSA and 

private sector rates.27 However, these results varied by region: selected 

independent leases in the National Capital Region were generally less 

costly or comparable to matched private sector lease rates, but outside 

the National Capital Region, independent leases were more likely to be 

above the private sector market rate. While our selection of 37 leases is 

non-generalizable to the universe of all independent leases, they provide 

examples of how independent leases compare with GSA and private 

sector leases.

We reviewed 37 selected independent leases across seven federal 

entities.28 Of these leases, 14 (38 percent) had rates that were less costly 

than matched GSA leases, and 11 (30 percent) had comparable rates.29

The remaining 12 leases (32 percent) had rates that cost more than 

matched GSA leases. Many selected independent leases were at or 

below matched GSA rates in the National Capital Region as well as in our 

other selected metropolitan areas.

30 (See table 2.) Further, three of four 

 27For the matched analysis of independent leases with GSA leases, we performed the 

analysis with the annual net present value for the full terms of the leases’ rates per 

rentable square foot. Net present value is the sum of costs over a period of time, in this 

case a lease’s term, adjusted using a discount rate. For the matched analysis of 

independent leases with the private sector, we performed the analysis using the full 

amount of the leases’ first years’ rent per rentable square foot. This matched analysis 

used only the leases’ first years’ rent due to limitations of the number of years of data 

available for private sector leases. Due to variation caused by the specific circumstances 

and unique features of each lease transaction, we considered independent leases’ rates 

that were within plus or minus (±) 10 percent of the matched GSA or private sector rates 

as comparable. 

28The seven federal entities included in our lease rate analysis were the FAA, FDIC, 

NASA, NCUA, PBGC, USCG, and USPTO. One of our selected federal entities—NOAA—

was not included in this analysis because its only selected lease did not require rent 

payments. As such, this unique aspect of the lease did not allow for us to find a 

comparable GSA or private sector lease.

29One of GSA’s goals related to lease acquisition is to procure leased space below the 

private sector’s market rate in order to generate savings to federal departments and 

entities. 

30In addition to the National Capital Region, our selected independent leases were also 

located in the Atlanta, Georgia; Los Angeles, California; and Miami, Florida, metropolitan 

areas. 

For Various Reasons, 

the 37 Selected 

Independent Lease 

Rates Were Often 

Comparable to or 

Lower Than Matched 

GSA and Private 

Sector Rates

The Majority of the 37 

Selected Independent 

Lease Rates Were at or 

below Matched GSA 

Lease Rates
Page 17 GAO-16-648 Federal Real Property

federal entities with more than two leases had most of their lease rates 

comparable to or less costly than GSA rates. (See table 3 and fig. 2.)

Table 2: Selected Independent Real Property Lease Rates Compared to Matched General Services Administration (GSA) Real 

Property Lease Rates, National Capital Region versus Other Metropolitan Areas

Metropolitan area

Number 

of leases

Leases Below 

GSA Rate

Leases Comparable 

to GSA Ratea Leases AboveGSA Rate

National Capital Regionb 19 7 (37%) 5 (26%) 7 (37%)

Other areasc 18 7 (38%) 6 (33%) 5 (28%)

Total 37 14 (38%) 11 (30%) 12 (32%) 

Source: GAO analysis of federal lease data. | GAO-16-648

Note: All comparisons were made using the annual net present values per rentable square foot for 

the full terms of all leases.

a

Due to variation caused by the specific circumstances and unique features of each lease transaction, 

we considered independent leases’ rates that were within plus or minus (±)10 percent of the matched 

GSA rates as comparable.

b

The National Capital Region includes Washington, D.C., and local jurisdictions in Maryland and 

Virginia.

c

Includes Atlanta, Georgia; Los Angeles, California; and Miami, Florida, metropolitan areas.

Table 3: Selected Independent Real Property Lease Rates Compared to Matched General Services Administration (GSA) Real 

Property Lease Rates, by Federal Entity

Federal entity

Number 

of leases

Leases Below 

GSA Rate

Leases Comparable

to GSA Ratea Leases Above GSA Rate

Federal Aviation Administration 15 6 (40%) 4 (27%) 5 (33%)

Federal Deposit Insurance 

Corporation 7 1 (14%) 2 (29%) 4 (57%)

National Aeronautics and Space 

Administration 6 3 (50%) 3 (50%) —

Pension Benefit Guaranty 

Corporation 5 2 (40%) 2 (40%) 1 (20%)

Other entitiesb 4 2 (50%) — 2 (50%)

Total 37 14 (38%) 11 (30%) 12 (32%) 

Source: GAO analysis of federal lease data. | GAO-16-648

Note: All comparisons were made using the annual net present values per rentable square foot for 

the full terms of all leases.

a

Due to variation caused by the specific circumstances and unique features of each lease transaction, 

we considered independent leases’ rates that were within plus or minus (±) 10 percent of the matched 

GSA rates as comparable.

b

For the purposes of this table, the National Credit Union Administration, the United States Patent and 

Trademark Office, and the United States Coast Guard were combined due to the small number of 

individual leases per entity in our selected sample.
Page 18 GAO-16-648 Federal Real Property

Figure 2: Selected Independent Real Property Lease Rates Compared to Matched 

General Services Administration (GSA) Real Property Lease Rates, by Federal 

Entity

Note: Due to variation caused by the specific circumstances and unique features of each lease 

transaction, we considered independent leases’ rates that were within plus or minus (±) 10 percent of 

the matched GSA rates as comparable. The gray band represents this range.

a

For the purposes of this figure, the National Credit Union Administration, the United States Patent 

and Trademark Office, and the United States were combined due to the small number of individual 

leases per entity in our selected sample.

b

All comparisons were made using the annual net present values per rentable square foot for the full 

terms of all leases.

Of the leases we analyzed, more independent leases were less 

expensive than matched GSA leases. Based on our analysis and 

interviews, we identified several possible factors that could be influencing 

why some of the independent leases we analyzed were less expensive 

than matched GSA leases:

Aspects unique to GSA leasing: Officials from GSA and two other 

federal entities said that aspects specific to GSA’s leasing process itself 

may contribute to the higher lease rates. Specifically, GSA officials stated 
Page 19 GAO-16-648 Federal Real Property

that GSA uses standardized lease documents that include clauses that 

can be more rigorous than the leases provided by private sector 

landlords. For example, GSA leases could include clauses with higher—

and thus possibly more expensive—energy conservation, security, and 

seismic safety requirements. The 37 selected independent leases we 

reviewed include a spectrum of different lease types, including leases that 

were provided by the landlord. GSA officials noted that GSA-provided 

leases shift more responsibility and risk to the landlord, and these 

requirements in GSA leases may increase lease rates. For example, 

private sector officials told us that GSA leases allow the government 

unilateral rights to substitute tenants, which increases landlord 

uncertainty. This uncertainty may result in less competition and higher 

rental payments. In addition, we previously found that GSA’s leasing 

process is lengthy and in some cases the process can take up to 8

years.31 This long process can result in potential landlords dropping out of 

the competition for GSA tenants, limiting competition and increasing 

rates.

Tenant improvement allowances: We found tenant improvement 

allowances in about 64 percent of the matched GSA leases and in only 

about 43 percent of our analyzed independent leases.32 In a recent 

report, we also found that nearly 60 percent of over 4,000 GSA leases 

included tenant improvement allowances.33 GSA regional officials told us 

that tenants typically choose to amortize at least some of these tenant 

improvements over the term of the lease and ask landlords to assume the 

risk—GSA does so on behalf of its tenant agencies—of customizing a 

space according to specific requirements. Because landlords that lease to 

the federal government often assume this responsibility and obtain the 

resources required to construct, operate, and maintain real property over 

the course of its lifecycle, federal entities then pay private-sector interest 

rates as they pay for their improvements over the firm term of their GSA 

 31GAO, Federal Real Property: GSA Could Decrease Leasing Costs by Encouraging 

Competition and Reducing Unneeded Fees, GAO-16-188 (Washington, D.C.: Jan. 13, 

2016).

32A tenant improvement allowance includes the costs of changes to leased spaces. These 

costs are associated with additions or alterations of the structure and base building 

systems that adapt the workspace to the specific uses of the tenant. The tenant typically 

bears these costs.

33GAO-16-188. 
Page 20 GAO-16-648 Federal Real Property

lease. Further, those independent leases that did include tenant 

improvements averaged $2.93 per square foot per year over the 

amortization period, while matched GSA leases averaged $4.01 ($1.08 or 

about 37 percent more), and this can contribute to more costly leases for 

the GSA. In one instance, an analysis of an independent lease and its 

matched GSA lease (the leases share the similar term length, 

approximate size, and are in nearby locations), showed that the GSA paid 

nearly $400,000 in tenant improvements, while its matched independent 

lease had no tenant improvement costs. Officials from two entities, 

including GSA, stated that GSA leases often include tenant improvement 

allowances. 

Periods of free rent: The independent leases we analyzed had periods 

of free rent built into the leases more frequently than the matched GSA 

leases. These periods of free rent reduce the average lease rate over the 

term of the lease. According to GSA officials, landlords typically prefer to 

provide periods free of rent instead of decreasing the rate charged per 

square foot. These officials said landlords want to keep that rate as high 

as possible for when their property is advertised to other potential 

tenants. Analysis of the selected independent leases and GSA leases 

showed that only two of 56 (4 percent) matched GSA leases had periods 

of free rent, while 14 of 37 (38 percent) of our selected independent 

leases had periods of free rent.34 On average, these 14 independent 

leases had periods of free rent for about 9 percent of the total duration of 

their tenancy. The majority of these leases’ periods of free rent were 

within the range of 4 to 6 percent of the total duration of the lease. These 

periods of free rent can have a large impact on total rent paid—for 

example, in one independent lease, the federal entity had a period of free 

rent for the first 5 months of its 10-year tenancy (4 percent of the total 

lease’s duration), resulting in about $2.8 million less paid over the term of 

the lease. 

Real estate brokers: Officials from one federal entity with independent 

leasing authority said that their use of private sector real-estate brokers 

with knowledge of particular market areas may have contributed to lower 

leasing rates. This entity’s officials said they often use brokers with robust 

knowledge of local markets to find the best properties that also meet their 

 34In some instances, independent leases were able to be matched with more than one 

GSA lease. This resulted in the greater number of GSA leases in the analysis when 

compared to our 37 selected independent leases.
Page 21 GAO-16-648 Federal Real Property

entity’s requirements. Additionally, officials from one entity said that when 

there are multiple offers, their broker would use the lowest offer as 

leverage to negotiate for lower rates with other potential landlords. As we 

previously reported, GSA does use private sector brokers for some 

leases, although the brokers are national in scope.35 GSA officials also 

told us that these brokers are limited in the extent they can use one offer 

as leverage to solicit lower offers from other bidders.

Lastly, it is important to note that for both GSA and independent leases 

there are costs paid by the tenant outside of rent. For example, federal 

tenants pay GSA a fee for its services related to the leased space, and 

we found in January 2016 that GSA’s fee is between 5 and 7 percent.36 In 

contrast, an entity using independent leasing authority reported that there 

are administrative costs, such as paying its staff to perform various duties 

associated with the lease acquisition process. 

Most independent leases we reviewed (27 of 37) had rates that were 

comparable to or below matched private sector rates. (See fig. 3.) Across 

the different regions, however, there was variation. We looked at 19 

leases in the National Capital Region and found that 16 (84 percent) were 

comparable to or less costly than matched private-sector lease rates. 

Only 3 (16 percent) of the leases in the National Capital Region were 

more costly. However, we looked at 18 leases in the other three 

metropolitan areas and found that 7 (39 percent) independent leases 

were more costly than matched private sector rates. (See table 4.)

 35GAO, Federal Real Property: GSA Should Clarify Savings Goals for the National Broker 

Contract Program, GAO-14-14 (Washington, D.C.: Oct. 31, 2013).

36GAO-16-188.

The 37 Selected 

Independent Lease Rates 

Were Comparable to 

Private Sector Rates, 

Particularly in the National 

Capital Region
Page 22 GAO-16-648 Federal Real Property

Figure 3: Selected Independent Real Property Lease Rates Compared to Matched 

Private Sector Real Property Market Rates, by Federal Entity

Note: Due to variation caused by the specific circumstances and unique features of each lease 

transaction, we considered independent leases’ rates that were within plus or minus (±) 10 percent of 

the matched private sector market rates as comparable.

a

For the purposes of this figure, the National Credit Union Administration, the United States Patent 

and Trademark Office, and the United States Coast Guard were combined due to the small number of 

individual leases per entity in our selected sample.

b

All comparisons were made using the full amount of the leases’ first years’ rent per rentable square 

foot.
Page 23 GAO-16-648 Federal Real Property

Table 4: Selected Independent Real Property Lease Rates Compared to Matched Private Sector Real Property Market Rates, 

National Capital Region versus Other Metropolitan Areas

Source: GAO analysis of federal lease data and private sector lease data. | GAO-16-648

Note: All comparisons were made using the full amount of the leases’ first years’ rent per rentable 

square foot.

a

Due to variation caused by the specific circumstances and unique features of each lease transaction, 

we considered independent leases’ rates that were within plus or minus (±)10 percent of the matched 

private sector market rates as comparable.

b

National Capital Region includes Washington, D.C., and local jurisdictions in Maryland and Virginia.

c

Includes Atlanta, Georgia; Los Angeles, California; and Miami, Florida, metropolitan areas.

Outside of the National Capital Region, private sector real-estate 

professionals from a real estate firm said that a lower supply of office 

space coupled with the federal government’s smaller market share may 

result in higher lease rates. These professionals said that the federal 

government has the largest market share in the National Capital Region 

and can therefore get favorable rates in the market. These professionals 

added that the region’s large supply of offices facilitates competition 

between landlords, which can result in more favorable lease rates for the 

federal government. GSA officials said that in other markets there 

sometimes is no suitable office space available. In several cases, a 

complete lack of office space required the government to instead lease 

retail space. Retail space can be more expensive than office space, and 

leasing retail space did result in higher rental payments in some 

instances. Additionally, GSA officials stated that although the government 

is highly reliable with rental payments and is often seen as a desirable 

tenant, landlords outside the National Capital Region might be uneasy 

and unfamiliar with working with the federal government. In a January 

2016 report, we found that GSA was also able to secure leases in the 

National Capital Region generally at or below market rates.37

 37GAO-16-188. 

Metropolitan area

Number 

of leases

Leases Below 

Market Rate

Leases Comparable to

Private Sector Market Ratea Leases Above Market Rate

National Capital Regionb 19 9 (47%) 7 (37%) 3 (16%)

Other areasc 18 5 (28%) 6 (33%) 7 (39%)

Total 37 14 (38%) 13 (35%) 10 (27%)
Page 24 GAO-16-648 Federal Real Property

We previously found that policies and procedures should establish 

expectations for strategically planning acquisitions and managing the 

acquisition process. Failing to address these principles can contribute to 

missed opportunities to achieve savings, reduce administrative burdens, 

and improve acquisition outcomes.38 Federal internal control standards 

also state that documentation of transactions enables management to 

control operations and make decisions that can help the organization run 

efficiently.39 We reviewed the Federal Management Regulation, GSA 

policies and procedures, and other applicable documents to develop a list 

of leading practices that all federal entities should incorporate into their 

real property leasing functions to help ensure that mission needs are met 

in a cost-effective and transparent manner. (See fig. 4.) In addition to 

leading practices, federal entities must follow all applicable laws related to 

real property management. For example, the recording statute requires 

that federal entities record the full amount of their contractual liabilities, 

including for leases, against funds available at the time the contract is 

executed.40 Previously, we found that two federal entities with 

independent leasing authority—the Commodity Futures Trading 

Commission and the Securities and Exchange Commission—did not fully 

comply with the recording statute in the way they recorded the lease 

 38GAO-05-218G.

39GAO-14-704G.

4031 U.S.C. §1501(a)(1). GSA, however, has the authority to record obligations for 

multiple-year leases on a year-to-year basis. 40 § U.S.C. 585(a)(2).

Most Selected 

Entities’ Leasing 

Policies Generally 

Align with Leading 

Practices but Lack 

Documentation, and 

Space Allocations 

Exceed the GSA 

Target

Leading Government 

Practices Can Help 

Improve Leasing 

Outcomes
Page 25 GAO-16-648 Federal Real Property

obligations against funds available at the time the leases were 

executed.41 Violations of the recording statute such as these can also 

result in Antideficiency Act violations if lease obligations exceed available 

budget authority at the time the lease is executed.

Figure 4: Leading Government Practices for Leasing Federal Real Property

a

OMB Circular A-11, Appendix B outlines specific criteria in order for a lease to be considered an 

operating lease. If any of the specific criteria are not met, the lease is considered a capital lease. 

Entities other than GSA entering into an operating lease that includes a cancellation clause must 

possess budget authority sufficient to cover the lease payments for the first year plus an amount 

sufficient to cover the costs associated with cancellation of the contract. For each subsequent year, 

sufficient budget authority is required to be obligated to cover the annual lease payment for that year 

 41GAO, Commodity Futures Trading Commission—Recording of Obligations for MultipleYear Leases, B-327242 (Washington, D.C.: Feb.4, 2016); GAO, Securities and Exchange 

Commission—Recording of Obligation for Multiple-Year Contract, B-322160 (Washington, 

D.C.: Oct. 3, 2011).
Page 26 GAO-16-648 Federal Real Property

plus any additional cancellation costs. Entities entering into capital leases and operating leases 

without cancellation clauses are required to obligate upfront the amount necessary to cover the 

government’s total legal obligation.

When the FRPC was created, it was envisioned to be an interagency 

collaboration of senior management officials who would develop 

guidance, facilitate the efforts of the members’ overall management of 

federal real property, and serve as a clearinghouse for leading practices. 

As noted previously, the FRPC is composed of senior management 

officials from the specified agencies covered by the CFO Act, including 

GSA and chaired by OMB. OMB staff told us that FRPC currently meets 

on a monthly basis and provides a forum to discuss, among other things, 

current real-property management policies and their implementation, 

member agencies’ leading practices related to real property management, 

and technical issues associated with data reporting. OMB staff said that 

the FRPC has been instrumental in improving the management of federal 

real property and serving as a forum for disseminating related guidance 

on government-wide initiatives, such as the National Strategy for the 

Efficient Use of Real Property (National Strategy) and Reduce the 

Footprint. Our body of work has shown the importance and value of 

interagency collaboration.42 Federal entities can enhance and sustain 

their coordinated efforts by engaging in key practices, such as defining 

and articulating a common outcome and developing mechanisms to 

monitor, evaluate, and report on results. However, successful 

collaboration benefits from having certain key features, such as including 

all relevant participants. But there are currently limited opportunities for 

non-FRPC member entities to participate in federal coordination on real 

property management issues and the sharing of leading practices that 

occurs in the FRPC.

According to OMB staff, increasing the membership of FRPC to include 

all executive branch federal entities would essentially double the size of 

the group, which would make it more difficult to manage. OMB staff said 

that although their focus has been on the current FRPC member entities, 

which lease and hold the majority of federal real property, any land-

 42GAO, Evaluating and Managing Fragmentation, Overlap, and Duplication,

GAO-15-49SP (Washington, D.C.: Apr. 14, 2015); GAO, Managing for Results: Key 

Considerations for Implementing Interagency Collaborative Mechanisms, GAO-12-1022 

(Washington, D.C.: Sept. 27, 2012); GAO, Results-Oriented Government: Practices That 

Can Help Enhance and Sustain Collaboration among Federal Agencies, GAO-06-15 

(Washington, D.C.: Oct. 21, 2005); and GAO, Managing for Results: Barriers to 

Interagency Coordination, GAO/GGD-00-106 (Washington, D.C.: Mar. 29, 2000). 
Page 27 GAO-16-648 Federal Real Property

holding federal entity would likely benefit from the collaboration and 

leading practices shared through FRPC. Currently, the guidance, 

resources, and leading practices shared during FRPC meetings are not 

publicly available, but may be requested by non-FRPC member entities. 

As previously mentioned, non-FRPC members are also not required to 

participate in the National Strategy and Reduce the Footprint initiatives; 

however, OMB staff said that they would support and assist any nonFRPC member federal entity in complying with the policies, if asked. The 

Small Agency Council may also be in a good position to efficiently 

coordinate with smaller federal entities and share relevant leading 

practices, such as those shared with FRPC member entities. An official 

from the Small Agency Council said that such a coordinating role would fit 

within the Council’s mission.

Six of our eight selected federal entities have policies that generally 

aligned with leading government practices; two entities did not have any 

documented leasing policies.43 The two entities without leasing policies 

(NCUA and PBGC) are non-FRPC member entities. However, the six 

entities with leasing policies (five of which are FRPC-member agencies 

and one, FDIC, which is not) either have established their own policies, 

refer to the Federal Management Regulation, or GSA policies that 

include, among other things, space utilization standards, market research 

requirements, preferences for full competition, and evaluating leases as 

operating or capital leases. The following bullets illustrate how the policies 

of these six federal entities addressed each of the leading practices.

• Assess needs: All of the leasing policies we reviewed contained 

some element of assessing needs including varied space-utilization 

targets.

• Plan ahead: All of the leasing policies we reviewed contained an 

element of acquisition planning, including a requirement for 

establishing clear criteria for evaluating lease offers.

• Ensure best value: Some entities we reviewed had more guidance 

regarding advertising than others. For example, FAA policy 

 43To gain understanding about the extent to which federal entities with independent 

leasing authority have policies that align with leading practices, we reviewed our eight 

selected entities: FAA, FDIC, NASA, NCUA, NOAA, PBGC, USCG, and USPTO.

Most Selected Federal 

Entities Have Established 

Leasing Policies That 

Generally Align with 

Leading Government 

Practices
Page 28 GAO-16-648 Federal Real Property

referenced specific forms of advertising to consider, whereas USCG

policy listed advertising as an example of the responsibilities of the 

real estate specialist, but does not specify how advertising should 

occur. NASA, NOAA, and USPTO’s leasing policies did not articulate 

strategies for advertising real-property leasing opportunities.

• Analyze and document the budget effects: Five of six policies we 

reviewed specifically mentioned evaluating leases as either operating 

leases or capital leases in accordance with OMB Circular A-11. Some 

budget scoring policies were more detailed. For example, while FAA 

policy includes a worksheet to score its leases, FDIC’s policy did not 

explicitly require that the lease’s budget-scoring evaluation be 

documented.

Although most of our selected entities had established policies consistent 

with leading government practices, we found numerous instances where 

individual lease files lacked evidence to support that the leading practices 

were actually used. Federal internal control standards also state that 

documenting transactions enables management to control operations and 

make decisions that can help the organization run efficiently.44 To 

evaluate the extent that entities’ leasing practices aligned with leading 

government practices, we analyzed 30 selected lease files from 6

selected agencies.

45 We looked for documentation of 10 sub-practices

within the 4 leading practices. (See list of sub-practices in figure 5.) 

Evaluating lease file documentation across these entities with 

independent leasing authority is inherently challenging because each

entity may have its own specific requirements of what should be 

documented in a lease file and for what length of time. As such, we were 

only able to evaluate what was provided to us, which may not fully reflect 

all the steps taken by the entity to execute the lease. As a result, if there 

was documented evidence that all of the sub-practices were included in 

the lease file, we had reasonable assurance that the four leading 

 44GAO-14-704G.

45NOAA and the USCG were not included in this analysis because all of their selected 

leases (one lease and four leases, respectively) fell below GSA’s Simplified Lease 

Acquisition Threshold of $150,000 net annual rent per year as some leading practices are 

not applicable for low value leases. We also excluded an additional 6 FAA leases that fell 

below GSA’s Simplified Lease Acquisition Threshold. For example, GSA guidance says 

that some leases that fall under the Simplified Lease Acquisition Threshold are not 

required to have written acquisition plans or required to be advertised.

Selected Entities Often 

Lacked Documentation to 

Support That Leading 

Practices Were Used
Page 29 GAO-16-648 Federal Real Property

practices were implemented.46 However, we found the extent to which the 

lease files contained documented evidence that the sub-practices were 

being used varied. For example, the vast majority of our 30 selected 

lease files lacked evidence of (1) advertisement of need for space (88 

percent); (2) determining if the lease qualifies as an operating lease or a 

capital lease (83 percent); (3) documenting factors used to evaluate offers 

(77 percent); and (4) documenting the time frame for acquiring space (77 

percent). However, most of our selected lease files contained some 

documented evidence of specifying geographical area for needed space 

(80 percent) and conducting market research (53 percent).47 (See fig. 5.)

 46For the purpose of this analysis, we considered a lease file in alignment with a leading 

practice if there was sufficient documented evidence of the sub-practice in the lease file. 

We determined the lease file to be in partial alignment if there was some evidence in the 

file that a sub-practice was implemented, but the evidence was incomplete, insufficient, or 

not entirely aligned with the leading practice. We determined the lease file not to be in 

alignment if there was no evidence a sub-practice was being implemented in the lease file. 

47The percentages listed are the percentages of lease files for which the particular 

practice was applicable. All 10 sub-practices were not necessarily applicable to all 30 

lease files. For example, if a lease was advertised, a sole source justification would not 

need to be included in the file.
Page 30 GAO-16-648 Federal Real Property

Figure 5: Percentage of Selected Entities’ Lease Files GAO Analyzed That 

Documented Alignment with Applicable Leading Government Practices for Leasing 

Federal Real Property

The extent to which lease files documented alignment with the leading 

practices varied by entity, but none of the lease files contained evidence 

of full alignment with all the leading practices. For three of the six entities, 

all of the lease files were in partial alignment with leading practices.48 Two 

entities had some lease files that were in partial alignment and others that 

were not in alignment with leading practices. We were unable to 

 48Since all of the selected leases at two of the eight entities we reviewed (USCG and 

NOAA) fell below the Simplified Lease Acquisition Threshold of $150,000 net annual rent 

per year, we excluded them from this analysis because, as previously mentioned, not all 

of the leading practices are necessarily applicable to smaller-value leases.
Page 31 GAO-16-648 Federal Real Property

determine whether the one selected USPTO lease file was in alignment 

with leading practices because the entity was unable to provide required 

documentation. (See table 5.) Without documented evidence in the lease 

files that all of the leading practices and sub-practices were used in the 

acquisition of leased space, it is difficult to determine whether the federal 

entities performed the leading practices that would help them achieve the 

best lease rate in a competitive and transparent manner.

Table 5: Percentage of Selected Lease Files GAO Analyzed That Documented Alignment with Leading Government Leasing 

Practices, by Selected Entity

Federal entity 

Number of lease 

files

In full alignment with 

all leading practices

In partial alignment 

with leading practices

Not in alignment with 

leading practices

Federal Aviation Administration 9 — 8 1

Federal Deposit Insurance 

Corporation 7 — 5 2

National Aeronautics and Space 

Administration 6 — 6 —

National Credit Union 

Administration 2 — 2 —

Pension Benefit Guaranty 

Corporation 5 — 5 —

United States Patent and 

Trademark Office 1 — — 1a

Total 30 — 26 4

Source: GAO analysis of 30 selected lease files. | GAO-16-648

a

We were unable to determine whether this selected lease file was in alignment with leading practices because the entity was unable to provide required documentation.
Page 32 GAO-16-648 Federal Real Property

All selected entities we reviewed leased more office space per employee 

on average than GSA’s recommended target. According to GSA officials, 

GSA recommends that federal entities allocate approximately 150 

rentable square feet per employee for office space. The 30 selected 

leases we reviewed averaged more than double the GSA recommended 

target per employee.

49 Figure 6 below illustrates the comparison of the 

average rentable square feet per employee for our selected leases 

(grouped by entity) to the GSA target. 

In most of the 30 selected leases we reviewed, more office space was 

leased per employee on average than the GSA recommended target of 

150 rentable square feet per employee.50 Twenty-eight of the 30 selected 

office leases analyzed for space allocation exceeded the GSA target, and 

two offices met the target. Both of the offices that met GSA’s 

recommended target were FAA offices. 

 49This analysis excludes 7 additional leases from our previously discussed sample of 

leases used in our GSA and private sector lease rate analysis: 5 warehouse leases where 

GSA’s recommended target for office space is not applicable and 2 offices with large nonoffice related spaces attached which can skew the office space allocations. One of these 

offices is a PBGC office with a large space attached which is dedicated to a continuity-ofoperations center, and the other is a NASA office with a large space attached that is used 

as a server room. 

50Entities vary in how they measure space utilization. However, because all of the leases 

in our review were measured in rentable square feet and because GSA’s recommended 

target is also measured in rentable square feet, we felt it most appropriate to analyze 

utilization at the selected office locations in rentable square feet per employee. 

Most Office Space 

Allocations Exceed GSA’s 

Recommended Target, but 

Entities Are Taking Steps 

to Reduce Space 

Allocations
Page 33 GAO-16-648 Federal Real Property

Figure 6: Selected Federal Entities’ Per-Employee Office Space Allocation Averages

and GSA’s Recommended Target

Note: This analysis is based on information gathered from 30 lease files and interviews with entity 

officials. It excludes two office properties with significant non-office spaces attached and five 

warehouse properties.

Space allocations greater than the GSA’s recommended target do not 

necessarily equate to larger offices. For example, we visited all of our 

selected independently-leased offices and found many vacant office 

spaces which can inflate the per-employee space allocation. Figure 7 

illustrates some of the vacant spaces we observed at the selected lease 

sites. NCUA officials told us that its number of employees at one of its 

locations is lower than it was when the lease was signed due to a staff 

reorganization. Additionally, an FDIC official told us that the sizes of the 

offices at one location were likely larger than the entity’s design standards 

because FDIC accepted the space as it was, without significantly 

reconfiguring it.
Page 34 GAO-16-648 Federal Real Property

Figure 7: Examples of Unoccupied Office Spaces 

Officials from FAA and FDIC also described actions they are taking to 

increase space utilization. For example, FAA officials told us that the staff 

at one of our selected office locations recently reduced from 13 to 5. In 

response to the recent downsizing, FAA officials said they are planning to 

reduce the office space by returning some space to the landlord. Officials 

at FDIC told us they had to temporarily increase the amount of space at 

one location from four floors to six floors when they brought on additional 

staff a few years ago in response to the financial crisis. In March 2015, 

after its staffing levels had decreased, FDIC exercised its right to 

terminate the lease of four of the six floors it was leasing to account for 

reduced staffing levels and currently occupies two floors of that building.

In addition, as part of the 2015 National Strategy, FRPC member entities 

are required to, among other things, establish space reduction targets for 

domestic office and warehouse space using FRPP data, and issue entityspecific maximums for usable square feet per workstation for leased 
Page 35 GAO-16-648 Federal Real Property

domestic office space.51 OMB staff said that FRPC has created an 

effective forum for promoting more efficient space-use standards that are 

key to the success of the National Strategy. However, the National 

Strategy does not extend to non-FRPC members. Though not required, 

non-FRPC member entities may also benefit from the leading practices 

shared at the FRPC to modify their internal policies to meet utilization 

targets for the space they lease.

Having complete and accurate data on the nature, use, and extent of 

federal real property assets is important for making informed decisions 

and identifying and addressing challenges. Currently, there is no 

mechanism to track federal entities with independent leasing authority 

and their real property assets, resulting in an information gap that can 

lead to a lack of oversight and accountability. This is particularly true for 

the 25 federal entities identified through our survey that are outside the 

FRPC’s membership. FRPP was created to be a single, comprehensive 

database of the federal government’s real property assets, but it cannot 

achieve that without data from all federal entities, including those with 

independent leasing authority. Currently, most of the 25 federal entities 

that are outside the FRPC’s membership do not report their real property 

data to FRPP.

FRPC members coordinate efforts and share leading practices, and OMB 

staff said that the FRPC has been critical to improving real property 

management since its creation through executive order in 2004. However, 

FRPC’s membership has remained limited to agencies covered by the 

CFO Act. We found that for the selected entities we reviewed, the FRPC 

member entities were more likely to have leasing policies that aligned 

with leading practices than the entities that were not FRPC members. 

Increasing FRPC participation would allow all federal entities to benefit 

from the collaboration and sharing of leading practices and increase the 

completeness of the FRPP. However, despite the benefits to any federal 

entity with a real property program, OMB staff noted that these federal 

entities represent a small overall share of the federal government’s 

portfolio and that there would be administrative challenges associated 

with increasing the membership of the FRPC. OMB staff continued by 

 51OMB, Memorandum to All CFO Act Executive Agencies: Implementation of OMB 

Memorandum M-12-12 Section 3: Reduce the Footprint. Management Procedures 

Memorandum No. 2015-01 (Washington, D.C.: March 25, 2015).

Conclusions
Page 36 GAO-16-648 Federal Real Property

saying that increasing participation would need to be done efficiently so 

that the FRPC and FRPP remain manageable and the effort does not 

draw from other critical efforts. The Small Agency Council already 

coordinates with OMB on other policy matters and may offer an efficient 

way to increase involvement in FRPC and FRPP.

To increase the completeness of information on the federal government’s 

real property holdings and improve the coordination among federal 

entities that lease real property, we recommend that the Deputy Director 

of the OMB—as chair of the FRPC—establish efficient methods for:

• including data from non-FRPC member entities in the FRPP, and

• increasing collaboration between FRPC member and non-member 

entities, including sharing leading real-property management 

practices.

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

concurred with our two recommendations and provided technical 

comments, which we incorporated, where appropriate.

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

and our eight selected federal entities: FAA, FDIC, NASA, NCUA, NOAA, 

PBGC, USCG, and USPTO. FAA, FDIC, NASA, NOAA, and USCG did 

not have any comments on our draft report.

GSA provided technical and clarifying comments to the findings of our 

draft report, which we incorporated where appropriate. GSA officials 

stated that they did not have enough information to validate our 

comparison of the 37 independent leases with matched GSA leases. 

However, GSA officials provided a number of potential reasons that may 

explain the differences in GSA and independent lease rates that we 

observed. These reasons included, among others, relatively higher 

energy conservation, security, and seismic safety requirements in GSA 

leases. We included a discussion of these requirements and their impact 

on lease rates in our report. GSA also observed that a key difference 

between independent leases and GSA leases is that the GSA supplies its 

own federal lease contract documents in lease transactions. GSA noted 

that using standardized federal lease documents helps GSA more 

accurately compare the costs of different offers, helps to satisfy budgetary 

scorekeeping criteria, and ensures that various requirements of federal 

Recommendations for 

Executive Action

Agency Comments

and Our Evaluation
Page 37 GAO-16-648 Federal Real Property

law and regulation are complied with. Some federal entities with 

independent leasing authority supply their own lease documents. In our 

report, however, we stated that federal entities with independent leasing 

authority used a spectrum of lease types, which also include leases 

provided by the private sector landlord. GSA also provided an updated 

recommended target for office space utilization per employee of 150 

rentable square feet that is in line with government-wide initiatives, such 

as the National Strategy and Reduce the Footprint, which are aimed at 

improving the efficiency of federal space. We incorporated changes 

throughout our report to reflect this updated target. 

NCUA did not have any technical comments, but provided a letter with 

additional information on NCUA’s office space requirements, which has 

been included in appendix III. NCUA noted that it is revising its leasing 

policies and plans on incorporating the leading government leasing 

practices provided in our report, as well as leading practices regarding 

space efficiency per employee, as appropriate. PBGC provided one 

technical comment, which we incorporated.

USPTO provided technical comments in a letter, which has been included 

in appendix IV. USPTO disagreed with our finding that the selected 

USPTO lease we reviewed was not in alignment with leading practices. 

We determined that a lease file was not in alignment because we were 

not provided with evidence that the leading practices were being met. 

USPTO opined that the selected independent lease project was an 

anomaly because it was done in conjunction with a much larger GSA 

space acquisition. As a result, the required documents were comingled 

with GSA documents. In the letter, USPTO asserted that leading 

practices were followed for the selected USPTO lease; however, USPTO 

was not able to provide us with additional supporting documentation, 

noting that on June 13, 2016, USPTO requested GSA to undertake a 

search for relevant documentation. Without any supporting 

documentation, we were unable to determine if the USPTO lease file 

aligned with leading practices, and we reflected this in table 5 of the 

report.

We are sending copies to the appropriate congressional committees and 

the Director of the OMB. In addition, the report will be available at no 

charge on GAO’s website at http://www.gao.gov.

If you or your staff 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 38 GAO-16-648 Federal Real Property

page of this report. GAO staff who made major contributions to this report 

are listed in appendix V.

David Wise

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

Methodology

Page 39 GAO-16-648 Federal Real Property

Our objectives were to determine: (1) what is known about which federal 

entities have independent leasing authority and their use of this authority 

to lease office and warehouse space, (2) how selected independent 

leases compare to General Services Administration (GSA) and private 

sector leases in terms of cost, and (3) to what extent selected federal 

entities with independent leasing authority have leasing policies and 

practices that align with leading government leasing practices.

To determine what is known about which federal entities have 

independent leasing authority and use this authority to lease office and 

warehouse space, we administered a survey to 103 civilian federal 

entities.1 Federal entities may have independent leasing authority to lease 

other types of real property besides buildings such as offices and 

warehouses, for example land and other structures. There are also 

different types of building classifications that these entities may have 

authority to independently lease such as hospitals, laboratories, and 

prisons. However, for the purposes of our review, we focused on 

domestic offices and warehouses, which are the two primary types of 

federal real property that GSA generally leases and would be the most 

practical to try to compare across federal entities. Our survey universe 

included all federal entities identified in a prior GAO report on federally 

created entities such as executive departments,2 other executive branch 

entities, government corporations, and other federally established 

organizations in the executive branch that received an average of over 

$20 million in annual appropriations from fiscal years 2005 through 2008.3

We administered our survey and collected responses from October 2015 

to April 2016, and received a response rate of 100 percent. To inform our 

survey, we conducted pretests with three of our selected federal entities 

with different sized leasing portfolios. The survey was a Microsoft Word 

form that was sent to designated contacts at each of the federal entities. 

The survey was used to first identify whether or not a federal entity 

reported having independent leasing authority. If the federal entity 

 1

Defense and intelligence-related federal entities were outside of the scope of our review. 

2

We also surveyed the federal entities within executive departments that we either 

identified or the executive department identified as having independent leasing authority 

(e.g., Federal Aviation Administration (FAA) within the Department of Transportation). 

3

GAO, Federally Created Entities: An Overview of Key Attributes, GAO-10-97 

(Washington, D.C.: Oct. 29, 2009). 

Appendix I: Objectives, Scope, and 

Methodology
Appendix I: Objectives, Scope, and 

Methodology

Page 40 GAO-16-648 Federal Real Property

reported that it had independent leasing authority, it was also asked to 

complete additional survey questions to identify the authorizing legislation 

or appropriations act that granted it the authority to lease domestic office 

and warehouse space independently. The survey also asked the federal 

entity to complete additional descriptive information about the amount of 

domestic office and warehouse space and associated annual rent cost as 

of October 1, 2015, for the space that each entity independently leased. 

The majority of the information collected through the survey has been 

compiled and reported in appendix II.

To assess how independent leases compare with GSA and private sector 

lease costs, we collected and analyzed lease data from selected federal 

entities that reported having independent leasing authority and contracted 

with a professional services real-estate firm to compare independent 

leases to GSA and private sector lease rates. The scope of this review 

includes information on independent leases, GSA leases, and private 

sector leases commencing between calendar years 2001 through 2015. 

We initially collected 43 independent leases from eight selected civilian 

federal entities with offices and warehouses located in four different U.S. 

metropolitan regions: Atlanta, Georgia; Los Angeles, California; Miami, 

Florida; and Washington, D.C. We selected these four metropolitan 

regions because of the availability of independently leased office and 

warehouse spaces. The eight civilian federal entities were the Federal 

Aviation Administration (FAA) within the Department of Transportation, 

the Federal Deposit Insurance Corporation (FDIC), the National 

Aeronautics and Space Administration (NASA), the National Credit Union 

Association (NCUA), the National Oceanic and Atmospheric 

Administration (NOAA) within the Department of Commerce, the Pension 

Benefit Guaranty Corporation (PBGC), the U.S. Coast Guard (USCG) 

within the Department of Homeland Security, and the U.S. Patent and 

Trademark Office (USPTO) within the Department of Commerce. We 

selected these federal entities using a variety of considerations based on 

professional judgment such as the type of entity, number of properties, 

square footage, and rent paid, among other factors. The selected leases 

encompass all independent leases present in each region from all eight 

entities except for selected FAA properties in the National Capital Region. 

We omitted FAA properties at Dulles International Airport, Reagan 

National Airport, and Baltimore Washington International Airport because 

of the relatively large representation of FAA leases already in our 

selection (15 of the 43 leases were from FAA) and resource limitations. 

While our selection of 43 leases from eight federal entities is nongeneralizable to the universe of all independent leases, they serve as 

case studies and provide examples of how independent leases compare 
Appendix I: Objectives, Scope, and 

Methodology

Page 41 GAO-16-648 Federal Real Property

with GSA and private sector leases. In addition to reviewing the leases 

and additional supporting documentation from our selected federal 

entities, we also interviewed knowledgeable officials at the respective 

entities regarding the history and details of each individual lease.

Of these 43 independent leases collected from the eight entities, we 

compared a subset of 37 leases from seven of the federal entities against 

GSA and private sector leases. We excluded four leases on the basis that 

they did not require the tenant to pay any rent,4 and excluded two 

additional leases because leases of comparable building finish quality 

could not be identified in their respective market.5 We extracted specific 

cost-affecting data elements identified by the contractor from each of the 

37 leases to the extent they were available within the lease documents, 

as applicable. Specifically, we extracted data for the following 

parameters:

• lease address,

• rentable square footage of the leased space,

• total square footage of the building,

• building type (i.e., office or warehouse),

• soft and/or firm lease term periods,6

• the lease’s start date,

• annual rent cost,

• any rental abatement periods,

• the tenant’s share of operating expenses,

• any renewal options,

• lease holdover rates,

• the tenant’s ability to sublet (assignment), and

• availability of parking spaces and their associated cost.

 4

The uniqueness of these arrangements and lack of rent payment precludes identification 

of comparable GSA and private sector leases. Excluding these leases eliminated NOAA’s 

lease from the scope of analysis.

5

These two properties were mobile trailers that were converted into open floor plan offices 

and subsequently leased to NASA. Consequently, the qualities of their finishes were 

below any comparable GSA or market leases in the region.

6

The firm term is the length of the lease that the tenant is required by contract to pay rent 

for without breaking the terms of the lease contract. The soft term refers to the portion of a 

lease’s term after the firm term ends and during which the tenant can terminate the lease 

without breaking the terms of the lease contract.
Appendix I: Objectives, Scope, and 

Methodology

Page 42 GAO-16-648 Federal Real Property

Other parameters of the leases that had implications on cost were also 

included—such as free shuttle services, the tenant’s right of first refusal, 

or the tenant’s ability to reduce its square footage—if present. One team 

member extracted the above parameters for each of the 37 leases, and 

the information was independently reviewed by another team member to 

ensure for consistency and accuracy.

The contractor used GSA’s lease data from 2001 through 2016. The 

contractor reviewed the data provided by GSA for inconsistences, and we 

discussed the data in interviews with knowledgeable federal entity 

officials to assess the appropriateness of the data’s use. We also 

reviewed the contractor’s report, including its steps taken to assess the 

reliability of the GSA data used and the types of analysis conducted, and 

found them to be sufficiently reliable for the purpose of comparing 

independent lease rates to GSA lease rates.

The contractor subsequently performed the following steps to find 

comparable GSA lease matches for each of the 37 independent leases. 

For each independent lease, the contractor:

• filtered GSA leases that were potential matches for only those that 

shared the same building class and building type (i.e., office or 

warehouse);

• filtered leases for those that started in the same year, or one year 

before or after the starting year;7

• filtered the remaining GSA leases for only those leases in the same 

metropolitan region, opting for leases in the same submarket, if 

available; and

• filtered the results so that only GSA leases within 30 to 50 percent of 

the square footage of the independent lease remained. In instances in 

which there were not sufficient GSA leases within that range of square 

feet, the contractor appraised each potential comparable GSA lease 

on an individual basis, and leveraged its staffs’ professional discretion 

to determine if these potential GSA spaces could have been 

 7

The contractor used a range of 3 years—the base year plus or minus one year—to 

increase the number of comparable GSA lease options. 
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-16-648 Federal Real Property

considered when the independent lease was being negotiated.

This process resulted in each of the 37 selected independent leases

being matched to at least one GSA lease, with up to five matches in some 

cases. The contractor then analyzed the matched leases’ rates. In order 

to compare leases with different terms and sizes, the contractor 

calculated the net present value of the rent per square foot of the entirety 

of the GSA leases’ terms. This net present value analysis used the Office 

of Management and Budget’s (OMB) nominal 10-year discount rate of 2.9

percent for calendar year 2016. In instances where there was only one 

GSA lease available, the contractor compared the direct percentage 

difference between the rent in costs per square foot. For instances where 

there were more than one sufficiently comparable GSA lease, the 

contractor used the weighted average of the GSA leases’ rents per 

square foot net present value to calculate the percentage difference. For 

this analysis, the contractor determined that a 10 percent variation above 

or below the independent lease’s rate was the range for which the GSA 

lease(s) were considered equivalent to the independent lease’s rate. We 

allowed this range to account for variations caused by the specific 

circumstances and unique features of each lease transaction. Otherwise, 

we considered independent leases beyond the 10 percent comparable 

range to be either more costly or less costly than its matched lease. Rent 

for all the leases included the shell rent, the amortized tenantimprovement costs—both general and custom—and the operating costs 

paid by the tenant.8 GSA’s fee of 5 to 7 percent that it charges to tenant 

federal entities for its services related to the leased space—that we 

identified in a prior report—was not included in this analysis of rental 

rates.9

For the comparison of independent leases to private sector leases, the 

contractor collected the following data on private sector lease markets:

 8

The shell rent is the rent paid for the tenant’s use of the building’s physical structure and 

land. 

9

GAO, Federal Real Property: GSA Could Decrease Leasing Costs by Encouraging 

Competition and Reducing Unneeded Fees, GAO-16-188 (Washington, D.C.: Jan. 13, 

2016).
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-16-648 Federal Real Property

• Private-sector lease rate data for the four markets were collected from 

quarterly and annual market reports that included rental rates from 

national and regional brokerage companies from 2001 through 2015.

• For the operating expenses of these office buildings, the contractor 

reviewed line item breakdowns of central business districts’ and 

regional submarkets’ expenses in their respective markets from the 

Institute of Real Estate Management’s database.

• To generally assess the appropriateness of these private-sector data, 

the contractor reviewed brokerage reports from several sources for 

each market and conducted interviews with 35 nationwide privatesector real-estate brokers using semi-structured interviews, which 

addressed topics such as typical term lengths, market practices, and 

responsible parties for various expenses and service fees.

In addition, we reviewed the source of the broker market reports and 

clarified analytical steps with the contractor. As a result of these steps, we 

found the private sector’s lease data to be sufficiently reliable for the 

purpose of comparing independent lease rates to GSA lease rates.

To perform the analysis of the performance of the independent leases 

with the market data acquired, the contractor:

• Identified private sector lease rates from broker reports by city and 

submarket to compare with the base year independent lease rates, 

and developed separate city and submarket rates by building class—

that is, Class A and Class B offices—for each year of the analysis;10

• Used the Institute of Real Estate Management’s database to identify 

the average operating expenses in each annual Class A or B 

submarket’s rental rate. Used broker reports to identify tenant 

improvement costs;

• Matched the appropriate annual Class A or B submarket rental rate to 

each of the independent leases; and

 10Building class refers to the subjective quality of a building’s exterior and interior finishes 

and amenities. There are three classes of buildings, Class A, B, and C, of which Class A 

is considered to be the highest quality.
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-16-648 Federal Real Property

• Compared the first year of the independent leases’ rent per square 

foot to the same year’s submarket’s rate and calculated the 

percentage differences. The contractor determined that a 10 percent 

variation above or below the independent lease’s rate was the range 

where the private sector’s annual Class A or Class B submarket-lease 

rate was considered equivalent to the independent lease’s rate.

To evaluate the extent that selected entities’ leasing policies aligned with 

leading government leasing practices we first had to establish federal 

lease acquisition leading practices that could broadly apply to entities with 

various leasing authorities. We developed a list of leading practices that 

could be used by all federal entities to help ensure that real-property 

leasing acquisitions meet mission needs in a cost-effective and 

transparent manner. To develop our list of leading practices, we reviewed 

leasing acquisition practices contained in the General Services 

Acquisition Regulation, the GSA’s Leasing Desk Guide,

11 the Federal 

Management Regulation, OMB Circular A-11,

12 and prior GAO reports.13

We identified practices common among these sources that dealt with the 

portion of the acquisition cycle that starts with identifying a need for space 

through selecting the offer that meets the entity’s needs at the best value 

to the entity. The four leading practices we developed were: assess 

needs, plan ahead, ensure best value, and analyze and document the 

budget effects of the lease. (See fig. 4.) Once the list was developed, we 

shared it with GSA officials and incorporated their comments. In defining 

these leading practices, we identified 10 types of documentation (which 

we refer to as “sub-practices”) that may be included in a lease file to

provide reasonable assurance that the leading practice was used in 

acquiring the respective leased property. (See fig. 5.) To determine the 

extent that our selected entity’s policies aligned with our list of leading 

practices, we reviewed the real property policies provided to us by the 

 11GSA, Leasing Desk Guide, (Washington, D.C.: 2015).

12OMB, Preparation, Submission and Execution of the Budget, OMB Circular No. A-11

(revised 2015).

13GAO, Standards for Internal Control in the Federal Government, GAO-14-704G 

(Washington, D.C.: Sept. 10, 2014); GAO, Acquisition Planning: Opportunities to Build 

Strong Foundations for Better Services Contracts, GAO-11-672 (Washington, D.C.: Aug. 

9, 2011); GAO, Framework for Assessing the Acquisition Function at Federal Agencies,

GAO-05-218G (Washington, D.C.: Sept. 1, 2005); and GAO, Federal Office Space: More 

Businesslike Leasing Approach Could Reduce Costs and Improve Performance, 

GAO/GGD-95-48 (Washington, D.C.: Feb. 27, 1995).
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-16-648 Federal Real Property

entity and documented where there was evidence that leading practices 

were incorporated into the policies. The evidence was aggregated in a 

spreadsheet and was verified by another team member.

To determine the extent that selected lease files aligned with leading 

government leasing practices, we reviewed all of the documentation 

provided by the entities related to 3 warehouse leases and 27 office 

leases selected in our four select metropolitan areas.14 In reviewing the 

lease files, we documented when there was evidence of the leading 

practices. We created an abstract of each of the selected leases and 

noted where, if at all, evidence was contained of leading practices within 

the lease files. Each of the abstracts was then reviewed by another team 

member and any discrepancies were reconciled. Thus, each lease file 

was reviewed by two different team members who came to the same 

decision with regard to the extent that the lease file contained evidence of 

the leading practices. For the purpose of this analysis, we considered a 

lease file in alignment with leading practices if there was sufficient 

documented evidence of the sub-practices in the lease file. We 

determined the lease file to be in partial alignment if there was some 

evidence in the file that the sub-practice was implemented, but either the 

evidence was incomplete, insufficient, or not entirely aligned with the 

leading practice. We determined the lease file not to be in alignment if 

there was no evidence of the sub-practice being implemented in the 

provided documentation.

To evaluate the independent leases’ space utilization rates, we collected 

two pieces of information for each lease. First, we asked officials from our 

selected federal entities for the number of employees assigned to the 

selected offices during the first quarter of fiscal year 2016. Second, we 

determined total rentable square feet per lease.15 We obtained this 

 14There were 43 leases originally selected to be part of the review. Seven of the 43 leases 

were excluded from the analysis of lease files that fell below GSA’s Simplified Lease 

Acquisition Threshold of $150,000 net annual rent as some leading practices are not 

applicable for these low value leases. For example, GSA guidance says that some leases 

that fall under the Simplified Lease Acquisition Threshold are not required to have written 

acquisition plans or required to be advertised. Six leases were excluded for other reasons:

two NASA offices in the original selection were excluded because they are housed in 

trailers located on NASA-owned property; and three USCG offices and one NOAA office 

were excluded because the offices were deemed special arrangements where no rent was 

paid and the terms were indefinite.

15Rentable square feet is the gross square footage of a building minus areas such as 

stairwells and elevator shafts.
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-16-648 Federal Real Property

information from each lease document that federal entities provided to us. 

If the square footage was not in a lease, we asked knowledgeable federal 

entity officials. We divided the number of rentable square feet per lease 

by the number of employees to determine the space utilization rate. We 

then compared each lease’s space utilization rate with GSA’s 

recommended space utilization target of 150 rentable square feet per 

employee for office space. We did not evaluate the per-employee space 

utilization of warehouses in our analysis because of the fundamentally 

different purpose of warehouses as compared to office space—

warehouses are primarily intended for storage purposes. We also did not 

evaluate the utilization of spaces where there were special arrangements 

in which no rent was paid. In addition to reviewing the leases and 

obtaining employee counts from our selected federal entities, we also 

interviewed knowledgeable officials at their respective selected entities 

regarding the purposes of each of the buildings, and visited each office or 

warehouse space as part of our review. As a result, we excluded two 

additional buildings from this analysis since a large percentage of the 

buildings’ space was not designed for typical office use—one PBGC 

office housed a large continuity-of-operations spare office space, while

another NASA office housed a large computer server facility. In total, we 

reviewed 30 selected leases for this analysis. Lastly, we interviewed 

relevant officials from the GSA, OMB, and the Small Agency Council.

We conducted this performance audit from June 2015 to July 2016 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: Federal Entities That Reported Having Independent Leasing Authority for Domestic Offices and Warehouses, as of 

September 30, 2015

Page 48 GAO-16-648 Federal Real Property

In our survey, 52 federal entities reported having independent leasing authority to lease domestic office and warehouse spaces. Of these, 27 

entities fell within the specified member agencies of the Federal Real Property Council (FRPC), which are agencies covered under the Chief 

Financial Officers Act of 1990. (See table 6.) The remaining 25 were federal entities that were not FRPC member entities and also reported 

having independent authority to lease domestic office and warehouse spaces. (See table 7.)

Table 6: Federal Real Property Council Member Agencies that Reported Having Independent Leasing Authority for Domestic Offices and Warehouses

Offices Warehouses

Federal Entity Agency Statute Number Rentable sq. ft. Annual rent ($) Number Rentable sq. ft. Annual rent ($)

Department of 

Agriculture

Agricultural Marketing 

Service

7 U.S.C. § 473a(f)

35 59,659 $1,091,918 0 — —

Animal and Plant Health 

Inspection Service

7 U.S.C. § 8312

87 298,446 $6,326,605 16 61,776 $403,916

Commodity Credit 

Corporation

15 U.S.C. § 714b(h)

0 — — 0 — —

Federal Crop Insurance 

Corporation

7 U.S.C. § 1506(c)

0 — — 0 — —

Department of 

Commerce

National Institute of 

Standards and Technology

15 U.S.C. § 278e

0 — — 0 — —

National Oceanic and 

Atmospheric Administration

16 U.S.C. §§ 1382(c),

1442(d); 49 U.S.C. § 47305 2 19,448 $140,001 0 — —

United States Patent and 

Trademark Office

35 U.S.C. § 2(b)(3)

2 112,977 $10,359,785 0 — —

Department of 

Energy

— 42 U.S.C. § 7256

22 358,424 $6,529,465 2 68,045 $324,732

Bonneville Power 

Administration

16 U.S.C. § 832a

14 158,348 $4,219,210 6 80,771 $356,745

Department of 

Health and Human 

Services

Indian Health Service 25 U.S.C. § 1674

6 29,722 $530,557 2 5,447 $61,134

Department of 

Homeland Security

Customs and Border 

Protection

8 U.S.C. § 1103(b)

0 — — 0 — —

Appendix II: Federal Entities That Reported Having 

Independent Leasing Authority for Domestic Offices and 

Warehouses, as of September 30, 2015
Appendix II: Federal Entities That Reported Having Independent Leasing Authority for Domestic Offices and Warehouses, as of 

September 30, 2015

Page 49 GAO-16-648 Federal Real Property

Offices Warehouses

Federal Entity Agency Statute Number Rentable sq. ft. Annual rent ($) Number Rentable sq. ft. Annual rent ($)

Federal Emergency 

Management Agency

42 U.S.C. § 5196

0 — — 0 — —

Transportation Security 

Administration

49 U.S.C. § 114(j)

81 2,148,236 $72,077,948 2 317,251 $1,767,755

United States Coast Guard 14 U.S.C. § 92(f) 55 679,090 $12,393,618 12 249,310 $6,101,801

Department of the 

Interior

Bureau of Land 

Management

Pub. L. No. 113-235 (2014)a

4 19,095 $124,695 5 30,318 $314,642

National Park Service Pub. L. No. 96-487 (1980); 

Pub. L. No. 95-290 (1978); 

Pub. L. No. 108-413 (2004) 1 3,502 $129,308 2 13,731 $24,718

Department of Labor Job Corps 29 U.S.C. § 3249 8 133,537 $1,662,192 1 63,000 $1,181,299

Department of 

Transportation

Federal Aviation 

Administration

49 U.S.C. § 106

341 3,085,667 $71,303,155 70 1,301,513 $10,285,536

Maritime Administration 40 U.S.C. § 113(e) 3 5,326 $391,149 2 152,700 $2,258,000

Saint Lawrence Seaway 

Development Corporation

33 U.S.C. § 984(a)(8)

1 6,380 $358,767 0 — —

Department of 

Treasury

Office of the Comptroller of 

the Currency

12 U.S.C. § 5416

71 1,466,761 $63,688,730 0 — —

United States Mint 31 U.S.C. § 5136 1 232,000 $12,702,400 0 — —

Environmental 

Protection Agency

— 42 U.S.C. §§ 4704(b), 

9604(j); 33 U.S.C. § 1254(k) 0 — — 0 — —

National Aeronautics 

and Space 

Administration 

— 51 U.S.C. § 20113(c)

8 335,276 $4,769,823 3 101,841 $623,304

National Science 

Foundation

— 42 U.S.C. § 1870(e)

0 — — 0 — —

Nuclear Regulatory 

Commission

— 42 U.S.C. § 2201(g)

0 — — 0 — —
Appendix II: Federal Entities That Reported Having Independent Leasing Authority for Domestic Offices and Warehouses, as of 

September 30, 2015

Page 50 GAO-16-648 Federal Real Property

Offices Warehouses

Federal Entity Agency Statute Number Rentable sq. ft. Annual rent ($) Number Rentable sq. ft. Annual rent ($)

United States 

Agency for 

International 

Development

— 22 U.S.C. § 2396 

0 — — 0 — —

Total 27 — 742 9,151,894 $268,799,326 123 2,445,703 $23,703,582

Source: Information reported by the respective federal entities in a GAO survey. | GAO-16-648

Note: This list of selected civilian federal entities with independent leasing authority was compiled from responses to a survey. It is not intended to be a complete list of all entities or agencies 

that have independent leasing authority for office or warehouse space. We did not conduct an independent legal analysis to verify the information provided by the respondents. All reported 

figures were as of October 1, 2015.

a

This authority is found in an annual appropriations act. A provision in an annual appropriations act is presumed to be effective only for the covered fiscal year unless language in the act or the 

nature of the provision makes it clear that Congress intended for the provision to be permanent.
Appendix II: Federal Entities That Reported Having Independent Leasing Authority for Domestic Offices and Warehouses, as of 

September 30, 2015

Page 51 GAO-16-648 Federal Real Property

Table 7: Federal Entities Not Part of the Federal Real Property Council That Reported Having Independent Leasing Authority for Domestic Offices and 

Warehouses

Federal Entity Statute

Offices Warehouses

Number Rentable sq. ft. Annual rent ($) Number Rentable sq. ft. Annual rent ($)

American Battle Monuments 

Commission

36 U.S.C. § 2103(a)

0 — — 0 — —

Appalachian Regional 

Commission

40 U.S.C. § 14306(a)(7)

1 21,626 $858,629 0 — —

Farm Credit Administration 12 U.S.C. § 2249 0 — — 0 — —

Farm Credit Insurance System 

Corporation

12 U.S.C. §§ 2277a-7, 2277a-8

1 4,325 $155,813 0 — —

Federal Deposit Insurance 

Corporation

12 U.S.C. §1819

91 1,912,379 $47,161,467 0 — —

Federal Reserve Board 12 U.S.C. § 244 2 498,038 $21,309,208 1 47,132 $379,942

Federal Retirement Thrift 

Investment Board

5 U.S.C. § 8474(c)

1 92,179 $5,236,601 0 — —

Inter-American Foundation 22 U.S.C. § 290f(e)(6) 1 14,332 $713,000 0 — —

Millennium Challenge 

Corporation

22 U.S.C. § 7713(a)(5)

2 129,206 $8,300,000 0 — —

National Credit Union 

Administration

12 U.S.C. §§ 1766(i)(2), 1789, 

1795f(a)(14), (15) 7 64,480 $1,371,304 1 9,261 $85,013

National Endowment for the Arts 20 U.S.C. § 959(a)(7) 0 — — 0 — —

National Endowment for the 

Humanities

20 U.S.C. § 959(a)(7)

0 — — 0 — —

National Transportation Safety 

Board

49 U.S.C. § 1113(b)(1)(B)

2 84,681 $2,715,075 0 — —

Overseas Private Investment 

Corporation

Pub. L. No. 87-195, § 239(d) 

(1961), as amended, codified at 22 

U.S.C. § 2199 1 116,487 $7,504,813 0 — —
Appendix II: Federal Entities That Reported Having Independent Leasing Authority for Domestic Offices and Warehouses, as of 

September 30, 2015

Page 52 GAO-16-648 Federal Real Property

Federal Entity Statute

Offices Warehouses

Number Rentable sq. ft. Annual rent ($) Number Rentable sq. ft. Annual rent ($)

Peace Corps Pub. L. No. 87-293, § 15(d)(1), (9) 

(1961) 0 — — 1 6,500 $348,281

Pension Benefit Guaranty 

Corporation

29 U.S.C. § 1302(b)(5)

9 564,703 $28,222,074 0 — —

Railroad Retirement Board 45 U.S.C. § 231f(b)(1), (9) 0 — — 0 — —

Securities and Exchange 

Commission

15 U.S.C. § 78d(b)(3)

8 1,882,484 $90,854,696 0 — —

Smithsonian Institution Pub. L. No. 113-235 (2014)a 14 777,153 $37,002,284 36 710,241 $15,007,574

Tennessee Valley Authority 16 U.S.C. § 831c(f) 19 141,000 $2,665,000 2 82,500 $308,000

United States African 

Development Foundation

22 U.S.C § 290h-4(a)(8)

1 15,705 $803,502 0 — —

United States Commodity Futures 

Trading Commission

7 U.S.C. § 16(b)(3)

4 434,679 $20,066,000 0 — —

United States Holocaust 

Memorial Museum

36 U.S.C. § 2304(b)

4 10,528 $403,376 0 — —

United States Postal Service 39 U.S.C. § 401 35b 701,613 $11,888,432 0 — —

United States Tax Court 26 U.S.C. § 7472 0 — — 0 — —

Total 25 202 7,465,598 $287,231,274 41 855,634 $16,128,810

Source: Information reported by the respective federal entities in a GAO survey. | GAO-16-648

Note: This list of selected civilian federal entities with independent leasing authority was compiled from responses to a survey. It is not intended to be a complete list of all entities or agencies that 

have independent leasing authority for office or warehouse space. We did not conduct an independent legal analysis to verify the information provided by the respondents. All reported figures 

were as of October 1, 2015.

a

This authority is found in an annual appropriations act. A provision in an annual appropriations act is presumed to be effective only for the covered fiscal year unless language in the act or the 

nature of the provision makes it clear that Congress intended for the provision to be permanent.

b

According to a United States Postal Service (USPS) official, USPS does not categorize its buildings as “offices.” For the purposes of our review, we are using as a proxy, USPS’s independently 

leased spaces where over 50 percent of the total square footage was used for administrative functions. These spaces may include office buildings, as well as small offices or administrative space 

located in non-office buildings. 
Appendix III: Comments from the National 

Credit Union Administration

Page 53 GAO-16-648 Federal Real Property

Appendix III: Comments from the National 

Credit Union Administration 
Appendix III: Comments from the National 

Credit Union Administration

Page 54 GAO-16-648 Federal Real Property
Appendix IV: Comments from the United 

States Patent and Trademark Office within the 

Department of Commerce

Page 55 GAO-16-648 Federal Real Property

Appendix IV: Comments from the United 

States Patent and Trademark Office within 

the Department of Commerce
Appendix IV: Comments from the United 

States Patent and Trademark Office within the 

Department of Commerce

Page 56 GAO-16-648 Federal Real Property
Appendix IV: Comments from the United 

States Patent and Trademark Office within the 

Department of Commerce

Page 57 GAO-16-648 Federal Real Property
Appendix V: GAO Contact and Staff 

Acknowledgments

Page 58 GAO-16-648 Federal Real Property

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

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

Director; Timothy Carr; Catherine Kim; Terence Lam; Hannah Laufe; 

Steve Rabinowitz; Malika Rice; Kelly Rubin; Sean Standley; Michelle 

Weathers; and Crystal Wesco made key contributions to this report.

Appendix V: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(542248)
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