Federal Energy Management: GSA's Recovery Act Program Is on Track, but Opportunities Exist to Improve Transparency, Performance Criteria, and Risk Management
Published: 2010-06-16T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The American Recovery and Reinvestment Act of 2009 (Recovery Act) provided the General Services Administration (GSA) with $5.55 billion to invest in federal buildings and promote economic recovery. This funding includes $4.5 billion to convert buildings to high-performance green buildings (HPGB), which seek to reduce energy and water use, among other goals. GAO was asked to address the (1) steps GSA has taken to implement the program and make its Recovery Act projects transparent to the public, (2) extent to which GSA's Recovery Act projects are helping the agency convert buildings to HPGB and addressing federal energy and water conservation requirements and goals, and (3) extent to which GSA has identified potential risks to its Recovery Act program and developed strategies to mitigate those risks. GAO reviewed GSA documents and relevant laws and executive orders, and interviewed GSA officials at headquarters and staff for 12 projects, which varied in type, size, and location.
section_title: What GAO Found
paragraphs: GSA has put an organizational structure in place to implement its Recovery Act program and, as of April 30, 2010, had obligated just over $4 billion of its $5.55 billion appropriation, and is on track to meet the act's obligation deadlines. GSA also has published information on its Recovery Act program, such as agencywide plans for spending funds and lists of projects, but this information does not identify the nature of the work being conducted or describe the 263 projects GSA has selected for Recovery Act funding. Without this information, the program is less than fully transparent--a key GSA Recovery Act goal--because the public cannot readily discern what individual projects entail or are expected to achieve with Recovery Act funding. GSA's Recovery Act projects will enhance energy and water conservation performance in the 263 projects to varying degrees. GSA has begun collecting the data it would need to measure the likely extent of improvement. GSA set minimum performance criteria for its projects, which include reducing energy use by 30 percent. The criteria do not, however, include reducing the energy and environmental impacts of transportation through building location and site design, although this is part of the statutory definition of a HPGB. Under the Recovery Act, GSA is to use this definition when converting existing buildings. According to GSA, some managers are designing transportation-related improvements into their projects. However, because it is not part of GSA's criteria, other managers may not be systematically considering such improvements. According to GSA, the agency has begun to roll out a new centralized data system to collect and report on specific information for Recovery Act projects' green improvements and performance. GSA has identified risks to its Recovery Act program, such as the risk that Recovery Act reporting is inaccurate or incomplete, and risk mitigation strategies. In addition, GSA's approach to risk management is generally consistent with best practices we have developed. However, GSA relies on informal communication to identify project-level risks and has not taken steps to ensure the completion of project-level risk planning documents required by GSA. GAO found that the required documents, which are intended to help plan for project-level risks, had not been fully completed for 9 of the 12 projects reviewed. Unidentified risks to GSA's Recovery Act projects could potentially limit GSA's ability to achieve Recovery Act goals.

section_title: Letter
paragraphs: In January 2003, we designated federal real property as a high-risk area, in  part because of deteriorating facilities and unreliable real property data.  In addition, in 2007, we reported that addressing the needs of aging and  deteriorating federal facilities remains a problem for major real property- holding agencies, and that, according to recent estimates, tens of billions  of dollars will be needed to repair or restore these assets. The American  Recovery and Reinvestment Act of 2009 (Recovery Act) provided the  General Services Administration (GSA) with $5.55 billion to invest in  federal buildings, create jobs, and promote economic recovery. Of this  $5.55 billion, over $1 billion is being used by GSA for new federal  buildings, courthouses, border stations, and land ports of entry.  Additionally, the Recovery Act provided that at least $4.5 billion be used  “for measures necessary to convert GSA facilities to high-performance  green buildings” as defined by section 401 of the Energy Independence and  Security Act of 2007 (EISA). High-performance green buildings are  designed to achieve a number of environmental goals, including reducing  energy, water, and material resource use and the buildings’ impact on the  environment and on building occupants, by means such as using recycled  or nontoxic products in the buildings.
The federal government is the nation’s single largest energy consumer, and  federal buildings accounted for about 35 percent of the government’s total  energy use in fiscal year 2009. Converting federal facilities to high- performance green buildings could help reduce the federal government’s  energy consumption and bring federal buildings more in line with federal  energy and water conservation requirements and goals. Over the last  several years, a number of laws and executive orders have established new  requirements and direction for improving the energy and water  conservation performance of federal facilities. For example, in December  2007, EISA established new requirements for reducing energy use at  federal buildings, reducing fossil fuel use for certain federal buildings, and  managing storm water runoff. GSA’s Recovery Act funding, which is more  than three times greater than the agency’s 2009 funding for new  construction and renovations, provides a unique opportunity for GSA to  address the deterioration of some of its aging buildings while also  improving their energy and water conservation performance. However, to  obligate this funding within the time frame required by the Recovery Act,  GSA will have to implement hundreds of projects across the country at an  accelerated pace.
Given the magnitude of GSA’s Recovery Act program and the associated  time frame, you asked us to review GSA’s plans and efforts related to the  use of Recovery Act funds. This report provides information and analysis  on (1) the steps GSA has taken to implement the program and make its  Recovery Act projects transparent to the public, (2) the extent to which  GSA’s Recovery Act projects are helping the agency convert buildings to  high-performance green buildings and address energy and water  conservation requirements and goals, and (3) the extent to which GSA has  taken steps to identify potential risks to its Recovery Act program and  developed strategies to mitigate those risks.
To address these questions, we reviewed key documents describing GSA’s  efforts to organize and implement the program, publicly available  information about GSA’s Recovery Act program, the scope of GSA’s  Recovery Act projects, and GSA’s progress in obligating and spending  funds. We compared criteria GSA established for Recovery Act projects  with selected legislation and executive orders relevant to the energy and  water conservation performance of federal buildings. Also, we interviewed  GSA officials in headquarters and regional offices, including project  management staff for 12 full and partial building modernization projects  we selected as case studies using a judgmental sample. Because the  sample is judgmental, the information we obtained from those projects  cannot be generalized to all of GSA’s Recovery Act projects. Among the  factors we considered in selecting the 12 projects was whether GSA had  identified them as being far enough along in the design process to have  information on their expected performance. In addition, we used the  projects’ type, size, and geographic location as selection criteria. We  collected information from our 12 case studies on their expected energy  and water conservation performance. Finally, we reviewed GSA’s efforts  to develop and implement a risk management plan, compared those efforts  with accepted risk management best practices, and compared the project  risk planning efforts from our 12 case studies with GSA policies and Office  of Management and Budget (OMB) guidance on project-level risk planning.  See appendix I for a more complete description of our scope and  methodology.
We conducted this performance audit from June 2009 through June 2010 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.
subsections: section_title: Background
paragraphs: Of the $5.55 billion the Recovery Act provided to GSA’s Federal Buildings  Fund, $750 million is being used by GSA for new federal buildings and  U.S. courthouses, $300 million is being used for new border stations and  land ports of entry, and $4.5 billion is being used for measures necessary  to convert existing GSA facilities to high-performance green buildings.  Overall, for its Recovery Act program, GSA selected 263 projects in all   50 states, the District of Columbia, and 2 U.S. territories. As shown in  table 1, GSA’s Recovery Act projects fall into the following four main  categories: (1) new construction, (2) full and partial building  modernizations, (3) limited scope projects, and (4) small projects.
The following information describes the four main categories for GSA’s  Recovery Act projects:    New construction: Projects associated with building entirely new  structures or significant extensions to existing structures, including the  construction of new federal buildings and courthouses, as well as border  stations and land ports of entry.
Full and partial building modernizations: Projects associated with the  replacement or upgrade of multiple building systems and components  (such as windows, roofs, and plumbing, electrical, and mechanical  systems), which are intended to significantly increase the usable life of the  buildings. Full modernizations are comprehensive renovations that replace  or restore nearly all the major systems in a building. Partial  modernizations are more limited and address one or a few systems in the  building.
Limited scope projects: Projects associated with a single building  system—such as lighting or plumbing—that could include upgrading  existing systems or installing energy and environmental improvements,  such as installing energy-generating photovoltaic panels on the roof of a  building.
Small projects: Limited scope projects whose costs are below the  prospectus level.
GSA officials told us that in selecting Recovery Act projects, they gave  priority to those projects that would help transform federal buildings into  high-performance green buildings and obligate funds quickly. Obligating  funds quickly was important because the Recovery Act requires GSA to  obligate $5 billion by September 30, 2010, and to obligate the full Recovery  Act funding amount, $5.55 billion, by September 30, 2011. To reflect these  priorities, GSA developed selection criteria for full and partial building  modernization projects, which are presented in table 2 in descending order  of weight.
GSA scored projects in accordance with the relative priority it assigned to  each criterion and then ranked potential Recovery Act projects on the  basis of these results. GSA assigned the highest priority to the first three  criteria listed in table 2. The execution timing and minimizing execution  risk criteria are designed to identify projects that could be started quickly,  would create jobs as soon as possible, and would also have a low risk of  not being completed within the Recovery Act’s deadlines. Recovery Act  funds must be spent no later than 5 years after the end of the fiscal year in  which the funds are required to be obligated. Typically, the funds for a  large construction project are obligated throughout the life of the project,  and the 5-year limitation on expenditures generally does not apply to funds  made available to GSA for acquisition and construction. Therefore, the  Recovery Act’s establishment of deadlines for obligating and spending  funds differs from the typical time frames for GSA’s construction projects.
Many of the projects GSA selected for new construction and full and  partial building modernizations had previously received partial funding for  design or for early project phases. For example, 41 of the 63 new  construction and full and partial building modernization projects had  received funding from previous fiscal year appropriations. GSA officials  said that they used Recovery Act funding to quickly start or expand  construction on these projects, while also identifying ways to incorporate  energy savings or environmental improvements into their design.  Additionally, GSA funded cost escalation for some ongoing projects—that  is, projects that needed additional funding to start or to complete  construction. For example, according to GSA officials, the renovation of  the Thurgood Marshall U.S. Courthouse in New York, a full building  modernization, needed Recovery Act funding to address an increase in  cost after bids from contractors came in higher than expected.
According to GSA officials, the other five criteria listed in table 2 are those  GSA typically uses when selecting capital projects, such as improving  facility condition. In GSA’s supplemental information to its financial  statements for fiscal year 2009, GSA reported an inventory of capital  repairs and alterations estimated to cost approximately $5.0 billion. The  buildings GSA selected for its Recovery Act program account for about  $3.7 billion of this estimate, but the Recovery Act funding will not fully  address the needs of each selected building, since reducing GSA’s capital  repairs and alterations inventory was not the intent of the Recovery Act,  according to GSA officials. GSA officials also stated that they will use  Recovery Act funds for projects or elements of projects that are not among  the estimated capital improvement needs, such as projects to incorporate  high-performance green building features. While improving facility  condition was one of GSA’s selection criteria, making facilities greener  and obligating funds quickly received higher priority. GSA officials  estimated that Recovery Act projects will reduce the agency’s total capital  repairs and alterations estimate by $1.5 to $2.0 billion.
According to the Web site, www.recovery.gov (Recovery.gov), the  Recovery Act has three immediate goals: (1) create new jobs and save  existing ones, (2) spur economic activity and invest in long-term growth,  and (3) foster “unprecedented” levels of accountability and transparency  in government spending. In addition, GSA’s Recovery Act program plan  states that GSA will maintain an unprecedented level of openness and  transparency in operations. GSA has published information on its  Recovery Act program on both its own Recovery Act Web site and  Recovery.gov. The information includes the following documents:    The Agencywide Recovery Plan details GSA’s broad Recovery Act goals  for the entire agency, GSA programs funded by the Recovery Act,  contracting operations, and agency accountability efforts. The agencywide  plan also outlines the public benefits GSA expects from its investments,  such as job creation and environmental benefits.
The Federal Buildings Fund Program Plan contains a summary of the  objectives and activities that GSA’s Public Buildings Service (PBS) plans  to implement with the $5.55 billion in Recovery Act funds. The plan also  includes information on the projects’ selection, delivery schedule, and  performance measures. Additionally, the plan describes how GSA will  address issues such as monitoring and evaluation, transparency, and  accountability for its Recovery Act program.
The PBS Project Plan details how GSA will spend its $5.55 billion in  Recovery Act funds. The project plan lists all of the GSA building projects  that will receive Recovery Act funds and, for each project, includes the  name, location (city and state), and estimated cost. GSA has the ability to  shift funds from one project to another but must give the Senate and  House Committees on Appropriations 15 days notice before doing so.  Agency officials stated that they will continue to revise GSA’s project plan  in the future.
The weekly financial and activity reports contain information on GSA’s  Recovery Act weekly appropriations, obligations, and disbursements,  along with activities and planned actions.
The Federal Buildings Fund Investments Map shows where GSA is  spending its Recovery Act funds and provides information on spending to  date, measured in obligations and expenditures, for individual projects or  states. GSA posted an interactive map on its Web site, which graphically  depicts its Recovery Act obligations and expenditures by state and project.
Recipient reporting guidance for registration and reporting offers  assistance for prime recipients of Recovery Act funds, who must register  with the government and report on how Recovery Act funds were used.  GSA posts its recipient reporting data on Recovery.gov, along with other  participating agencies.
GSA also reports frequently to OMB and congressional committees on  Recovery Act plans, progress, and accomplishments. For example, at the  request of OMB and the White House, GSA produced a 100 Days Report,  which updated current Recovery Act obligations and reported planned  obligations to the end of calendar year 2009. GSA also produces monthly  reports on obligations versus expenditures for the House Committee on  Transportation and Infrastructure.
Since the 1970s, federal statutes and executive orders have established  and revised a number of requirements and goals for changing the way  federal agencies use or obtain energy. For example, EISA established new  energy management requirements and goals, such as energy-efficiency  performance standards for new buildings and major renovations. In  addition, EISA defined a high-performance green building, which includes  eight elements, as shown in table 3.
While the Recovery Act specifies that GSA should use Recovery Act funds  for measures necessary to convert GSA facilities to high-performance  green buildings, as defined in section 401 of EISA, GSA also has to follow  federal energy and water conservation requirements and goals established  in federal statutes and executive orders. The federal energy and water  conservation requirements and goals which we refer to later in this report  are summarized in table 4.
section_title: GSA Has Processes to Manage Its Program and Meet Obligation Deadlines but Has Not Provided Key Information about Its Projects to the Public
subsections: section_title: GSA Has Processes in Place to Manage Its Program and Is on Track to Meet Recovery Act Obligation Deadlines
paragraphs: In March 2009, GSA created a national program management office (PMO)  to oversee its Recovery Act program and established interim obligation  milestones to help it achieve its Recovery Act obligation deadlines. The  PMO is supported by the Recovery Program Executive Steering  Committee headed by the PBS Deputy Commissioner. The Executive  Steering Committee has developed a nationwide program strategy and  priorities for the program. Figure 1 illustrates the organization of the PMO.  A program management recovery executive heads the PMO and is  supported by zone and regional recovery executives, who are responsible  for monitoring and reviewing the performance of Recovery Act projects  and managing risks at the regional level. In addition, subject matter  experts support the regional teams in delivering projects, and two  contractors are responsible for project tracking and for reporting and  communication. The PMO uses data from projects to look for trends in  cost and schedule performance for the program.
As shown in figure 2, GSA has grouped its 11 regions into three Recovery  Act zones. GSA officials stated that the objectives of the zone structure  are to create and foster the sharing of ideas and resources and to provide  project oversight. Also, the zone structure provides a link between the  project leadership and the PMO. According to GSA officials, the PMO’s  efforts and success have also contributed to improvements in GSA’s other  operations. For example, GSA is reorganizing PBS’s internal structure to  create more national coherence by having all 11 regions work together, as  under the Recovery Act zone structure, rather than independently.  Furthermore, GSA is realigning its Office of Design and Construction to  directly coordinate with the PMO, which will allow the two offices to  w the two offices to  share ideas.  share ideas.
The PMO established interim milestones to help GSA achieve the two  Recovery Act obligation deadlines. As we have previously noted, the  Recovery Act requires GSA to obligate $5.0 billion by September 30, 2010,  and to obligate the full Recovery Act funding amount, $5.55 billion, by  September 30, 2011. Table 5 shows the four interim milestones that the  PMO set and the cumulative amount that GSA obligated by each of the  milestones. As of April 30, 2010, GSA had obligated just over $4.0 billion.  According to GSA officials, GSA remains on track to achieve its overall  Recovery Act obligation deadlines.
According to GSA’s Agencywide Recovery Plan, GSA’s goal is to award 99  percent of Recovery Act dollars through competitive awards. GSA has  identified approximately 1 percent of Recovery Act funds that may be  awarded through other-than-fully-competitive means. To help achieve  this goal, GSA plans to add Recovery Act projects to existing,  competitively awarded contracts when they are within the scope of work,  award ceiling, and terms of the agreement. In March 2010, the GSA Office  of Inspector General (OIG) reported that GSA incorrectly executed the  construction portion of the contract to which a Recovery Act project was  added—a federal courthouse in Austin, Texas— and concluded that the  award was not competitive. PBS disagreed with the OIG’s findings. GSA  has awarded additional work to this project using Recovery Act funding  and considered it to be competitively awarded because it considers the  initial contract to have been competitively awarded.
GSA’s $5.55 billion in Recovery Act funding, which must be obligated over  2 fiscal years, is over three times the agency’s 2009 funding for new  construction and renovations. To address this increase in its workload,  GSA determined that it would need to add over 200 full-time-equivalent  personnel, including contracting officers. Additionally, GSA officials said  they have transferred experienced personnel from other work to Recovery  Act projects. GSA is also hiring temporary federal personnel and  contractors, both to address the increased workload and to fill the gaps  created by transferring experienced staff to Recovery Act work. As of  April 23, 2010, GSA had hired 96 full-time-equivalent personnel and 38  contractors, and it plans to hire an estimated 68 additional personnel by  the end of fiscal year 2010.
The Recovery Act requires recipients to report data on jobs funded each  calendar quarter. GSA established an outreach and call center to assist  recipients in meeting their reporting requirements. According to GSA  officials, 99.0 percent of GSA’s prime recipients have reported during the  April 2010 reporting period, which represents 99.8 percent of GSA’s  Recovery Act obligations for PBS. For the most recent reporting period— January 1, 2010, to March 31, 2010,—GSA recipients reported 2,847 jobs  funded. GSA officials stated that the requirement for recipient reporting,  including jobs data, is a contractual obligation, and if recipients do not  report it is considered a breach of contract.
The GSA OIG received $7 million from the Recovery Act for oversight and  audit of programs, grants, and projects. To promote accountability and  transparency on the use of Recovery Act funds, the Recovery  Accountability and Transparency Board worked with Federal Inspectors  General to establish a multiphased approach for reviewing agencies’  oversight of recipients’ Recovery Act data. The first phase, conducted  before the start of the first recipient reporting cycle, provided a snapshot  of agencies’ data review processes. The second phase, conducted after  the first reporting cycle ended, reviewed data oversight at seven agencies,  including GSA, by their respective OIG. The GSA OIG is currently  examining the effectiveness of GSA’s review process, comparing GSA and  OMB guidance to determine whether any conflict exists, and will issue a  report no later than June 2010. We did not evaluate recipient-reported data  as part of this review. However, we have reported on problems with data  reported by recipients of Recovery Act funds administered by federal  agencies generally, though not by GSA specifically. For example, in  November 2009, we reported that although the job data reported by  recipients provided some insight into their use of Recovery Act funding, a  range of significant reporting and quality issues needed to be addressed.  In December 2009, OMB issued guidance to further improve the quality of  the data that Recovery Act recipients submit. Furthermore, in March  2010, we reported that while progress was achieved in addressing some  data quality and reporting issues identified in the first round of recipient  reporting, data errors, reporting inconsistencies, and decisions made by  some recipients not to use the new job reporting guidance for the second  round compromised data quality and the ability to aggregate the data.  Overall, while significant issues remain, the second round of reporting  appears to have gone more smoothly as recipients have become more  familiar with the reporting system and requirements.
section_title: GSA Makes Overall Information on Its Recovery Act Program Publicly Available but Has Not Provided Key Information about Its Projects to the Public
paragraphs: While GSA has provided information on the goals of its Recovery Act  program, the projects selected to receive Recovery Act funding, and its  own progress in obligating and expending Recovery Act funding, it has not  included details on the nature of the work being conducted on individual  projects or clearly identified or explained why it has added or removed  projects from its program in GSA’s project plan revisions. According to  Recovery.gov, one of the goals of the Recovery Act is to foster  “unprecedented” levels of accountability and transparency in government  spending. In addition, GSA states in its Federal Buildings Fund program  plan that it will maintain an unprecedented level of openness and  transparency in operations. As we have previously discussed, GSA posted  information on its program plans, project plan, funding activities, and  recipient-reported data on its Web site and Recovery.gov.
The lack of information on the nature of work being conducted on  individual projects and their expected outcomes makes it difficult for the  public to determine what improvements are being funded by the Recovery  Act, such as which building systems are being upgraded or what types of  building improvements are being made. Project scopes can cover a range  of activities, including improvements to lighting, mechanical/electrical  system upgrades, water use, roof repair, or window work. Individual  projects can also address multiple areas and can be designed to achieve  renewable energy targets. Such information on the nature of the work  being conducted, while not required, could provide context for the public  to understand how Recovery Act funds are being used to meet these goals.  GSA’s project plan, which is available on the agency’s Web site and  Recovery.gov, contains information for each GSA Recovery Act project,  such as its name, location (city and state), and estimated cost. Descriptive  information about the projects is limited to their category—new  construction, full and partial building modernization, and limited scope.  Additionally, full and partial building modernizations are listed together,  without information on which project falls under which category, thereby  making it difficult to distinguish between the two types. This distinction is  important because a full building modernization, which is a complete  renovation of an entire building, would be expected to incorporate more  green features than a partial building modernization. Moreover, without  this distinction, the public lacks context for evaluating GSA’s efforts to  convert existing federal facilities to high-performance green buildings, as  provided in the Recovery Act.
OMB reviewed GSA’s project plan, and on March 31, 2009, GSA submitted  the plan, with the list of selected projects, to the Senate and House  Committees on Appropriations as required by the Recovery Act. GSA later  published project plan revisions—dated November 2009, January 2010,  and March 2010—which reflected adjustments to the original project  plan’s allocations for existing projects. GSA officials said they made these  adjustments, in part, to take advantage of cost savings that they realized  when bids came in lower than expected, partly because of current  economic conditions. These adjustments led to changes in the amounts  of funds allocated for certain project categories, primarily affecting small  projects, as shown in table 6.
While the revisions to GSA’s project plan to date track the changes in  project cost estimates, they do not fully explain the addition or removal of  projects, nor do they address the lack of information on project scope. For  example, in the November 2009 revised project plan, GSA states that it  removed a project because it was no longer appropriate to go forward.  GSA did not clearly highlight or mention which project it removed or the  type of project. The removed project can be identified only by looking  through the entire list of all Recovery Act projects and comparing the  previous and new project cost totals. In the January 2010 revision, GSA  added nine new projects to its program—one new construction project,  two projects in the full and partial building modernization category, and  six limited scope projects. These nine projects are expected to cost a total  of approximately $86 million, but the project plan did not clearly highlight  which projects were new additions to the plan. GSA has an opportunity to  further meet its Recovery Act transparency goals by clearly identifying  projects that have been added to or deleted from its program.
section_title: Projects Could Result in Greener Buildings, but GSA’s Data Are Not Yet Available to Measure the Extent of Progress
paragraphs: GSA has developed minimum performance criteria that will help it convert  buildings to high-performance green buildings and address energy and  water conservation requirements and goals, although these criteria do not  align completely with federal requirements. The resulting modernized  buildings will likely vary greatly in the extent of their green improvements,  for several reasons. Finally, GSA does not yet have sufficient data on the  progress of its Recovery Act improvements, but it is implementing a  system to track this.
subsections: section_title: GSA’s Minimum Performance Criteria for Recovery Act Projects Align with Federal Requirements, with Two Exceptions
paragraphs: GSA has developed minimum performance criteria (MPC) to help ensure  that Recovery Act funding results in improvements to buildings’ energy  and water conservation performance. The MPC are to be incorporated into  the project designs and cover the areas of energy, water, indoor  environmental quality, materials, and building design. The following are  examples of the MPC that are expected to be incorporated in GSA’s  Recovery Act projects:  install advanced meters that measure the building’s consumption of  electricity, natural gas, steam, and other sources of energy;    use high-efficiency water fixtures to help reduce water consumption;    use occupancy sensors on lighting to help conserve energy in areas of the  building that are unoccupied; and    salvage, recycle, or reuse at least 50 percent of construction and  demolition waste generated on a project.
Each Recovery Act project is required to meet all MPC that are applicable  to its scope of work, unless it receives a waiver from the Regional  Recovery Executive and the PMO. Meeting the MPC for reducing water  consumption by 20 percent could be waived for projects that do not  include significant plumbing system upgrades, for example. As we have  noted previously, federal energy and water conservation requirements and  goals differ for different building categories. Therefore, GSA has  established two sets of MPC, one for new construction and full building  modernization projects and a second, less stringent set for partial building  modernizations and limited scope projects. (App. II provides more detailed  information on the two sets of MPC.)
We found that both sets of MPC generally align with most of the elements  of a high-performance green building, as established by EISA, and with key  federal energy and water conservation requirements and goals (see tables  3 and 4). However, the MPC do not address one statutory high- performance green building element—to reduce the environmental and  energy impacts of transportation through building location and site design.  For example, a project could address this element by installing the  infrastructure necessary for alternative fuel vehicles or giving priority  parking to carpool and van-share participants. According to GSA officials,  they did not include this element in the MPC because the MPC are based  on the Guiding Principles for Federal Leadership in High Performance  and Sustainable Buildings, which does not specifically address  transportation. GSA officials noted that a number of the GSA Recovery Act  projects are making transportation-related improvements as part of their  efforts to obtain a Leadership in Energy and Environmental Design  (LEED) Silver rating. However, because the MPC do not require such  improvements, project managers may not be systematically determining  whether transportation-related improvements can be included in projects,  as they are for energy and water conservation improvements, thereby  missing opportunities to incorporate that high-performance green building  element. Furthermore, because GSA has not given transportation-related  improvements the MPC designation, GSA will not be collecting data on  those improvements that are being done as part of Recovery Act projects.
We also found that the MPC are expected to contribute toward meeting  the federal conservation requirements and goals to reduce energy and  water intensity, although they do not explicitly address these objectives.  The MPC do not mention the specific percentages and dates set out in law  and executive order for reducing energy and water intensity. GSA officials  said that this is because the objectives apply to GSA’s building inventory  as a whole, rather than to individual buildings. Nevertheless, the officials  stated that they expect Recovery Act projects to contribute significantly  toward meeting the agency’s inventorywide federal requirements and goals  for both energy and water. According to the officials, new construction  and full building modernization projects should exceed these requirements  and goals because they must meet other, more stringent, MPC for energy  and water conservation. For example, they explained, the MPC require  new construction and full modernization projects to exceed ASHRAE  Standard 90.1-2007 by 30 percent, which is a higher energy conservation  standard than the federal requirement to decrease energy intensity by 3  percent per year. GSA officials said they expect partial building  modernizations and limited scope projects to make a more modest  contribution toward meeting these requirements due to their reduced  scope.
section_title: GSA Recovery Act Projects Are Likely to Vary Greatly in the Extent of Their Energy and Water Conservation Improvements
paragraphs: According to GSA officials, all buildings receiving Recovery Act funds are  expected to move toward becoming high-performance green buildings.  The officials stated they have not developed an exact number of projects  that could result in a high-performance green building because the  definition from EISA is too broad and is a relative measure. For example,  two projects that reduce water consumption by 1 percent and 10 percent,  respectively, both meet the high-performance green buildings element of  reducing water usage. In addition, GSA officials said that the high- performance green building criteria in EISA can sometime be at odds.  Applying high-performance green building criteria by increasing the  amount of space for tenants in an effort to improve worker productivity,  for example, can actually result in an increase in the building’s energy use  as opposed to a decrease. Consequently, GSA officials said that they  developed the MPC in an attempt to provide a better structure for gauging  the expected energy and water conservation performance of Recovery Act  projects.
Furthermore, the buildings are likely to vary greatly in the extent of their  energy and water conservation improvements because of a variety of  factors. Some Recovery Act projects, for example, are broad in scope and  are being used to modernize multiple building systems—such as electrical;  water; and heating, ventilation, and air conditioning systems (HVAC)— while others are modernizing relatively few systems or a specific  component of a building. Additionally, existing infrastructure may affect  the extent of energy and environmental improvements for certain  buildings. For example, it will likely be more difficult to make certain  green improvements to historic federal buildings because of the need to  preserve features of the buildings, such as historic windows or ornate wall  coverings. Finally, some projects were designed prior to the Recovery Act  and may only have included a small number of green improvements. To  include more green improvements at this juncture may mean that the  projects would have to undergo significant redesign. Finally, the number  of green improvements employed for a project may also be affected  because of unanticipated problems discovered during the modernization.  The discovery of asbestos on a project, for example, may result in the need  to shift project funds originally slated for green improvements to asbestos  abatement. In general, according to GSA officials, the new construction  and full modernization projects are expected to significantly improve their  energy and water conservation performance and exceed some federal  energy and water conservation requirements and goals, especially those  related to energy and water reduction. Conversely, GSA officials expect  smaller projects to have less significant green improvements and to  address only those federal energy and water conservation requirements  and goals that fall within their scope of work. For example, a project  primarily involving plumbing upgrades might only address the federal  water conservation goal concerning reductions in water intensity.
The 12 GSA Recovery Act projects (8 full and 4 partial modernizations) we  examined differed significantly in their planned green improvements.  (App. III provides more detailed information on the 12 projects we  examined.) For 3 of the projects, GSA is either implementing or planning  to implement a broad array of green improvements that will touch on  multiple systems throughout the buildings. These full building  modernizations will principally focus on replacing older, less efficient  mechanical, electrical, and plumbing systems with newer, high-efficiency  systems. While these projects had already been receiving agency funding  for some time, Recovery Act funding, according to some project managers,  has enabled them to add features that will enhance buildings’ energy and  water conservation performance. Many of these features were not  originally planned. Examples of full building modernization projects that  are expected to result in extensive improvements include the following:    Edith Green-Wendell Wyatt Federal Building in Portland, Oregon. GSA  plans to transform the deteriorating 30-year-old federal building into a  high-performance green building by replacing the building’s electrical,  plumbing, and HVAC systems. GSA also plans to upgrade the building’s life  safety, mechanical, elevator, and security systems as well as install  photovoltaic panels and rain harvesting features on the building’s roof.  The project management staff said that Recovery Act funding gave them  the opportunity to vacate the entire building during the renovation, rather  than proceeding two floors at a time, a key decision that allowed them to  expand the scope of the project and add significant green improvements to  the building. GSA is exploring the option of adding wire mesh or a  perforated metal screen up the side of the building to shade the facade  from the sun, thus helping to reduce the amount of energy needed for  cooling the building.
Mary Switzer Building in Washington, D.C. GSA is also planning  extensive green improvements for the Switzer building. The project  includes new HVAC, plumbing, and emergency power systems;  replacement of aged plumbing; asbestos abatement; and restoration work  performed on the building’s historic windows. According to project  management staff, the Recovery Act allowed them to accelerate the  modernization of the building by 1 year. It also allowed them to exceed  some of the MPC issued by GSA, including an estimated 55 percent  reduction in water use—above the 20 percent called for in the MPC for  water use. In addition, the project estimates that it will address 30 percent  of its hot water demand using solar hot water equipment. GSA also  expects that approximately 70 to 75 percent of all the materials from the  demolition phases of the project will be recycled.
In five of the full building modernization projects we examined, GSA is  planning to implement green improvements that are less extensive but that  still address major systems or building components. These projects will  generally focus on upgrades to current building components, but some  building systems will also be replaced. Two projects contain historical  elements that will have to be addressed as well. Several of the project  managers stated that many of the green improvements slated for their  projects would not have been funded without the Recovery Act. Examples  of these projects include the following:    John W. Peck Federal Building in Cincinnati, Ohio. The modernization  of the 44-year-old John W. Peck Federal Building in Cincinnati, Ohio,  includes extensive exterior upgrades, such as installing insulated, dual- glass windows to decrease the heating and cooling loads for the entire  building. GSA estimates the improved windows alone will reduce energy  consumption for heating and cooling by about 24 percent compared with  the industry standard. The project also includes extensive interior work  that will save energy—for example, new lighting fixtures and controls. The  lighting improvements are expected to reduce energy consumption for  lighting by about 50 percent, according to the project manager. This  reduction would be significant since lighting consumes about 30 percent  of the building’s energy.
Birch Bayh U.S. Courthouse in Indianapolis, Indiana. The project  involves numerous system upgrades while preserving the historical  character of the 1905 courthouse. For example, the project will upgrade  the courthouse’s HVAC system, where most of the air handling units and  associated controls and equipment will be replaced. This change will allow  the building managers to keep a more constant temperature and humidity  in the historic courtrooms, while conserving energy in other areas of the  building when they are not in use. Another green improvement will be the  installation of a vegetative roof and a 10,000 gallon rainwater collection  system. The system will allow the building to meet the federal requirement  for storm water control, according to the project manager, and reduce  indoor potable water use by using the collected rainwater for toilets. The  project manager anticipates a 20 to 30 percent reduction in indoor potable  water use.
Finally, four partial modernization projects we examined plan to  implement relatively few green improvements. The focus of each project  was primarily to improve the efficiency of individual building components,  as opposed to replacing or upgrading an entire building system. In general,  project managers stated that these projects would have been slow to  receive funding or would probably not have received funding at all if had it  not been for the Recovery Act. Examples of these projects include the  following:    Denver Federal Center in Lakewood, Colorado. The Lakewood project  will upgrade an approximately 70-year-old utility system that provides  both water and sewer services to the center. According to the project  manager, the current system leaks profusely. Since 2001, there have been  90 water line breaks exceeding $1 million in repair costs. GSA officials  further stated that although the project is not specifically building-related,  it is an important project to GSA and its tenants because the federal center  houses approximately 6,000 federal employees from 30 agencies. Failure  of this system could force the center to close, with associated lost wages  of about $1.5 million per day, according to the GSA manager for the  project.   26 Federal Plaza in New York City. The project will address severe water  damage to the plaza’s underground parking garage caused by leaks in the  plaza. The project’s green improvements include photovoltaic lighting and  security cameras that will work with lower-intensity lighting, a new chiller,  and lighting controls on several floors of the building.
Table 7 shows details of the 12 GSA Recovery Act projects we examined.
section_title: GSA Does Not Have Sufficient Data to Measure Progress but Is Taking Steps to Improve Data Collection
paragraphs: In adhering to the MPC that include both high-performance green building  and energy and water conservation requirements and goals, GSA’s  Recovery Act projects are making the buildings greener and addressing  the requirements and goals. However, GSA cannot measure the extent of  progress because it does not have sufficient data on improvements  resulting from the projects. In October 2009, GSA began collecting energy  and performance information on Recovery Act projects through a “data  call” that asked project managers to categorize the status of each of a  project’s MPC as either “not started,” “in progress,” “complete,” “not  applicable,” or “waiver.” However, GSA officials said their guidance was  not detailed enough to clearly define the response categories, thereby  making it difficult for project managers to determine when each status  should be selected. In December 2009, GSA reported that the data  collected through this effort were, in some instances, incomplete and  unreliable. GSA concluded that it needed to revise future data calls to  gather more specific information on how projects would address their  MPCs and to facilitate the tracking and reporting of the data. Furthermore,  the data were limited to about 28 percent of the Recovery Act projects  because those were the only projects that had progressed far enough to  have such data. Several of the project managers from the 12 Recovery Act  projects we examined reported problems in responding to the data call.  For example, two project managers stated that they initially  misinterpreted the appropriate response category for their projects and  consequently inadvertently completed the incorrect MPC checklist.  However, these mistakes were corrected in subsequent updates to the  MPC checklists for the projects.
To obtain more complete and reliable data, GSA is rolling out a new  centralized system for collecting data on Recovery Act projects’ energy  and water conservation performance. GSA officials told us the goals of the  system are to (1) collect information on the MPC for each project and to  aggregate that information, thereby allowing GSA to know the extent to  which projects are collectively addressing MPC; (2) provide subject matter  experts with a means of reviewing projects’ progress in achieving the MPC  and suggesting changes as appropriate; and (3) generate customized  reports upon request. GSA officials said the agency began using the system  in April 2010 and expects it to be available online to all project managers  soon.
According to GSA officials, the new system will include more detailed  information on each project’s MPC, such as the types of green  improvements that will be installed, as well as supporting documentation  that demonstrates exactly how the MPC will be accomplished. Moreover,  the system will include supporting documentation for cases in which a  project was scheduled to meet a MPC, like using renewable energy, but  was unable to do so. Supporting documentation could include such things  as projections, calculations, milestones, constraints, and associated cost- benefit analyses. GSA officials cautioned, however, that energy and  environmental performance is difficult to project accurately and can be  affected by a number of variables beyond GSA’s control, such as tenants’  behavior and changes in a tenant agency’s mission. For example, GSA’s  estimate of energy savings for a building could be based on a tenant’s  expected 13-hour workday, while the tenant’s actual workday might be  longer. Similarly, an agency may need to hire additional staff in order to  respond to an emergency, which would unexpectedly increase energy use.  According to the GSA officials, a design-phase estimate that falls within  about 20 percent of actual performance would be considered “pretty  good.” GSA officials stated that the system will be used to track the  progress of Recovery Act projects until their completion.
According to GSA officials, they have nearly finished developing guidance  for project staff who will use the system. GSA has also begun to train staff,  starting with those with new construction or full and partial building  modernization projects that are far enough along in the design process to  have information on how they will achieve the MPC. To date, six project  managers have been trained in using the system, according to GSA  officials. GSA plans to use a separate training module for managers of  limited-scope projects because less information is required for them than  for new construction and full and partial building modernization projects.  GSA officials have not estimated when all project managers would be  trained. However, these officials said they expect to have preliminary or  high-level data in the system for all projects by the end of July 2010.
section_title: GSA Identifies Risks to Its Program and Risk Mitigation Strategies, but Some Project-Level Risk Plans Are Not Complete
paragraphs: GSA has identified risks to its Recovery Act program and risk mitigation  strategies. GSA’s approach to risk management is generally consistent  with best practices we have developed. GSA focuses on broad risks that  could affect GSA’s ability to address objectives for the agency as a whole,  such as ensuring program goals are achieved and fraud, waste, and abuse  are minimized; stimulating the economy; and improving the environmental  performance of federal buildings. Broadly defined, risk management is a  strategic process for helping policymakers make decisions about assessing  risk and typically involves appraising and evaluating risks to a program or  project and selecting mitigation strategies. In April 2009, GSA developed a  plan to guide risk management efforts for agencywide risks to its Recovery  Act program and developed an initial inventory of those risks. In March  2010, PMO developed a Recovery Risk Mitigation Plan specific to PBS.  This plan identified 48 risks to PBS’s program, 14 of which were  considered key risks, shown in table 8.
This plan also contains assessments of the likelihood and potential impact  of the key risks, identifies mitigation strategies, and establishes  mechanisms for monitoring the risks and mitigation actions. The key risks  are associated with areas such as financial tracking and reporting,  acquisitions, and project management. For example, as indicated in table  8, GSA identified a risk that Recovery Act funds could be used for  unauthorized purposes, limiting GSA’s ability to meet Recovery Act  accountability goals. To mitigate this risk, GSA identified various internal  processes, including national and regional approval of a project’s scope,  multiple levels of review of project expenditures, and a process for  reviewing contractor invoices to ensure services are valid and authorized.  Agency officials told us that internal auditors, as part of GSA’s existing  internal audit program, will test the mitigation actions put in place for the  14 key risks. In addition, they plan to assess and update the key risks on a  monthly basis.
We assessed GSA’s risk management approach against best practices that  we developed in the areas of strategic planning, risk assessment,  evaluation and selection of alternatives for addressing risks, and  implementation and monitoring of risk-mitigation strategies (see table 9).
We found that GSA’s approach generally reflected the best practices in all  four areas noted in table 9. In the area of strategic planning, GSA clearly  identifies Recovery Act goals and objectives as well as GSA program goals  when considering potential risks to the program, such as stimulating the  economy by spending Recovery Act funds quickly and improving the  environmental performance of federal facilities. In addition, in the area of  assessing risks, GSA established a process for documenting its assessment  of risks that allows for updates and results in a qualitative assessment of  the likelihood and potential impact of the risks on its Recovery Act goals  and strategic objectives. Also, for monitoring the implementation of risk  responses, GSA officials said the risk management team holds monthly  meetings with senior officials to review key risks, identify any new risks,  and ensure that proper controls are in place. However, there were areas  where GSA could improve its risk management efforts. For example, in the  area of evaluating and selecting alternatives for addressing risks, GSA had  limited information in its plan and other risk management documents  about its process for evaluating and selecting alternative mitigation  strategies. GSA officials said that many of the mitigation strategies were  put in place before the formal risk assessment was completed as part of  GSA’s planning to implement the program and during ongoing discussions  about risks facing the program. Therefore, a full analysis of potential risk  mitigation alternatives was not completed.
During our review of 12 Recovery Act case study projects, project  management staff told us about some of the key project-level risks that  could affect the success of the projects. Staff at 5 of the 12 case study  projects we examined cited risks associated with the accelerated timelines  imposed by the Recovery Act. Project management staff with whom we  spoke at one case study said the tight timeline imposed by the Recovery  Act was the most serious risk to their project. They said the project faces a  challenge to complete all of the work necessary to achieve its  environmental and energy goals, including completing a study of the  building to identify potential energy-reducing upgrades, working through  the study recommendations for upgrading the building with all of the  stakeholders on the project, and completing the additional design work  related to the selected upgrades. This study must be completed at an  accelerated pace to enable the additional work to be awarded and the  associated funding to be obligated within the Recovery Act’s time frames.  In addition, 8 of the 12 case study project staff with whom we spoke said  that they faced the more typical project risks associated with uncertainty  about aspects of a building that is slated to receive upgrades, such as the  degree of contamination with hazardous material, the absence of building  system and structural drawings, or questions about the drawings’  accuracy. For example, project management staff for one project said that  they had concerns about the accuracy of the as-built drawings—the plans  that detail the construction of the building and other work performed on  the building. These staff noted that if the building needs more structural  work than originally planned, the project’s cost could increase and less  funding might be available for green improvements to the building.
Although GSA has developed a systematic process for identifying and  planning for risks for its Recovery Act program, GSA officials said that to  address project-level risks, such as those we have previously discussed,  they rely on informal communication between headquarters and project  management staff in the regions. Specifically, regional staff discuss  project-level risks or challenges during weekly telephone calls with the  PMO. In addition, GSA officials said they track whether projects are on  budget and on schedule so they can identify when projects are  encountering problems. GSA officials said that because so many projects  are being implemented, it would be difficult for GSA to systematically  assess and respond to individual project risks at the PMO level. In  addition, because of the accelerated pace necessary to implement the  program within Recovery Act deadlines and the additional responsibilities  for regional staff associated with Recovery Act funding, such as new  reporting requirements, GSA officials said they were reluctant to add new  risk management reporting requirements for project management staff.
GSA officials said they rely on project management staff in the regions to  manage project risks and complete risk planning documents that are  required by GSA’s Project Management Guide for the Public Buildings  Service. The guide, issued by the PBS Office of the Chief Architect, is  GSA’s road map for project management and details what project  management staff should do to manage risks at the project level. The guide  discusses two planning documents for projects, the Comprehensive  Project Plan (CPP) and the Project Definition Rating Index (PDRI), both of  which GSA project management staff identified as related to risk planning.  The guide says the CPP ensures efficient and effective project delivery by  articulating project goals and implementation strategies and should be  updated throughout a project to evaluate the success of the plan to date  and to adapt it to changing circumstances. In addition, the guide says the  PDRI provides an objective evaluation of the project at various stages of  its development and its benefits include a more refined definition of the  scope of a project and an assessment of risk. Instructions for filling out the  PDRI say the tool should be updated during the development of the  project, from the preliminary stages to the start of construction. Finally,  OMB’s Capital Programming Guide cites the need for developing and  documenting a systematic plan to address project risk and calls for risk  planning to continue throughout the life of the project.
In September 2009, GSA’s OIG found that the PMO was not requiring full  CPPs for Recovery Act projects and raised concerns about the adequacy of  risk planning at the project level. During our review, we found that 9 of  our 12 case study projects had not fully completed the required risk  planning documents. For example, for 1 project we visited, the CPP had  not been updated since before Recovery Act funding was received and did  not list Recovery Act funding in the section detailing project funding  sources. For 1 project we visited, staff said that although they did not  complete a PDRI, they continually work to identify potential risks and  develop risk mitigation strategies as needed. Some of the project  management staff with whom we spoke for our 12 case studies said they  have regular meetings with regional management about their projects to  discuss potential risks or challenges facing the project. Staff from 1 project  that had not completed GSA’s risk planning documents said they had  completed other documents that were similar. Finally, some project staff  told us that they considered the PDRI a requirement for projects that go  through GSA’s normal project approval process, but that GSA’s Recovery  Act-funded projects were unique and they did not think it was required.  GSA officials said that the PDRI is typically completed during the approval  process for prospectus-level projects, but that Recovery Act projects did  not go through this process to get funding. However, GSA officials from  the PMO said that a CPP was required for all full and partial  modernizations, adding that Recovery Act projects should complete the  risk planning documents called for in the guide. In addition, project  management staff in the regions said that Recovery Act projects are being  implemented at an accelerated pace and that this presents challenges to  the agency. Finally, as we have previously mentioned, OMB’s Capital  Programming Guide calls for risk planning at the project level. OMB’s  guide calls for project managers to develop and document a systematic  approach to risk planning that continuously identifies, assesses, responds  to, and monitors project-level risks, adding that risk management is an  integral part of project management. It is important for GSA to ensure that  risk planning at the project-level meets the agency’s standards, as laid out  in GSA’s guide or other guidance, such as OMB’s Capital Programming  Guide. GSA’s reliance on informal communication channels for overseeing  project-level risks, without ensuring that project-level risks are being  identified and planned for, could result in some vulnerabilities going  unidentified and increase the potential for risks to negatively affect GSA’s  program as projects move from preliminary stages to construction.
section_title: Conclusions
paragraphs: The Recovery Act has provided GSA with an unprecedented opportunity  to repair or restore aging, deteriorating federal buildings and, in so doing,  to enhance their energy and environmental performance. With this  opportunity comes a responsibility to be accountable for how the funds  are spent and to ensure that the projects are successful and the buildings  progress toward becoming high-performance green buildings. GSA has the  opportunity to enhance its accountability by making publicly available  information about the nature of work being performed through its  Recovery Act projects. In addition to knowing which buildings are  receiving funding, this will enable the public to understand how Recovery  Act funding is being used to improve GSA’s buildings. While GSA has made  progress in moving buildings modernized under the Recovery Act toward  high-performance green buildings, by not including criteria for reducing  transportation’s energy and environmental impacts for Recovery Act  projects, GSA’s minimum performance criteria for projects are not in  alignment with the definition of a high-performance green building called  for by the Recovery Act. GSA may also be missing opportunities to include  transportation-related improvements in the projects, where appropriate,  and to track those improvements. Finally, given the accelerated pace at  which many projects are being implemented, taking steps to ensure that  project management staff are systematically addressing risks to the  projects could decrease the potential for risks to negatively affect GSA’s  program as projects move from preliminary stages to construction.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the GSA Administrator take the following three  actions:    Consistent with GSA’s Recovery Act transparency goal of providing the  public with an understanding of how its tax dollars are being spent, make  information on the nature of the work being conducted and its expected  outcome publicly available for each Recovery Act project.
To reduce the environmental and energy impacts of transportation  through site designs that support a full range of transportation choices for  users of buildings, revise the MPC to require that project managers  consider transportation-related improvements for Recovery Act projects,  as appropriate.
To ensure that steps are being taken to identify and plan for project-level  risks, require Recovery Act project management staff to complete risk  planning documents.
section_title: Agency Comments and Our Evaluation
paragraphs: The GSA Administrator provided written comments on a draft of this  report, which are reproduced in appendix IV. The Administrator agreed  with our recommendations and noted that GSA has begun to take action to  implement them. GSA officials also provided technical comments, which  we incorporated as appropriate.
We are sending copies of this report to the appropriate congressional  committees, the GSA Administrator, and other interested parties. In  addition, the report will be available at no charge on GAO’s Web site at  http://www.gao.gov.
If you or your staffs have questions about this report, please contact  Terrell Dorn at (202) 512-2834 or dornt@gao.gov or Mark Gaffigan at   (202) 512-3841 or gaffiganm@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. GAO staff who made key contributions to this report are  listed in appendix V.
section_title: Appendix I: Scope and Methodology
paragraphs: To examine the steps the General Services Administration (GSA) has  taken to implement the program and make its Recovery Act projects  transparent to the public, we collected publicly available supporting  documentation, including GSA’s Recovery Act program plans, spending  plans, weekly financial activity reports, and recipient reported data on the  number of jobs created or retained and funded. In addition, we collected  documentation of GSA’s hiring resources and competitive contract  awards. Furthermore, we collected information on individual project  scopes, master schedules, the factors considered when selecting projects,  and estimates of needed capital improvements in buildings receiving  Recovery Act funds. We also interviewed senior staff from GSA’s Recovery  Act Program Management Office (PMO), including the Recovery  Executive, Directors, Zone Executives, Zone Managers, and subject matter  experts. In addition, we interviewed senior staff from GSA’s Office of  Federal High-Performance Green Buildings (OFHPGB). Specifically, we  discussed GSA’s goals for its Recovery Act program, efforts to identify and  select projects, progress in meeting Recovery Act goals for obligating  funds, and efforts to collect data and report on the program. We also  interviewed and coordinated with officials from the GSA Office of  Inspector General and collected their reports identifying GSA’s Recovery  Act implementation challenges and reviewing specific Recovery Act  projects. Furthermore, we collected a report examining the data quality of  recipient reported data for GSA and several other agencies, which was the  result of coordinated efforts of various Federal Inspectors General and the  Recovery Accountability and Transparency Board.
To determine the extent to which GSA’s Recovery Act projects will help  the agency convert buildings to high-performance green buildings and  meet federal energy and water conservation requirements and goals from  statutes and executive orders, we compared GSA’s minimum performance  criteria with the elements of a high-performance green building as set  forth in the Energy Independence and Security Act (EISA) of 2007. We also  compared GSA’s minimum performance criteria with federal energy and  water conservation requirements and goals from statutes and executive  orders. These include EISA, the Energy Policy Act of 2005, Executive  Orders 13423 and13514, and the Interagency Sustainability Working  Group’s Guiding Principles for Sustainable New Construction and Major  Renovations. Also, we interviewed senior staff and subject matter experts  from the PMO and OFHPGB to determine what information GSA was  collecting with regards to energy and water conservation performance and  what type of system GSA used for gathering this type of information. We  interviewed senior staff and subject matter experts from the PMO and  OFHPGB. Furthermore, we selected 12 GSA Recovery Act projects as case  studies and collected information on the types of improvements being  made to help convert the buildings to high-performance green buildings  and the extent to which the projects are expected to meet future energy  and environmental performance requirements. We selected 12 full and  partial modernizations—since GSA allocated the majority of its Recovery  Act funds to these project categories—on the basis of a number of factors,  including whether the project had been identified by GSA as having  information on its expected performance. In addition, we selected a range  of project types and sizes and projects from various geographic locations.  We did not select any projects from the new construction, limited scope,  or small project categories for our case studies. Because the sample is  judgmental, the information we obtained from them cannot be generalized  to all of GSA’s Recovery Act projects.
We visited 5 of our case study projects, including the following:    26 Federal Plaza, New York, New York;    Birch Bayh U.S. Courthouse, Indianapolis, Indiana;    Mary Switzer Building, Washington, D.C.;    Minton-Capehart Federal Building, Indianapolis, Indiana; and    Thurgood Marshall U.S. Courthouse, New York, New York.
At the remaining 7 case study projects, we spoke with senior staff from the  regions and project managers:    Denver Federal Center Infrastructure, Lakewood, Colorado;    Edith Green-Wyndell Wyatt Federal Building, Portland, Oregon;    Federal Building, Huntington, West Virginia;    Federal Building, Hilo, Hawaii;    G.T. Leland Federal Building, Houston, Texas;    John W. Peck Federal Building, Cincinnati, Ohio; and    Prince Jonah Kuhio Kalanianaole Federal Building Courthouse, Honolulu,  Hawaii.
To determine the extent to which GSA has taken steps to identify potential  risks to its Recovery Act program and and developed strategies to mitigate  those risks, we reviewed supporting documentation, including GSA’s risk  management plan, risk mitigation plan, assessments of identified risks and  mitigation strategies, and GSA’s project management guide for the Public  Buildings Service. We also assessed GSA’s risk management documents  against GAO-developed best practices. Furthermore, we collected  documentation of project-level risk planning efforts from our case study  projects and compared them with the risk planning efforts called for in  GSA’s project management guidance. In addition, we interviewed senior  staff from the Office of the Chief of Financial Officer and the PMO. Finally,  we interviewed managers from our 12 case study projects to discuss  project-specific risks and GSA’s efforts to mitigate them.
We conducted this performance audit from June 2009 to June 2010 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.
section_title: Appendix II: GSA’s Minimum Performance Criteria for Recovery Act Projects
subsections: section_title: Minimum Performance Criteria for New Construction and Full Modernizations
paragraphs: Use an integrated design process to establish performance goals for sustainable design principles and  develop a plan to ensure implementation of high-performance green building goals throughout the  project.
Hire a qualified, independent commissioning agent working for GSA at the beginning of design.
Include commissioning tailored to the size and complexity of the project, including an experienced  commissioning provider from the project initiation through the project closeout.
Use Energy Star Target Finder to set an energy goal that achieves a fossil-fuel reduction of 55 percent  for 2010 design starts.
Achieve at least 30 percent reduction in energy use compared with an American Society of Heating,  Refrigerating and Air-Conditioning Engineers (ASHRAE) Standard 90.1-2007 baseline building.
Install advanced meters. Include meters for electricity, natural gas, steam, and water.
Use Energy Star or Federal Energy Management Program (FEMP)-designated Energy Efficient  Products.
Install solar thermal systems to meet at least 30 percent of the hot water demand. If not life-cycle cost- effective, provide an engineering study and letter of explanation signed by the Regional Recovery  Executive.
Plan for on-site renewable energy systems (photovoltaic, wind, geothermal, and solar thermal/hot  water). If no on-site renewable energy systems are included, provide a letter of explanation signed by  the Regional Recovery Executive.
Assess the effects of solar heat gain based on site conditions and building orientation.
Provide a complete envelope design to include thermal breaks, insulation, continuous air barriers,  external sun control devices, and green roof potential.
Choose glazing systems, including frames, glass, films, and gasses based on visual needs, elevation,  orientation, heat loss, and solar load.
Cooling and heating plants will use a Life Cycle Cost (LCC) methodology (e.g., National Institute of  Standards and Technology Handbook 135) for equipment selection to include lifetime operating costs  based on efficiency, reliability, and maintainability of equipment.  variable frequency drives, high-efficiency chillers and boilers with modular design for part load  efficient operations in HVAC design;  radiant space conditioning and thermal storage systems;  energy recovery ventilators to recover heat from exhaust to preheat outdoor air;  separate HVAC for 24x7 spaces; and  evaporative cooling (direct or indirect) strategies, in suitable climates.
Reduce indoor potable water use by at least 20 percent compared with EPAct 1992, Uniform Plumbing  Code (UPC) 2006, and International Plumbing Code (IPC) 2006.
Reduce outdoor potable water use for irrigation by at least 50 percent compared with conventional  baseline for the building. Smart controllers using evapotranspiration and weather data are required for  irrigation systems.
Evaluate strategies to capture rainwater for nonpotable uses, including flushing fixtures, cooling tower,  and irrigation. Consider harvesting condensation from all cooling coils for nonpotable use. (See GSA  Recovery Act Program Management Office Design Build Guidance Criteria—Water Efficiency  Requirements issued 5/29/2009.)
Evaluate alternative strategies to reduce cooling tower use of potable water. Strategies include the use  of captured rainwater and HVAC condensate recovery.
Manage the 95th percentile rain event on-site through infiltration, reuse, or evapotranspiration.
Strategies include permeable paving, vegetated roofs, or other low-impact development techniques.  Environmental Protection Agency (EPA) guidance is under development.
Where available, use EPA’s WaterSense labeled products—faucets, toilets, urinals, showerheads, and  irrigation controls.
Use high-efficiency fixtures in accordance with new GSA water guidance.
Meter cooling tower water makeup.
Provide occupant lighting controls in accordance with new GSA lighting specifications.
Provide occupancy sensors.
Provide daylight sensors for fixtures within 15 feet of windows.
At a minimum, comply with ASHRAE Standard 55-2004 and ASHRAE Standard 62.1-2007.
Consider moisture control strategies to reduce risk for mold and damaging moisture.
Use demand control ventilation to control indoor air quality.
Use low-emitting building materials.
Follow Sheet Metal and Air Conditioning Contractors’ National Association Indoor Air Quality Guidelines  for Occupied Buildings under Construction.
Flush out space for a minimum of 72 hours.
Select products with lesser or reduced effect on human health and the environment. See  http://www.epa.gov/epp.
Use products with recycled content according to the Comprehensive Procurement Guidelines. See  http://www.epa.gov/cpg/products.
Use products with biobased content according to U.S. Department of Agriculture’s (USDA) BioPreferred  program. See http://www.biopreferred.gov/DesignationltemList.aspx.
Salvage, recycle, or reuse at least 50 percent of construction and demolition waste generated on a  project. Develop a construction waste management plan to quantify material diversion goals and  maximize the materials to be salvaged, recycled, or reused.
Eliminate the use of ozone-depleting compounds where alternative environmentally preferable products  are available.
Use an integrated team to assess conditions, identify areas for improvement, establish performance  goals for sustainable design principles, and develop a plan to ensure implementation of high- performance green building objectives.
Hire a qualified, independent commissioning agent working for GSA at the beginning of design.
Include commissioning tailored to the size and complexity of the project, including an experienced  commissioning provider from the project initiation through 1 year after occupancy.
Recommission the building to determine performance improvement goals.
Target an Energy Star score of 80 or higher.
Achieve at least 20 percent reduction in energy use from the 2003 baseline for the building.
Achieve at least 20 percent reduction in energy use compared with an ASHRAE Standard 90.1-2007           baseline building.
Use Energy Star or FEMP-designated Energy Efficient Products.
Consider renewable energy generation through photovoltaic, building integrated photovoltaic, solar  thermal, and building integrated wind power, when life-cycle cost-effective.
Evaluate lighting in office areas, stairwells, parking garages, exterior parking lots, and mechanical  spaces for redesign in accordance with new GSA lighting specifications.
HVAC retrofits must consider the use of  an LCC methodology (e.g., National Institute of Standards and Technology Handbook 135) for  cooling and heating plant equipment selection to include lifetime operating costs based on  efficiency, reliability, and maintainability of equipment;  variable frequency drives, high efficiency chillers and boilers with modular design for part load  efficient operations;  radiant space conditioning and thermal storage systems;  energy recovery ventilators to recover heat from exhaust to preheat outdoor air;  separate HVAC systems for 24x7 spaces; and  evaporative cooling (direct or indirect) strategies, in suitable climates.
Reduce indoor potable water use by at least 20 percent from the 2003 baseline for the building.
Reduce water use by 20 percent compared with 120 percent of UPC 2006 or IPC 2006 for fixtures  installed after 1994 or 160 percent for fixtures installed before 1994.
Reduce outdoor potable water use for irrigation by at least 50 percent compared with conventional  baseline or compared with 2003 measured baseline for the building. Smart controllers using  evapotranspiration and weather data are required for irrigation systems.
Consider harvesting condensation from cooling coils for nonpotable use.
Evaluate alternative strategies to reduce cooling tower use of potable water. Strategies include  increased cycles of concentration, use of captured rainwater, and systems that treat the water for a  longer use without chemicals.
Manage the 95th percentile rain event on-site through infiltration, reuse or evapotranspiration.
Strategies include permeable paving, vegetated roofs or other low impact development techniques.  EPA guidance is under development.
Where available, use EPA’s WaterSense labeled products - faucets, toilets, urinals, showerheads and  irrigation controls.
Consider fixture retrofits in accordance with new GSA water guidance, including high-efficiency single  or dual flush handles or the installation of automatic flush valves.
Meter cooling tower water makeup.
Provide occupant lighting controls in accordance with new GSA lighting specifications.
Provide occupancy sensors.
Provide daylight sensors for fixtures within 15 feet of windows.
At a minimum, comply with ASHRAE Standard 55-2004 and ASHRAE Standard 62.1-2007.
Use demand control ventilation to enhance indoor air quality.
Consider moisture control strategies to reduce risk for mold and damaging moisture.
Use low-emitting building materials.
Select products with lesser or reduced effect on human health and the environment. See  http://www.epa.gov/epp.
Use products with recycled content according to the Comprehensive Procurement Guidelines. See  http://www.epa.gov/cpg/products.
Use products with bio-based content according to USDA’s BioPreferred program. See  http://www.biopreferred.gov/DesignationltemList.aspx.
Salvage, recycle or reuse at least 50 percent of construction and demolition waste generated on the  project. Develop a construction waste management plan to quantify material diversion goals and  maximize the materials to be salvaged, recycled or reused.
Eliminate the use of ozone depleting compounds where alternative environmentally preferable products  are available.
section_title: Appendix III: Descriptions for 12 Case Studies
subsections: section_title: Project description
paragraphs: The 18-story building contains 510,659  gross square feet, including 199 inside  parking spaces, and houses  approximately 1,200 federal employees.  A comprehensive modernization is  planned for the project.
The modernization will include the replacement and  upgrades to building systems, including the exterior  façade, accessibility, life safety, mechanical, electrical,  elevator, and security.
The overall objective of this project is to  provide a full building modernization of  the Federal Building located at 330 C  Street, SW, in Washington, D.C. This  two-phase major modernization will  replace all major building systems and  includes historic restoration.
The American Recovery and Reinvestment Act (ARRA)  project comprises Phase II of the modernization of the  Mary E. Switzer building. Work items include new HVAC  systems, automatic sprinkler systems where not  currently in place, new emergency generator, new  emergency power distribution system, replacement of  electric branch circuit wiring and selected panel boards,  replacement of aged plumbing equipment and piping,  new Americans with Disabilities Act (ADA)/Uniform  Federal Accessibility Standards water coolers, toilet  room finish restoration and modification, minor exterior  repairs and lighting, selective asbestos abatement,  modifications to C and D Street lobbies, security  modifications, forced pressure (blast) resistance  upgrades, and an additional floor and new  telecommunications backbone.
The Prince Jonah Kuhio Kalanianaole  Federal Building and Courthouse  consists of a nine-story and a five-story  concrete and glass complex built in 1977.  A two-phased, full modernization and  renovation is scheduled for the building.
ARRA funding will be used to fund Phase I of the  project, which includes design for both the courthouse  and federal building and construction for the  courthouse. The building’s HVAC systems will be  upgraded to meet required energy performance  standards, the building’s plumbing and electrical  systems will be upgraded, the building will be renovated  to meet ADA requirements, the building’s elevators will  be improved, the building’s life safety systems will be  improved, the building’s hazardous materials will be  abated, and the interior spaces will be altered to result  in a more modern and efficient facility.
The proposed project is focused on  transforming the Federal Building into a  high-performance green building through  upgrades to the building’s infrastructure.
The project includes upgrades to the HVAC, plumbing,  electrical service, and fire protection systems. New  energy-efficient lighting will be installed. The roof will be  replaced, and windows will be replaced or restored as  needed, resulting in energy savings. The HVAC  improvements will result in improved air quality,  temperature control, and energy efficiency.
The project proposes to transform the  building into a high-performance green  building through improvements to the  building envelope as well as interior  upgrades to the building infrastructure.
The project includes window replacements, energy- efficient HVAC and electrical system upgrades, security  enhancements, fire alarm system replacement, and  sprinkler protection improvements.
The Minton-Capehart Federal Building is  a 636,000 gross square feet office  building that was constructed in 1974.  The scope of this project includes  upgrades to the HVAC system to align  with high-performance green building  goals.
The HVAC upgrades will improve air quality and  temperature control and will significantly reduce energy  consumption. This project will also provide a new fire  alarm system, sprinkler system installation and other fire  protection improvements. Lighting and ceiling in the  building will be upgraded with energy-efficient light  fixtures and occupancy sensors. In addition, electrical  upgrades will be accomplished in support of the HVAC  and fire and life safety upgrades.
The project will upgrade the infrastructure  of the Thurgood Marshall U.S.  Courthouse and extend the useful life of  the asset. The project will also address  life safety and accessibility issues. The  project is a two-phased modernization.  Phase I work includes bulk demolition  and exterior facade work. Phase II work  is discussed in the next column.
ARRA funding will be used for Phase II work, which  includes selective interior demolition and new  mechanical, electrical, plumbing, and architectural work  associated with the mechanical work.
The window system at the 22-story  Leland Federal Building has been leaking  for several years. There are also air  infiltration issues, which make the facility  expensive to heat and cool. The  modernization is two-phased and is  intended to remedy those issues and  create a more comfortable environment  for the building’s tenants. Major tenants  of the building include the Internal  Revenue Service, U.S. Department of  State, Equal Employment Opportunity  Commission, and Social Security  Administration.
Phase I for the project will include some or all of the  following: replacing and upgrading the window systems;  improving and upgrading the outdoor plaza; installing a  new breezeway; making garage improvements,  including a new elevator from tunnel to breezeway;  building exterior repairs and interior upgrades to public  spaces inclusive of finish, ceilings, lighting fixtures, ADA  upgrades, and first-floor upgrades; and will include an  option for significant improvements to the HVAC  system. Phase II of this project includes full HVAC  modernization and advanced lighting controls in the  window zone of the building.
The Federal Building in Huntington is a  seven-story office building containing  94,307 usable square feet, 125,246  rentable square feet, and 138,588 gross  square feet with no parking spaces on a  1.33 acre lot. This seven-story building  was constructed in 1956 and is made of  brick with a polished granite base. The  ARRA project for this building will reduce  energy consumption.
Work on the project will include installing a new high- performance HVAC system, replacing windows, facade  replacement, and installing solar panels on the roof to  generate electricity.
The Hilo Federal Building and Post Office  was built in 1917 and is a two-story  Classical Revival style building. The  building is scheduled to receive a partial  modernization.
Major work to be performed includes a seismic upgrade.  The building’s plumbing and electrical systems will be  upgraded, the building will be altered to meet ADA  requirements; the building’s security and life safety  systems will be improved; and the building’s hazardous  materials will be abated.
The Denver Federal Center in Lakewood,  CO, contains 52 buildings on a 670-acre  site, housing 6,000 employees from 30  federal agencies. The utilities include  13.4 miles of underground fire lines, 11.3  miles of domestic water and drain lines,  8.3 miles of sanitary sewer lines, 25  miles of sidewalks, and 9 miles of roads.  The primary goal of the project is to  provide a reliable utility infrastructure to  service tenant agencies for the next 50  years.
Work on the project will include replacement of the  water systems and sanitary sewer lines, removal of an  inactive gauging station, installation of storm drainage,  and repair of site drainage.
This project will repair and upgrade the  grand plaza on the Lafayette Street side  of 26 Federal Plaza above the  underground parking garage, which is  leaking.
Work on the project will include waterproofing and  replacing the plaza.
section_title: Appendix IV: Comments from the General Services Administration
section_title: Appendix V: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contacts
section_title: Staff Acknowledgments
paragraphs: In addition to the contacts named above, Maria Edelstein, Assistant  Director; Karla Springer, Assistant Director; Daniel Cain; Elizabeth  Eisenstadt; Brandon Haller; John Johnson; Susan Michal-Smith; Ben  Shouse; and Adam Yu made significant contributions to this report.