Federal Real Property: Actions Needed to Improve How Agencies Manage Structures
Published: 2014-01-06T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The federal government's real property portfolio includes land, buildings, and structures. GAO has designated the management of federal real property as high-risk based largely on the management of federal buildings. However, over half of the assets are structures, such as roads, dams, and radio towers. GAO was asked to examine management issues related to structures. This report examines (1) the scale and scope of federally owned or leased structures, (2) how federal agencies track and categorize federal structures, and (3) the extent to which the challenges federal agencies face in managing buildings also apply to structures. GAO analyzed FRPP data on structures managed by federal civilian agencies against federal internal control standards for executive branch agencies and OMB guidelines, visited 24 sites selected to represent a variety of structure types from five civilian federal agencies with high numbers of structures, and interviewed officials from the five agencies, OMB and GSA about FRPP data collection and how agencies manage their structures.
section_title: What GAO Found
paragraphs: In 2012, federal agencies reported to the Federal Real Property Council (FRPC)--an organization comprised of all real property holding federal agencies--that they are responsible for operating over 480,000 federally owned structures. Information about these structures is recorded in the FRPC's Federal Real Property Profile (FRPP), the government's comprehensive database that describes the nature, use, and extent of federal real property. About 176,000 of those structures are operated by civilian federal agencies. The federal government manages a wide variety of structures. Some of these are common across agencies, such as roads and parking structures, while some are more specific to agencies' missions, such as historic structures or particle accelerators.
Agencies take different approaches to defining and inventorying structures making the aggregation of data in the FRPP's database unreliable. Agencies we reviewed defined structures differently leading to inconsistencies in what assets are included in the FRPP, including counting some building-like facilities as structures. We also found that these agencies counted structures differently, provided inaccurate structure location information, and categorized their structures inconsistently, all of which limits the usefulness of the data on structures in the FRPP. Additionally, the agencies we reviewed submitted incorrect information for key data elements, such as the replacement value, annual operating costs, and condition. General Services Administration (GSA) officials who manage the FRPP said that FRPC chose to provide flexibility in the reporting guidance for data on structures to account for the wide diversity in federal structures, but it also aggregates the data as if they were comparable. Even if this data were useful, FRPC reports very little information on structures, and officials at GSA told us that there is low interest in and demand for this information, creating few incentives to improve data reliability. In prior reports, we have stressed the importance of limiting the number of elements to the vital few that are considered essential for producing data for decision making in light of the costs in collecting this data.
Agencies generally face similar challenges in managing structures as they do in managing buildings. Officials from all of the selected agencies stated that most challenges centered on prioritizing resources to maintain structures, disposing of excess structures, and ensuring their safety and security.
section_title: What GAO Recommends
paragraphs: GAO recommends that OMB, in coordination with the FRPC, develop guidance to improve agencies internal controls to produce consistent, accurate and reliable information on their structures. GSA, in coordination with the FRPC, should clarify the definition of structures and assess the feasibility of limiting the data collected on structures submitted to the FRPP. OMB and GSA agreed with the recommendations, and GSA provided an action plan to implement GAO's recommendations.

section_title: Letter
paragraphs: Federal real property management has been on our high-risk list since  2003 due to overreliance on leasing, the presence of unneeded and  underutilized facilities, and security challenges at federal facilities.  Federal agencies have reported to the Federal Real Property Council  (FRPC)—an organization comprised of all real property holding  departments and agencies subject to the Chief Financial Officers Act of  1990—that they are responsible for operating over 480,000 federally- owned structures, such as roads and bridges, railroads, utility systems,  weapons ranges, and monuments and memorials. Although structures  account for more than half of all reported federal real property assets,  FRPC’s attention, including our work, has focused on the management of  buildings more than structures. This may be due to the costs of housing  and protecting federal workers in federal buildings and the potential  private sector value of unneeded buildings.
You asked us to review issues related to how federal agencies manage  structures. This report examines: (1) the scale and scope of federally- owned or leased structures, (2) how federal agencies track and  categorize federal structures, and (3) the extent to which the challenges  federal agencies face in managing buildings also apply to structures.
To address these objectives, we reviewed pertinent laws, regulations,  policies, and other documents related to federal real property  management. We reviewed guidance from the FRPC regarding  structures, including the Guidance for Real Property Inventory Reporting  for the Federal Real Property Profile (FRPP)—the government-wide  database of real property holdings. We obtained FRPP summary data  from fiscal year 2012, the most recent data available, for structures  owned and operated by the federal government. We selected five  agencies for more in-depth review: the Department of Agriculture (USDA),  the Department of Energy (DOE), the Department of the Interior (Interior),  the Department of Transportation (DOT), and the Department of Veterans  Affairs (VA). According to FRPP data, these five agencies were  responsible for 83 percent of the federal structures among federal civilian  agencies. For each of these agencies, we reviewed agency-specific  policies, guidance, and other documents related to structures and  conducted interviews with agency officials about how they manage  structures. We also analyzed information submitted to the fiscal year  2012 version of the FRPP for each of the selected agencies. Using the  most recent FRPP submissions we had at the time for each agency, we  selected a non-probability sample of sites and conducted four site visits  (Los Angeles and San Francisco, California; Chicago, Illinois; and  Washington, D.C.). During our site visits, we viewed structures at 24  locations for our five selected agencies. We selected these sites and  locations to obtain a variety of locations for our selected agencies and  discuss management issues related to different types of structures. We  selected a variety of structures from each agency’s FRPP submission  using factors such as the structure’s type, replacement value, operating  costs, and condition. We compared the FRPP data for those structures  with the agency’s real-property tracking systems and with observations of  the actual structure. We also interviewed local agency officials at each  site. Our findings based on our examination of the selected agencies and  sites are illustrative and do not support generalizations about other  federal agencies or properties. See appendix I for more detailed  information on our scope and methodology.
We conducted this performance audit from January 2013 to January 2014  in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: In 2004, the President issued Executive Order 13327 establishing the  FRPC, composed of senior federal real property managers, and  representatives from the Office of Management and Budget (OMB) and  the General Services Administration (GSA), among others. The  executive order required FRPC to work with GSA 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, except when otherwise required for reasons of national  security. To meet this requirement, GSA in coordination with FRPC  established the FRPP and provides guidance to agencies about how to  annually report real property under the custody and control of executive  branch agencies in three categories: land, buildings, and structures.
Agencies are required to annually submit 23 separate data elements to  FRPP for all of their structures. The data elements include basic inventory  data (type, use, size, and location) and other elements (condition,  replacement value, operating costs, congressional district, and historical  status). Some of the FRPP data elements differ for structures as  compared with the data for buildings or land. For example, for measures  of size, which are standard square feet for buildings or acres for land,  agencies should report a unit of measure based on the type of structure  (such as linear feet for canals or lane miles or square yards for roads and  bridges). The FRPC also made some changes to the fiscal year 2013  FRPP guidance related to how agencies collect and report data for  structures. For example, the FRPP will no longer contain information on  mission dependency, will add a new field for repair needs, and will  automatically calculate the condition index using the replacement value  field and the newly created repair needs field.
As we stated in the 2013 update to the High-Risk Series, although some  progress has been made in obtaining data about federal real property, the  government still continues to lack consistent, accurate, and useful data  that could support strategic decision-making about federal real property.  Internal control standards for federal executive branch agencies require  that agencies have relevant, reliable, and timely information for decision- making and external-reporting purposes. OMB guidelines state that  agencies should develop detailed guidance necessary for producing  quality data. Among other things, OMB’s definition of quality ensures that  accurate, reliable, and unbiased information is presented in an accurate,  clear, complete, and unbiased manner. These guidelines state that  agencies should treat information quality as integral to every step in the  creation of that information, from creation, collection, maintenance, and  dissemination. We have also found that consistency means that the data  are sufficiently clear and well-defined to yield similar results in similar  situations. The Government Accountability and Transparency Board,  established in 2011 to provide strategic direction for enhancing  transparency of federal spending data, found that lack of consistent data  creates obstacles to transparency and accountability. In addition, it  determined that consistent data promote more accurate and comparable  data for improved reporting and decision-making. However, we also  found in 2012 that collecting and analyzing data creates costs for federal  agencies as they must direct time and staff resources to this task and  emphasized the importance of limiting the number of measures to the  vital few measures considered essential for producing data for decision- making.
section_title: Agencies Operate a Wide Variety of Structures, Including Structures Specific to Their Missions
paragraphs: In the fiscal year 2012 FRPP, federal agencies reported that they were  responsible for over 480,000 structures. Of the nearly 176,000 structures  that federal civilian agencies were responsible for, about 98 percent were  owned by the federal government and about 2 percent were leased. The  five agencies we selected for our review were responsible for 83 percent  of civilian federal structures. The FRPP categorizes structures into 22  different types. The most commonly reported type was roads and bridges  followed by recreational structures, which include outdoor recreational  structures such as athletic fields and courts, stadiums, golf courses, and  ski slopes.structures as reported by federal civilian agencies.
section_title: Inconsistent Approaches to Tracking Structures and Inaccurate Information May Undermine the Reliability of Nationwide Data on Structures
paragraphs: Agencies take different approaches to defining and inventorying  structures making the aggregation of data in the FRPP’s database  unreliable. Agencies we reviewed defined structures differently leading to  inconsistencies as to what assets are included in the FRPP, including  counting some building-like facilities as structures. We also found that the  agencies we reviewed counted structures differently, provided inaccurate  location information, and categorized their structures inconsistently, all of  which limits the usefulness of their data on structures in the FRPP.  Additionally, the agencies we reviewed submitted outdated or incorrect  information for key data elements, such as the replacement value, annual  operating costs, and condition. GSA officials that manage FRPP said that  FRPC chose to provide flexibility in the reporting guidance to account for  the wide diversity in federal structures, but the FRPP also aggregates the  data as if they were comparable. Even if this data were useful, FRPC  reports very little of what it collects from agencies and officials at GSA  told us that there is low interest in and demand for information on  structures, a situation that creates few incentives to improve data  reliability. In addition, OMB officials stated that their focus in recent years  has been primarily on buildings relative to structures. In prior reports, we  have stressed the importance of limiting the number of elements to the  vital few that are considered essential for producing data for decision  making in light of the costs of collecting this data.
subsections: section_title: Agencies Define Structures Differently
paragraphs: Agencies we reviewed defined a structure differently when inventorying  their assets. Differing definitions resulted in inconsistent data as different  types of assets were being labeled as structures across agencies (see  table 2). Two of the agencies we reviewed—USDA and DOE—did not  develop a standard definition for a structure. OMB guidelines state that  agencies should develop detailed guidance necessary for producing  reliable, consistent data. GSA real property officials responsible for the  FRPP stated that they, in coordination with FRPC, chose to give agencies  the flexibility to define structures themselves and that FRPP guidance,  therefore, does not define a structure.
For the agencies we reviewed, these different definitions led to the  inconsistent identification of similar structures when aggregated across  agencies, thereby reducing the reliability and accuracy of FRPP data on  structures. For example, VA has created an “other” category that is  different from buildings, land, and structures. This category includes  monuments, statues, and flagpoles—items other agencies report as  structures in FRPP. While this approach may be legitimate for VA  purposes as long as it is applied consistently, it will not create consistent  information government-wide when aggregated in FRPP. Because  USDA and DOE did not define what constituted a structure, the  categorization of structures may vary by installation, resulting in  inconsistent information within the agencies. For example, officials at  DOE’s Lawrence Livermore National Laboratory (LLNL) and the Interior’s  Bureau of Land Management (BLM) Fort Ord National Monument  classified the landscaping at a location as a structure in FRPP.  Conversely, officials at DOE’s Argonne National Laboratory did not  classify landscaping, such as a fountain in front of a building, as a  structure but considered it part of the building. This approach resulted in  variation within DOE at the installation level, as well as being inconsistent  with the FRPP guidance, which instructs agencies to report landscaping  as a structure under “All Other.”
Some facilities we visited were classified by some agencies as structures,  even though they were similar to buildings (having features such as walls,  roofs, doors, windows, and air-conditioning systems in some cases).  Figure 2 shows some of these examples.
GSA officials also said that different approaches to defining structures are  legitimate under the guidance, but agreed that best practices require a  consistent agency-wide approach. However, as a starting point to ensure  that all agencies have a similar understanding of what constitutes a  structure, the FRPC should update the FRPP guidance to include such a  definition. Until this action occurs, there will be the increased likelihood  that agencies will continue to define structures differently, thus negatively  affecting the reliability of the data being collected.
section_title: Agencies Count Structures Differently
paragraphs: We found that officials, across agencies we reviewed, also counted  structures differently, undermining the accuracy of the number of  structures when totaled nationwide. OMB guidelines state that agencies  should develop detailed guidance necessary for producing reliable,  consistent data.count structures, and GSA officials stated that agencies can use different  approaches as long as they are consistently applied by those agencies.  GSA officials that manage FRPP said that they recognize that flexibility in  the guidance could result in differences in how agencies designate  structures, thereby creating issues with how comparable the data are  across agencies.
FRPP guidance does not instruct agencies on how to  We found inconsistencies in how officials at different agencies for the  sites we visited counted the same types of structures. For example,  officials at the DOE sites we visited aggregated primary roads together  into singular entries in the FRPP, while officials at the DOT sites we  visited generally listed each road as separate entries. We also found that  some officials at the agencies we visited separated features of a structure  into multiple FRPP entries while other officials included all features as a  one-structure entry. For example, at the Interior’s Bureau of Reclamation  (BOR) sites we visited, officials manage large structures, such as power  plants, dams, and canals, generally grouping various portions of the  supporting infrastructure related to a main asset together into a single  entry in the FRPP. Conversely, officials at the FAA sites we visited  generally disaggregated the components of structures into multiple  entries in the FRPP because the agency officials track their expenditures  in multiple systems, and renovations sometimes result in additional  entries. See figure 3 for an example of how agencies count structures  differently.
We found inconsistencies within agencies when counting structures. For  example, Interior officials at the sites we visited would both aggregate and  disaggregate roads. Officials at the BLM site we visited and all four NPS  sites we visited, listed each road separately, while officials at the BOR  sites and one of the Interior’s U.S. Fish and Wildlife Service (FWS) sites  we visited sometimes included roads with related infrastructure, such as  flood control dikes. Similarly, we found that officials at some of the sites  we visited, such as the VA and DOE sites, included all the parts of a utility  system—such as sewage and electrical systems and their components— into one entry, while officials at other sites, such as NPS’s Prince William  Forest Park in Virginia separate out certain parts of utility systems into  multiple entries. Officials from these agencies told us that the decision to  aggregate or disaggregate structures in the FRPP is dependent on how  the assets are being managed. For example, Interior officials said that it  makes sense to combine a road with an asset if it is integral to and  maintained along with that asset. However, this kind of variation  undermines the reliability of both the aggregated agency and FRPP data.
We also found that structures without operation and maintenance costs  may not even be included in some real property databases. For example,  officials at USDA’s Beltsville Agricultural Research Center (BARC) site  said structures that existed before the creation of the FRPP do not appear  in the database unless USDA has spent money to repair or replace them.  As a result, USDA officials estimated that there were many more  structures located at the BARC site, which is over 100 years old, than the  125 structures listed in the FRPP. However, FRPP guidance requires the  inclusion of this information; the FRPP database is intended to be a  comprehensive real property database of real property assets. Without  guidance to ensure a common understanding, agencies will likely  continue to count structures differently thus negatively affecting the  reliability of the information being collected.
section_title: FRPP Is Not Reliable for Identifying or Determining the Location of Structures
paragraphs: Although all of the agencies we reviewed provided location information for  their structures, we found that the location data for several of these  structures were inaccurate, thereby limiting the usefulness of FRPP data.  FRPP guidance requires that location data be included in the database,  but allows agencies flexibility in terms of the specificity used to identify the  location of structures. For example, agencies may use the street  address or the longitude and latitude coordinates. However, the  Standards for Internal Control in the Federal Government and OMB  guidance state that management should put in place control mechanisms  and activities to enable it to enforce its directives and achieve results. In  addition, GAO and OMB guidance state that one such result should be  providing data that are consistent and reliable. At several sites we  visited, local agency officials could not specify the structure using the data  listed in the FRPP database. For example, we found at VA sites that the  local officials could not confirm that the pieces of infrastructure they  showed us related to the sites’ utility systems, such as the power  distribution or water systems, were a part of the structure listed in the  FRPP database. Even in instances where latitude and longitude  coordinates were listed in the database, agencies’ officials had difficulties  finding some structures. For example, local BOR officials at the San Luis  Dam and Reservoir in California could not locate a recreational structure  valued at about $96 million. Although there were specific coordinates  listed in the FRPP for that structure, officials stated that there was nothing  there that could be considered a recreational structure worth that amount.  While local officials were unable to use the FRPP location information to  identify this structure, headquarters agency officials explained that this  structure includes a variety of recreation components, including roads and  other amenities, located within that geographical area and that the  latitude and longitude represented a specific point within that area, not a  specific structure.
At some of the sites we visited, officials told us they had difficulties  determining location for larger structures, such as canals, roads, airport  runways, and irrigation systems, some of which can span several miles  and even cross county and state lines. In these instances, agency  officials told us they measure coordinates at one end or at the center of a  structure, which does not accurately capture the structure’s location. For  example, at one of the BOR sites we visited, officials said they measure  the geographic coordinates at the beginning of canals that can span over  100 miles. Officials from two agencies we reviewed do not use  geographic coordinates to identify structures’ locations and said  measuring the coordinates is too challenging and that there was limited  value for expending resources needed to measure coordinates for  structures that are already known to the local facility managers at their  sites. Instead, officials use a central address for the structures they  manage, which could be a long distance from the actual structure. These  challenges may result in inaccurate location data on structures in the  FRPP.
section_title: Agencies Categorize Structures Differently
paragraphs: We found inconsistencies with how officials categorize structures that  may limit the usefulness of the data. OMB guidelines state that agencies  should develop detailed guidance necessary for producing reliable,  consistent data. As stated above, FRPP guidance categorizes structures  into 22 different types and includes brief descriptions of the types of  structures for each category. The guidance allows similar structures to be  categorized differently. For example, FRPP guidance describes three  different categories for which dams could fit, such as power development  and distribution, reclamation and irrigation, and flood control and  navigation. This categorization means that these dams could be included  in these FRPP categories along with other non-dam structures (such as  power plants, canals, or docks). We found that five different dams in five  locations, all of which served different purposes were categorized  differently in the FRPP database (see fig. 4 below). This makes it even  more difficult to make decisions based upon numbers of structures in the  categories because structures comprise such varied assets, with some  similar type assets, such as dams, reported in different categories.
Officials from sites we visited from three of the five agencies we reviewed  told us that they have difficulty identifying the appropriate category for  structures because the agencies’ structures vary and have unique  characteristics. As a result, these agencies frequently use the FRPP  catchall, “All Other,” category when their structures do not fit within the  other 21 categories; civilian agencies used the “All Other” category  23,294 times in fiscal year 2012 elevating it to the third largest category,  accounting for 13.2 percent of structures listed. For example, during our  site visits, officials showed examples of structures that were categorized  as “All Other” in the FRPP database, such as fences, sidewalks and  paths, observation decks and platforms, lagoons, and signs. These  structures are legitimately reported in the “All Other” category, but the  FRPP database does not allow for further disaggregation limiting the  usefulness of the category for identifying the type of the structure. GSA  officials recognized that that the 22 categories of structures in the FRPP  do not capture the wide variety of different structures agencies operate.  However, the GSA officials said that because of a lack of detail as to what  the agencies include in the “All Other” category, they are unsure of what  category additions or changes they should make. These officials  acknowledged that it would be difficult to develop a comprehensive list of  categories. Wide use of the “All Other” category reduces the usefulness  of FRPP for managing structures by limiting the amount of detail that the  database can have.
section_title: Key Data Elements in FRPP for Structures Are Not Reliable
paragraphs: Key FRPP elements for structures—replacement value, annual operating  costs, and condition—are not reliable because some of the data   GSA  submitted by agencies we reviewed are outdated or incorrect.officials said that while they have taken steps to improve data quality,  they ultimately rely on the agencies, which are required to certify that the  data they transmit to FRPP are complete and reliable. Specifically, GSA  officials said that agency submissions are not altered in any way once  submitted to FRPP, meaning that any inaccuracies originated at the  agency level.
subsections: section_title: Replacement Value
paragraphs: FRPP guidance states that the intent is for agencies to define their own guidance and  regulations for implementing the replacement value formula found in the guidance. It also  states that GSA and DOD have published cost guidance that can be used by other  agencies. Officials from DOT and local officials from one USDA site we visited told us they  use the DOD’s Facilities Pricing Guide for estimating the replacement value for certain  structures. achieve results. GAO and OMB guidance state that one such result  should be providing data that are consistent and reliable. Without this  guidance, agencies cannot ensure that they are collecting and reporting  consistent and reliable data on their structures internally, data that are  then submitted to FRPP. For example, officials told us that replacement  values in the FRPP seemed too high or too low, and other officials told us  the replacement value did not match or come close to matching the  replacement value listed in agencies’ own property-management  databases (see fig. 5). However, because local agency officials were  often not the ones entering data into the agencies’ real property  databases or entering the data into the FRPP database, they could not  explain why there were differences between FRPP and their agency’s  own property databases for these structures.
To calculate the replacement value for all structures annually as required  by FRPP guidance, the agencies we reviewed reported using a number of  different methods, including adjusting cost models designed for buildings  to structures, escalating the original cost of constructing structures, and  relying on estimates made by local officials and experts. While there are  cost-estimating models available for calculating the replacement value of  a building, there are no standard estimation methods available for all  types of structures. Officials from Interior, VA, and DOE said that the lack  of standard cost-estimating models for structures makes it more  challenging and could introduce variation into the estimates as agencies  develop their own models.
Although the agencies we reviewed identified annual operating costs for  structures as required by FRPP guidance, we found that these costs were  not always accurate, thereby reducing the consistency and reliability of  FRPP data. As stated earlier, the Standards for Internal Control in the  Federal Government and OMB guidance state that management should  put in place control mechanisms and activities to enable it to enforce its  directives and achieve results. In addition, GAO and OMB guidance state  that one such result should be providing data that are consistent and  reliable. Officials from one USDA site we visited said that none of the  annual operating costs listed in the FRPP are accurate because the  calculation is based on a standard formula of 1 percent of the  replacement value, which does not reflect the structures’ true costs.  USDA officials agreed that their approach to calculating the operating  costs did not produce accurate results at the individual structure level, but  they said that USDA does not have the capacity to collect operating cost  data for individual structures. Although FRPP guidance does not address  the issue, GSA officials recognize that agencies must estimate the  operating costs if they do not have the capacity to track operating costs  for individual structures. We also found instances where local officials at  sites we visited told us the annual operating costs listed in the FRPP are  inaccurate. For example, officials at several of the sites we visited could  not explain why some structures had zero operating costs listed in the  FRPP or why some of the FRPP listed costs were higher compared to the  amount of maintenance performed related to the structure. However,  headquarters officials with VA said that structures listed as having zero  operating costs, such as the committal shelter at the Quantico (VA)  National Cemetery shown in Figure 6, are included in the operating costs  under the associated building or land entries in FRPP.
Additionally, we found that some agencies reported the costs of  structures operated and maintained by other entities. For example,  officials at the BOR sites we visited in Arizona and California reported  annual operating costs of $1.9 million and $3.8 million attributed to the  Mark Wilmer Pumping Plant and the Delta-Mendota Canal, which  includes the Tracy C.W. “Bill” Jones Pumping Plant. However, these two  assets are fully managed and operated by state and district entities and  are fully funded from the revenues generated from the sale of water and  electricity. Interior officials told us these costs are to be reported because,  as a term-limited management agreement, future responsibility for  maintenance is still a federal liability, and the FRPP guidance instructs  agencies to report annual operating costs for structures managed by  other entities. However, the actual costs paid by the federal government  on an annual basis may be overestimated in the FRPP, because  according to local Interior officials, a portion of those costs are paid from  revenues collected by the state and district entities. We also found that  USDA reported the annual operating costs for a bullet trap on a weapons  range located at BARC, but the bullet trap is fully maintained and  operated by a separate federal entity. USDA officials said that they were  following FRPP guidance as they understood it.
Officials from the agencies we reviewed also noted that it is often  challenging to calculate annual operating costs for structures and that  different approaches may be used for different structures within agencies.  For example, agency officials at some sites we visited told us they use  associated costs—such as labor, utilities, and maintenance—to report  annual operating costs. However, officials from DOE and VA sites that we  visited told us that these data can be difficult to calculate at the individual  asset level. Instead, they apportion certain types of costs, such as for  electricity, evenly across certain structures. Different approaches within  agencies undermine the consistency and, consequently, the reliability of  the operating-cost data for these agencies.
section_title: Condition Index
paragraphs: Although the agencies we reviewed reported the condition of their  structures as required by FRPP guidance, the FRPP data on the  condition of these structures were not always accurate. According to  FRPP guidance, condition index is a general measure of the constructed  asset’s condition and is calculated using the ratio of repair needs to the  replacement value. We found numerous examples at the sites we  visited where the listed FRPP condition did not match the observed  condition of the structure. For example, we found a parking lot and a road  at one FAA site that had a condition index listed as zero in the FRPP  (which, according to FRPP guidance, represents the worst possible  condition for the asset), and we found cooling towers at DOE’s LLNL that  had a condition index listed as 100. However, we did not find these  structures to be in the most critical or excellent conditions. Officials from  Interior, VA, and DOE told us they will also sometimes submit zero-dollar  repair needs to FRPP for some of their structures that they no longer use  and may be ultimately disposed of, even though the structure may be in  disrepair, because it allows the agencies to prioritize funds for other  assets. However, this can result in the inaccurate reporting of the  structure’s conditions in the FRPP because the condition index  calculation relies on the amount of repair needs. For example, agency  officials responsible for FRPP data at the FWS’s Don Edwards San  Francisco National Wildlife Refuge calculated the condition index for a  historic cannery as 100, which would indicate the best condition  reportable. However, as shown in figure 7, the condition index of the  structure does not match its true condition. Agency officials told us the  reason the condition is listed as 100 is because they entered zero dollars  needed for repair to free funds for other structures, as this structure is not  open to the public and does not currently serve a purpose on the FWS  property. Also, officials told us if there is no intent to repair or maintain a  structure, there is no reason to spend limited resources to complete a  comprehensive condition assessment. Officials from NPS’s Golden Gate  National Recreation Area told us that a historic battery built for use during  World War I and valued at almost $200 million, had about $450,000 in  deferred maintenance, but we found its condition listed as 100 in the  FRPP. According to officials at USDA’s BARC site, all of the listed  conditions for the structures we viewed at the site were inaccurate. These  officials could not explain why the condition index, calculated by an  independent contractor, was the same for all but one of the structures,  and they agreed these metrics were not reflective of the structures’ true  conditions. As stated above, the FRPC has made changes for 2013 by  having the FRPP automatically calculate the condition index using the  formula stated above as well. While the formula has not changed, the  FRPC has also revised FRPP guidance to require that agencies report all  the repair needs, including the repairs agencies do not plan to make.  OMB staff told us they hope this will prevent agencies from submitting  inflated conditions.
section_title: Incentives to Improve FRPP Data on Structures Are Limited Due to Low Demand for and Utility of the Data
paragraphs: Even if data on federal structures were reliable, FRPC reports very little of  what it collects from agencies. Internal control standards for federal  executive branch agencies require that agencies have relevant  information for decision-making and external-reporting purposes. For  fiscal year 2012, public access to FRPP data are limited to a 23-page,  high-level summary report for all 361,318 federal buildings, 485,866  federal structures, and about 44 million acres of federal land. The high- level summary report includes aggregated data on 5 of the 23 elements  that agencies are required to submit. This raises questions about the  importance of aggregating structures data government-wide. As stated  earlier, in previous reports we have stressed the importance of limiting the  number of elements to the vital few that are considered essential for  producing data for decision making in light of the costs of collecting this  data. This will help agencies focus their limited resources on ensuring that  those vital elements are reliable. In addition, GSA and OMB officials said  there is low interest in and demand for government-wide information  specifically related to structures, resulting in little incentive to make  improvements. They said the majority of requests for information from  users of FRPP data—the administration, the Congress, and the public— are related to buildings, not structures, so they have focused their efforts  at improving and more extensively evaluating FRPP data related to  buildings. Based on conversations we had with OMB staff, FRPP building  data may be of more interest than structures because buildings that are  occupied by federal workers and visited by the public have safety,  security, and resale factors that do not generally exist for structures.
Buildings also can have value to the private sector, making them targets  for sale, while structures are less likely to have commercial value and  (like some federally-owned buildings) could also be located inside a large  federal land area. Figure 8 illustrates how some structures likely have no  private-sector value.
While OMB staff acknowledged that the FRPP’s data on structures have  reliability issues and that there is lower demand for information on  structures compared to buildings, they also said that structures represent  investments of taxpayer money and as such agencies should continue to  track their structures because the data are valuable to agency officials.  Agency officials consistently said that they would continue tracking their  structures even if they did not submit it annually to the FRPP. However,  some agencies might not track the same elements. For example, FAA  officials said that the agency only tracks the congressional district of each  of their structures because it is a required element in the FRPP guidance.
section_title: Agencies Face Similar Challenges in Maintaining, Securing, and Disposing of Structures as They Do for Buildings
paragraphs: We found that agencies generally face similar challenges in managing  structures as they do in managing buildings. All agency officials we spoke  with stated that most challenges centered on prioritizing resources to  maintain structures, ensuring the safety and security of structures, and  disposing of excess structures.
subsections: section_title: Prioritization of Resources for Maintaining Structures Is Difficult
paragraphs: Officials from all the agencies we spoke with stated that prioritizing  resources is their primary challenge to managing structures. For example,  Interior officials stated that their major challenge is to maintain Interior’s  mission critical assets as the current funding levels are less than half of  the minimum they consider necessary to sustain acceptable conditions.  We have previously developed criteria for addressing real property  maintenance backlogs based on National Academy of Sciences reports  on maintenance and repair of federal facilities. Our criteria includes,  among other things, setting priorities among the outcomes to be achieved  from maintenance activities, identifying critical assets to invest in, and  analyzing tradeoffs and optimizing results from competing investments in  maintenance. Interior officials told us they provide department-wide  guidance for capital investment strategies. Following this guidance, for  example, NPS has developed an investment matrix that combines  mission criticality and historic importance with the amount of deferred  maintenance to determine which structures to invest in first. FAA officials  in one FAA region are using their own unique database to determine the  maintenance costs for structures to prevent failure of mission critical  structures that support the national airspace. FAA is currently undertaking  an agency-wide initiative to address their deferred maintenance needs for  these structures.
section_title: Location and Condition of Some Structures Present Security and Safety Challenges
paragraphs: Agency officials at the sites we visited stated some security and safety  challenges were related to the location and condition of structures for  which they were responsible. One of the security concerns mentioned by  some NPS and BLM officials was that some structures were spread out  over the park or other federal land area making it challenging to ensure  their security. For example, the NPS’ Golden Gate National Recreational  Area has over 500 structures spread out over 60 miles around the San  Francisco Bay area, and BLM’s Fort Ord National Monument has 67  structures spread out over 7,200 acres. NPS officials also mentioned that  there are challenges in securing nationally significant structures in  National Parks while encouraging the public to visit those structures and  working to provide a favorable experience during their visit. Other  structures present security and safety challenges different from buildings.  NPS officials stated that some structures may be in rugged terrain, have  multiple points of approach, all making security and safety more  challenging than for buildings where security and safety features can be  built in and access controlled more easily. The BOR’s 117-mile long  Delta-Mendota Canal in California, which provides critical water resources  to southern California, presents a security challenge due to its long length  through sparsely populated areas as well as a safety challenge as parts  of the canal are open to the public (see fig. 9). To mitigate the safety risk  presented by the canal’s swiftly flowing waters, safety lines have been  installed to help people climb out of the canal if they fall in.
section_title: Agencies Have Unneeded Structures, but Uniqueness, Location, and Resources Complicate Disposal
paragraphs: Federal agencies we reviewed have structures that they are not utilizing.  However, agencies struggle to dispose of excess structures. In some  cases, the agencies may just leave the obsolete structures. For example,  many structures at the USDA’s Agricultural Research Service’s Beltsville  research facility in Maryland are no longer used but remain in place on  the 6,700 acre site. Figure 10 shows a water tower on the site that has  been unused for years and that is slowly being recaptured by nature.
section_title: Conclusions
paragraphs: Federal agencies are required to report 23 separate elements for every  one of their structures to FRPP every year, but the data have two types of  reliability problems. First, at the most basic level, some of the data  agencies submit on their structures are incorrect, undermining agencies’  ability to manage their structures and the reliability of the data in FRPP.  Agencies must improve their data quality in accordance with OMB’s  guidelines in order to document performance and support decision  making. Second, even if agencies effectively apply the OMB guidance,  the government-wide data will continue to face reliability problems  because of the flexibility built into FRPP guidance on how agencies track  key elements, such as defining and counting structures. FRPC chose not  to establish a clear definition for structures, but a clear demarcation  between buildings and structures would be useful for ensuring that  FRPP’s data related to buildings are complete and that agencies do not  use the flexibility they have in defining structures to include assets that  are more appropriately considered buildings. Better defining structures  alone, however, will not change the fact that reasonable differences in  how agencies track their structures create inconsistencies when FRPP  data are aggregated government-wide. For vital information, it would be  worth the time, resources, and effort needed to harmonize agency  approaches. However, while agencies need to track structures for their  own purposes, it is unclear if it is necessary to aggregate the information  government-wide. GSA and OMB officials said that demand for structures  information is low, and FRPC only summarizes selected elements of the  data annually, and most of those elements relate to buildings not  structures.
section_title: Recommendations for Executive Action
paragraphs: To better ensure the quality of both the more detailed data that agencies  collect on their structures and the summary information submitted in the  FRPP, we recommend that the Director of OMB, in collaboration with  FRPC, develop guidance to improve agencies’ internal controls to  produce consistent, accurate, and reliable data on their structures.
To better ensure the quality of the data in FRPP and focus agency  resources to consistently account for structures, we recommend that the  Administrator of GSA, in collaboration with the FRPC, take the following  two actions:  Issue guidance to federal agencies clarifying the definition of  structures. This clarification should ensure that building-like structures  are identified as buildings.
Assess the feasibility of limiting the data elements agencies would be  required to submit for structures submitted to the FRPP.
section_title: Agency Comments
paragraphs: We sent a copy of this report to the Director of the Office of Management  and Budget; the Administrator of the General Services Administration;  and the Secretaries of Agriculture, Energy, the Interior, Transportation,  and Veterans Affairs for their review and comment. OMB generally  agreed with our findings and recommendation and made technical  comments, which we incorporated as appropriate. GSA agreed with our  recommendations and provided its action plan for addressing the  recommendations. GSA’s response is reprinted in appendix II. USDA,  DOE, Interior, and VA provided technical comments, which we  incorporated as appropriate. DOT did not have any comments on the  report.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date.  At that time, we will send copies to the Director of the Office  of Management and Budget; the Administrator of the General Services  Administration; and the Secretaries of Agriculture, Energy, the Interior,  Transportation, and Veterans Affairs.  In addition, this report will be  available at no charge on GAO’s website at http://www.gao.gov.
If you or your staff have any questions, please contact me at (202) 512- 2834 or at wised@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 IV.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to determine (1) the scale and scope of federally- owned or leased structures, (2) how federal agencies track and  categorize federal structures, and (3) the extent to which the challenges  the federal agencies face in managing buildings also apply to structures.  To address these objectives, we reviewed pertinent laws, regulations,  policies, and other documents related to federal real property  management. The primary source of government-wide federal real  property information is the Federal Real Property Council’s (FRPC)  Federal Real Property Profile (FRPP). We reviewed guidance from the  FRPC regarding structures, including the Guidance for Real Property  Inventory Reporting for the FRPP. We obtained FRPP summary data  from fiscal years 2010 and 2012, the most recent data available, for  structures owned and operated by the federal government.
We recently reported that the FRPC has not followed data collection  practices that would help them collect FRPP data in a way that is  sufficiently consistent and accurate to make property management  decisions. We recommended that GSA develop a plan to improve FRPP  data. GSA agreed with the recommendation but has not yet finished  implementing it. Nonetheless, we also found that the FRPP can be used  in a general sense to track federal real property. As such, for this report  and a similar report using FRPP data, we have determined that FRPP  data were sufficiently reliable for limited purposes, such as: identifying  agencies within our scope, selecting site visit locations, summarizing  agency-level statistics for structures, and to compare against agency  source data on structures for our selected agencies.
We identified five civilian real property-holding agencies for our review:  the Departments of Agriculture (USDA), Energy (DOE), the Interior  (Interior), Transportation (DOT), and Veterans Affairs (VA). On the basis  of the latest FRPP summary data for federal structures available, these  five agencies reported being responsible for approximately 83 percent of  all federal civilian structures. We used the following criteria to select these  agencies as reported to the FRPC for inclusion in the FRPP: number of  structures, diversity in types of structures, and high replacement value  and operations and maintenance costs. These agencies gave us a  diverse array of structures to review, a high reported dollar value for  replacement value (a reported combined $5.9 billion of operating costs  per year) and annual operating costs and a mix of challenges, such as  sensitive security or critical systems used in operating a large hospital.  We excluded the Department of Defense (DOD) agencies because GAO  has completed other engagements focused exclusively on DOD real  property. We excluded the Department of State as most of its real  property holdings, including structures, are outside of the United States.  We excluded the Department of Homeland Security, an agency that is  responsible for more structures than DOE or VA, from our agency  selection as some structures could be security sensitive and we  determined that our other selected agencies had a good representation of  the different kinds of structures in the FRPP.
To determine to the scale and scope of federal structures, we obtained  and analyzed FRPP data submissions and other real property data from  the five selected agencies; interviewed real property officers at these  agencies; visited sites where the agencies had structures; interviewed  Office of Management and Budget and General Services Administration  staff about the FRPP data for structures; and reviewed FRPC guidance  and other documents related to the agencies’ real property data and the  FRPP database. We obtained the agencies’ FRPP data submissions for  structures for fiscal year 2012. In addition, for select data elements and  for structures we saw during our site visits, we obtained real property data  for structures from the source databases that each agency uses to  generate its annual FRPP submissions. We obtained source system data  to compare what was in the FRPP against the data that were in the  agency’s own databases for those structures. As we have determined in  prior reports on FRPP data, FRPP submissions can only be changed by  the agency submitting the data. As a result, we believe that the FRPP  submissions obtained from the agencies match the data contained in the  FRPP database. In addition, for select data elements, we obtained real  property data from the source databases that each agency uses to  generate its annual FRPP submissions. We obtained source system data  to get information on description, replacement value, operational costs,  location, and condition of selected structures.
We posed questions to senior real property officers at the five agencies  about their processes for collecting and calculating data for structures. To  gather detailed examples of structures and to learn about the processes  by which data on such properties are collected or calculated and then  submitted to the FRPP database, we visited sites where the five agencies  we selected had structures. We selected these sites using information  from the agencies’ FRPP submissions. Using the most recent FRPP  submissions we had at the time for each agency, we selected a non- probability sample of sites. Because this is a non-probability sample,  observations made at these site visits do not support generalizations  about other properties described in the FRPP database or about the  characteristics or limitations of other agencies’ real property data for  structures. Rather, the observations made during the site visits provided  specific, detailed examples of issues that were described by agency  officials regarding the way agencies collect and calculate data for  structures. We focused on sites clustered around four cities: Washington,  D.C.; Chicago, Illinois; Los Angeles, California; and San Francisco,  California. This strategy afforded both geographic diversity and balance  among our selected agencies while also accommodating time and  resource constraints. In selecting sites and buildings in and around these  four cities, we took into account the following factors:
We prioritized sites that had multiple selected agency sites where a  high concentration of structures was present. This allowed us to see  more properties in a limited amount of time.
We prioritized the selection of as many different types of structures  (as defined in the FRPP) as possible.
We also selected sites with high replacement values, high operations  and maintenance costs, exceptionally low replacement values or  operations and maintenance costs, those reported to be in good and  poor condition, and structures registered as historic.
We visited at least two sites for each selected agency across our four  site-visit areas. In all, we selected 24 sites. Whereas we selected sites  based in large part on the numbers and kinds of structures present, the  structures we saw at each site depended on additional factors. At some  sites, there were too many structures to see them all, given our limited  time at each site. In those circumstances, we prioritized structures that  were close to one another to see as many structures as we could in the  time we had, those structures with high or exceptionally low reported  replacement values or high operation and maintenance costs, and  different structure types as classified by the agency in FRPP. At several  sites, local real property officials identified other structures that we toured  and analyzed.
Prior to each site visit, we analyzed the FRPP data submissions for the  latest year available, and developed questions about the data  submissions for local property managers. We also contacted the local  property managers to answer those questions and to solidify the exact  structures we would see at each location. During our site visits, we  interviewed local property managers and compared what we observed at  each structure with the FRPP data for that structure, and we took  photographs of the structures. In addition to questions about individual  properties, we questioned the local officials about the kind of data they  collect on the properties, how they collect that data, and how that data  differed from the FRPP data we had for the structures at the location.
To identify the challenges facing federal agencies in managing structures,  we analyzed agency property management reports, strategic plans, and  FRPP reports along with statements from agency officials both at agency  headquarters and at sites we visited about their challenges. We  compared these challenges to those we had identified in our reports  about federal real-property management challenges for buildings to  determine how similar the agency’s challenges for buildings were to those  for managing structures.
We conducted this performance audit from January 2013 to January 2014  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
section_title: Appendix II: Comments from the General Services Administration
section_title: Appendix III: Full Text for Figure 3 on How Agencies Aggregate and Disaggregate Structures in FRPP
section_title: Appendix IV: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the named contact above, Keith Cunningham (Assistant  Director), Melissa Bodeau, Anthony Costulas, Anne Doré, Kathleen  Gilhooly, Greg Hanna, Robert Heilman, Joshua Ormond, Sara Ann  Moessbauer, and Sandra Sokol made key contributions to this report.