Federal Real Property: Improved Data Needed to Strategically Manage Historic Buildings, Address Multiple Challenges
Published: 2012-12-11T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: The federal government has made some progress addressing previously identified issues with managing federal real property. This includes establishing the Federal Real Property Council (FRPC) and creating the FRPP database to identify and report agencies' real property, including attributes such as historic status. GAO was asked to assess issues related to historic preservation at nondefense agencies. GAO's review focused on-- GSA, NPS, and VA--three nondefense agencies that hold significant numbers of historic buildings. This report identifies (1) actions these agencies have taken to manage historic federal buildings, and (2) any challenges they have faced. GAO selected and visited a sample of 31 historic buildings managed by the three agencies. The results of these site visits cannot be generalized but provide important insights. GAO interviewed agency officials and reviewed agencies' efforts to preserve, use or lease, and improve the sustainable performance of those buildings. GAO also interviewed officials from the selected agencies about their agencies' preservation programs, including actions to identify and report on their historic buildings.
section_title: What GAO Found
paragraphs: The General Services Administration (GSA), the National Park Service (NPS), and the Department of Veterans Affairs (VA) have undertaken portfolio-wide efforts in recent years to identify historic buildings they hold, nominate some of those buildings to the National Register of Historic Places, and manage their historic buildings in an effort to comply with the requirements in the National Historic Preservation Act (NHPA) and relevant executive orders. While these agencies use and preserve some of their historic buildings to meet mission needs, others are excess or unsuited for current mission needs. GAO found several instances in which these agencies leased part or all of some historic buildings to non-federal entities that could use and preserve the buildings. GAO also found that these agencies had implemented projects in some of their historic buildings to improve their sustainable performance, such as installing green roofs and energy-efficient heating and cooling systems.
GSA, NPS, and VA face an array of challenges in managing historic buildings, including functional limitations of older buildings in relation to contemporary mission needs and current building codes, budgetary limitations, and competing stakeholder interests. Competing stakeholder interest can become apparent during the required consultation with stakeholders, such as the state historic preservation officers, prior to implementing projects that may affect a historic building. Compounding these property management challenges, the selected agencies' data on historic buildings in the Federal Real Property Profile (FRPP) are not complete. GSA and VA are still working to evaluate many buildings that are over 50 years old. Also, GSA and NPS have not reported complete and consistent historic-building data to the FRPP--in comparison to data they track within their agencies' historic-building databases. GAO reported its concerns with the reliability of FRPP data in 2012. This review emphasizes the relevance of these concerns to the historic-building data included in the database. In June 2012, GAO recommended improvements to the FRPP database to enhance its consistency, completeness, and usefulness in federal decision making. Such improvements are also necessary to increase the consistency and completeness of historic-building data in the FRPP.
section_title: What GAO Recommends
paragraphs: GSA--in collaboration and consultation with NPS, VA, and FRPC member agencies, and others--should ensure that the action plan being developed to improve FRPP also addresses the need for improved data on historic buildings. GSA agreed with GAO's recommendation and further reported that it has, in part, already taken action to rectify inconsistencies GAO found between GSA's FRPP data and its internal data sources.

section_title: Letter
paragraphs: The federal government’s real property portfolio is vast and diverse,  including almost 400,000 buildings that are owned or leased. Thousands  of these buildings have been recognized as historically significant. The  National Historic Preservation Act of 1966 (NHPA), as amended requires  agencies to establish a preservation program to identify, evaluate, and  nominate historic federal buildings to the National Register of Historic  Places (National Register) and manage those buildings in a manner that  considers their historic character. As federal buildings continue to age  and become eligible for historic designation, agencies will increasingly  face decisions about balancing preservation with the best use, which may  include leasing or selling these assets.
Historic preservation is one of many challenges federal agencies face in  the area of real property management. We have designated federal real  property management as a high-risk area. In 2007 we reported that  federal agencies have large backlogs of deferred maintenance, and we  highlighted the deteriorated conditions of some federal buildings,  including some that were historic. Other management problems affect  both historic and non-historic buildings, and have included, for example,  issues pertaining to the use and disposition of underutilized and excess  property, over-reliance on costly leasing, and unreliable real property  data. Over the last decade, the federal government has taken steps to  manage this area more strategically, including developing the Federal  Real Property Profile (FRPP)—a government-wide database—and  establishing the Federal Real Property Council (FRPC). These efforts  notwithstanding, challenges to federal real property management persist.  For example, as we reported in 2007, competing stakeholder interests— such as those of historic building advocates and local communities—can  present obstacles to disposing of real property, including historic  buildings. Various versions of the Civilian Property Realignment Act are  pending in Congress and are aimed at, among other things, disposing of  and consolidating civilian real property.
You requested that we assess issues related to historic preservation at  non-defense agencies. In response, we focused on three non-defense  agencies that hold significant numbers of historic buildings—the General  Services Administration (GSA), the Department of the Interior’s National  Park Service (NPS), and the Department of Veterans Affairs (VA). Our  objectives were to identify (1) actions these agencies have taken to  manage historic federal buildings, and (2) any challenges they have  faced.
To address our objectives, we reviewed relevant laws, regulations, and  executive orders governing how agencies should identify, report on, and  manage the historic buildings in their portfolios. Not only do GSA’s, NPS’s  and VA’s portfolios include significant numbers of historic buildings, but  these agencies also include a diverse range of building types, such as,  office buildings, courthouses, park facilities, museums, and hospitals. We  interviewed agency officials about their historic preservation programs  and obtained and analyzed related agency documents. To gather detailed  examples of agencies’ historic preservation efforts, we visited a non- probability sample of 31 federal historic buildings in five metropolitan  areas: (1) Boston, Massachusetts; (2) Washington, D.C.-Baltimore,  Maryland; (3) Chicago, Illinois; (4) Milwaukee, Wisconsin; and (5) San  Francisco, California. We selected buildings based on input received from  agency officials, the Advisory Council on Historic Preservation (ACHP),  state historic preservation officers, and our own judgment. This approach  yielded a diverse group of buildings in terms of use, age, size, and  condition that provided illustrative examples of the agencies’ broader  policy initiatives. We reviewed agencies’ documentation on recent,  current, or planned efforts to manage these historic buildings. We also  gathered and analyzed agency data on historic buildings, including data  reported by these agencies to government-wide data sources such as  FRPP, the National Register, and the ACHP’s triennial Preserve America  reports. Appendix I provides a more detailed description of our scope  and methodology. Appendix II provides a list of the 31 buildings where we  conducted site visits.
We conducted this performance audit from November 2011 to December  2012 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: The federal government’s real property portfolio reflects the diversity of  agencies’ missions and includes a variety of building types, such as office  buildings, courthouses, post offices, hospitals, prisons, laboratories,  border stations, and park facilities. That portfolio includes many historic  buildings held by GSA, NPS, and VA. GSA and NPS’s real property  policies place an emphasis on historic building stewardship. GSA serves  as broker and property manager for many civilian federal agencies while  NPS manages the nation’s national park system for current and future  generations. GSA established its “Legacy Vision” in 2002 as a strategy  for meeting its federal historic stewardship responsibilities and declared  a policy preference for using, preserving, and leasing historic buildings.  Similarly, in providing for the stewardship of the nation’s cultural  resources, NPS reinforced its commitment and goal to preserve historic  buildings in its 2011 Call to Action: Preparing for a Second Century of  Stewardship and Engagement. VA’s core mission is to provide care and  services to the nation’s veterans. While hospital buildings, some of which  are historic, are critical to providing healthcare services, VA began to  realign its real property portfolio in 2004 to better respond to the  demographic shifts and evolving needs of both its older and younger  veteran populations. As VA realigns its portfolio, it has determined many  of its historic buildings are not suitable to support modern healthcare  delivery and are now inactive or excess to VA’s needs.
In NHPA, Congress expressed concern that historic properties significant  to the nation’s heritage—which include both public and privately owned  buildings—were being lost or substantially altered. Thus, NHPA  authorized the Secretary of the Department of the Interior to maintain and  expand the National Register as a means of identifying historic  properties, including those owned by the federal government, and  NHPA requires federal agencies to identify and nominate their historic  properties to the National Register. The National Register is comprised  of many different types of historic properties to include historic districts,  sites, buildings, structures (such as a bridge), and objects (such as a  fountain) that are significant to American history, architecture,  archaeology, engineering, and culture. A building is generally not  eligible for National Register listing until it is at least 50 years old, unless  its historic significance is considered exceptional. While many federal  buildings are historic because of the passage of time and a corresponding  recognition of their historical or architectural significance locally or  regionally, a smaller subset are treasured assets considered significant to  the nation’s history. In recognition of this, the National Register also  includes buildings meeting the criteria for a national historic landmark.  National historic landmarks are designated by the Secretary of the Interior  as possessing exceptional value or quality in representing the heritage of  the nation. The NPS reports that public and privately held national  historic landmarks constitute more than 2,400 of almost 87,000 “entries”  (i.e., listings) in the National Register (nearly 3 percent).
Other statutory and regulatory provisions also govern agencies’  stewardship of their historic buildings. For example, agencies are required  to: (1) assume responsibility for the preservation of their historic  properties; (2) consider, when a historic property is no longer needed,  alternative uses or lease to persons or organizations if the action will  preserve the property; and (3) consult with ACHP and non-federal  stakeholders, such as state and tribal historic preservation officers,  before undertaking actions that may affect a historic property listed or  eligible for listing on the National Register. NHPA does not mandate a  particular governmental decision, but instead mandates a particular  process for reaching decisions.
The Secretary of the Interior’s Standards and Guidelines for Federal  Agency Historic Preservation Programs indicate that where it is not  feasible to maintain a historic building or to rehabilitate it for contemporary  use, an agency may decide to modify it in ways that are inconsistent with  the Secretary’s treatment standards, limit maintenance and repair  investments in the building, or demolish it. Such a decision can be  reached only after following appropriate consultation with stakeholders as  required by NHPA. Federal historic buildings that are declared surplus  may be made available for other uses, such as a public benefit  conveyance. Under the public benefit conveyance program, state or local  governments and certain tax-exempt nonprofit organizations can obtain  surplus federal real property, including historic buildings, for an approved  public benefit use, such as for educational facilities or to assist the  homeless. Additionally, property declared excess to the federal  government’s need may be sold. Certain land-holding agencies have  independent authority to sell real property.
In addition to NHPA and other statutory and regulatory provisions, several  Executive Orders also provide guidance for the management of federal  historic buildings.    Executive Order 13287, Preserve America, sets forth federal historic  stewardship requirements, including, requiring executive agencies to  report to ACHP on their efforts to identify, protect, and use historic  federal properties, which include historic federal buildings. In fiscal  year 2011, GSA reported to ACHP that more than one-third of the  1,676 federally-owned buildings under its custody and control  are  more than 50 years old and 479 buildings are listed on or eligible for  the National Register. In fiscal year 2011, NPS reported to ACHP that  it held historic properties totaling 26,636 buildings and structures (out  of more than 70,000 real property assets). It further indicated that  among these historic properties, 1,482 are listed on the National  Register. In fiscal year 2011, VA did not provide to ACHP a reporting  of the number of historic buildings that it owns or has listed on the  National Register.    Executive Order 13514, Federal Leadership in Environmental,  Energy, and Economic Performance, requires agencies to ensure,  among other things, that new construction, major renovations, repairs,  and alterations of federal buildings comply with the Guiding Principles  for Federal Leadership in High Performance and Sustainable Building  (Guiding Principles), such as optimizing energy performance and  conserving water. Also, agencies should ensure, when rehabilitating  historic buildings, that sustainable technologies (to achieve energy  and environmental conservation goals) are used to promote the long- term viability of the buildings. We have reported that the Office of  Management and Budget (OMB) has incorporated information about  agencies’ progress in implementing those green building requirements  into scorecards that OMB uses to rate agencies’ performance, but that  agencies face challenges.    Executive Order 13327, Federal Real Property Asset Management,  requires GSA to collect data from executive branch agencies  describing the nature, extent, and use of federal real property. The  data are reported within FRPP and include data on the historic status  of federal buildings and other data, such as a building’s condition and  if the building meets the Guiding Principles. The FRPP is maintained  by GSA on behalf of FRPC. The FRPP database includes  approximately 400,000 buildings that are owned and leased by the  federal government, many thousands of which have been determined  to be historically significant. GSA releases a summary level FRPP  report each fiscal year to provide an overview of the federal  government’s real property, but those reports do not identify how  many historic federal buildings are held by individual agencies or the  executive branch as a whole.
GSA and FRPC require agencies to update their FRPP data on a fiscal  year basis. FRPP guidance to agencies on coding historic status  indicates agencies should code their federally owned buildings within  FRPP as one of the following:    national historic landmark,    National Register listed,    National Register eligible,    non-contributing element of a national historic landmark/National    not evaluated, and    evaluated, not historic.
section_title: GSA, NPS, and VA Are Taking Action to Manage Their Historic Buildings
paragraphs: The three agencies we reviewed are taking steps to improve the  management of their historic buildings. For example, all three agencies  have undertaken portfolio-wide management initiatives directed at  nominating historic buildings in their portfolios to the National Register as  required by NHPA. In addition, among the buildings we reviewed, we  found examples where agencies were utilizing their historic buildings to  the extent feasible for current mission needs. We also found that when  the buildings were no longer suitable for current mission purposes,  agencies were leasing all or part of some historic buildings to non-federal  entities, as authorized by NHPA and other real property authorities.  Also, we found that GSA, NPS, and VA were implementing projects in  some historic buildings to improve their sustainable performance.
subsections: section_title: Portfolio-Wide Management Efforts
paragraphs: All three agencies have undertaken efforts in recent years to identify the  historic buildings across their real property portfolios, nominate those  buildings to the National Register, and are working to manage those  buildings in an effort to comply with the requirements of NHPA and the  executive orders. For example, GSA started a multiyear initiative in 2004  to assess many of its older buildings that it believed were eligible for  listing on the National Register. GSA officials reported this effort is  nearing completion and has resulted in National Register nominations for  more than 150 buildings. In particular, GSA evaluated the National  Register eligibility for all of its legacy monumental buildings as part of this  effort. These include buildings such as courthouses, post offices, and  agency headquarters, which were designed to serve symbolic,  ceremonial, and functional purposes. In addition, GSA’s “Legacy Vision”  policy in 2002 laid the groundwork for the agency’s current stewardship  efforts that are focused on the preservation, use, and disposal of historic  buildings, as appropriate. GSA also used American Recovery and  Reinvestment Act of 2009 (Recovery Act) funding to rehabilitate and  modernize 150 of its historic buildings. These projects were intended to  address GSA’s historic building repair and alterations backlog and ranged  from comprehensive modernizations of entire buildings, such as the  Federal Building at 50 United Nations Plaza in San Francisco, California,  to limited scope sustainability projects such as the roof replacement  project at the Milwaukee Federal Building and Courthouse in Wisconsin.
Similarly, NPS implemented an agreement with ACHP to address NHPA  compliance and streamline consultation for its projects at national parks  nationwide. NPS also recently completed its first 5-year cycle of  comprehensive condition assessments on what NPS termed as a critical  subset of its buildings that included accessibility assessments to identify  barriers to disabled persons. This information will be used to prioritize  preservation and improvement of its historic buildings, among others, and  help ensure compliance with federal accessibility requirements. In  addition, NPS published The Secretary of the Interior’s Standards for  Rehabilitation and Illustrated Guidelines on Sustainability for  Rehabilitating Historic Buildings in 2011, which, for example, outlined  approaches for improving the energy efficiency of historic buildings while  preserving their historical character.
To enhance the management of its portfolio of historic buildings, VA  began two multi-year national studies of 90 of its medical centers that  resulted, as of April 2012, in 45 in-process or recently completed National  Register district nominations. In addition, five individual medical center  National Register nominations not associated with these studies were  completed and four VA campuses were designated national historic  landmarks in the last 3 years. Further, VA recently updated its policies  and procedures governing historic preservation including identifying and  evaluating historic properties, and complying with various historic  preservation laws and regulations. In 2011, VA also completed a review  and identified unused and underused buildings—many of which are  historic—with the potential to develop, through public-private  partnerships, affordable housing for homeless or at-risk veterans and  their families. VA has also developed training on NHPA requirements for  VA field staff. This training, for example, focuses on the need to consult  with stakeholders such as the ACHP and state historic preservation  officers as required by NHPA and its implementing regulations.
section_title: Agencies’ Approaches to Manage Historic Buildings
paragraphs: Among the buildings we reviewed, we found examples where GSA, NPS,  and VA preserved, used, and adapted historic buildings to meet their  current mission needs. When historic buildings were either excess or  unsuited for mission needs, we found several instances in which agencies  leased part or all of a building to a non-federal entity that could use the  building while preserving its historic character. As noted previously, these  cases provide useful insights into agency actions related to historic  preservation but are not generalizable to agencies’ actions across their  historic building portfolios or across the government. Among the 31  historic buildings we reviewed, we found:    20 buildings that were used by the federal government;    5 buildings that were used, in part, by federal agencies while some  space was leased within those buildings—or used under a  cooperative agreement—by non-federal entities;    4 buildings that were leased in their entirety to non-federal entities;    2 buildings that were vacant.
Continued use of historic buildings to meet mission needs often involves  balancing the need to modernize building systems, such as mechanical  systems, while preserving historical features. For example, in its  renovation of the Stewart Udall Building in Washington, D.C. (Department  of the Interior headquarters), GSA installed fire-rated emergency egress  stairs within office space that is not historically significant in a manner that  preserved the building’s historic corridors. In another example, GSA  repaired and restored nearly 500 historic wooden windows in the  Milwaukee Federal Building and U.S. Courthouse—built in 1899—in  Wisconsin, while also retrofitting the window frames with modern  insulated glass. Figure 1 shows a representative window before the  rehabilitation (left), a window after the rehabilitation (center photos), and  an exterior view of the building (right).
Among the buildings we reviewed, we found examples where agencies  sought to lease historic buildings that were not used for mission needs to  non-federal entities that could fund their preservation, maintenance, and  repair, and use them in ways that were sometimes supportive of the  agency’s mission. As previously mentioned, the selected agencies were  leasing out either all or part of 9 of the 31 historic buildings we reviewed.  For example, when the Golden Gate National Recreation Area was  created in 1972 in California, a number of Department of Defense  installations were transferred to NPS, including Fort Mason. Through a  public-private partnership, NPS has leased the 100-year old Pier #2 Shed  at Fort Mason—a former military warehouse that served as an  embarkation point for the U.S. Army during World War II—to a non-profit  group that facilitates performing arts events within the building, thus  providing a cultural resource to the public consistent with NPS’s mission.  See figure 2.
When a federally owned historic building becomes underutilized because  it no longer serves mission needs, agencies may sell a building or  exchange it for comparable historic property so long as the exchange will  ensure the preservation of the historic property. Although the 31  buildings we reviewed did not include any executed sales or exchanges,  at the time of our review, NPS was considering the sale or exchange of  Old City Hall—at Lowell National Historic Park in Lowell,  Massachusetts—which NPS has leased to a commercial bank for more  than 25 years. Outside the 31 historic buildings included in our review,  examples of sales or exchanges of federally owned historic buildings  include a former U.S. Courthouse in Cedar Rapids, Iowa, that was  transferred to the City of Cedar Rapids in 2010 in exchange for a site to  support the construction of a new federal courthouse. In addition, the  building that formerly housed the Immigration and Naturalization Service  in Seattle, Washington, was sold at auction in 2008 for $4.4 million. In a  third example, GSA sold a historic building in Washington, D.C., in 2001  that housed the Clara Barton Apartment and Missing Soldiers Office. The  sale included a preservation easement that provides for the operation of  a museum within the building by a non-profit group to recognize Clara  Barton’s efforts to aid Civil War soldiers.
section_title: Sustainable Performance of Historic Buildings
paragraphs: In addition to efforts to preserve and use historic buildings, we found that  GSA, NPS, and VA were implementing projects in some of the historic  buildings we reviewed to improve the sustainable performance of the  buildings and begin meeting the Guiding Principles, as required by  Executive Order 13514. Because buildings and their sites affect the  natural environment, the economy, and the health of people that use  them, the Guiding Principles established a common strategy for federal  agencies to use for planning, designing, constructing, and operating their  buildings. More specifically, the Guiding Principles address five  performance goals:      optimizing energy performance;  integrating the planning, design and construction process;      enhancing indoor environmental conditions such as air quality; and    reducing water consumption and storm runoff;  reducing the environmental impact of materials used to construct and  operate buildings.
Sustainable projects we observed at some of the buildings we visited  included improved energy-efficient heating and cooling systems, “green”  vegetated and “white” reflective roofs, and window retrofits or  replacements, among others. For example, as part of the modernization  of the federal building located at 10 West Jackson Boulevard in Chicago,  Illinois, GSA is installing energy-saving “daylight harvesting” technology  that automatically adjusts office lighting according to the amount of  natural light entering through the building’s windows. GSA recently  installed both green roof and white reflective roof technologies to reduce  the amount of heat gain and loss through the building’s roof. See figure 3  below.
According to OMB’s January 2012 sustainability scorecards for the  agencies, GSA’s and VA’s efforts to assess and incorporate sustainable  Guiding Principles in their buildings are on track, but Department of the  Interior’s effort is not. While NPS has a Sustainable Buildings  Implementation Plan, agency officials report that they have not assessed  many of their historic buildings to determine if they currently meet the  Guiding Principles. NPS officials told us that their efforts thus far to  comply with the Guiding Principles have focused largely on new  construction projects—such as new visitor centers—or on existing  building rehabilitations rather than on historic buildings where there are  no planned projects. While NPS is not currently on track to meet the  Guiding Principles as assessed by OMB, we found that NPS had  implemented sustainable projects in 9 of 13 NPS buildings we visited and,  in some cases, had conducted energy audits to identify where future  projects could improve the sustainable performance of its historic  buildings.
We discussed the issues faced by federal agencies to make historic  buildings sustainable with three outside experts. Based on our  discussions with those experts—and a review of professional articles  written by those individuals—we found that many historic buildings may  be inherently sustainable. In general, historic buildings built before World  War II often incorporated many sustainable principles, such as orienting a  building for solar efficiency and making effective use of natural light and  ventilation. In addition, generally, the rehabilitation and reuse of a historic  building consumes fewer raw materials and affects the environment to a  lesser degree than constructing a new building of comparable size. All  three experts indicated that NPS has generally been an effective  advocate for disseminating information about incorporating sustainable  improvements in historic buildings. They identified actions—by NPS’s  National Center for Preservation Training and Technology or its Technical  Preservation Services—to make sustainable green building information  available to the preservation community such as NPS’s recently released  technical preservation brief entitled Improving Energy Efficiency in  Historic Buildings. Independent of our discussion with these experts, we  found that GSA and VA have been partnering with NPS as well as other  federal agencies—such as the Department of Energy—to further advance  federal initiatives aimed at improving the sustainability of historic federal  buildings.
section_title: GSA, NPS, and VA Face Challenges in Managing Historic Buildings
paragraphs: The three agencies we reviewed face challenges related to the  functionality of historic buildings, the amount of funding available for  preservation projects, and federal requirements to consult stakeholders  on historic preservation. Maintaining and making historic buildings  functional for contemporary purposes in a constrained budget  environment poses a challenge. Also, competing stakeholder interests  can arise when agencies consult with stakeholders. Compounding these  challenges, agencies are required to identify and report on their historic  buildings and their reported data is not consistent and complete.
subsections: section_title: Functional, Budgetary, and Stakeholder Challenges
paragraphs: Functional and budgetary limitations as well as competing stakeholder  interests have been long-standing challenges in the area of federal real  property management and to agencies’ efforts to preserve historic  buildings. These challenges are significant for the selected agencies  given they have reported that identified historic buildings represent  approximately 25 to 30 percent of their buildings.
Based on our site visits and discussions with agency officials, we found  that the three agencies faced challenges in rehabilitating and modernizing  historic buildings for contemporary use because of age, specific  characteristics of buildings’ original designs, and their particular historical  features. For instance, it can be difficult to address current building codes  in some historic buildings, install modern building systems—particularly  with regard to heating, ventilation, and cooling—and provide access for  disabled persons. For example, NPS officials reported they have not been  able to improve accessibility at the John F. Kennedy house in Brookline,  Massachusetts—which now serves as a museum—as it would adversely  affect the historic character of the building. In lieu of being able to make  accessibility improvements to the John F. Kennedy house’s narrow  hallways and stairwell, NPS officials report they are considering leasing  space in a nearby commercial building to create a new visitor center that  could accommodate visitors with special accessibility needs and provide  additional interpretation exhibits for all visitors.
Similarly, in the case of the Old Grist Mill—built sometime around 1735— at VA’s Perry Point Medical Center in Maryland, installing modern building  systems and making building code improvements—such as adding a  bathroom and a stairwell—will be challenging. VA’s plan to reuse the  building as a training facility will require penetrating some historic beams  and floors. See figure 4 for representative exterior and interior photos of  the Old Grist Mill as it exists today and the proposed design for the  adaptive reuse of building.
We have previously reported on how real property funding limitations— such as funding needed to maintain, repair, and modernize federal  buildings—have been a long-standing challenge for agencies and that  agencies’ actions to defer maintenance have resulted in large backlogs of  deferred maintenance and the deteriorated condition of some federal  buildings, including historic buildings. Agencies’ total annual budgets  allotted for historic preservation are difficult to determine because funding  requested to implement projects to maintain, repair, rehabilitate, and  modernize historic buildings is dispersed across multiple budget  accounts. Projects are identified within agencies’ budgets as line items,  and funding for historic preservation can also be allotted in programmatic  and operating budget accounts for conducting other activities like routine  maintenance. Also, funding across those sources includes funding for  non-historic buildings.
We recently reported that GSA has identified a $4.6 billion maintenance  and repair liability (i.e., needed projects) for its federally owned real  property over the next 10 years, which includes both historic and non- historic buildings. According to GSA officials, its historic buildings require  comparatively more maintenance and repair work than its non-historic  buildings. We also reported that the annual funding Congress has made  available to GSA for obligation from the Federal Buildings Fund has  trended downward in recent years, and much of this reduction has been  absorbed by the repairs and alterations funding account, meaning that  GSA has reduced its spending on repairs and alterations. According to  GSA officials, the constrained federal budget and competing project  demands have affected GSA’s ability to complete historic building  modernizations. For example, GSA allocated $162 million in Recovery  Act funding to undertake the first phase in its renovation of half of the 95- year old GSA headquarters building in Washington, D.C.; however, GSA  does not have funding to complete the second phase of the project.  Similarly, the final phase of GSA’s 12-year, six-phase modernization to  the Department of the Interior’s headquarters building in Washington,  D.C., has been delayed pending funding availability. GSA officials  reported that because of shrinking budgets and increasing reinvestment  needs within GSA’s real property portfolio, GSA evaluated the risks of  delaying various projects, and determined that delaying the completion of  the GSA headquarters building project posed a lower risk as compared  with more critical projects. GSA officials further reported that GSA’s fiscal  year 2013 construction program incorporates OMB’s response to the  nation’s economic distress by including fewer projects and focusing on  critical needs such as safety improvements.
According to NPS’s fiscal year 2013 budget justification, less than 60  percent of its historic buildings and structures are in good condition.  NPS headquarters officials report that limited funding is the greatest  challenge NPS faces in maintaining its historic buildings. We found that  some NPS sites have experienced maintenance staffing reductions as  NPS has faced declining operating budgets. For example, the  maintenance unit that jointly serves the Fort McHenry National Monument  and Historic Shrine and Hampton National Historic Site, both located in  Maryland, has been reduced from 15 to 10 positions over the last 3  years. One NPS official commented that staffing reductions pose a risk  to historic buildings because maintenance projects may get deferred,  which can lead to such projects needing to be addressed later as larger,  bundled, and more costly capital projects. Delaying maintenance projects  may also cause irreversible damage to historic buildings, according to the  NPS official.
In reviewing NPS’s fiscal year 2013 budget justification, we found that  NPS has requested $96.3 million for its cyclical maintenance program,  aimed at conducting preventative maintenance on a predictive cycle to  keep buildings—both historic and non-historic—in acceptable condition.  However, NPS’s fiscal year 2013 budget justification also shows that its  annual cyclical maintenance requirements for its buildings exceed $450  million. Since NPS’s budget request is substantially less than its stated  requirement, it is likely that some maintenance projects will be deferred.
In June 2012, VA reported to us that much of its inventory is over 50  years old, with an average building age of 57 years. In addition to the  age of its buildings, VA reported that many of those buildings have been  designated as historic and many are in poor condition. In VA’s fiscal  year 2013 budget justification, 18 of 21 Veteran Integrated Service  Networks (i.e., regional administrative offices for their hospitals,  comprised of multiple hospital campuses) reported that, in general, their  aging and historic buildings are a significant infrastructure challenge  because of the poor condition of many of the buildings, the functional  limitations of some historic buildings, and stakeholder interests about  rehabilitating, reusing or disposing of historic buildings. VA’s fiscal year  2013 budget request included $1.1 billion for major and minor  construction projects, which includes funding for rehabilitation of both  non-historic and historic buildings. The budget request also included $712  million to fund non-recurring maintenance requirements in VA’s existing  buildings, including historic buildings. The latter includes funding for  repairs and life-cycle projects, such as modernizing mechanical or  electrical systems and replacing windows and roofs. However, VA’s  budget request also shows it would need over $9 billion to adequately  address the condition deficiencies in its buildings. One VA official  indicated that VA expects to seek funding in future budget requests, for  projects to correct those deficiencies.
We have reported that in addition to Congress, OMB, and real property- holding agencies, several other stakeholders have an interest in how the  federal government carries out its real property acquisition, management,  and disposal practices. In the case of historic buildings, these  stakeholders may include, but are not limited to, state, local, and tribal  governments; business interests in the local communities; historic  preservation groups; and the general public. For example, in the case of  VA, veterans’ organizations have had an interest in being consulted on  VA’s plans to reuse or demolish its historic buildings and how those plans  affect the services provided to veterans. Competing interests over how to  reuse a historic building, or whether to demolish a building, may arise  between an agency and its stakeholders. As a result, final decisions  about a property may reflect broader stakeholder considerations which  may not necessarily align with what an agency views as the most cost- effective or efficient alternative.
Stakeholders for historic buildings include state historic preservation  officers and ACHP, both of which have a role in consulting and advising  federal agencies on preservation, repair, or alteration of historic buildings.  For example, in 2011, the California state historic preservation officer was  concerned that VA had not solicited his office’s consultation on some  projects at the San Francisco VA Medical Center, which included the  development of a master plan to address the campus’ future needs and  its effect on the site’s historic buildings. We found that VA is reexamining  its master plan—and the extent of new construction proposed on the  campus—to try to address concerns raised, in part, by the California state  historic preservation officer. According to ACHP officials, preservation  organizations, such as the National Trust for Historic Preservation, and  members of the public may also have an interest in being consulted about  decisions affecting federal historic buildings.
Among the buildings we reviewed, we found examples where competing  stakeholder interests have affected the preservation, reuse, or lease of  historic buildings. For example, VA attempted to use its enhanced-use  lease authority to enter into a long-term public-private partnership with a  non-federal entity for the use of some of VA’s historic buildings in  Milwaukee, Wisconsin. However, public stakeholder groups raised  concerns about aspects of the lease proposal and the related  construction plans for a high-tech business park, which contributed to the  failure of the Milwaukee proposal. We have previously reported on VA’s  challenges with its non-federal stakeholders when trying to implement  plans to repurpose some historic buildings. The failure of enhanced-use  lease negotiations in Milwaukee has, in part, contributed to the failure to  find a suitable use for one building in particular, the “Old Main” hospital  building, which is in an advanced state of deterioration. During our site  visit we observed that the roof was partially collapsed. ACHP officials  said that VA funding for maintenance of the building was severely limited  over many years and that VA’s medical center staff lacked a familiarity  with the historic preservation review process, which contributed to the  building’s current condition. In 2011, VA and ACHP initiated  consultations—which included NPS, the state historic preservation officer,  veterans’ groups, and others—to discuss planned projects on the historic  campus to include a project to stabilize Old Main from further collapse.
The work to stabilize Old Main began in September 2012. The medical  center director told stakeholders that VA will continue to seek alternative  uses for Old Main. See figure 5 for representative views of the exterior  and interior of the building.
Compounding the challenges the three agencies face in managing their  historic buildings, we also found that the data the three agencies reported  on historic buildings were not complete or consistent. FRPP was intended  to provide a comprehensive database of federal buildings, including  identifying historic buildings, but data collection and control issues have  hindered the reporting of complete and consistent data. However, if data  reported to FRPP were improved, FRPP could be used as a vehicle to  strategically manage and oversee the government’s historic buildings.
Under Executive Order 13287, agencies are required to report to ACHP  on their progress in identifying, protecting, and using historic buildings  and other properties, as well as their condition. ACHP consolidates  agency-reported data every 3 years into the Preserve America report on  the state of the federal government’s historic properties. The three  selected agencies, however, did not report consistent information on their  historic properties. For example, in 2011, GSA reported to ACHP the total  number of historic buildings it evaluated and nominated to the National  Register over the last 3 years, but NPS did not report how many  additional buildings achieved historic status and were listed on the  National Register within the reporting period. Also, according to an ACHP  official, VA did not meet ACHP’s fiscal year 2011 reporting requirement  because of VA’s internal review processes. Therefore, ACHP could not  report the number of historic buildings held by VA in its recent Preserve  America report.
As noted, NPS manages the National Register. Historic property records  are listed on the National Register after a building is nominated by an  agency and the NPS agrees with the agency’s determination that the  building meets the historic designation criteria. The National Register is  intended to be an authoritative guide and planning tool to identify  properties agencies should consider for protection and, before  undertaking a project related to such properties, to provide ACHP, state  historic preservation officers, and other stakeholders a reasonable  opportunity to comment on the project. According to GSA and VA  officials, the data in the National Register are not complete. Specifically,  GSA and VA are still working to complete backlogs of National Register  nominations to fully report on historic buildings that the federal  government owns. GSA still needs to conduct evaluations on 5 percent of  its buildings over 50 years old, and VA is still conducting evaluations for  30 of its medical campuses, which encompass hundreds of buildings,  built approximately between 1918 and 1960. Further, according to the  official that manages the National Register, listings are typically not  updated to denote the federal agency currently responsible for a building  or a non-federal entity if the building were sold or transferred. Rather,  listings generally reflect the federal agency that was responsible for the  building at the time of its nomination.
Executive Order 13327 directs the Administrator of GSA, in consultation  with FRPC, to establish and maintain a database (which became the  FRPP) and to establish data and information technology standards to  facilitate reporting on a uniform basis. In June 2012, we reported that data  elements in the FRPP database are not always defined and reported  consistently and accurately. In our current review of agencies’ FRPP  historic building data, we found that the historic status of over 75 percent  and 63 percent of GSA and NPS buildings, respectively, are categorized  as “not evaluated” in FRPP. See table 1 below for examples of  inconsistencies we identified. A noteworthy example is the West Wing of  the White House, which is a GSA-held property that was designated a  national historic landmark in 1960, but is listed as “not evaluated” in  FRPP.
In addition, FRPP data for NPS in fiscal year 2011 showed that NPS had  almost 1,500 national historic landmark buildings, while its reporting to  ACHP in 2011 indicates NPS had 177 national historic landmarks. These  data inconsistencies are because of FRPP’s lack of a status code for  buildings that are “contributing” elements in a national historic landmark  (or National Register listed) site or district. We found that in internal data  on historical buildings, NPS categorizes many buildings as “contributing”  historic buildings. For example, the Frederick Law Olmstead House in  Brookline, Massachusetts, is reported as a single national historic  landmark site on the National Register, but is comprised of five buildings  including a shed and barn. While the house is categorized as “nationally  significant,” the historic significance of the shed and barn are categorized  as “contributing.”
In 2009, the Department of the Interior recommended that FRPC add a  new “contributing” category within FRPP coding options for historic status  to better clarify how many buildings have actually been designated as  historic, particularly for those within national historic landmark and  National Register listed sites and districts. FRPC did not implement the  recommendation, in part, because it was considered too specific to the  Department of the Interior’s portfolio. However, we also found this  recommendation to have relevance to many of the historic buildings  reported by VA and GSA. For example, in the case of VA, most of its  historic buildings are not individually listed to the National Register, but  are considered to be included within a historic site or district. Therefore,  the lack of a “contributing” category makes it unclear whether historic  building status data are being reported consistently or accurately across  agencies and whether the executive branch can reliably identify the total  number of historic buildings it holds, and also distinguish those that are  exceptionally significant to the nation and commensurate with national  historic landmark status.
GSA and NPS historic building officials also stated that FRPP data on the  number of historic buildings they hold are inconsistent with data  maintained within their internal historic buildings databases. The  agencies have not fully reconciled their historic building databases with  their real property databases, the latter of which are used to report to  FRPP. FRPP data, therefore, cannot be used to assess the numbers of  federal buildings individually designated or account for those that are  “contributing buildings” within a larger historic site or district.
Lastly, ACHP officials told us that they do not have access to FRPP  data—despite their request to GSA—to conduct analyses on federal  historic buildings. We found that FRPC allows access to agency FRPP  data only when access is granted by individual agency data  administrators. ACHP officials also noted it is difficult for ACHP to draw  quantifiable summary data from individual agencies’ Preserve America  submissions because agencies inconsistently report historic building  data. ACHP officials further indicated that ACHP would like some  consistency in how historic building data are reported and said the  responsibility is on individual agencies to report uniform data as was  intended by FRPP.
The FRPP database’s lack of completeness and consistency for historic  data are not consistent with sound data collection practices. We have  long held that results-oriented organizations assure that data they collect  are sufficiently complete, accurate, and consistent enough to document  performance and support decision making, as well as to collaborate with  others who would benefit from the data.
In June 2012, we reported that FRPC has not followed sound data  collection practices in designing and maintaining the FRPP database,  raising concern that the data are not a useful tool for describing the  nature, use, and extent of excess and underutilized federal real  property. For example, FRPC has not ensured that key data  elements—including buildings’ utilization, condition, annual operating  costs, mission dependency, and replacement value—are defined and  reported consistently and accurately. As a result, we recommended that  GSA, in collaboration with FRPC member agencies, develop and  implement an action plan to improve FRPP, consistent with sound data  collection practices, so that data collected are sufficiently complete,  accurate, and consistent, and collaboration between agencies is effective.
In addition to developing the database, Executive Order 13327 required  FRPC to be a clearinghouse of best practices for real property  management and establish performance measures to determine the  effectiveness of federal real property management. The executive order  specifically states that performance measures shall be designed “to  enable the heads of executive branch agencies to track progress in the  achievement of government-wide property management objectives, as  well as allow for comparing the performance of executive branch  agencies against industry and other public sector agencies.” FRPP has  four data elements that FRPC considers performance measures: (1)  utilization (overutilized, utilized, underutilized, and not utilized); (2)  condition index (general measure of the constructed asset’s condition at a  specific point in time); (3) annual operating costs (expenses for recurring  maintenance and repair costs, utilities, cleaning or janitorial costs, and  roads or grounds expenses); and (4) mission dependency (the  importance an asset brings to the performance of the agency’s  mission). However, we reported in June 2012 that these performance  measures are ineffective because they are not routinely linked to any  performance goals, and FRPC guidance does not explain what  constitutes acceptable performance on these measures.
These performance measures, if tied to performance goals, could  potentially be useful to the agencies and OMB in the area of historic  preservation, where, OMB and FRPC could benchmark performance  across agencies and, potentially identify progress, areas of concerns, or  lessons learned. For example, of the three agencies we reviewed, only  NPS had a performance metric reported within its fiscal year 2013 budget  justification that showed the number and percentage of historic buildings  in good condition for prior fiscal years, the planned goal for the fiscal year  2012, and a proposed goal for fiscal year 2013. Furthermore, data on  mission-dependent buildings with historic status could help agencies  justify funding requests for those buildings’ maintenance and  rehabilitation, and historic buildings with high operating costs could be  candidates for sustainability investment. The data could also show how  the condition of mission-dependent historic buildings may either be  adversely or positively affected given reduced or increased funding  scenarios. Lastly, complete and accurate data identifying agencies’  historic buildings would be needed to assess whether agencies have  managed and provided for those buildings’ continued use or have  pursued leases with persons or organizations to provide for the buildings’  reuse and preservation as called for by NHPA.
In June 2012, we recommended that FRPP performance measures  should be linked to clear performance goals consistent with Executive  Order 13327. GSA agreed with the recommendation and has begun to  take action to address the recommendation. GSA also reported that it will  propose refining the performance measures and limit the number of  measures to ensure that only essential measures, linked to performance  goals, are collected consistent with directives in Executive Order 13327.  Improving historic building data could complement this recommendation,  not only at the agency-level for GSA, NPS, and VA, but for all executive  agencies included in FRPP and in GSA’s capacity as the agency  responsible for establishing and maintaining FRPP.
section_title: Conclusions
paragraphs: Federal real property management is a challenging area, and  requirements to preserve and manage historic buildings place added  expectations on federal agencies that are stewards of many treasured  assets. NHPA, executive orders, and other requirements establish the  overall federal policy regarding historic buildings. Those requirements  reflect that federal historic buildings are an important part of America’s  heritage and should be preserved, protected, enhanced, and where  possible, adapted for contemporary use.
In 2004, the President issued an executive order establishing the FRPC  and requiring GSA to collect data from executive branch agencies  describing the nature, extent, and use of federal real property. While  this was a positive step, we reported in June 2012 that GSA needed to  improve FRPP so that data are consistent, complete, and collaboration  among agencies is effective. GSA agreed with this recommendation  and is taking steps to implement it. In the case of historic building data,  FRPP data are similarly limited, which negates the potential for agencies  and stakeholders, including OMB and Congress, to use the data to  strategically manage the historic building subset of the federal real  property portfolio and try to address related challenges. Focusing on how  to improve the historic building data in FRPP, in conjunction with GSA  efforts under way to improve FRPP data on all federal buildings, would  better equip stakeholders to make decisions about where to direct limited  federal resources for historic preservation and foster greater  accountability and transparency.
section_title: Recommendation for Executive Action
paragraphs: We recommend that the Acting Administrator of GSA—in collaboration  and consultation with ACHP, NPS, VA, and FRPC member agencies— ensure that the action plan being developed to improve FRPP data  includes actions to improve historic-building data by addressing the  following areas, at a minimum:    determining whether changes are needed—to historic data elements  or guidance—to ensure that data are consistently and accurately  reported;    developing, in FRPP fiscal-year summary reports, data that will better  convey to the public and stakeholders—including OMB and  Congress—a sense of the extent of historic buildings held by  agencies, such as total numbers or percentages; and,  facilitating ACHP’s access to FRPP data, as appropriate, so that  ACHP can better fulfill its historic-building advisory role to Congress  and the President.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to GSA, the Department of the Interior,  VA, and ACHP for review and comment.
GSA agreed with our recommendation and further reported that it has, in  part, already taken action to rectify inconsistencies we found between  GSA’s FRPP data and its internal data sources used for NHPA  compliance and reporting required by Executive Order 13287. GSA also  indicated it will: (1) assess and determine whether changes are needed to  the FRPP historic status data element and guidance; (2) provide future  data on historic buildings within GSA’s FRPP fiscal-year summary  reports; and, (3) work with ACHP by sharing FRPP data and reports, as  appropriate. GSA’s response is reprinted in appendix III.
The Department of the Interior and VA provided technical comments,  which we incorporated as appropriate.
In commenting on our draft, ACHP said this report provides a useful  analysis of these agencies’ programs and their stewardship of historic  buildings. However, ACHP emphasized that the greatest challenge facing  agencies’ federal buildings—irrespective of historic status—is that their  buildings have not been maintained because of agencies’ decisions to  defer maintenance. While we understand ACHP’s perspective, our  assessment pointed to budgetary limitations as a challenge that can  cause agencies to defer maintenance on historic buildings. Nonetheless,  in recognition of ACHP’s comment, we have included a reference to  GAO’s past reporting on agencies’ deferred maintenance backlogs for  federal buildings and have noted the link between budgetary limitations  and deferred maintenance, in the report. It is also important to note that,  in addition to budgetary limitations, as discussed in the report, the  agencies face challenges in adapting some historic buildings to meet  contemporary needs and in involving stakeholders on proposals—such as  building reuse and demolition plans—that may adversely affect a historic  building. ACHP’s response is reprinted in appendix IV. ACHP also  provided technical comments, which we incorporated as appropriate.
As agreed with your office, 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 Acting Administrator of  GSA, the Secretaries of the Interior and VA, and the Executive Director of  ACHP. Additional copies will be sent to interested congressional  committees. We will also make copies available to others upon request,  and the report is available at no charge on the GAO website at  http://www.gao.gov.
If you have any questions about this report, please contact me at   (202) 512-2834 or wised@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Major contributors to this report are listed in appendix V.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to identify (1) actions selected nondefense agencies  have taken to manage historic federal buildings, and (2) any challenges  they have faced. We identified three agencies for our review: (1) the  General Services Administration (GSA); (2) the National Park Service  (NPS) within the Department of the Interior; and (3) the Department of  Veterans Affairs (VA). We selected GSA, in part, because it is the federal  government’s principal real property steward for many federal agencies.  In addition, GSA was selected because it also maintains the Federal Real  Property Profile (FRPP) database that is used to identify and report on  federal real property, to include the historic status of federal buildings,  held by executive branch agencies. We selected NPS, in part, because it  is responsible for the stewardship of most of the Department of the  Interior’s historic buildings, many of which reside within the nation’s  national historic parks, districts, and sites. In addition, we selected NPS  because it establishes and manages the nation’s historic preservation  standards such as the Secretary of the Interior’s: (1) Standards for the  Treatment of Historic Properties with Guidelines for Preserving,  Rehabilitating, Restoring, and Reconstructing Historic Buildings; (2)  Standards for Rehabilitation & Illustrated Guidelines on Sustainability for  Rehabilitating Historic Buildings; and (3) Standards and Guidelines for  Federal Agency Historic Preservation Programs Pursuant to the National  Historic Preservation Act. In addition, on behalf of the Secretary of the  Interior, NPS manages the National Register of Historic Places, the  nation’s official list of historic places, both publically and privately held.  Lastly, we sought and received recommendations from the Advisory  Council on Historic Preservation (ACHP) on a third federal agency to add  to our review. Based on recommendations received from ACHP and our  judgment and knowledge of the inventories of the agencies  recommended, we selected VA because it is the steward for the nation’s  historic veterans’ hospitals and many of its buildings are over 50 years  old. In finalizing our selection, we estimated that the federally owned  building portfolios of the three non-defense agencies encompassed over  33,500 buildings, including at least 10,000 identified historic buildings  (based on our preliminary review of those agencies’ FRPP 2010 fiscal  year data) and that these agencies’ real property portfolios would provide  a diverse range of building types including office buildings, courthouses,  park facilities, museums, and hospitals.
To understand the issues and requirements related to federal historic  preservation, we reviewed relevant laws, regulations, and executive  orders governing how agencies should identify, report, and manage  historic buildings in their portfolios. We reviewed NHPA and its  implementing regulations as well as the following executive orders: (1)  Executive Order 13287, entitled Preserve America; (2) Executive Order  13327, entitled Federal Real Property Asset Management; and (3)  Executive Order 13514, entitled Federal Leadership in Environmental,  Energy, and Economic Performance. Executive Order 13514 requires  agencies, among a number of initiatives, to improve the sustainable  performance of their existing buildings and ensure that all new  construction, major renovation, or repair and alteration of federal buildings  complies with the Guiding Principles for Federal Leadership in High  Performance and Sustainable Buildings (Guiding Principles). We  reviewed those Guiding Principles, as well as ACHP’s sustainability  guidance to federal agencies entitled Sustainability and Historic Federal  Buildings, and The Secretary of the Interior’s Illustrated Guidelines on  Sustainability for Rehabilitating Historic Buildings. In addition, we  reviewed the aforementioned federal standards and guidelines on historic  preservation managed by NPS on behalf of the Secretary of the Interior.  We also reviewed past GAO reports on federal real property.
To understand the challenges faced by agencies in managing their  historic buildings and to identify agencies’ portfolio-wide efforts to  preserve their historic buildings, we interviewed our selected agencies’  real property and preservation officials about their agencies’ preservation  programs. We also reviewed agencies’ fiscal year 2013 budget requests,  but we did not independently verify agencies’ fiscal year 2013 budget  requirements. To gather detailed examples of selected agencies’ actions  to manage historic buildings, we visited a nonprobability sample of 31  federally owned historic buildings held by GSA, NPS, and VA, in five  metropolitan areas: (1) Boston, Massachusetts; (2) Chicago, Illinois; (3)  Milwaukee, Wisconsin; (4) San Francisco, California; and (5) Washington,  D.C.-Baltimore, Maryland. We selected buildings to visit based on a  combination of input received from agencies’ preservation officials,  ACHP, state historic preservation officers, and our own judgment as  informed by our review of selected agencies’ preservation documents and  their FRPP submissions. This approach yielded a diverse group of  buildings in terms of use, age, size, and condition that provided illustrative  examples of agencies’ broader policy initiatives and specific preservation  and sustainability projects.
Prior to our site visits, we reviewed selected agencies’ documentation on  recent, current, or planned efforts to manage those historic buildings. To  the extent documents were available, we requested and reviewed  National Register nomination forms, facility condition assessments,  historic structure reports, and sustainability scorecards for buildings we  visited. In preparation for our visits, we also provided agency officials  knowledgeable about our selected nonprobability sample of buildings with  a series of questions, and asked for written responses, regarding their  historic preservation, maintenance and repair, and sustainable  improvements, if any. For example, we inquired about the current building  condition and asked the officials to identify specific major renovation,  rehabilitation, or sustainability projects that were undertaken in the  buildings within the last 3 fiscal years, if any. While we reviewed projects  that were in-process or recently completed in those buildings, we did not  review the extent projects were within scope, cost, and schedule. We also  inquired about agencies’ progress in meeting government-wide  sustainable Guiding Principles for their existing buildings, and specifically  if the buildings currently met the Guiding Principles. We also conducted a  literature review about historic preservation and sustainability. Finally, to  better understand the challenges that agencies may face, we spoke with  three experts with academic or professional expertise in improving the  sustainable performance of historic buildings. We selected these experts  based on a combination of input received from the selected agencies’  preservation officials, ACHP, and our own judgment as informed by our  literature search.
To determine whether FRPP could be used to reliably identify the  historical status of selected agencies’ federally owned buildings and the  numbers of historic buildings held by those agencies, we reviewed GSA’s  annual FRPP reporting guidance to executive branch agencies on how to  report their historic buildings. We also obtained and analyzed selected  agencies’ FRPP data submissions for fiscal year 2011, and other real  property data such as agencies’ past and current Preserve America  reports submitted to ACHP about the agencies’ historic buildings and their  efforts to preserve those buildings. We also interviewed agency officials  about data and reviewed FRPP guidance and other documents related to  the agencies’ real property data and FRPP database. In the case of GSA  and NPS—which maintain separate historic building databases in addition  to their respective agencies’ real property databases—we obtained and  reviewed data from those agencies respective historic buildings  databases about the historic status of their buildings and compared it with  data agencies reported to FRPP and in their reports to ACHP.
We conducted this performance audit from November 2011 to December  2012 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: List of 31 Federal Historic Buildings Where GAO Conducted Site Visits
section_title: Appendix III: Comments from the General Services Administration
section_title: Appendix IV: Comments from the Advisory Council on Historic Preservation
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individuals named above, other key contributors to this  report were David Sausville, Assistant Director; John Bauckman, Analyst- in-Charge; Lindsay Bach; Leia Dickerson; Colin Fallon; Catherine Kim;  Hannah Laufe, Joshua Ormond; Crystal Wesco; and Elizabeth Wood.