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U.S. ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
EPA Can Further
Reduce Space in
Under-Utilized Facilities
Report No. 13-P-Q162
February 20, 2013
Scan this mobile
code to learn more
about the EPA OIG.

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Report Contributors:
Marcia Hirt-Reigeluth
Jennifer Hutkoff
Yeon Kim
Heather Layne
Mike Davis
Abbreviations
CFR	Code of Federal Regulations
EPA	U.S. Environmental Protection Agency
FMSD	Facilities Management and Services Division
GSA	U.S. General Services Administration
HQ	Headquarters
OARM	Office of Administration and Resources Management
OIG	Office of Inspector General
SLATE	Strategic Lease and Asset Tracking Enterprise
USF	Usable Square Feet
Cover photos: EPA facilities, from left: the EPA Region 5 Ralph H. Metcalfe Federal
Building, Chicago, Illinois; and the EPA Region 1 John W. McCormack
Federal Building, Boston, Massachusetts. (EPA photos)
Hotline
To report fraud, waste, or abuse, contact us through one of the following methods:
e-mail:	OIG Hotline@epa.gov	write: EPA Inspector General Hotline
phone:	1-888-546-8740	1200 Pennsylvania Avenue, NW
fax:	202-566-2599	Mailcode 2431T
online:	http://www.epa.gov/oiq/hotline.htm	Washington, DC 20460

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

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At a Glance
Why We Did This Review
We sought to determine to what
extent the U.S. Environmental
Protection Agency's (EPA's)
efforts to reduce under-utilized or
unneeded property resulted in cost
savings. The February 2004
Executive Order 13327, Federal
Real Property Asset Management,
promotes efficient and economical
use of federal real property assets
and assures management
accountability for implementing
federal real property management
reforms such as the development
and implementation of agency
asset management plans. Federal
real property is defined as any real
property owned, leased, or
otherwise managed by the federal
government. The June 2010
Presidential Memorandum,
Disposing of Unneeded Federal
Real Estate, requires federal
agencies to eliminate excess
properties and lease
arrangements that are not cost
effective.
This report addresses the
following EPA Goal or
Cross-Cutting Strategy:
• Strengthening EPA's Workforce
and Capabilities
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
www.epa.qov/oiq/reports/2013/
20130220-13-P-0162.pdf
EPA Can Further Reduce Space in
Under-Utilized Facilities
What We Found
Although EPA has been releasing unneeded space since 2007, it continues to
have under-utilized space. The U.S. General Services Administration (GSA)
owns or leases facilities for EPA use. At 13 of the 16 facilities reviewed, we
estimated that EPA had 433,336 square feet of under-utilized space as of
February 2012. EPA is limited in what type of space it can release back to
GSA before a lease expires. Space can only be released if it is marketable;
configuration issues and the cost to relocate employees can pose problems.
If all under-utilized space in our sample was marketable, we estimate EPA
could save up to $21.6 million annually by releasing under-utilized space.
Also, EPA does not have a policy for determining when it should be housing
contractors on-site in its facilities. Contractors occupied an estimated 197,000
square feet in the sampled facilities. We estimated that EPA spent up to
$9.9 million annually in housing contractors on-site at the sampled facilities.
EPA lacks accurate, current, and complete information on the number of
personnel and usable square feet (USF) in its Strategic Lease and Asset
Tracking Enterprise (SLATE) system for its GSA-owned/leased offices. As of
April 2012, SLATE had incorrect personnel information for 13 of the 16
facilities sampled (81 percent), and 5 of 16 facilities sampled (31 percent) had
incorrect information on USF. SLATE recorded a net 548 more personnel than
what EPA facility managers had provided for the sampled facilities and a net
235,918 less USF than the sampled facilities had. Additionally, the entire USF
of 325,128 for the Region 5 Ralph H. Metcalfe building was not reported in
SLATE. This occurred because updates to SLATE are sporadic and
inconsistent. Inaccurate data in SLATE hamper EPA's ability to make
informed decisions about managing its facilities.
Recommendations and Planned Agency Corrective Actions
We recommend that the Assistant Administrator for Administration and
Resources Management assess utilization of space and relocate staff where
warranted. We also recommend that the Assistant Administrator develop and
enforce a policy that requires contracting staff ensure that approval for
on-site contractor performance is obtained from the responsible office, and
require that personnel information for each facility be consistently tracked and
updated in the appropriate EPA systems. The Agency concurred with all of the
recommendations and proposed revised language, which we incorporated
where appropriate.
Noteworthy Achievements
Since fiscal year 2007, EPA has saved nearly $12.9 million by reducing space
and plans to save an additional $1.8 million by fiscal year 2014, for a total of
$14.7 million in savings.

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
February 20, 2013
MEMORANDUM
SUBJECT: EPA Can Further Reduce Space in Under-Utilized Facilities
Report No. 13-P-0162
FROM: Arthur A. Elkins, Jr.
TO:
Craig E. Hooks
Assistant Administrator for Administration and Resources Management
This is our report on the subject audit conducted by the Office of Inspector General (OIG) of the
U.S. Environmental Protection Agency (EPA). This report contains findings that describe the
problems the OIG has identified and corrective actions the OIG recommends. This report
represents the opinion of the OIG and does not necessarily represent the final EPA position.
Final determinations on matters in this report will be made by EPA managers in accordance with
established audit resolution procedures.
Action Required
In accordance with EPA Manual 2750, you are required to provide a written response to this
report within 60 calendar days. Your response will be posted on the OIG's public website, along
with our comments on your response. Your response should be provided in an Adobe PDF file
that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of
1973, as amended. If your response contains data that you do not want to be released to the
public, you should identify the data for redaction. You should include a corrective actions plan
for agreed-upon actions, including milestone dates. We have no objections to the further release
of this report to the public. This report will be available at http://www.epa.gov/oig.
If you or your staff have any questions regarding this report, please contact Melissa Heist,
Assistant Inspector General for Audit, at (202) 566-0899 heist.melissa@epa.gov; or Mike Davis,
Director for Efficiency Audits, at (513) 487-2363 or davis.michaeld@epa.gov.

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EPA Can Further Reduce Space
in Under-Utilized Facilities
13-P-0162
Table of C
Chapters
1	Introduction		1
Purpose		1
Background		1
Noteworthy Achievements		3
Scope and Methodology		3
2	EPA Can Further Strive for Space Reduction		6
Federal Policies Seek to Reduce Space		6
EPA Has Under-Utilized Space		7
EPA Does Not Have a Policy for Determining When Contractors
Should Be On-Site		9
Conclusion		11
Recommendations		12
Agency Response and OIG Evaluation		12
3	Personnel and Usable Square Feet Data in SLATE Not Updated Timely		14
SLATE and Its Data Quality and Integrity Important		14
Personnel Information in SLATE Not Accurate		15
USF Information in SLATE Not Accurate		16
Number of Facilities in SLATE Not Accurate		17
Conclusion		17
Recommendations		17
Agency Response and OIG Evaluation		17
Status of Recommendations and Potential Monetary Benefits		19
Appendices
A Details on Scope and Methodology		20
B Calculations for Under-Utilized Space and Excess Cost
for 16 Sampled Facilities		22
C Cost of Housing Contractors On-Site at 16 Sampled Facilities		24
D Agency Response to Draft Report		25
E Distribution 		29

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Chapter 1
Introduction
Purpose
The June 2010 Presidential Memorandum, Disposing of IJnneeded Federal Real
Estate, required federal agencies to accelerate efforts to identify and eliminate
excess properties. Agencies were to dispose of surplus assets, consolidate
facilities, and eliminate lease arrangements that were not cost effective.
Accordingly, we sought to determine to what extent the U.S. Environmental
Protection Agency's (EPA's) efforts to reduce under-utilized or unneeded
property resulted in cost savings.
Background
EPA facilities are comprised mostly of offices and laboratories in space owned or
leased by either EPA or the U.S. General Services Administration (GSA). As of
November 2011, the data in EPA's Strategic Lease and Asset Tracking Enterprise
(SLATE) system showed that EPA occupied 170 facilities with approximately
10 million usable square feet (USF) of space at an annual operating cost of
approximately $279 million. USF is the net space occupied by a tenant for its
personnel and equipment use and does not include fire corridors, toilets,
mechanical rooms, and common building areas. SLATE also reported that these
facilities housed 23,498 personnel; that number includes not only EPA staff but
contractors, grantees, Senior Environmental Employment enrollees, and interns.
Details are in table 1.
Table 1: EPA facilities by legal interest
Legal interest
No. of
facilities
Percent
Personnel
USF3
Annual cost
EPA owned/leased
24
14.12%
5,536
4,224,479
$45,530,093
EPA special use agreement1
10
5.88%
46
30,475
519,697
GSA-owned/leased 2
134
78.82%
17,909
5,793,357
232,607,245
State government owned
2
1.18%
7
2,050
-
Total
170
100.00%
23,498
10,050,361
$278,657,035
Source: Office of Inspector General (OIG) analysis of EPA's data in SLATE as of November 2011.
1	Facilities where EPA personnel are co-located with other federal agencies or have special use arrangements
with state or local entities.
2	Includes offices, laboratories, warehouses, storage, child care, and parking lots.
3	Includes rentable square feet for one facility that did not record usable square feet.
EPA facilities are spread throughout the United States and Puerto Rico. Of the
170 facilities, approximately 59 are large facilities—greater than 20,000 USF.
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The remainder of EPA's facilities are smaller, special-purpose buildings and
project offices. Each of EPA's 10 regions has a regional office and at least one
laboratory. Figure 1 shows details.
Figure 1: EPA regions and major facilities
Hawaii
~ EPA national headquarters - Washington, DC
Regional headquarters
Central regional laboratories
Program laboratories
Source: EPA's 2009 Nationwide Facilities Guide
Initiatives to Reduce Federal Property
The February 2004 Executive Order 13327, Federal Real Property Asset
Management, promotes efficient and economical use of federal real property
assets and assures management accountability for implementing federal real
property management reforms such as the development and implementation of
agency asset management plans. For the purpose of this executive order, federal
real property is defined as any real property owned, leased, or otherwise managed
by the federal government.
The June 2010 Presidential Memorandum, Disposing of Urmeeded Federal Real
Estate, directed agenci es to take immediate steps to make better use of remaining
real property assets as measured by utilization and occupancy rates, annual
operating costs, energy efficiency, and sustainability. Agencies were to dispose of
surplus assets, consolidate facilities, and eliminate lease arrangements that were
not cost effective. Agencies were directed to use innovative approaches to space
management and alternative workplace arrangements such as telework.
To carry out the requirements of the June 2010 memorandum, the Office of
Management and Budget, in consultation with the GSA Administrator and the
Federal Real Property Council, developed guidance in July 2010 for actions that
agencies should take. The memo included agency-developed targets to achieve
$3 billion in cost savings by the end of fiscal year 2012. These savings included
proceeds from the sale of assets; reduced operating, maintenance, and energy
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expenses from disposals; and other space consolidation efforts, including ending
of leases. EPA planned to contribute approximately $7.8 million as part of the
$3 billion in savings.
EPA's July 2010 initial and April 2011 updated Real Property and Innovation
Plan stated the Agency's commitment to reducing its environmental footprint
through efficient management of its real property portfolio. The plan stated that
the Agency would continue to monitor and assess its facilities' space utilization
and take steps to reduce under-utilized space. Additionally, the Agency would
continue to implement sustainable design, construction, alterations, and
operations and maintenance.
The June 2011 Presidential Executive Order 13576, Delivering an Efficient,
Effective, and Accountable Government, calls for a government that cuts waste
and is fully accountable to the American public. As part of this executive order,
the President charged federal chief financial officers with increasing efforts to
identify, execute, and report on cost savings within federal agencies.
Noteworthy Achievements
Since fiscal year 2007, EPA has released more than 380,000 square feet of space
with cost savings of nearly $12.9 million. EPA plans to save an additional
$1.8 million in fiscal years 2012 through 2014 by releasing additional space, for a
total of $14.7 million in savings (table 2).
Table 2: EPA space released
Year
Square feet released
Cost savings
Fiscal years 2007-2011
380,756
$12,864,283
Planned for fiscal years 2012-2014
71,157
$1,843,112
Total
451,913
$14,707,395
Source: OIG analysis of EPA's data.
Scope and Methodology
We conducted this performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a reasonable basis
for our findings and conclusions based on our review objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objective.
We performed the audit from November 2011 to October 2012. We visited the
Facilities Management and Services Division (FMSD) and Office of Acquisition
Management in the Office of Administration and Resources Management,
Washington, DC. We interviewed FMSD officials in headquarters (HQ) and regional
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facility managers for 16 sampled facilities to determine their roles and
responsibilities and to verify information on personnel head counts and USF in
SLATE. We interviewed the Office of Acquisition Management Special Assistant
and Region 9's contracting personnel to gain a better understanding of EPA's
policies and procedures regarding allocation of space to on-site contractors.
We selected 16 GSA-owned/leased facilities for review, as shown in table 3.
Table 3: Sixteen Sampled Facilities
Region
State
City
Building Name
Usable
Square Feet
No. of
Personnel
HQ
District of Columbia
Washington
Ariel Rios Federal Building
446,324
1,649
HQ
District of Columbia
Washington
1310 L Street
135,901
570
HQ
District of Columbia
Washington
Ronald Reagan Building
230,664
1,137
HQ
District of Columbia
Washington
Colorado Building
9,667
20
1
Massachusetts
Boston
John W. McCormack Building
224,261
845
2
New York
New York
Ted Weiss Federal Office Building
269,834
851
2
Puerto Rico
Guaynabo
City View Plaza
19,700
60
3
Pennsylvania
Philadelphia
1650 Arch Street
268,968
1,133
5
Illinois
Chicago
Ralph H. Metcalfe Federal Building
0
1,558
5
Michigan
Ann Arbor
National Vehicle & Fuel Emissions
Laboratory - Office Building
59,100
235
5
Ohio
Norwood
Norwood Professional Building
28,594
85
6
Texas
Dallas
Fountain Place
239,130
1,052
7
Kansas
Kansas City
901 North 5th Street
182,554
700
9
California
San Francisco
75 Hawthorne Street
253,919
1,160
9
California
Los Angeles
Los Angeles Field Office
13,813
25
10
Washington
Seattle
Park Place Building
154,006
669
Total
2,536,435
11,749
Source: OIG analysis of EPA data in SLATE as of November 2011 (further details on OIG methodology in appendix A).
To determine applicable criteria, we reviewed the following:
•	Code of Federal Regulations (CFR), 41 CFR Part 102-79, Assignment and
Utilization of Space
•	Executive Order 13327, Federal Real Property Asset Management,
February 2004
•	GSA's July 2011 report, Workspace Utilization and Allocation Benchmark
•	Federal Real Property Council's Guidance for Improved Asset
Management, December 2004
•	Presidential Memorandum, Disposing of Unneeded Federal Real Estate,
June 2010
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•	Office of Management and Budget's July 2010 Management Procedures
Memorandum No. 2010-07, Development of a Real Property Cost Savings
and Innovation Plan
•	Executive Order 13576, Delivering an Efficient, Effective, and
Accountable Government, June 2011
Further details on the scope and methodology used—including the methodology
to select our sample, calculate under-utilized space, and calculate cost savings—
are in appendix A.
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Chapter 2
EPA Can Further Strive for Space Reduction
Although EPA has been releasing unneeded space since 2007, EPA continues to
have under-utilized space. At 13 of the 16 GSA-owned/leased EPA facilities
reviewed, we estimated that EPA had 433,336 square feet of under-utilized space
as of February 2012. EPA is limited in what type of space it can release back to
GSA before a lease expires. Space can only be released if it is marketable;
configuration issues and the cost of relocating employees can pose additional
problems. If all the under-utilized space in our sample were marketable, we
estimate EPA could save up to $21.6 million annually by releasing under-utilized
space. Also, EPA does not have a policy for determining when it should be
housing contractors on-site in its facilities. Contractors occupied an estimated
197,000 usable square feet in the sampled facilities. We estimated that EPA spent
at least $5.8 million and up to $9.9 million annually in housing contractors on-site
at the sampled facilities.
Federal Policies Seek to Reduce Space
The June 2010 Presidential Memorandum, Disposing of Unneeded Federal Real
Estate, required:
•	Federal agencies to take immediate steps to make better use of remaining
real property assets, as measured by utilization and occupancy rates and
annual operating costs.
•	To the extent permitted by law, agencies dispose of surplus assets,
eliminate lease arrangements that are not cost effective, pursue
consolidation opportunities within and across agencies in common asset
types, increase occupancy rates in current facilities through innovative
approaches to space management and alternative workplace arrangements
such as telework, and identify offsetting reductions in inventory when new
space is acquired.
Assignment and Utilization of Space, 41 CFRPart 102-79, states:
An Executive agency must promote maximum utilization of
Federal workspace, consistent with mission requirements, to
maximize its value to the Government. 41 CFR §102-79.10.
Executive agencies must promote the optimum use of space for
each assignment at an economical cost to the Government, provide
quality workspace that is delivered and occupied in a timely
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manner, and assign space based on mission requirements. 41 CFR
§102-79.20.
EPA Has Under-Utilized Space
EPA planned to save $7.8 million as part of the federal government's efforts to
reduce space to comply with the June 2010 Presidential Memorandum. Since
fiscal year 2007, EPA has released over 380,000 square feet of space with a
savings of nearly $13 million, and plans to save an additional $1.8 million in
fiscal years 2012 through 2014 (see table 2, chapter 1). Nonetheless, despite
EPA's efforts, at 13 of the 16 EPA facilities in our sample of GSA-owned/leased
facilities, we estimated that EPA had 433,336 square feet of under-utilized space
as of February 2012. We estimated the annual operating cost of this under-utilized
space to be approximately $21.6 million annually. A breakdown is in table 4 and
further details are in appendix B.
Table 4: Under-utilized space and annual costs for 13 facilities using 210 USF per
person

Total under-utilized
Excess annual
Location and building name
space
operating cost
HQ-Ariel Rios Federal Building
100,589
$5,664,167
R 2-Ted Weiss Federal Building
64,676
5,274,975
R 1-John W. McCormack Building
78,064
4,350,507
R 7-901 North 5th Street
49,849
1,941,619
R 5-Ralph H. Metcalfe Federal Building
33,360
1,336,402
R 3-1650 Arch Street
41,192
1,112,184
R 10-Park Place Building
10,275
448,812
R 2-City View Plaza, Puerto Rico
6,489
393,169
HQ-Colorado Building
6,103
345,674
R 6-Fountain Place
11,924
245,754
R 9-Los Angeles Field Office
7,830
183,770
HQ-310 L Street
18,500
182,595
R 5-Norwood Professional Building
4,485
96,966
Total
433,336
$21,576,594
Source: OIG analysis of EPA data provided by FMSD and regional facility managers as of
February 2012.
GSA's July 2011 report, Workspace Utilization and Allocation Benchmark,
recommended a federal benchmark of 190 USF per person. GSA staff stated that,
in determining the benchmark, they included only office or cubicle areas and a
portion of shared space such as conference rooms and hall space. Also, GSA's
July 2011 report further states that the average space allocated could be reduced
to only 60 square feet in the next 5 years. In response to our draft report, the
Agency stated that "the GSA document hypothesises (sic) that the 60 square feet
could be achieved only through extensive use of alternative workspace
arrangements, such as hoteling, home office and teleworking on a fulltime basis.
The EPA's current policy limits telework to no more than two days per week and
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would therefore have to be modified. Such a significant change has already been
the subject of extensive negotiation and delay. Hence, at this time, the EPA does
not recognize that the average office space can be reduced to 60 square feet in
upcoming years." We recognize that the 60 square feet relates to alternative
workspace arrangements for teleworking employees. However, as the Agency has
already started to move toward enhanced telework in Regions 7 and 9 that allows
employees to telework more than 2 days per week, this option could become a
viable option.
In determining EPA's under-utilized space, we used EPA's internal standard of
210 USF per person as opposed to GSA's 190 USF because EPA office spaces
include a variety of support spaces that GSA does not include in its 190 USF
benchmark. These support spaces include areas for conferences, copying, public
information, computers, library, filing, storage, mail and stock, and an employee
lounge. We decided to use 210 USF since EPA tracks all of the support space that
GSA excludes from its benchmark when computing USF, and since FMSD does
not readily track the excluded GSA support space. We believe that applying
210 USF per person for calculating space utilization is the generalized and
conservative workspace average and demonstrates whether EPA's facilities are
under-utilized. EPA's 2011 draft New Mobile Work Space Design Guidelines
require a typical work station to be up to 60 USF and a telework station up to
30 USF per person not including support spaces. In response to the draft report,
the Agency stated that the guideline numbers of 60 and 30 USF are not considered
reductions from the 210 square feet per person number, which incorporates
required space outside the actual workstation for circulation, filing, conferencing,
collaboration, and small meeting rooms. The Agency stated a reasonable design
reduction from 210 square feet would be 175 square feet per person.
EPA had conducted space assessments in 2005 and 2007. Given the under-utilized
space disclosed by the OIG, the Agency needs to further assess utilization of
GSA-owned and leased facilities and consider relocating staff to reduce under-
utilized space.
EPA Needs to Establish Space Guidelines for Support Spaces
EPA's normal practice is to make a determination 5 years before a lease expires
whether the Agency will stay in its current location or put out a request for
proposals for new space. As part of this process, EPA performs a space
assessment to determine space requirements. However, EPA's draft 2011 space
guidelines do not include specific guidelines for support spaces.
In a 2005 rent analysis conducted by an EPA contractor, the contractor
recommended that EPA define and allocate support spaces (training, conference,
filing rooms, etc.) based on the actual requirements for these spaces. However,
FMSD performs an overall assessment of space on a case-by-case basis when a
lease is up for renewal. The Chief of FMSD's Architecture, Engineering and
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Asset Management Branch explained that during the assessment, support space is
determined by need at the individual facility. EPA's July 2004 Space Acquisition
and Planning Guidelines describe the approximate size and frequency of special
spaces typically found in EPA facilities. However, EPA's October 2011 draft
New Mobile Work Space Design Guidelines focus on workstations and offices.
It generally describes what should be in the support space but does not include
specific space allowance guidelines for these spaces. Establishing guidelines,
analyzing the support space specifically based on need, and determining that it is
within the established guidelines are essential in determining whether an office is
sized correctly and fully utilized.
Limitations on Returning Space to GSA
EPA is limited in returning marketable space to GSA. EPA's occupancy
agreement with GSA allows EPA to return marketable space or terminate a lease
with 120 days notice. EPA is locked into long-term lease agreements (10 years)
with GSA unless it can return a marketable space to GSA during the lease.
Otherwise, EPA must remain in place until the lease expires.
Other factors related to space configuration impact the ability of EPA to return
under-utilized space to GSA. For example, EPA Region 3 planned to return an
entire floor and portions of two others to GSA before abandoning such plans for
security reasons. The original GSA lease for the EPA Region 3 building required
space where only government employees could use an elevator bank with access
to its space. Returning the space would potentially have allowed the general
public to have access to the elevator bank and EPA space. In addition, FMSD's
Chief of the Architecture, Engineering and Asset Management Branch said that
the Ariel Rios building and the Colorado building in Washington, DC, along with
the John W. McCormack building in Region 1 (Boston, Massachusetts) are
historic buildings that have corridors and hallways that cannot be reduced.
FMSD's Chief of the Architecture, Engineering and Asset Management Branch
also stated that there is substantial cost involved when the Agency relocates
employees for space reduction; if the cost outweighs the benefits, the Agency will
not implement the space reduction.
EPA Does Not Have a Policy for Determining When Contractors Should
Be On-Site
EPA houses contractors on-site without determining in advance if they should be
housed on-site. Our review of 16 GSA-owned/leased facilities determined that
contractors occupied space in 14 facilities totaling an estimated 197,000 square
feet of EPA space. However, there is no Agency policy outlining what contractor
functions are essential to the Agency and require contractors working on-site, and
program officers are not required to justify the need to house contractors on-site.
EPA spends at least $5.8 million and up to $9.9 million annually housing
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contractors and a policy is needed to ensure contractors are only housed in EPA
space when justified.
EPA Studies and Guidance Address Contractors Being Off-Site
EPA's 2009 Rent Efficiencies Report recommended that EPA explore options to
have contractors located at contractor-provided locations if those contractors are
deemed "non-mission critical" or not meeting on-site qualifying criteria. Also, the
EPA Support Service Contracting Guide states that efforts should be taken to
ensure that contractor employees do not occupy the same space with federal
employees unless it is required.
EPA's Contracts Management Manual, Section 3.2.5, states that program and
regional offices must identify all contracts where the contractor is working at a
government facility and evaluate whether this is appropriate and necessary and,
if not, relocate the place of performance to an off-site location.
No Policy for Determining On-Site Contractors
There is no overarching EPA policy regarding housing contractors on-site in EPA
space. Each region has its own way of determining which contract personnel need
to be housed in EPA space. Often, it is decided on a contract-by-contract basis.
The Special Assistant to the Director of the Office of Acquisition Management
and a senior Region 9 contracting officer confirmed that there is no official EPA
policy regarding contractor personnel being assigned space within EPA
owned/leased facilities. The Special Assistant to the Director of the Office of
Acquisition Management also stated that program officers were not required to
justify the need to house contractors on-site. Without a policy on what contractors
should be provided space in EPA facilities, upfront determinations are not made
on the space that contractors need and EPA may pay for unnecessary contractor
space.
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As of February 2012, EPA spent approximately $9.9 million annually housing
contractors on-site for the 16 sampled facilities (table 5 and appendix C).
Table 5: Cost of housing contactors on-site at 16 sampled facilities

No. of
Annual cost for
Location and building name
contractors
contractor space
R 1-John W. McCormack Building
53
$951,081
R 2-City View Plaza, Puerto Rico
-
-
R 2-Ted Weiss Federal Building
79
1,843,653
R 3-1650 Arch Street
82
549,007
R 5-National Vehicle & Fuel Emissions
36
300,026
R 5-Norwood Professional Building
7
37,716
R 5-Ralph H. Metcalfe Federal Building
58
543,097
R 6-Fountain Place
77
350,906
R 7-901 North 5th Street
11
123,723
R 9-75 Hawthorne Street
59
640,458
R 9-Los Angeles Field Office
3
33,786
R 10-Park Place Building
40
392,863
Subtotal - contractors only
505
$5,766,316
HQ-Ronald Reagan Building
135'
2,193,470
HQ-Ariel Rios Federal Building
117'
1,784,260
HQ-1310 L Street
511
124,330
HQ-Colorado Building
-
-
Subtotal - contractors and
303
$4,102,060
nonfederal personnel


Total
808
$9,868,376
Source: OIG analysis of data in SLATE and from EPA sampled office facility managers as of
February 2012:
1 Calculation includes contractors as well as Senior Environmental Employment enrollees,
and others as FMSD was unable to provide breakdowns.
Conclusion
EPA can potentially achieve up to $21.6 million in cost savings annually by
releasing all under-utilized office space for 13 of the 16 sampled facilities
reviewed. EPA can also potentially save at least $5.8 million and up to
$9.9 million annually by not housing contractors on-site in 14 of the 16 sampled
facilities that housed contractors. EPA's occupancy agreement with GSA allows
EPA to return space or terminate a lease with 120 days notice if it is marketable.
However, EPA is locked into 10-year, long-term lease agreements with GSA for
these office spaces unless it can return a marketable space to GSA during the
lease, and also faces other obstacles in eliminating under-utilized space.
Nonetheless, EPA has the potential to achieve savings when office space is
renovated or relocated, and EPA should continue to pursue reducing under-
utilized space.
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Recommendations
We recommend that the Assistant Administrator for Administration and Resources
Management:
1.	Assess utilization of GS A-owned and leased facilities and relocate staff as
warranted to reduce under-utilized space.
2.	Develop space guidelines for support spaces and assess the number and size
of support spaces needed at the time of a new or renewal lease.
3.	Require the Office of Acquisition Management, in conjunction with the
Office of Administration, to develop and enforce a policy that requires
contracting staff ensure approval for on-site contractor personnel is
obtained from the responsible office and documented in the contract file.
Agency Response and OIG Evaluation
The Agency concurred with the findings and recommendations and provided
milestone dates for the recommendations. The Agency also proposed some
revised language, which we incorporated where appropriate in the report. The
Agency's full response is in appendix D.
The Agency concurred with recommendation 1 and stated that the Office of
Administration and Resources Management (OARM) continues to identify
options throughout program offices and the regions to do work differently in
support of the June 2010 Presidential Memorandum, Disposing of Unneeded
Federal Real Estate. To further this initiative and at the direction of the
Administrator and Chief Financial Officer, OARM is implementing a plan to
reduce the EPA's office space by 20 percent at its leased facilities. In
subsequent discussions, the Agency stated that given the breadth of the
Agency's space consolidation project and the unknowns involved, it is difficult
to provide a meaningful completion date. However, Office of Administration's
projected completion date, based on the availability of sufficient funding, is
December 2022. On December 17, 2012, Craig E. Hooks, Assistant
Administrator issued a memo to EPA's senior leadership on EPA's Space
Redesign Effort. The memo stated that, "To further this effort and at the
direction of the Administrator and Chief Financial Officer, OARM is
implementing a plan to reduce the EPA's office space by 20 percent at our
leased facilities. The plan is to transform agency work space so that it is more
efficient, collaborative and technologically sophisticated, and will reduce the
agency's physical and environmental footprints. ...This is an ambitious,
multiyear, agencywide effort for which I am seeking your support as the EPA's
senior leaders. It will position the agency to better achieve our mission through
greater openness and collaboration; enhance the quality of work life in our
workplace; support the government wide mobile/flexible workplace initiative
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and reduce our energy and greenhouse gas emissions." We agree with the
Agency's corrective action for recommendation 1.
The Agency concurred with recommendation 2 and stated that OARM will
revise the October 2011 draft New Mobile Work Space Design Guidelines to
include support space guidance that will be used for new and renewal leases.
The corrective action is expected to be completed by December 2013. We agree
with the Agency's corrective action for recommendation 2.
The Agency initially did not concur with recommendation 3 to require the Office
of Acquisition Management, in conjunction with the Office of Administration, to
develop and enforce a policy that requires justification for contractor personnel
to utilize on-site work space at EPA facilities and confirmation of the
justification by FMSD and regional facility managers. The Agency stated that
decisions regarding on-site contractors are strictly based on the work being
performed. Rather than developing and enforcing a policy, OARM believes
that a more prudent approach would be to require EPA's contracting staff to
ensure that approval for on-site contractor performance is obtained from the
responsible office and documented in the contract file. We agree with the
Agency's proposed language for recommendation 3 and have revised it
accordingly. However, our position remains unchanged for development of a
policy. During the exit conference, OAM stated that it will establish a work
group to develop an agency-wide process with associated guidance, for
consideration for contractor personnel to be housed in on-site, EPA occupied
work space. EPA expects to have this process in place by September 2013. We
agree with the Agency's corrective action for recommendation 3.
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Chapter 3
Personnel and Usable Square Feet Data in SLATE
Not Updated Timely
EPA lacks accurate, current, and complete information on the number of
personnel and usable square feet (USF) in SLATE for its GSA-owned/leased
offices. As of April 2012, SLATE had incorrect personnel information for 13 of
the 16 facilities sampled (81 percent), and 5 of 16 facilities sampled (31 percent)
had incorrect information on USF. SLATE recorded a net 548 more personnel
than what EPA had working in the sampled facilities and listed a net 235,918
fewer USF than the sampled facilities had. Additionally, the entire USF of
325,128 for the Region 5 Ralph H. Metcalfe building was not reported in SLATE;
it only reported rental square feet in SLATE. This occurred because updates to
SLATE are sporadic and inconsistent. Inaccurate data in SLATE hamper EPA's
ability to make informed decisions for managing its facilities.
SLATE and Its Data Quality and Integrity Important
The SLATE system describes SLATE as follows:
SLATE is a Web-based, comprehensive management and strategic
planning system developed for use by those responsible for real
property management at EPA. SLATE is designed to maintain and
allow viewing of all EPA facilities, including building plans, lease
information, photographs, personnel, space and energy usage,
budget requests, cost, and construction project tracking.
SLATE allows a user to submit and maintain facility level data as well as to view,
create reports on, and print a wide range of facility information. The system tracks
construction projects from their planning stages through the budget process and
supports design, construction, and commissioning by maintaining drawings,
photographs, contracts, work plans, and other supporting project data. SLATE
also provides space use analyses of EPA buildings and allows EPA to do long-
term planning for buildings and facilities budgets.
FMSD's Standards of Behavior for Strategic Lease and Asset Tracking Enterprise
(SLATE), Section 2.5, Integrity, states, "Employees shall protect the integrity and
quality of information." Section 2.5.1 requires employees to "[rjeview the quality
of information as it is collected, generated, and used to make sure it is accurate,
complete and up-to-date."
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Personnel Information in SLATE Not Accurate
As of April 2012, SLATE had incorrect personnel information for 13 of the 16
facilities sampled, or 81 percent (table 6). Personnel information is the number of
employees and other non-federal staff in each facility. Personnel numbers include
full-time EPA employees, Stay-in-Schools, Senior Environmental Employment
enrollees, and on-site contractor personnel.
Table 6: Comparison of personnel information for 16 sampled facilities



Personnel

Per facility
Per
over/(under)
Location and building name
managers
SLATE
in SLATE
%
HQ-Ariel Rios Federal Building
1,649
1,649
-
-
HQ-1310 L Street
500
570
70
14%
HQ-Ronald Reagan Building
1,137
1,137
-
-
HQ-Colorado Building
17
20
3
18%
R 1-John W. McCormack Building
697
845
148
21%
R 2-Ted Weiss Federal Building
851
851
-
-
R 2—City View Plaza, Puerto Rico
63
60
(3)
(5%)
R 3-1650 Arch Street
1,084
1,133
49
5%
R 5-Ralph H. Metcalfe Federal Building
1,390
1,558
168
12%
R 5-National Vehicle & Fuel Emissions
282
235
(47)
(17%)
R 5-Norwood Professional Building
115
85
(30)
(26%)
R 6-Fountain Place
1,084
1,052
(32)
(3%)
R 7-901 North 5th Street
631
700
69
11%
R 9-75 Hawthorne Street
987
1,160
173
18%
R 9-Los Angeles Field Office
29
25
(4)
(14%)
R 10-Park Place Building
685
669
(16)
(2%)
Total
11,201
11,749
548
4.89%
% of facilities not updated in SLATE
81.25%
Source: Data from SLATE and facility managers as of April 13, 2012.
FMSD does not require facility managers to update personnel information on a
systematic or regular basis and there is no quality assurance or verification of this
data in SLATE. The Chief of FMSD's Architecture, Engineering and Asset
Management Branch stated that personnel information is entered into SLATE at
the time the Occupancy Agreement/Lease is signed with GSA, and it is only
updated when an office is realigned or is in the process of being moved or
relocated. In addition, the FMSD SLATE project manager said that FMSD does
not track personnel numbers in SLATE because it is a "moving target." Further,
facility managers determine personnel numbers in a variety of different ways,
including:
•	Information Services Information System-regionally developed system
•	Systematic basis when in the process of a move
•	Employee directory database
•	Roster database
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USF Information in SLATE Not Accurate
As of April 2012, SLATE had incorrect USF information for 5 of the 16 facilities
sampled, or 31 percent (table 7).
Table 7: Comparison of USF information for 16 sampled facilities
Location and building name
USF per
FMSD
USF per
SLATE
USF over/(under)
in
SLATE
%
HQ-Ariel Rios Federal Building
446,324
446,324
-
-
HQ-1310L Street
123,279
135,901
12,622
10%
HQ-Ronald Reagan Building
230,664
230,664
-
-
HQ-Colorado Building
9,667
9,667
-
-
R 1-John W. McCormack Building
224,261
224,261
-
-
R 2-Ted Weiss Federal Building
243,057
269,834
26,777
11%
R 2-City View Plaza, Puerto Rico
19,700
19,700
-
-
R 3-1650 Arch Street
268,968
268,968
-
-
R 5-Ralph H. Metcalfe Federal Building
325,128
-
(325,128)
(100%)
R 5-National Vehicle & Fuel Emissions
59,100
59,100
-
-
R 5-Norwood Professional Building
28,594
28,594
-
-
R 6-Fountain Place
239,130
239,130
-
-
R 7-901 North 5th Street
182,554
182,554
-
-
R 9-75 Hawthorne Street
204,014
253,919
49,905
24%
R 9-Los Angeles Field Office
13,907
13,813
(94)
(1%)
R 10-Park Place Building
154,006
154,006
-
-
Total
2,772,353
2,536,435
(235,918)
(8.51%)
% of facilities not updated in SLATE
31.25%
Source: FMSD and SLATE as of April 13, 2012.
Similar to SLATE's personnel information, the Chief of FMSD's Architecture,
Engineering and Asset Management Branch said that USF information is entered
into SLATE at the time the Occupancy Agreement/Lease is signed with GSA, and
there is no quality assurance or verification of this data in SLATE. In addition,
this information is updated only when the lease is renewed or when EPA gives up
space. FMSD provided the following examples of where USF was not updated in
SLATE:
•	San Francisco office—It was under a third lease extension due to the
design/construction for a succeeding lease.
•	Los Angeles field office—A reduction in space is planned, and the realty
specialist was waiting for information on the reduction's scope.
•	New York office—It was not updated as GSA re-measured the building.
•	1310 L Street building at HQ, and Chicago facilities—It was not timely
updated due to an inadvertent oversight.
Accurate information on personnel and USF is a key component in determining
under-utilized office space and in determining office requirements when an office
space is realigned or relocated. For our calculation of under-utilized space for our
16 sampled offices, we had to obtain the updated personnel information for the
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audit from the regional facility managers of the 16 sampled facilities and updated
information on USF from the Chief of FMSD's Architecture, Engineering and
Asset Management Branch. Inaccurate personnel and USF data in SLATE on
GSA-owned/leased offices hampers EPA's ability to make informed decisions for
managing its facilities.
Number of Facilities in SLATE Not Accurate
As of April 2012, information in SLATE showed 172 EPA facilities but showed
one of those facilities as a "Nationwide" facility with no data. This should not be
considered a facility for listing purposes. Another line item, "La Plaza Building
(Off Campus Facilities)," in Region 9, was a duplicate entry; it was a summary of
five offices also listed. These two line items should not be listed in SLATE, and
the total number of facilities in SLATE should have only been 170.
Conclusion
EPA lacks sufficiently accurate, complete, and up-to-date information on the
number of personnel and USF in SLATE for its GSA-owned/leased offices. If this
information is not updated on a systematic basis, EPA's ability to make informed
decisions for managing its facilities is hampered.
Recommendations
We recommend that the Assistant Administrator for Administration and Resources
Management:
4.	Require that personnel information be consistently tracked and updated in
EPA's designated real property management system on an annual basis or
more often if needed.
5.	Require FMSD to update USF information whenever a change in office
space is made.
Agency Response and OIG Evaluation
The Agency concurred with the findings and recommendations, and provided
milestone dates for the proposed corrective actions. The Agency's full response is
in appendix D.
The Agency concurred with recommendation 4 and stated that OARM is
developing a process whereby facility mangers will be required to update
personnel data in the designated real property asset management system.
SLATE is no longer an active system. FMSD staff will provide oversight to
ensure updates are provided. The corrective action is expected to be
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completed by December 2013. We agree with the Agency's corrective action
for recommendation 4.
The Agency concurred with recommendation 5 and stated that OARM has an
internal policy to update the usable square feet of any agency facility once the
EPA assumes or releases occupancy of space. F acility managers will update
the usable square feet which will be audited by FMSD staff. The corrective
action is expected to be completed by December 2013. We agree with the
Agency's corrective action for recommendation 5.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
POTENTIAL MONETARY
BENEFITS (In $000s)
Rec.
No.
Page
No.
Subject
Status1
Action Official
12 Assess utilization of GSA-owned and leased
facilities and relocate staff as warranted to reduce
under-utilized space.
12 Develop space guidelines for support spaces and
assess the number and size of support spaces
needed at the time of a new or renewal lease.
12 Require the Office of Acquisition Management, in
conjunction with the Office of Administration, to
develop and enforce a policy that requires
contracting staff ensure approval for on-site
contractor personnel is obtained from the
responsible office and documented in the contract
file.
Planned
Completion
Date
Claimed
Amount
Ag reed-To
Amount
Assistant Administrator for	December
Administration and	2022
Resources Management
Assistant Administrator for	December
Administration and	2013
Resources Management
Assistant Administrator for	September
Administration and	2013
Resources Management
17 Require that personnel information be consistently
tracked and updated in EPA's designated real
property management system on an annual basis
or more often if needed.
Assistant Administrator for December
Administration and	2013
Resources Management
17 Require FMSD to update USF information
whenever a change in office space is made.
Assistant Administrator for December
Administration and	2013
Resources Management
O = recommendation is open with agreed-to corrective actions pending
C = recommendation is closed with all agreed-to actions completed
U = recommendation is unresolved with resolution efforts in progress
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Appendix A
Details on Scope and Methodology
We reviewed EPA's Metropolitan Architects and Planners contract for information on EPA
contract space reduction activities. We also reviewed EPA's Asset Management Plan, EPA's
Real Property Cost Savings and Innovation Plan, EPA's Space Acquisition and Planning
Guidelines, and draft Mobile Work Space Design Guidelines, to determine EPA's criteria and
methodology for managing space and identifying and realizing real property cost savings.
We reviewed space consolidation efforts such as the 2009 EPA Rent Efficiencies Report, EPA's
master rent avoidance charts, and the Metropolitan Architects and Planners' October 2005 final
report US EPA Nationwide Rent Analysis. We verified EPA's rental space and cost reduction
accomplished to its records. We verified GSA's Rent-On-Web annual operating costs in SLATE
to billings in GSA's Rent-On-Web website. We also obtained updated head counts from regional
facility managers and USF from FMSD.
We reviewed fiscal years 2010 and 2011 Integrity Act Annual Assurance Letters for EPA's
OARM and Office of the Administrator to determine whether those letters identified any
weaknesses related to property and space reduction. The letters did not identify such weaknesses.
Methodology to Select Sample and Calculate Cost Savings
To select a sample of EPA facilities for review, we:
•	Obtained a listing of facilities in SLATE. We determined that there were 170 facilities
that EPA used as of November 2011 at an annual operating cost of approximately
$279 million.
•	Analyzed the 170 EPA facilities. We excluded laboratories because, in July 2011, the
U.S. Government Accountability Office reviewed laboratories that mainly consisted of
EPA-owned facilities. We also excluded warehouses, parking spaces, storage rooms, and
child care facilities because they had low annual costs. We used the remaining 92
owned/leased and EPA special use offices for the audit universe. These facilities have
total annual operating costs of approximately $206 million, which is approximately
74 percent of the annual operating cost of the 170 facilities.
•	Using GSA's recommended federal benchmark of 190 USF per person, selected sample
offices for review that had a potential annual cost savings of over $225,000. This came to
16 offices with total operating costs of approximately $135 million and potential annual
savings of $31.8 million.
•	Calculated under/over-utilized space for the 16 sampled offices based on EPA's internal
standard of 210 USF per person and GSA's federal benchmark of 190 USF per person
(appendix B).
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To calculate potential cost savings, we:
•	Divided office USF by number of personnel and compared it to the EPA rate of 210 per
person, thus arriving at under-utilized USF per person.
•	Multiplied under-utilized USF per person by number of personnel to arrive at total under-
utilized USF for the building.
•	Divided annual operating cost by office USF to arrive at operating cost per USF.
•	Multiplied total under-utilized USF for the building by annual operating cost per USF to
arrive at potential cost savings.
Prior Reports
In January 2009, the OIG issued Report No. 09-P-0080, Congressionally Requested Report on
EPA Staffing Levels and Total Costs for EPA Facilities. This report provided Congress with
information on staffing levels, rental/lease fees, and utility and security costs for all EPA
facilities and locations where EPA incurred employee-associated costs.
We reviewed the U.S. Government Accountability Office's July 2011 Report No. GAO-11-347,
To Better Fulfill Its Mission, EPA Needs a More Coordinated Approach to Managing its
Laboratories, to determine whether EPA laboratories should be included in our audit. As a result
of that report, we decided to exclude laboratories.
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Appendix B
Calculations for Under-Utilized Space and
Excess Cost for 16 Sampled Facilities
Using EPA's 210 USF per person
Location and
building name
USF
Personnel
Current
Under-
utilized
Total
under-
utilized
USF
Annual operating
Excess
annual
operating
cost
USF per person
cost
cost
per USF
HQ-Ariel Rios Building
446,324
1,649
271
61
100,589
$25,130,427
$56.31
$5,664,167
R 2-Ted Weiss Building
243,057
851
286
76
64,676
19,824,229
81.56
5,274,975
R 1-John W. McCormack
224,261
697
322
112
78,064
12,497,786
55.73
4,350,507
R 7-901 North 5th Street
182,554
631
289
79
49,849
7,110,492
38.95
1,941,619
R 5-Ralph H. Metcalfe
325,128
1390
234
24
33,360
13,023,915
40.06
1,336,402
R 3-1650 Arch Street
268,968
1,084
248
38
41,192
7,262,002
27.00
1,112,184
R 10-Park Place Building
154,006
685
225
15
10,275
6,727,108
43.68
448,812
R 2-City View Plaza, PR
19,700
63
313
103
6,489
1,193,687
60.59
393,169
HQ-Colorado Building
9,667
17
569
359
6,103
547,545
56.64
345,674
R 6-Fountain Place
239,130
1,084
221
11
11,924
4,928,459
20.61
245,754
R 9-Los Angeles Field Off
13,907
29
480
270
7,830
326,437
23.47
183,770
HQ-310 L Street
123,279
500
247
37
18,500
1,216,534
9.87
182,595
R 5-Norwood Prof. Building
28,594
115
249
39
4,485
618,300
21.62
96,966
R 5-Nat'l Vehicle & Fuel 1
59,100
282
210
Utilized
-
2,345,783
39.69
-
R 9-75 Hawthorne Street2
204,014
987
207
Utilized
-
10,692,122
52.41
-
HQ-Reagan Building J
230,664
1,137
203
Utilized
-
18,463,553
80.05
-
Total
2,772,353
11,201


433,336
$31,908,379

$21,576,594
Source: Source: OIG analysis of EPA data provided by FMSD and regional facility managers.
1	Due to using 210 USF and increased personnel head count, the audit result disclosed that it is utilized.
2	Due to using 210 USF and decreased USF and personnel head count, the audit result disclosed that it is utilized.
3	Due to using 210 USF, the audit result disclosed that it is utilized.
Descriptions for above table
Column description
Calculation formula
Usable square feet (USF)
Provided by FMSD
Personnel
Provided by regional facility managers
Current USF per person
Usable square feet divided by personnel
Under-utilized USF per person
Current USF per person minus 210 USF
Total under-utilized USF
Under-utilized USF per person times personnel
Annual operating cost
Obtained from SLATE as of 2/1/2012
Annual operating cost per USF
Annual cost divided by USF
Excess annual operating cost due to total under-utilized USF
Annual operating cost per USF times total under-utilized USF
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Using 190 USF per person
Location and building name
USF
Net usable
plus
circulation
square feet
Personnel
USF
Undercover)
utilized
Per person
HQ-Colorado Building
9,667
6,434
17
378
188
R 2-Ted Weiss Federal Building
243,057
187,542
851
220
30
HQ-Ariel Rios Federal Building
446,324
330,888
1,649
201
11
R 1-John W. McCormack Building
224,261
128,250
697
184
(6)
R 5-Ralph H. Metcalfe Federal Building
325,128
224,855
1,390
162
(28)
R 7-901 North 5th Street
182,554
110,668
631
175
(15)
HQ-1310 L Street
123,279
87,635
500
175
(15)
R 3-650 Arch Street
268,968
185,282
1,084
171
(19)
R 9-75 Hawthorne Street
204,014
146,321
987
148
(42)
R 6-Fountain Place
239,130
155,253
1,084
143
(47)
HQ-Ronald Reagan Building
230,664
167,536
1,137
147
(43)
R 10-Park Place Building
154,006
93,788
685
137
(53)
R 2—City View Plaza, Puerto Rico
19,700
Information not
provided
63
N/A
N/A
R 5-National Vehicle & Fuel Emissions
59,100
Information not
provided
282
N/A
N/A
R 5-Norwood Professional Building
28,594
Information not
provided
115
N/A
N/A
R 9-Los Angeles Field Office
13,907
Information not
provided
29
N/A
N/A
Total
2,772,353

11,201


Source: Data provide by FMSD and facility managers as of February 2012.
Descriptions for above table
Column description
Calculation and Source
Usable square feet
Provided by FMSD
Net usable plus circulation square feet
Offices, cubicles, conference rooms, and hallways
Personnel
Provided by facility managers
USF per person
Net use plus circulation square feet divided by personnel
Undercover) utilized at 190 USF per person
USF per person minus 190
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Appendix C
Cost of Housing Contractors On-Site
at 16 Sampled Facilities
Location and building
name
USF
Personnel
Current
USF per
person
No of
USF for
%of
USF for
Annual operating
contractors
cost
cost for
contractors
R 1-John W. McCormack
224,261
697
322
53
17,066
7.61%
12,497,786
951,081
R 2-Ted Weiss Building
243,057
851
286
79
22,594
9.30%
19,824,229
1,843,653
R 2-City View Plaza, PR
19,700
63
313
-
-
0.00%
1,193,687
-
R 3-1650 Arch Street
268,968
1,084
248
82
20,336
7.56%
7,262,002
549,007
R 5-Ralph H. Metcalfe
325,128
1390
234
58
13,572
4.17%
13,023,915
543,097
R 5-Nat'l Vehicle & Fuel
59,100
282
210
36
7,560
12.79%
2,345,783
300,026
R 5-Norwood Prof. Building
28,594
115
249
7
1,743
6.10%
618,300
37,716
R 6-Fountain Place
239,130
1,084
221
77
17,017
7.12%
4,928,459
350,906
R 7-901 North 5th Street
182,554
631
289
11
3,179
1.74%
7,110,492
123,723
R 9-75 Hawthorne Street
204,014
987
207
59
12,213
5.99%
10,692,122
640,458
R 9-Los Angeles Field Off
13,907
29
480
3
1,440
10.35%
326,437
33,786
R 10-Park Place Building
154,006
685
225
40
9,000
5.84%
6,727,108
392,863
Subtotal - contractors
only
1,962,419
7,898

505
125,720

86,550,320
5,766,316
HQ-Reagan Building*
230,664
1,137
203
135 1
27,405
11.88%
18,463,553
2,193,470
HQ-Ariel Rios Building
446,324
1,649
271
117 1
31,707
7.10%
$25,130,427
1,784,260
HQ-1310 L Street*
123,279
500
247
51 1
12,597
10.22%
1,216,534
124,330
HQ-Colorado Building
9,667
17
569
-
-
0.00%
547,545
-
Subtotal - contractors &
nonfederal personnel
809,934
3,303

303
71,709

45,358,059
$ 4,102,060
Total
2,772,353
11,201

808
197,429

$131,908,379
$ 9,868,376
Source: OIG analysis of data in SLATE and from EPA sampled office facility managers as of February 2012.
1 Calculation includes contractors as well as Senior Environmental Employment enrollees and others as FMSD was unable to
provide breakdowns.
Descriptions for above table
Column description
Calculation formula
Current USF per person
USF divided by personnel
No. of contractors
Provided by facility managers
USF for contractors
Current USF per person times number of contractors
% of USF for contractors
USF for contractors divided by USF
Annual operating cost
Obtained from SLATE as of 2/1/2012
Annual cost for contractors
Annual operating cost times percentage of contractors
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Appendix D
Agency Response to Draft Report

PROTECTION AGENCY
WASHINGTON. D.C. 20460
tfov - 5 i::
SUMHM
§1 BJKC 1 • Response to Drift Report: EPA Cm Further Reduce Space in Under-Utilized Facilities
, / /
FROM:	fiwift R l-lnsfilre A«eie#a«l &.titmmmirtatr%e / ' V I
Thank you for the opportunity to review and comment on the draft report (Project No. OA-
FY12-0056), dated October 4, 2012. In the attachment we are providing clarification of three
issues pertaining to factual accuracy and a discussion regarding our concurrence or
nonconcurrence with your five proposed recommendations.
If you have any questions pertaining to this response, please contact Renee Page, Director,
Office of Administration, at (202) 564-8400.
Attachment
cc: Renee Page
Office of lr, spec: or General
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Office of Administration and Resources Management
Response to Draft Report: Project No. OA-FY12-0056
EPA Can Further Reduce Space in Under-Utilized Facilities
Issues pertaining to factual accuracy
Report language in Executive Summary and on page 12: "EPA omitted reporting in SLATE
an entire Region 5 building (325,128 USF)."
According to the methodology on page 17, you obtained a listing of facilities in
SLATE as of November 2011, and determined that the Ralph H. Metcalfe Federal
Building was not included. This is an incorrect conclusion. An April28, 2011,
SLATE report already included the building in the inventory.
Report language on page 11: "Both GSA and EPA recognize that the average office
space can be reduced to 60 square feet in upcoming years."
The referenced document containing the GSA's60 square foot number is the
GSA'sJuly 2011 report, Workspace Utilization and Allocation Benchmark, as indicated
on page 4 of the draft. This GSA document hypothesises that the 60 square feet
could be achieved only through extensive use of alternative workspace
arrangements, such as hoteling, home office and teleworking on a fulltime basis.
The EPA's current policy limits telework to no more than two days per week and
would therefore have to be modified. Such a significant change has already been
the subject of extensive negotiation and delay. Hence, at this time, the EPA does
not recognize that the average office space can be reduced to 60 square feet in
upcoming years."
Report language on page 8: "Also, EPA's 2011 draft New Mobile Work Space DesignGuidelines
require a typical work station to be up to 60 USF and a telework station up to 30 USF per
person; both are substantial space reductions from the 210 USF per person used in our
analysis."
The guideline numbers of 60 and 30 USF are not considered reductions from the
210 square feet per person number, which incorporates required space outside the
actual workstation for circulation, filing, conferencing, collaboration and small
meeting rooms. A reasonable design reduction from 210 square feet would be 175
square feet per person.
Comments pertaining to concurrence or nonconcurrence with proposed recommendations
Chapter 2 — "EPA Can Further Strive for Space Reduction"
1. Assess utilization of GSA-owned and leased facilities and relocate staff as
warranted to reduce under-utilized space.
OARM response: Concur Anticipated completion - ongoing
The EPA's space consolidation efforts have been ongoing since 2007. OARM
continues to identify options throughout program offices and the regions to do
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work differently in support of the June 2010 Presidential Mem orandum, Disposing
of Unneeded Federal Real Estate. To further this initiative and at the direction of the
Administrator and Chief Financial Officer, OARM is implementing a plan to
reduce the EPA's office space by 20 percent at its leased facilities. The redesign
plan has already been implemented in the new Kansas City Regional Office and
plans are underway to incorporate collaboration, greater mobility and advanced
technology into the design of the new Region 9 offices. In Headquarters, several
pilot projects are in development that will also demonstrate open design principles.
Inaddition, we are in the process of relocating two offices within the Office of the
Administrator that will release more than 19,000 square feet of leased office space
and realize almost $lMin annual rent avoidance beginning in FY2013.
2.	Develop space guidelines for support spaces and assess the number and size of
support spaces needed at the time of a new or renewal lease.
OARM response: Concur	Anticipated completion - December 2013
The agency has guidance per the July 2004 Space Acquisition and Planning
Guidelines that describe the approximate size and frequency of special spaces
typically found at EPA facilities. OARM will revise the October 2011 draft New
Mobile Work Space Design Guidelines to include support space guidance that will be
used for new and renewal leases.
3.	Require the Office of Acquisition Management, in conjunction with the Office of
Administration, to develop and enforce a policy that requires justification for
contractor personnel to utilize on-site work space at EPA facilities and
confirmation of the justification by FMSD and regional facility managers.
OARM response: Does Not Concur
Decisions regarding on-site contractors are strictly based on the work being
performed. Rather than developing and enforcing a policy, OARM believes that a
more prudent approach would be to require the EPA's contracting staff to ensure that
approval for on-site contractor performance is obtained from the responsible office
and documented in the contract file.
Chapter 3 "Personnel and Usable Square Feet Data in SLATE Not Updated Timely"
4.	Require that personnel information be consistently tracked and updated in
EPA's designated real property management system and SLATE on an
annual basis or more often if needed.
OARM response: Concur	Anticipated completion - December 2013
OARM is developing a process whereby facility mangers will be required to
update personnel data in the designated real asset management system. Facilities
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Management and Services Division staff will provide oversight to ensure updates
are provided. SLATE is no longer an active system.
5. Require FMSD to update USF information whenever a change in the office
space is made.
OARM response: Concur	Anticipated completion - December 2013
OARM has an internal policy to update the usable square feet of any agency facility
once the EPA assumes or releases occupancy of space. As noted in the response to
recommendation 4 above, facility managers will update the usable square feet which
will be audited by FMSD staff.
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Appendix E
Distribution
Office of the Administrator
Assistant Administrator for Administration and Resources Management
Director, Office of Acquisition Management, Office of Administration and Resources Management
Director Office of Administration, Office of Administration and Resources Management
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for External Affairs and Environmental Education
Audit Follow-Up Coordinator, Office of Administration and Resources Management
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