dhs headquarters consolidation location...

DHS Headquarters Consolidation Location Analysis

SEPTEMBER 2008

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Table of Contents

A. Introduction page 4

B. GSA’s Role in Fulfilling Customer Requirements page 5

C. Secure Space page 9

D. DHS Need for Consolidated Space in the NCR page 12

E. Related Legislation page 13

F. Evaluation of Federally Owned Sites in the NCR page 15

G. Non-Federally Owned Sites page 52

H. Non-Federally Owned Sites – Acquisition page 54

I. Non-Federally Owned Sites – Lease page 58

J. Overall Conclusion page 64

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DHS Headquarters Consolidation Location Analysis

A. Introduction

The U.S. General Services Administration (GSA) is responsible for fulfilling Federal agencies’ real estate needs. In that capacity, GSA, when presented with an agency program, rigorously explores alternative methods of delivering the requirement such as utilizing space within GSA’s inventory, acquiring land, and leasing.

The Department of Homeland Security requested that GSA fulfill its requirement of collocating 4.5 million gross square feet (GSF) of office space plus parking for a total of approximately 6.4 million GSF (see DHS Consolidated Headquarters Collocation Plan in Appendix A). This Headquarters Consolidation Location Analysis provides an overview of GSA’s different approaches to delivering agency needs and summarizes the results of GSA’s efforts to accommodate the DHS program.

Since developing its headquarters consolidation requirements, and in response to comments on the Draft EIS, DHS has re-examined its requirements in order to find a way to minimize harm to the national historic landmark St. Elizabeths Campus. DHS has determined that, under the proper conditions, it would be possible to split its 4.5 million GSF requirement into two development parcels, one for 3.8 million GSF and one for 0.75 million GSF. DHS has stated that its ability to split its headquarters functions in this manner is dependent upon several conditions, including a requirement that the parcels are adjacent to one another and both provide the security level required by DHS. GSA has initiated discussions with the District of Columbia (DC) concerning its development plans for the St. Elizabeths East Campus that DC owns and controls. An area of the East Campus has been identified to study further as a possible location for a portion of DHS’ requirement. In light of DHS' determination that it could allow development of one component of its consolidated headquarters to be located on an adjacent parcel, GSA re-evaluated its location alternatives analysis to determine if any sites that were rejected due to insufficient size had sufficient land adjacent to the site that could be used to meet DHS' co-location requirement of 4.5 million GSF. GSA also re-examined available properties in the private sector to determine what, if any, sites were available that could accommodate DHS’ requirements either altogether on one site or spread between two adjacent sites.

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B. GSA’s Role in Fulfilling Customer Requirements

B.1. Overview

The U.S. General Services Administration (GSA) is an independent Federal executive agency.1 GSA’s Public Buildings Service works with other Federal agencies in determining and fulfilling those agencies’ real estate space needs – GSA’s experience and expertise allow it to effectively deliver Federal agencies’ real estate requirements. GSA’s knowledge results in time and cost savings for other Federal agencies, and ultimately the American taxpayer.

Federal agencies give GSA information on their program and mission requirements. GSA then works with those agencies to develop and refine their real estate space needs. GSA’s familiarity with the market and available space, Federal procurement, and innovative and proven methods of space design all result in the delivery of efficient work environments. Project requirements are based on the customer agency’s overall needs, facility and parking requirements, and operational needs.2 Through early joint planning, GSA works with agencies to shorten and simplify the space delivery process and provide space at the most reasonable cost to the government.

GSA is authorized to acquire any site which is deemed necessary to carry out GSA’s customers’ needs3 and to assign space for an executive agency in any Federal government-owned building.4

In accordance with Executive Order 120725, “site selection and space assignments take into account the management needs for consolidation of agencies or activities in common or adjacent space in order to improve administration and management and effect economies.”

5 1 40 USC § 301

2 GSA, Public Buildings Service, Office of the Chief Architect, March 2003.

3 40 USC § 3304

4 40 USC § 584

5 Federal Space Management, JIMMY CARTER, August 16, 1978.

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B.2. Prioritized Use of Government-Controlled Buildings/Sites versus Leased Buildings/Sites and Newly Acquired Buildings/Sites

When analyzing an agency’s needs and assigning space, GSA bases its recommendations on local market conditions, available vacant space, principles of professional space management, and the customer agency’s mission. GSA’s development decisions are guided by the principles laid out in Executive Order 13327: Federal Real Property Asset Management as established by the Federal Real Property Council (the Council). The Council’s ten guiding principles, applicable to Federal real property asset management are to:

1. Support agency missions and strategic goals

2. Use public and commercial benchmarks and best practices

3. Employ life-cycle cost-benefit analysis

4. Promote full and appropriate utilization

5. Dispose of unneeded assets

6. Provide appropriate levels of investment

7. Accurately inventory and describe all assets

8. Employ balanced performance measures

9. Advance customer satisfaction

10. Provide for safe, secure, and healthy workplaces

GSA satisfies customer agencies’ requests for space by first attempting to reassign available space in its inventory.6 In accordance with 41 CFR § 102-75.25, before it purchases non-Federal real property, GSA fulfills real estate needs by utilizing real property determined excess by other federal agencies. As well, 41 CFR § 102-73.255 directs GSA to consider the maximum utilization of Government-owned land prior to the purchase of a privately owned site. Further, GSA considers the lease of privately-owned land and buildings only when needs cannot be met satisfactorily in Government-controlled space, consistent with 41 CFR § 102-73.45.

As a general matter, GSA uses Federally-owned sites or space whenever practicable to meet requirements for computer and telecommunications operations, secured areas for national security or defense, or permanent court space for the judiciary. GSA uses Federally-owned sites or space as much as possible whenever it is adequate, economically adaptable to agencies’ requirements, and properly located. 6 6 See Footnote 1, supra.

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B.3. Certain Local Redevelopment and Historic Preservation Considerations in Locating Federal Agencies

In carrying out its duties to provide office space to Federal agencies, GSA is obligated to acquire and utilize space in suitable buildings of historical, architectural, or cultural significance unless use of the space would not prove feasible and prudent compared with available alternatives.7 Under 41 CFR § 102-73.255 “prior to acquiring, constructing, or leasing buildings (or sites for such buildings), [GSA] must use, to the maximum extent feasible, historic properties available to the agency.”

This requirement has been further enunciated by various Executive Orders. Under Executive Order 115938:

“Agencies of the executive branch of the Government shall…initiate measures necessary to direct their policies, plans and programs in such a way that federally owned sites, structures, and objects of historical, architectural or archaeological significance are preserved, restored and maintained….”

As well, under Executive Order 130069:

“When operationally appropriate and economically prudent…when locating Federal facilities, Federal agencies shall give first consideration to historic properties within historic districts. If no such property is suitable, then Federal agencies shall consider other developed or undeveloped sites within historic districts. Federal agencies shall then consider historic properties outside of historic districts, if no suitable site within a district exists.”

Further, under Executive Order 1328710:

“It is the policy of the Federal Government to provide leadership in preserving America's heritage by actively advancing the protection, enhancement, and contemporary use of the historic properties owned by the Federal Government…. The Federal Government shall recognize and manage the historic properties in its ownership as assets

7 7 40 USC § 3306

8 Protection and Enhancement of the Cultural Environment, RICHARD NIXON, May 6, 1971.

9 Locating Federal Facilities on Historic Properties in Our Nation’s Central Cities, WILLIAM JEFFERSON CLINTON, May 21, 1996.

10 Preserve America, GEORGE W. BUSH, March 3, 2003.

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that can support department and agency missions while contributing to the vitality and economic well-being of the Nation's communities and fostering a broader appreciation for the development of the United States and its underlying values. Where consistent with executive branch department and agency missions, governing law, applicable preservation standards, and where appropriate, executive branch departments and agencies shall advance this policy through the protection and continued use of the historic properties owned by the Federal Government…to promote the preservation of the unique cultural heritage of communities and of the Nation and to realize the economic benefit that these properties can provide.”

Note however, that Executive Order 13287 is not intended to require an agency to take any action that would conflict with or compromise national and homeland security goals, policies, programs, or activities.11

Finally, GSA also considers the redevelopment of U.S. cities when it locates Federal offices. Under Executive Order 1207212:

“Federal space shall conserve existing urban resources and encourage the development and redevelopment of cities. Procedures for meeting space needs in urban areas shall give serious consideration to the impact a site selection will have on improving the social, economic, environmental, and cultural conditions of the communities in the urban area.”

GSA is committed to maximizing the returns on its Federal real estate investment and to leveraging its investments in ways that support communities, wherever possible.13 GSA recognizes that collaboration with local officials, neighboring property owners, residents, and appropriate interest groups is essential to shape a given project in ways that provide positive benefits to the surrounding neighborhood and community.14

8 11 Ibid.


13 GSA Public Buildings Service Directive PBS-P-100, “Facilities Standards for the Public Buildings Service. (March 2005).

14 Ibid.

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B.4. Seat of Government Act

An additional consideration when locating offices in the National Capital Region is the legislative requirement for certain offices of the U.S. government to be located in the District of Columbia (DC), which requirement dates to 1790. The applicable provisions have been codified in 4 USC §§ 71-72. Under those provisions, the main offices of executive departments are required to be located in DC proper 15 unless a statutory waiver is granted:

“All offices attached to the seat of government shall be exercised in the District of Columbia, and not elsewhere, except as otherwise expressly provided by law.”

C. Secure Space

One of the federal government’s goals has always been to assure the physical safety of federal employees who work in, and the private citizens who visit government-owned or leased buildings. To address the quality and effectiveness of physical security requirements for federal facilities, the Interagency Security Committee (ISC) was created by Executive Order 12977 in 199516, following the domestic terrorist bombing of the Alfred P. Murrah Federal Building in Oklahoma City, OK. When completing new federal office buildings and major modernization projects, federal agencies follow guidance issued by the ISC.

The ISC’s responsibilities include:

establishing policies for security in and protection of federal facilities;

developing and evaluating security standards for federal facilities, developing a strategy for ensuring compliance with such standards, and overseeing the implementation of appropriate security measures in federal facilities; and

taking such actions as may be necessary to enhance the quality and effectiveness of security and protection of federal facilities.

C.1. What are the Various Levels of Security?

In 1995, the U.S. Department of Justice (DOJ) issued a report entitled Vulnerability Assessment of Federal Facilities. In this report, DOJ included security levels designated I

9 15 Location of Federal Government Offices, Congressional Research Service, January 8, 2003. 16 Interagency Security Committee, WILLIAM JEFFERSON CLINTON, October 19, 1995.

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through V for office buildings and minimum security standards for office buildings. According to the Vulnerability Assessment of Federal Facilities;

A Level I building is defined as having not more than 2,500 square feet (sq. ft.) of space, with 10 or fewer federal employees, and little public access.

A Level II building contains between 2,500 to 80,000 sq. ft. and has between 11 and 150 federal employees engaged in routine activities, with a moderate level of public access.

A Level III building is defined as occupying between 80,000 to 150,000 sq. ft. of space, and housing between 151 and 450 federal employees, with a moderate to high volume of public access.

Level IV facilities are categorized as occupying more than 150,000 sq. ft. of space, and housing more than 450 federal employees. Level IV facilities are defined as having “high volume public contact” and include federal courthouses with high-risk court chambers, judicial offices, and buildings that house sensitive government records.

Finally, there are Level V facilities which are similar to Level IV buildings in size and numbers of federal employees. However, the missions of Level V facilities are considered critical to national security and high threat/high profile facilities.

The Central Intelligence Agency headquarters and the Pentagon, for example, are both classified as Level V for security purposes. The missions of Level V facilities require that tenant agencies secure the site according to their own requirements. The degree to which these requirements dictate security features in excess of those for a Level IV facility should be set by the individual agency; however, a Level V facility should meet Level IV guidelines as a baseline.17

The U.S. Department of Homeland Security has determined that its headquarters facility is classified as ISC Level V.

C.2. Interagency Security Committee

In May 2001, the ISC issued its Security Design Criteria for New Federal Office Buildings and Major Modernization Projects, which sets forth facility security requirements based on the security 10 17 Vulnerability Assessment of Federal Facilities, DOJ, 1995.

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levels described in the DOJ Vulnerability Assessment. ISC security requirements for future construction projects included the use of glazing protection for windows, the establishment of distances that buildings should be set back from the street, the control of vehicular access to the buildings, and the location and securing of air intakes.

The September 2001 terrorist attacks on the Pentagon and the World Trade Center renewed concerns about the vulnerability of federal buildings to bombing or other forms of attack. On February 28, 2003, the chairmanship of the ISC was transferred to the Secretary of Homeland Security from the Administrator of General Services by Executive Order 13286.18 In July 2004, based on Homeland Security Presidential Directive/HSPD-7, the ISC began reviewing federal agencies’ physical security plans to better protect the nation’s critical infrastructure and key resources. The ISC issued its updated Security Design Criteria on September 29, 2004, which set forth enhanced physical security requirements for the construction of new federal buildings, as well as for major renovations of existing buildings.

The Security Design Criteria address protection zones of federal facilities, moving from the outer elements in – from the perimeter, including streetscape, parking, and sidewalks, to the building envelope, structural design, and interior components. The Criteria further specify that security planning should begin as soon as a project concept is developed, including during site evaluations and selection. Site security requirements, including perimeter buffer zones should be developed before a site is acquired. This is to prevent the acquisition of a site that lacks necessary features, especially sufficient setback, and to help reduce the need for more costly countermeasures such as blast hardening.

The Criteria note that Crime Prevention Through Environmental Design (CPTED) techniques are an important tool in protecting federal facilities. CPTED utilizes the strategy of employing natural access control and natural surveillance to increase safety and reduce the need for costly engineering measures. Examples of CPTED techniques include using site/design elements as borders that define controlled space and limit access, and locating critical/high risk people and assets away from public areas.

C.3. Elements of Secure Space

Depending on a given facility’s security level various security features apply. A variety of examples follow. For Level IV and Level V facilities, a 100 foot perimeter setback is

11 18 Amendment of Executive Orders, and Other Actions, in Connection With the Transfer of Certain Functions to the Secretary of Homeland Security, GEORGE W. BUSH, February 28, 2003.

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required. For Level IV and Level V facilities, exterior windows must provide ballistic glazing rated at level 3 and 8, respectively. For Level IV and Level V facilities, agencies must protect building ventilation equipment and locate that equipment away from high risk areas. Finally, for Level IV and Level V facilities, adjacent property parking must maintain a 100 foot distance between parked cars and the facility.

A given agency’s need for secure space must be taken into consideration during federal agency project planning.

D. DHS Need for Consolidated Secure Space in the National Capital Region

The U.S. Department of Homeland Security (DHS) requires a minimum of 4.5 million Gross Square Feet, plus parking, to consolidate its headquarters functions and to realign its real estate holdings in the National Capital Region (NCR) that are related to mission execution by departmental headquarters. DHS’ scattered current housing prevents it from accomplishing its mission to the best of its ability. DHS employees are currently scattered widely throughout the NCR. This dispersion results in significant inefficiencies in daily operations, and these inefficiencies are magnified considerably at the most important moments - when DHS must act as a nimble and integrated team responding to significant natural disasters or terrorist threats.

DHS’ mission is to lead a unified national effort to secure America. The lessons learned from Hurricane Katrina and the continued review of DHS organizational structure has reinforced the criticality of action in both the preparation for and the response to national disasters or terrorist attacks. DHS’ mission demands an integrated approach, yet DHS’ legacy facilities and dispersed locations throughout the NCR adversely impact critical communication, coordination and cooperation across the DHS components. To effectively perform its mission, the DHS needs to consolidate executive program leadership in a secure setting for policy, management and operational coordination to facilitate incident management functions and command and control capabilities. This will foster a “one-DHS” culture and optimize DHS’ prevention and response capabilities across the spectrum of operations.

Given the strategic and operational imperative to unify DHS operationally, administratively and culturally, DHS is in the process of implementing comprehensive strategies to tear down stove pipes (that is, to allow various personnel to communicate and operate effectively both within and across various DHS offices) and remove physical barriers that adversely impact

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mission performance. The goal is to promote unity of purpose and effort and to provide the best operational platform for DHS to perform its critically important mission. In order to resolve the physical barriers to improve mission performance, DHS has worked closely with GSA to develop planning level requirements for a consolidated headquarters campus, as well as a detailed Program of Requirements for all DHS and Component Headquarters functions throughout the NCR. DHS has determined that it requires a minimum collocation of 4.5 million Gross Square Feet (GSF) of office space to obtain the needed operational improvements. DHS has also determined that it needs to realign its real estate holdings as soon as possible to enhance mission performance and control costs.

Further detail regarding DHS’ determination of its requirements can be found in the DHS Consolidated Headquarters Collocation Plan and the DHS National Capital Region Housing Master Plan, enclosed herein, in Chapter 2 and Appendix A respectively.

E. Related Legislation

There are a variety of recent legislative actions dealing with St. Elizabeths and DHS. Those actions are discussed briefly below.

E.1. Appropriations

GSA has received the following appropriations in connection with St. Elizabeths:

Design Prospectus for $24,900,000 for the United States Coast Guard Headquarters at St. Elizabeths; authorized by the Senate on July 20, 2005, authorized by the House on October 26, 2005, and appropriated by PL 109-115 on November 30, 2005.

$13,095,000 was appropriated for infrastructure work on St. Elizabeths by PL 109-115, passed November 30, 2005.

Consistent with PL 110-5, (the full year Continuing Appropriations Resolution for FY ’07), GSA will expend $6,440,000 on infrastructure work at the St. Elizabeths appropriated by the Resolution.

E.2. Other Legislative Activity

On July 11, 2006, the Coast Guard Maritime and Transportation Act of 2006 was enacted.19 The Act prohibits the Commandant of the Coast Guard from moving any Coast Guard 13 19 PL 109-241.

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personnel, property, or other assets to St. Elizabeths until the Administrator of General Services submits to the Committee on Transportation and Infrastructure of the House of Representatives and the Committee on Commerce, Science, Transportation, and the Committee on Environment and Public Works of the Senate a plan addressing a variety of issues. GSA has prepared a plan responsive to these provisions of the Coast Guard Maritime and Transportation Act, and has submitted the plan to the relevant Committees.20

Under PL 109-295 (FY 2007 Homeland Security Appropriations Act, passed October 4, 2006) DHS was required to prepare and submit to Congress the DHS National Capital Region Housing Master Plan. This plan, submitted to Congress in October 200621, details DHS’ requirements for housing its headquarters and operating components in the DC area. The Plan identifies a need for DHS to consolidate executive leadership and operational management in a secure setting. DHS also needs to reduce significantly the total number of locations that house DHS components to lower overall costs.

Under PL 109-396, (“The Federal and District of Columbia Real Property Act of 2006”, enacted on December 15, 2006), the District of Columbia is directed to transfer five buildings and related land it owns (totaling less than 10 acres) on the St. Elizabeths West Campus to GSA. Once the transfer is completed, GSA will have care and custody of the entire 176-acre West Campus.

E.3. The President’s Budget for FY’09

On February 4, 2008, the President transmitted his Budget for fiscal year 2009 to the Congress. That budget requested the following funds for new construction for GSA, including funds for sites and expenses and associated design and construction service for the following:

DHS Consolidation and development of St. Elizabeths campus, $331,390,000.

St. Elizabeths Infrastructure, $8,249,000.

St. Elizabeths (Ancillary) Site Acquisition, $7,000,000. (Needed to accommodate vehicular access to the site.)

20 June 29, 2007, GSA Response to PL 109-241. 21 October, 2006, DHS National Capital Region Housing Master Plan,

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Federally Owned Sites under consideration for DHS Headquarters Consolidation

Department of Energy Germantown Campus

Germantown, Maryland

Consumer Product Safety Commission

Gaithersburg, Maryland

Suitland Federal Center

Suitland, Maryland

Federal Research Center at White Oak

Silver Spring, Maryland

Franconia Storage Depot

Franconia, Virginia

US Geological Survey Campus

Reston, Virginia

Cotton Annex

Washington, DC

Southeast Federal Center

Washington, DC

Reservation 13

Washington, DC

Armed Forces Retirement Home

Washington, DC

Robert F. Kennedy Stadium Site

Washington, DC

Nebraska Avenue Complex

Washington, DC

Walter Reed Army Medical Center

Washington, DC

Beltsville Agricultural Research Center

Beltsville, Maryland

St. Elizabeths Campus

Washington, DC

F. Evaluation of Federally-owned sites in the National Capital Region

F.1 Introduction and Methodology

As previously discussed, GSA Project requirements are based on the customer federal agency’s needs, facility and parking requirements, and operational needs.22

In accordance with Executive Order 1207223, “site selection and space assignments take into account the management needs for consolidation of agencies or activities in common or adjacent space in order to improve administration and management and effect economies.”

GSA’s development decisions are guided by the principles laid out in Executive Order 13327: Federal Real Property Asset Management as established by the Federal Real Property Council (the Council) (see p. 3 of this Appendix).

In carrying out its duties to provide office space to Federal agencies, GSA is obligated to acquire and utilize space in suitable buildings of historical, architectural, or cultural significance unless use of the space would not prove feasible and prudent compared with available alternatives.

An additional consideration when locating offices in the National Capital Region is the legislative requirement for certain offices of the U.S. government to be located in the District of Columbia (DC), which requirement dates to 1790.

15 22 GSA, Public Buildings Service, Office of the Chief Architect, March 2003.


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Finally, one of the federal government’s goals has always been to assure the physical safety of federal employees who work in, and the private citizens who visit government-owned or leased buildings.

In order to meet the evaluation criteria (discussed below) for assessing Federally-owned properties in and around the Washington-DC region to house the collocated DHS Headquarters, GSA identified a list of federally-owned sites in the National Capital Region. The table on the previous page provides a listing of each of the sites under consideration. The sites were then evaluated against a series of evaluation criteria.

The evaluation criteria were as follows: (1.) Is there developable land on the site with the potential to meet the DHS need for 4.5 million gross square feet plus parking?24 (2.) Is the site compatible with DHS’ need for Level 5 security? (3.) Is the site within close proximity to the White House and Congress?25 (4.) Is the developable land available for use by DHS? (5.) Can the site accommodate DHS’ FY2013 initial occupancy timetable?26 (6.) Is the site located in close proximity to major roadways? (7.) Is the site located in close proximity to a Metro station? (8.) Does the site have access to neighborhood amenities within walking distance? (9.) If the site does not contain sufficient developable land to meet the DHS need for 4.5 million gross square feet plus parking, does the site have developable land adjacent to it that will accommodate approximately 700,000 GSF of new development plus parking?

F.2. Department of Energy Campus, Germantown, Maryland

The federally-owned 109-acre Germantown Campus is located about 34 miles northwest of Washington, DC in Germantown, Maryland. The campus is located at 16 24 For purposes of evaluating sites for development capacity, GSA utilized existing site plans where available. Those plans include quantities of potential developable space on a given site.

25 For purposes of site comparison distances were calculated from the White House. 26 In several cases, it was determined that sites could not meet the initial occupancy timetable due to the need to develop a relocation strategy for existing site tenants. A relocation strategy would involve the following: A detailed project management plan that states the overall objective and that identifies actions (typical actions include developing programs of requirements, selecting architects, identifying and evaluating sites, identifying and procuring furniture, telecommunications systems, equipment and moving companies, design and constructing and/or leasing new space and decommissioning old space), resources, risks and mitigations and strategies to manage to execute one or multiple moves as required to meet an organization's occupancy objectives.

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the corner of MD Route 118 and I-270 in Montgomery County and currently houses the Department of Energy (DOE).

The campus is currently comprised of seven buildings totaling approximately 600K square feet of space and 1,847 parking spaces. The site is bordered by I-270 to the northeast, MD Route 188 to the northwest and a residential area to the south. The campus is not in proximity to a Metro stop or public transportation.

A 1994 Master Plan conducted by DOE noted that the site has a total of 55 developable acres and the existing facilities occupy approximately 10 acres of this developable area at the center of the site. The study noted that there is the potential to develop additional office space on the site ranging from 700,000 to 2,000,000 additional square feet plus parking while maintaining the existing buildings on the site. Due to these development constraints, any new development would likely be multiple buildings developed among and around DOE buildings located at the center of the site. Although there are no current plans in place, the study noted that the intent was for this campus to accommodate future DOE growth.

Current Ownership Federal

Total Acres 109 acres

Acres under GSA’s Control 109 acres

Current Tenant Department of Energy

Current Uses Office

Amount of Existing Space 600,000 GSF plus 1,847 parking spaces

Developable Acres 45 acres

Potential New Space 700,000-2M GSF plus parking per August 1997 Agency Master Plan

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Distance to Downtown DC 26 miles

Distance to Major Roadways Adjacent to Germantown Road and I-270

Distance to Transit 8.1 miles; Shady Grove Metro Station

Existing Availability of Utilities Well-served

Development Considerations Wetlands Conservation Area Floodplain

Legislation Needed Waiver of Seat of Government Act.

The Germantown Campus was evaluated for occupancy by DHS based on the DHS evaluation criteria:

DHS Need Evaluation Criteria Assessment

Space Needs Is there developable land with the potential to meet the DHS need for 4.5 million GSF plus parking?

No. Based on a previous master plan, the developable acreage can only support 2M GSF plus parking.

Security Needs Is the site compatible with DHS’ need for Level 5 security (a walled campus)?

Yes.

Proximity to Downtown DC

Is this site within close proximity to the White House and Congress?

No. The site is 26 miles from the White House.

Availability Is the developable land available for use by DHS?

Yes.

Schedule Can this site accommodate DHS’ FY2013 initial occupancy?

Highly unlikely as to the developed portion of the site because tenants would need to be relocated, triggering the need for a detailed relocation strategy. The housing plan for the current tenant would be disrupted. It is likely to meet schedule for the undeveloped portion of the site.

Roadway Access Is this site located in close proximity to major roadways?

Yes. The site is adjacent to I-270.

Transit Access Is this site located in close proximity to Metro station?

No. The nearest Metro station is over 8 miles from the site.

Access to Neighborhood Amenities

Does the site have access to neighborhood amenities within walking distance?

No. All amenities require vehicular travel.

Adjacent Parcel Does the site have developable land adjacent to it that will

Possibly, in either Middlebrook Industrial Park or Germantown Corporate Center. However,

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DHS Need Evaluation Criteria Assessment accommodate 750,000 GSF of new development plus parking?

the DOE site cannot accommodate the 3.8M GSF requirement.

F.3. Consumer Product Safety Commission – National Laboratory Campus

The Consumer Product Safety Commission (CPSC) National Laboratory Campus is located at 10901 Darnestown Road in Gaithersburg, Montgomery County, Maryland. The CPSC National Laboratory Campus is housed in seven one-story, free-standing cinder block structures totaling 27,751 gross square feet on a 9.5-acre site in Gaithersburg, Maryland. CPSC completed a long-range development plan outlining its goals for the site for the next ten years. NCPC approved a master plan to develop the site based on these long-range goals. This plan includes approximately 28,816 gross square feet of new space and upgrades for existing facilities. Since the original location analysis, CPSC has indicated to GSA that it wishes to move from this site and relocate its facilities with headquarters in Bethesda. For this reason, the CPSC campus has been included in this updated location analysis. Due to the approved plan and the type of development that DHS will require, this site is ruled out for consideration. Furthermore, the site will not support DHS’ need for up to 4.5M GSF, since only 28,216 GSF of new space remains available on the site.


Total Acres 9.5 acres

Acres under GSA’s Control None

Current Tenant Consumer Product Safety Commission

Current Uses Lab

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Amount of Existing Space 27,751 GSF

Developable Acres 9.5 acres

Potential New Space 28,216 GSF plus parking per CPSC’s long range development plan for the site


Distance to Major Roadways Approximately 2 miles west of I-270

Distance to Transit 6 miles to Shady Grove Metro Station


Development Considerations Wetlands / Conservation Area / Floodplain

Legislation Needed Waiver of Seat of Government Act.

The Gaithersburg Campus was evaluated for occupancy by DHS based on the DHS evaluation criteria:



No. Based on CSPC’s development plan, only 28,216 GSF plus parking is available to develop.

Security Needs Is the site compatible with DHS’ need for Level 5 security?

Yes.


Is this site within proximity to the White House and Congress?



Yes.


No.

Roadway Access Is this site located in proximity to major roadways?

Yes. The site is within 2 miles of I-270.

Transit Access Is this site located in proximity to a Metro station?

No. The nearest Metro station is 6 miles from the site.




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Adjacent Parcel Does the site have developable land adjacent to it that will accommodate 750,000 GSF of new development plus parking?

No. Site is surrounded by residential development of single family homes. Also, a site capable of supporting an additional 750,000 GSF when combined with the subject site would not provide sufficient space to meet the DHS need for 4.5 million GSF.

F.4. Suitland Federal Center

The Suitland Federal Center (SFC) is located in Prince George’s County, Maryland. The entire site consists of 226 acres, including a contiguous parcel of 41 acres owned by the US Navy. The landmass in GSA's inventory is 185 acres. The SFC is bounded to the north by Suitland Road, to the south by Suitland Parkway, to the east by Silver Hill Road, and to the west by the Washington National Cemetery. A new NOAA facility on the site was substantially completed in early FY2006. The new 1.5M GSF building for Census began construction in FY2004, occupancy for the first phase was completed in FY2007, and occupancy of the second phase was completed in May 2007. The current buildings known as Federal Office Building 3 and 4 plus the Suitland Federal Center were planned for demolition in FY2008. As of September 2008, FOB 3 is in the process of being demolished. No funds have yet been appropriated to demolish FOB 4. The master plan for SFC identifies a series of parcels for future development along the northern (Suitland Road) and eastern (Silver Hill Road) perimeter. These parcels will encompass up to 800,000 SF for federal tenants.

Sites that can be developed in FY2008

The SFC is currently well served by utilities infrastructure. These utilities include water, gas, telephone, telecommunications, electricity, sanitary sewer, and storm sewer from local public utility suppliers. The SFC meets criteria for transit accessibility as it is located in proximity to the Suitland Metro Station (Green Line) - a shuttle is used on campus from the Metro to all buildings on campus. The SFC campus is a secured site in proximity (8 miles) to Capitol

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Hill and Washington, DC. The campus has a 1:2 parking ratio, and generally lacks neighborhood amenities such as retail and eateries.



Acres under GSA’s Control 185 acres Current Tenant Census Bureau, Naval Intelligence Command,

Washington National Records Center, NOAA

Current Uses Office

Amount of Existing Space 3.5M GSF (GSA space only)

Developable Acres 24

Potential New Space 800,000 SF


Distance to Major Roadways Adjacent to Suitland Parkway; 4 miles east of Interstate 295

Distance to Transit On-site; Suitland Metro Station


Development Considerations Building height restriction per master plan – no more than 5 stories Designated open space per master plan Streams Existing roadway capacity Historic structure contributing to National Register-eligible historic district

Legislation Needed Waiver of Seat of Government Act

The Suitland Federal Center was evaluated for occupancy by DHS based on the DHS evaluation criteria:



No. Based on a previous master plan, the developable acreage can only support 800,000 SF of new space.


Yes. The site is in an enclosed Federal campus.

Proximity to Is this site within close No. The site is 10 miles from the White House.

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DHS Need Evaluation Criteria Assessment Downtown DC proximity to the White

House and Congress?


Yes.


Highly unlikely as to the developed portion of the site because tenants would need to be relocated, triggering the need for a detailed relocation strategy. GSA recently completed construction of the new Census Bureau Headquarters and NOAA facility and therefore, it is unlikely that those existing tenants could be relocated. It is likely to meet schedule for the undeveloped portion of the site.


Yes. Suitland Parkway is adjacent to the property.


Yes. There is a Metro Station on site.



Yes, but the amenities are very limited.

Adjacent Parcel

Does the site have developable land adjacent to it that will accommodate 750,000 GSF of new development plus parking?

Yes, but since SFC cannot accommodate more than 800,000 GSF, even the additional 700,000 GSF would not enable this site to meet the DHS need for 4.5 million GSF..

F.5. Federal Research Center at White Oak, Silver Spring, Maryland

The Federal Research Center at White Oak is located at 10903 New Hampshire Avenue in Silver Spring, MD. The White Oak site is a federally-owned, 662-acre site located on the jurisdictional line between Montgomery County and Prince George’s County. GSA received the White Oak site as part of the 1997 Base Realignment and Closure Act (BRAC) process. The property is part of the Naval Ordnance Laboratory (NOL) Historic District, which is eligible for inclusion on the National Register of Historic Places.

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White Oak consists of two primary parcels of land for development (Parcel A and Parcel B), a 76-acre golf course, 40 acres for the US Air Force Wind Tunnel Complex, and 90 acres of stream valley buffers and wetlands that are not developable. Parcel A is currently under development for the Food and Drug Administration (FDA) consolidation and Parcel B is available for future development.

The site has convenient access to the District of Columbia as it is located near I-495, I-95 and is within 5 miles of the four Metro stations. It is located one-mile north of the Capitol Beltway and is bordered by New Hampshire Avenue to the west, Cherry Hill Road to the east, and Army and residential land to the south. White Oak is located in a predominately residential area, although there are several clusters of commercial-retail areas within close driving distance to the site.

Parcel A is a 130-acre parcel located along New Hampshire Avenue on the western portion of the site and is designated for the consolidation of the FDA. It is anticipated that Parcel A will house 7,720 FDA employees plus parking in approximately 5.2M GSF by 2013.

In July 2004, GSA conducted a Land Use Feasibility Study for Parcel B. The draft found that Parcel B is comprised of three developable land bays (B.1, B.2 and B.3) consisting of 282 acres, but only 139.2 are developable. The developable acreage is what remains after eliminating the severly steep slopes, wetlands, and stream valley buffers, which render 142.8 acres of the site undevelopable . The study noted that there is the potential to develop up to 2.6M GSF on Parcels B.2 & B.3 with the transportation improvements being considered by GSA and a private developer. B.1 would be reserved for FDA growth.

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Current Tenant Food and Drug Administration and U.S. Air Force

Current Uses Office and Lab

Amount of Existing Space Unknown

Developable Acres 139.2 acres

Potential New Space 2.6M GSF per July 2004 Land Use Feasibility Study

Distance to Downtown DC 11.2 miles

Distance to Major Roadway Adjacent to New Hampshire Avenue (MD650); one mile north of Capital Beltway

Distance to Transit 2.9 miles; Silver Spring Station


Development Considerations Naval Ordnance Laboratory Historic District Environmental contamination Use III streams Slopes Existing roadway capacity

Legislation Needed Waiver of Seat of Government Act

The White Oak site was evaluated for occupancy by DHS based on the DHS evaluation criteria:



No. Based on a previous study, the developable acreage can only support 2.6M GSF plus parking.


Yes. The site provides for the appropriate setback.



No. The site is over 11 miles from the White House.


Yes.

Schedule Can this site accommodate DHS’ FY2013 initial

Highly unlikely as to the developed portion of the site because tenants would need to be relocated, triggering the need for a detailed relocation

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DHS Need Evaluation Criteria Assessment occupancy? strategy. GSA is currently constructing the FDA

Headquarters and therefore, it is unlikely that the existing tenants could be relocated. It is likely to meet schedule for the undeveloped portion of the site.


Yes. The site is adjacent to New Hampshire Avenue and one mile north of the Beltway.


No. The nearest Metro station is nearly 3 miles from the site.




Adjacent Parcel


Possibly. The White Oak site, however, will not support another 3.8 million GSF.

F. 6. Franconia Storage Depot

The Franconia storage depot is a 13 building, 70-acre warehouse site at 6999 Loisdale Road in Franconia, Virginia, close to the junction of the Henry Shirley Memorial Highway (I-95), Franconia Road (644), and the Franconia-Springfield Parkway (7700). The site contains 13 structures with approximately 1.3 million rentable square feet (RSF) that provide primarily warehouse space, as well as ancillary administrative and support space.

In the middle to late 1990s, several forces converged to encourage GSA to reconsider its use of the Pharr Warehouse (Franconia) site in the context of development pressures in the vicinity. In particular, the anticipated opening of the Franconia/Springfield Metrorail station prompted Fairfax County, with support from the local residential community, to embark on a comprehensive planning effort. Although Federal development isn’t subject to zoning, this effort produced changes to the existing zoning for the GSA site and remaining, adjacent industrial sites.

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Consequently, the site is now part of the County's Springfield Planning District, and is planned for "mixed-use, transit-oriented" development. An adjacent site is currently being developed by KSI Services consistent with this plan. In 2002, KSI Services and GSA agreed to coordinated site access. These developments have prompted GSA to consider whether to continue occupancy of its Pharr Warehouse complex, or to relocate its warehouse tenants to other locations, thereby enabling redevelopment of the site in accordance with the Fairfax County plan. Federal tenants are made aware of the on-going process and most new and renewal Occupancy Agreements are signed for a term of one year only, renewable at the beginning of each fiscal year. Franconia is almost entirely occupied with only about 55,000 RSF available.

A recent study prepared by another federal agency noted the development potential for the Franconia site was up to 6M GSF. However, if the site were to be redeveloped, existing tenants would need to relocate to other locations in order to redevelop the site, which would make FY2013 occupancy difficult. The property is close to Metro and is a secure property with potential for necessary setbacks in accordance with ISC's highest security level. The property is located in relative proximity to Washington, DC, is adjacent to neighborhood amenities and is currently well served by utilities infrastructure.

In addition, the National Defense Authorization Act for Fiscal Year 2008 (P.L. 110-181 dated January 28, 2008) authorizes the Fort Belvoir Office Complex to be constructed on one of three sites including the Franconia Warehouse. The Army is currently evaluating whether it will select the Franconia site.




Current Tenant GSA

Current Uses Warehouse

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Amount of Existing Space 1.3M GSF

Developable Acres 0 acres (70 acres if existing structures demolished)

Potential New Space 2M GSF if only a portion is redeveloped; up to 6M GSF if the entire site is redeveloped


Distance to Major Roadway Adjacent to Loisdale Road; near junction of I-95

Distance to Transit ½ mile; Franconia Metro Station


Development Considerations Existing roadway capacity

Legislation Needed Waiver of Seat of Government Act Congressional effort to use site for BRAC personnel would need to be abandoned.

The Franconia Storage Depot site was evaluated for occupancy by DHS based on the DHS evaluation criteria:



Yes. If the site was entirely redeveloped.


Yes. The site is an enclosed Federal campus.





No. P.L. 110-181 authorizes transfer of the site to the U.S. Army for the expansion of Fort Belvoir under the latest BRAC action.. Further, the site is occupied by another tenant irrespective of whether Army selects the site.


Unlikely. P.L. 110-181 authorizes transfer of the site to the U.S. Army for the expansion of Fort Belvoir under the latest BRAC action.


Yes. The site is proximate to I-95.


Yes. There is a Metro station ½ mile from the site.

Access to Does the site have access to Yes. There are amenities within walking

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DHS Need Evaluation Criteria Assessment Neighborhood Amenities

neighborhood amenities within walking distance?

distance.

Adjacent Parcel

Does the site have developable land adjacent to it that will accommodate 750,000 GSF of new development plus parking? No.

F.7. US Geological Survey Campus

The 84 acre site of the US Geological Survey (USGS) headquarters was purchased in the mid 1960s and the 1M GSF Powell Building was constructed in 1972-73. It is located at 12201 Sunrise Valley Drive in Reston, Virginia within a mile of the intersection of the Fairfax County Parkway and the Dulles Access and Toll Roads. GSA leased the building for 20 years, after which time title reverted to the government at lease expiration in 1993. The site currently contains the Powell Building plus a physics laboratory and a power generating plant.

The non-GSA parcels surrounding the site are zoned I-4, a light industrial/commercial classification that permits construction of office buildings and related structures with a Floor Area Ratio (FAR) of 0.70. Based on the structures currently on site, plus easements and required setbacks, there are approximately 15 acres on which additional development can be placed. Based on the low FAR, this translates into approximately 450,000 SF of additional development that is possible on site (although GSA is not obligated to comply with local zoning, it looks to those codes, if they exist, as a reference point). The existing tenant has indicated no need or desire to relocate, and access to public transportation is limited. In addition, a $40 million renovation project was completed on the site at the end of calendar year 2005.

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If the site were to be redeveloped, existing tenants would need to relocate to other locations in order to demolish and redevelop the site, which would make FY2013 occupancy highly unlikely.

The site does have access to neighborhood amenities, security setbacks, the ability to meet highest ISC security levels, and is well served by utilities infrastructure.




Current Tenant U.S. Geological Survey

Current Uses Office

Amount of Existing Space 1M GSF


Potential New Space 450,000 SF


Distance to Major Roadway One mile from Fairfax County Parkway (7100)

Distance to Transit 15 miles from Vienna/Fairfax/GMU Metro Station


Development Considerations Existing roadway capacity

Legislation Needed Waiver of the Seat of Government Act

The US Geological Survey Campus site was evaluated for occupancy by DHS based on the DHS evaluation criteria:



No. The site only has the potential for development of an additional 450,000 GSF.


Yes. The site is a Federal campus.




Availability Is the developable land available Yes.

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DHS Need Evaluation Criteria Assessment for use by DHS?


Highly unlikely. Tenants would need to be relocated, triggering the need for a detailed relocation strategy. The housing plan for the current tenants would be disrupted.


Yes. Dulles Toll Road is within 1 mile, so is the Fairfax County Parkway.


No. The site is 15 miles from the nearest Metro station.




Adjacent Parcel


Possibly, however, even the addition of 750,000 GSF to the subject site would not meet DHS' need for a total of 4.5 million .

F. 8. Cotton Annex

The Cotton Annex site is located at 12th Street and C and D Streets. The site includes a parking lot adjacent to the Cotton Annex Building, which used to be occupied by the Department of Agriculture (USDA). This parking lot is at an excellent location in Southwest Washington, DC just off Independence Avenue and across the street from a Metro stop entrance. It contains 374 surface parking spaces or 56,636 SF. The property is eligible for the National Register of Historic Places. It is currently being used by DHS’ Federal Protective Service (a division of the Immigration & Customs Enforcement agency) as a vehicle-screening facility that was relocated from the Southeast Federal Center which is under development by the private sector.

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The site does have proximity to a Metro station and neighborhood amenities, and is well served by utilities infrastructure. The site has the ability to accommodate potential development of an additional 423,200 GSF if the existing parking lot were developed for office space. If the existing Annex building was demolished and the parking lot developed under the maximum FAR allowable for this site, the maximum development potential would be approximately 931,500 GSF (although GSA is not obligated to comply with local zoning, it looks to those codes, if they exist, as a reference point). The shape of the lot is irregular and its location over a Metro easement does not make below grade construction practical.


Total Acres 1.86 acres

Acres under GSA’s Control 1.86 acres

Current Tenant FPS is using this site to screen vehicles.

Current Uses Office


Developable Acres 1.86

Potential New Space 931,500 GSF


Distance to Major Roadway Adjacent to 12th Street; .3 miles from I-395

Distance to Transit .11 miles; Smithsonian Metro Station


Development Considerations Site configuration Existing roadway capacity Location on top of Metro line

Legislation Needed N/A

The Cotton Annex site was evaluated for occupancy by DHS based on the DHS evaluation criteria:



No.


No. The site is very narrow and would not allow the necessary setbacks. There is also a Metro line below the site, which would present security issues.

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Yes. The site is 1.5 miles from the White House.


No. The site is being used by FPS as a vehicle screening facility.


No.


Yes. The site is adjacent to 12th street and .3 miles from I-395.


Yes. There is a Metro station across the street.



Yes. There are amenities within walking distance.

Adjacent Parcel


No. Site is bounded by a freeway exit, railroad tracks, and other federal buildings.

F. 9. Southeast Federal Center

The Southeast Federal Center (SEFC) is located on the west bank of the Anacostia River in Washington, DC and contains 55 acres. This property is on the National Register of Historic Places as an historic district. The SEFC Public Private Development Act of 2000 (P.L. 106-407) allows GSA to enter into agreements (including contracts, leases, cooperative agreements, limited partnerships, joint ventures, trusts, and limited liability company agreements) with a private entity to provide for the acquisition, construction, rehabilitation, operation, maintenance, or use of facilities at SEFC. The new Department of Transportation Headquarters' building is located on 11 acres of the site. The remainder is to be developed under a development agreement with a private sector developer, Forest City Washington, Inc., in accordance with the Act. Under the terms of the Act, GSA's primary

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purpose in selling or leasing the SEFC is to enhance the value of SEFC to the United States. GSA made the decision to pursue a mixed-use development for the federally-owned site as a means of revitalizing the Anacostia waterfront, as called for in the unveiled Anacostia Waterfront Initiative Framework Plan and the National Capital Planning Commission's 1997 Legacy Plan. The developer's concept plan proposes a new neighborhood centered on a 5.5 acre waterfront park. When complete, the development will have approximately 4,480 residents and 10,000 workers including the Department of Transportation headquarters employees; a variety of housing types, both for rent and for sale, grouped into distinct sub-neighborhoods; both daily use and destination retail; and a cultural component that includes programming to activate public spaces year round. It will be designed so that it is integrated with the neighborhoods surrounding it.

Due to the terms of its development agreement and local zoning, only 1.8M GSF of office space is permitted to be developed on this site. Although the cost of infrastructure is high at this location, this property is close to a Metro station and is located in proximity to downtown Washington, DC and Capitol Hill. The 100’ setbacks for security requirements are not achievable at this site and the presence of the stadium will make the area more congested.




Current Tenant Department of Transportation, National Geospatial Intelligence Agency

Current Uses Office



Potential New Space 5.224M GSF


Distance to Major Roadway Adjacent to M Street; connects to I-395 and I-295 via 11th Street and South Capitol Street

Distance to Transit Adjacent to Navy Yard Metro Station


Development Considerations Environmental contamination National Register-Eligible Washington Navy Yard

Annex Historic District Floodplain

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Legislation Needed May require amendment or repeal of Southeast Federal Center Public-Private Development Act of 2000.

The Southeast Federal Center site was evaluated for occupancy by DHS based on the DHS evaluation criteria:



No. Current zoning only allows 1.8M GSF of office development. GSA has entered into an agreement with a Private Developer for the redevelopment of the site for mixed-use per the approved zoning.


No. The commercial parcel would not allow for sufficient setbacks.





No. There is a master lease in place with Forest City Washington. Check with Victoria, GSA may have sold some of the parcels.


Highly unlikely. GSA has entered into an agreement with a Private Developer for the redevelopment of the site for mixed-use per the approved zoning. Meeting the schedule would require breaking existing agreements and developing new housing strategies, as well as relocating existing tenants (see also legislation needed in previous table).


Yes. The site is adjacent to New Jersey and M Street, which quickly connects to South Capitol and the SW/SE Freeway.


Yes. A Metro station is across the street.



Not yet. The area is being redeveloped, but there are minimum existing amenities within walking distance.

Adjacent Parcel

Does the site have developable land adjacent to it that will accommodate 750,000 GSF of new development

Yes. SEFC, however, cannot accommodate the other 3.8 million GSF of DHS’ requirement; therefore such adjacency does not meet DHS programmatic needs.

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DHS Need Evaluation Criteria Assessment plus parking?

F. 10. Reservation 13

Reservation 13 is located on the west bank of the Anacostia River in Washington, DC and contains approximately 65 acres of land bounded by Independence Avenue, SE, on the north, 19th Street, SE, on the west, G Street, SE, on the south, and U.S. Reservation 343 on the east. Care, custody, and control of the site was transferred to DC in October 2002 subject to rights of location to be maintained by the Court Services and Offender Supervision Agency (CSOSA) on a portion of the site per P.L. 107-96 (115 Stat. 931). Improvements consist of several buildings used by the old DC General Hospital plus the old DC Jail. Current plans are to build a new hospital on the site in conjunction with Howard University. As well, residential housing is proposed for the site. The only significant developable land is in the northwestern corner of the property, and that parcel is the site of the St. Coletta's School, construction of which is well under way pursuant to a land lease issued by the District of Columbia.

The site is under the control of the District of Columbia and, in accordance with P.L. 109-396, the fee title deed transfer from GSA to DC is currently pending the fulfillment of a precondition to closing, with an Exchange Agreement already having been executed by GSA and DC. However, the property is close to Metro, is in proximity to downtown Washington, DC and Capitol Hill and has adequate setbacks for security.




Current Tenant District of Columbia

Current Uses Hospital, clinics, and correctional facilities

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Amount of Existing Space Approx 2.3M GSF

Developable Acres 40 acres per DC Draft Master Plan for Reservation 13

Potential New Space 3.2M GSF (hospitals, clinics, residential, and retail)


Distance to Major Roadway Adjacent to Independence Avenue;

Distance to Transit On-site; Stadium-Armory Metro Station


Development Considerations National Register-eligible historic district Existing roadway capacity

Legislation Needed Repeal of P.L. 109-396

The Reservation 13 site was evaluated for occupancy by DHS based on the DHS evaluation criteria:



No. The current plans for Reservation 13 only allow for 3.2M GSF of institutional space.


Yes.



Yes. The site is 4 miles from the White House.


No. Federal law directed transfer of the site to the District.


No. Fee title to the site is slated to be transferred to DC in short course, in accordance with P.L. 109-396. Even if repealed, extensive existing tenancies would need to be relocated.


Yes. The site is adjacent to Independence Avenue.


Yes. There is a Metro station on site.

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No. The area is planned for redevelopment, but there are no existing amenities within walking distance.

Adjacent Parcel


Yes. However, the addition of 750,000 GSF would not enable the subject site to meet the DHS' need for a total of 4.5 million GSF.

F. 11. Armed Forces Retirement Home (AFRH-W)

AFRH-W is comprised of 272 acres located in north central Washington, DC. The southern border of the campus follows Irving Street, NW. The western border is formed by Park Place, NW and Rock Creek Church Road, NW. The northeastern border follows Harewood Road, NE and North Capitol Street. This property is a National Register of Historic Places eligible historic district and there is a National Historic Landmark on the northwestern side of the site.

Washington Hospital Medical Center and the Veterans Administration Hospital are located to the south. East of the site is Catholic University and the Basilica of the Shrine of the Immaculate Conception. Located north of the AFRH-W are the Soldiers' and Airmen's Home National Cemetery and the Rock Creek Church. To the west of the AFRH-W are residential areas comprised of row houses and garden apartments.

The site is limited in terms of access to public transportation and the cost of infrastructure is high. However, the property does have adequate setbacks to meet Level 5 security requirements and is located in relative proximity to downtown Washington, DC and Capitol Hill.

The AFRH-W is moving ahead with a Master Plan for development of underused property and land on its 272-acre Washington campus in the heart of the Capitol City. Development

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will generate income needed by the Home to maintain its reputation as the nation's premier independent living retirement community for military retirees and disabled veterans.

Development will be staged and compatible with the operation of a retirement community and reflect the scale and uses of the surrounding city neighborhoods and institutions. The Home intends to hold the development land and lease it long-term to developers, putting the land rent into the AFRH-W’s Trust Fund in accordance with 24 USC § 411. Compatible development has been identified as institutional, residential, medical, office/R&D, and retail.

The AFRH-W’s draft final Master Plan contemplated four development zones, one for the AFRH and three for leasing to private developers. The Environmental Impact Statement (EIS) prepared for the site redevelopment on Zones A through C, analyzed a range of development from 5.59M GSF to 8.28M GSF for a mixed use development, of which 2.5M GSF was the maximum amount of office space. In the approval of the final Master Plan, two of the zones contemplated for private development were rolled back into the AFRH zone. Now, the site is divided into two development zones with the AFRH retaining the AFRH Zone and with Zone A being the sole area to be used for private redevelopment. The preferred developer for the redevelopment of Zone A has been provisionally selected and is currently proposing a mixed-use development of residential, retail, office, hotel/conference, recreational, and medical office.

To reconfirm DHS occupancy potential at the AFRH campus, GSA issued a letter on May 30, 2007 to AFRH to describe a proposal whereby the GSA would exchange interests in land under its custody and control for portions of the AFRH campus in Northwest Washington, DC in order to house the core headquarters of DHS. On June 7, 2007, AFRH responded to GSA stating that (1) AFRH is already engaged in a redevelopment project involving its Washington DC Campus; and (2) Locating the DHS campus at AFRH would not be compatible with AFRH’s own important operations. In the response letter from AFRH, it is made clear that AFRH is not interested in allowing DHS to occupy all or a portion of this site due to AFRH schedule, financial and occupancy incompatibility concerns; and AFRH would not consider a land exchange for the St. Elizabeths West Campus. This letter reconfirms that the site is not available. Further, on July 10, 2007, the National Capital Planning Commission approved the Final Master Plan for development of the site pursuant to AFRH’s development plans and Record of Decision.



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Current Tenant Armed Forces Retirement Home

Current Uses Retirement Community


Developable Acres Zone A = 77 acres

Potential New Space Zone A = 4.3M GSF mixed use


Distance to Major Roadway Adjacent to North Capitol Street

Distance to Transit 3.4 miles; Petworth Metrorail Station


Development Considerations National Register-eligible historic district Existing roadway capacity


The Armed Forces Retirement Home site was evaluated for occupancy by DHS based on the DHS evaluation criteria:



Yes.


Yes. Overall property has deep setbacks from perimeter.



Yes. This site is 4 miles from the White House.


No. See reference to AFRH’s June 2007 letter.


No, given AFRH’s plans and stated position with regard to possible land swap with GSA.


Yes. The site is adjacent to North Capitol.


No. The closest Metro is 3.4 miles away.

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Adjacent Parcel


No. Site is surrounded by private residential and institutional development.

F. 12. Robert F. Kennedy Stadium (RFK)

RFK is located on a 190 acres site on the west bank of the Anacostia River in Northeast Washington, DC to the north of Reservation 13. The stadium site in the circle at East Capitol Street has virtually no developable area unless one demolishes the stadium. While the parking lots ancillary to the stadium could be viewed as having development potential, such development would seriously inhibit the function of the stadium. If the stadium were demolished, the maximum available development on this site would be approximately 1.8M GSF without parking, based on maximum allowable FAR for this site (although GSA is not obligated to comply with local zoning, it looks to those codes, if they exist, as a reference point).

RFK is comprised of federal land leased to DC under a fifty-year ground lease with the National Park Service. The lease authorizes DC to use the site for stadium purposes and it expires in 2032.27 The site is close to Metro and is in close proximity to downtown Washington, DC and Capitol Hill.



41 27 See December 12, 2005 letter from District of Columbia Chief Financial Officer to Chairman, District of Columbia Council.

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Current Tenant District of Columbia

Current Uses Recreational purposes



Potential New Space 1.8M GSF per December 2006 NCPC’s RFK Stadium Site Redevelopment Study


Distance to Major Roadway Adjacent to Constitution Avenue and Independence Avenue

Distance to Transit On-site; Stadium-Armory Metro Station


Development Considerations Existing roadway capacity Floodplain


The RFK Stadium site was evaluated for occupancy by DHS based on the DHS evaluation criteria:



No. Maximum development is only 2.7 million GSF.


No. It is too small to allow adequate setbacks for 4.5 million GSF.



Yes. The site is within 4 miles of the White House.


Not likely. Subject to ground lease to DC.


No. An existing ground lease would need to be breached.


Yes. The site is adjacent to Constitution and Independence Avenues.


Yes. There is a metro station on site.

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Adjacent Parcel


Yes. Reservation 13. However, the addition of 700,000 GSF would not allow this site to meet DHS' need for a total of 4.5 million GSF.

F. 13. Nebraska Avenue Complex (NAC)

The Nebraska Avenue Complex (NAC) is located at 3801 Nebraska Avenue, NW in Washington, DC. The NAC is a 38-acre, federally-owned site comprised of 30 buildings totaling 612,994 GSF plus 1,094 parking spaces currently occupied by portions of the DHS Headquarters. Most of the buildings were constructed in the 1940s and later after the Navy took over the site in 1942 from a women’s seminary. This site is a National Register of Historic Places eligible historic

district. P.L. 108-268 dated July 2, 2004 directed transfer of the site from the Navy to GSA with the express purpose of housing DHS. Current plans call for housing up to 2,000 DHS employees at this site.

The NAC is located at Ward Circle at the intersection of Massachusetts and Nebraska Avenues. The surrounding area includes American University to the north and west, Glover-Archbold Park to the east and primarily residential land uses to the south. The site is approximately .75 miles or an approximate 15 minute walk from the

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nearest Metro station (Tenlytown-AU on the Red Line) and has direct access to multiple Metro bus lines along the Massachusetts Avenue corridor.

A June 3, 2005 Site Capacity Study conducted by GSA for the site denoted multiple development opportunities for the NAC. One alternative proposed rehabilitation of the majority of the existing facilities and incorporating new development to yield a maximum total of 1,165,078 GSF on the campus. There is the potential to remove or modify existing buildings to provide for an additional 200-300K GSF of development on the site. A Feasibility Study is in the process of being procured to update the original Site Capacity Study.

As DHS organizations and mission requirements have matured and expanded since the department stood up in January 2003, the physical limitations of the NAC make it unsuitable as the permanent headquarters for DHS. DHS believes the NAC can serve as a site for certain DHS functions other than the Department’s headquarters.




Current Tenant Department of Homeland Security

Current Uses Office

Amount of Existing Space 612,994 GSF plus parking (1,094 spaces)

Developable Acres 0 acres (38 acres if existing structures demolished)

Potential New Space 1,165,078 GSF per June 2005 Site Capacity Study


Distance to Major Roadway Adjacent to Nebraska and Massachusetts Avenue

Distance to Transit ¾ miles; Tenleytown-AU Metro Station

Existing Availability of Utilities Not well-served

Development Considerations National Register-eligible historic district Existing roadway capacity Electrical capacity in area


The NAC was evaluated for occupancy by the DHS HQ Consolidation based on the DHS evaluation criteria:

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No. Site capacity is only 1.2 million GSF


Yes, but only up to 1.2 million GSF.




Availability Is there developable land available for use by DHS (Headquarters)?

No. Certain DHS support personnel will occupy NAC following completion of the DHS Headquarters.


Potentially no, because DHS support personnel projected to occupy the NAC following completion of the DHS Headquarters would need to be relocated from the NAC, triggering the need for a detailed relocation strategy.


Yes. It is at the intersection of Nebraska and Massachusetts Avenues.


Yes. The Metro is ¾ miles away.



To some degree - New Mexico Avenue businesses are within ½ a mile.

Adjacent Parcel


No. Adjacent sites are already built out and vacant land is Archbold Glover Park under the control of the National Park Service. Also, a site capable of supporting an additional 750,000 GSF when combined with the subject site would not provide sufficient space to meet the DHS need for 4.5 million GSF.

F. 14. Walter Reed Army Medical Center (Walter Reed)

The Walter Reed site is located in Northwest Washington, DC between 16th Street on the west and Georgia Avenue on the east. The site is not projected to be available for redevelopment until at least FY2012. It is GSA's understanding that the closure will not be a gradual one and that Army/DoD will continue to use the site until the date of closure. GSA is not guaranteed to gain custody and control of the property through the BRAC process.

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The Army intends to leave the site once a new hospital is built in Bethesda, MD; under BRAC, the Army has six years to relocate. On April 14, 2006, the Army granted GSA's request to transfer the northern parcel of the site, which is comprised of approximately 34 acres, to GSA's control in FY2012. GSA conducted a land use feasibility study of this parcel which found that this parcel has approximately 3.7M GSF of maximum redevelopment potential if the existing

hospital is demolished. The Army also granted the State Department's request for the transfer of the balance of the site, which is approximately 79 acres. State's intention is to adaptively re-use the existing buildings—1.7M GSF of existing—and develop International Chancery Centers in the only area of open land currently on the Walter Reed site (approximately 20+ acres).

The 34 acres initially granted to GSA are not part of the National Register-eligible historic district at Walter Reed. There are 3 to 4 buildings on the GSA portion that may be eligible for the National Register. Most, if not all of the rest of the site that the State Department is requesting at Walter Reed is in that district.



Acres under GSA’s Control 34 acres (pending BRAC)

Current Tenant U.S. Army

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Current Uses Hospital/Office


Developable Acres 34 acres (acreage GSA from Army)

Potential New Space 3.7M GSF per June 2006 Massing Studies


Distance to Major Roadway Adjacent to Georgia Avenue – 3 miles from Beltway (I-495)

Distance to Transit .6 miles; Takoma Metro Station


Development Considerations Existing structure with potential historic significance


The Walter Reed site was evaluated for occupancy by DHS based on the DHS evaluation criteria:



No. Massing studies show only 3.7 million GSF can be developed.


Yes.



Yes, the site is 5 miles from the White House.

Availability Is there developable land available for use by DHS (Headquarters)?

No. The site is not available until 2012 at the earliest and there is not adequate space to meet DHS’ requirements.


No. The site is not available until 2012 at the earliest. Construction commencement would be too late to meet the requirement.


Yes. The site is adjacent to Georgia Avenue and 16th Street.


Yes. The Metro station is 0.6 miles away.



Yes. There are amenities available within walking distance on Georgia Avenue.

Adjacent Parcel

Does the site have developable land adjacent to it that will accommodate 750,000 GSF of

No. Only four sites along Georgia Avenue are available to the northeast of Walter Reed. The sites range in size from 1,648

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DHS Need Evaluation Criteria Assessment new development plus parking? SF to 3,400 SF and are not contiguous.

F.15. Beltsville Agricultural Research Center

The Beltsville Agricultural Research Center (BARC) located in Beltsville, Maryland in Prince George’s County. BARC is a 6,541-acre site that is under the Department of Agriculture’s (DOA) custody and control. Due to federal law28 prohibiting transfer of this site outside DOA’s care, custody, and accountability, GSA would require Congress to authorize or direct a transfer of land from the Department of Agriculture in order to develop on any portion of this site.

BARC extends in a broad arc across eastern Prince George’s County and includes large portions of relatively undeveloped land. Although there are large portions of wetlands and marsh at BARC, there is also terrain which is suitable for office space development. The site is located with direct access to I-95 and is approximately 10 miles north of the Capitol building. The site is surrounded by Washington Metropolitan Area Transit Authority (WMATA) and other Federal installations.


Total Acres 6,541 acres


Current Tenant Department of Agriculture

Current Uses Agricultural purposes and Office

48 28 Under PL 100-202 Section 523, no funds appropriated in any fiscal year “may be obligated or expended in any way for the purpose of the sale, lease, rental, excessing, surplusing, or disposal of any portion of land on which the Beltsville Agricultural Research Center is located at Beltsville, Maryland, without the specific approval of Congress.”

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Developable Acres Unknown

Potential New Space Unknown


Distance to Major Roadway Approximately one mile from I-95/I-495

Distance to Transit 3 miles; Greenbelt Metro Station

Existing Availability of Utilities Unknown

Development Considerations Existing roadway capacity Wetlands

Legislation Needed Waiver of Seat of Government Act Repeal of PL 100-202 Section 523

The BARC site was evaluated for occupancy by DHS based on the DHS evaluation criteria:



Likely, if Congress were to pass legislation allowing for transfer of land to GSA.


Yes.





No, unless Congress authorized the transfer of land from USDA.


Not likely. Site transfer would need to be authorized, negotiated and consummated. Congressional action would be needed to allow the transfer of land from USDA to GSA.


Yes. The site is approximately one mile from the Beltway.


No. The nearest Metro station is 3 miles from the site.




Adjacent Parcel Does the site have developable land adjacent to it that will Yes.

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DHS Need Evaluation Criteria Assessment accommodate 750,000 GSF of new development plus parking?

F. 16. St Elizabeths Campus

St. Elizabeths is located in southeast Washington, DC on 176 acres. It is divided into the West Campus controlled by the federal government and the East Campus controlled by the District of Columbia. The West Campus contains 70 buildings (approximately 1.2M GSF) that were constructed between 1852 and 1965. The entire property, both West Campus and East Campus, is a National Historic Landmark.

The site is located in proximity to Capitol Hill, the White House and is accessible to I-295. The site is currently vacant and has the potential to absorb additional new square footage and adaptively reuse a significant amount of the existing structures on the current site. Based on the analysis included in a Land Use Feasibility Study, GSA determined that development potential could accommodate up to 4.5M GSF plus parking on the West Campus, inclusive of historic building rehabilitation.

The site has the potential for 100’ setbacks in accordance with ISC’s highest security level. The site offers a campus setting with the potential to consolidate departmental functions and provide operational efficiencies that proximity often brings. The site does have development constraints in terms of costs associated with new site infrastructure, steep slopes that are more costly to develop and costs associated with the rehabilitation of existing historic structures and landscapes. The site currently has limited direct vehicular access, limited access to public transportation, environmental contamination, and a lack of retail amenities in the surrounding neighborhood.



Acres under GSA’s Control 176 acres (includes realty subject to P.L. 109-396)

Current Tenant Vacant

Current Uses None


Developable Acres Up to 83 acres

Potential New Space 6.4M GSF (including parking)


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Distance to Major Roadway Adjacent to Martin Luther King Jr. Avenue; one mile from I-295

Distance to Transit .5 miles; Anacostia Metro Station

Existing Availability of Utilities Not well-served

Development Considerations

National Historic Landmark Existing roadway capacity Limited utilities (power and water)


The West Campus site was evaluated for occupancy by DHS based on the DHS evauation criteria:


Space Needs

Is there developable land with the potential to meet the DHS need for 4.5 million GSF plus parking?

Yes. Based on a 2005 Land Use Feasibility Study, GSA concluded the site could support the DHS need. But note complex approval process due to unique nature of site.

Security Needs

Is the site compatible with DHS’ need for Level 5 security (a walled campus)?

Yes. Deep setbacks from the perimeter are available on 3 sides.



Yes. The site is 6 miles from the White House.

Availability Is the developable land available for use by DHS? Yes.


Yes. No existing tenancies would need to be relocated. No Congressional action other than funding necessary. But note complex approval process due to unique nature of site.


Yes. I-295 passes parallel to the western perimeter. Suitland Parkway passes with ½ a mile of main entrance.

Transit Access Is this site located in proximity to Metro station? Yes. There is a metro station within ½ mile.

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No. There are insufficient amenities within walking distance.

Adjacent Parcel


Yes, the District is redeveloping the East Campus for mixed-used development including commercial space that can accommodate this requirement.

G. Non-Federally Owned Sites

G.1. Overview

GSA’s Public Buildings Service (PBS) translates customer Federal agencies’ needs into discrete requirements, marshals the necessary resources to assure that the requirements are met, and makes certain that the space is delivered. PBS’s space acquisitions are driven by customer agency requirements. Based on statute, regulation, and policy, GSA is generally required to utilize sites and buildings within its existing portfolio to satisfy its client agencies’ needs. However, GSA does have broad authority to acquire non-federal real property and leasehold interests in real property to further its mission. Occasionally, PBS will purchase an existing building to meet customer needs. To determine the acquisition method, PBS considers the following: how much space is needed, how quickly the space is needed, how long the space is needed, and how complicated the build out is to determine the acquisition approach that is most appropriate. Each of these factors has a significant impact on the cost of alternatives and thus the feasibility of the project acquired either by leasing or construction.

For the reasons discussed in the following sections, GSA has determined that acquiring a non-Federally owned site or pursuing a lease acquisition is not consistent with DHS’ requirements. A general discussion of considerations related to the acquisition of real property to satisfy Federal agency requirements follows, together with an analysis of non-federal sites considered.

G.2. Preference for Assets under GSA Control

GSA is required by regulation to use available resources prior to expending federal tax dollars for additional land. The following regulations are pertinent to GSA’s decision making:

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Federal Management Regulation (FMR), 41 CFR § 102-73.45; “When a requirement is received, GSA looks to use existing Government-owned space first and then to vacant leased space already under contract from the private sector.”

FMR, 41 CFR § 102-75.25; “What are landholding agencies’ responsibilities concerning the utilization of excess property? Landholding agencies’ responsibilities concerning the utilization of excess property are to— (a) Achieve maximum use of their real property, in terms of economy and efficiency, to minimize expenditures for the purchase of real property; (b) Increase the identification and reporting of their excess real property; and (c) Fulfill its needs for real property, so far as practicable, by utilization of real property determined excess by other agencies, pursuant to the provision of this part, before it purchases non-Federal real property.”

G.3. GSA Efforts to Use Existing Space

Using GSA-owned sites is generally the most cost effective solution when alternative housing strategies to fill a Government need are evaluated. In January 2003, GAO designated federal real property a high risk area for a variety of reasons including an over reliance on costly leasing.29 GSA will usually pursue the housing alternative that is the least costly to the Government. Typically, the ownership options of new construction and repair and alteration versus lease will be recommended where there is a large requirement that is long-term and in a strong real estate market. (Although for smaller customer space assignments less than 10,000 square feet, leasing is generally the lowest cost alternative.) Other factors can also impact the decision regarding leasing versus ownership such as the urgency of the requirement, the uniqueness and size of tenant space requirements and/or annual budget limitations.30

53 29 GAO-07-349, Federal Real Property, Progress Made Toward Addressing Problems, but Underlying Obstacles Continue to Hamper Reform, p. 1.

30 Managing Federal real property continues to be a high-risk area as designated by the Government Accountability Office (GAO) due to underlying conditions such as excess and underutilized space, deteriorating Federal buildings, and an increased reliance on leasing to meet space demands. The GAO report [GAO07-349] highlights continued challenges in managing federal real property utilization and identifies several agencies with over 10 percent of their inventory vacant or underutilized.

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G.4. TAPS Analyzes Housing Alternatives

GSA surveys the housing needs of its client agencies and the availability of Federal office housing in communities nationwide. As required by OMB Circular A-94, GSA performs a 30-year present value life cycle cost comparison of project alternatives. The alternatives may include new construction, upgrading or renovating existing government property, and leasing. The analysis considers both the Government’s equity and its capital and operating costs in each alternative to determine the lowest net cost expressed in present value terms for a given amount of space.

To assist in its evaluation of various housing scenarios, GSA has developed a model accepted by OMB for analyzing housing alternatives. In 1983, GSA’s Office of Planning engaged Dennis Eisen & Associates to develop an analytic planning tool to assist build vs. lease decision making within the Public Buildings Service. The resulting program is called TAPS (“The Automated Prospectus System”). The program incorporated all major provisions mandated by OMB Circular No. A-104 for the analysis of Federally-owned and Federally-leased real estate.

To ensure that TAPS meets the numerous conditions on the model imposed by OMB, periodic meetings were held between OMB and GSA as the model was developed. As a result of this interagency cooperation, OMB permitted the model’s unquestioned use for generating forecasts in connection with the analysis of Federal real estate – only inputs and results rather than methodology would be then subject to review and evaluation. Additional modifications were periodically incorporated because of changing Federal tax law and in response to various OMB directives that affected the Federal real estate process – including the revised version of OMB Circular No. A-104, issued June, 1986, and OMB Circular No. A-94, issued October, 1992.

H. Non-Federally Owned Sites – Acquisition

H.1. Methods for Acquiring Sites

GSA can acquire an interest in sites through a variety of methods:

1. Purchase

2. Ground Lease

3. Donation

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4. Exchange

5. Condemnation

6. Transfer

H.1.i. Purchase

When acquiring interests in real property, GSA’s preference is to acquire fee simple interest in real estate. However, fee simple acquisitions are typically expensive and time-consuming. Further, for large-scale land acquisitions, GSA must seek Congressional authorization and funding.

H.1.ii. Ground Lease

GSA has the authority to enter into ground leases when in GSA’s best interests. Assuming the Government’s needs are met by the relevant site, the disadvantage to this arrangement is ground rent and that fact the Government does not have a fee simple interest in the property. Identifying an appropriate ground lease site can also be time consuming.

H.1.iii. Donation

When offered, GSA may accept on behalf of the United States unconditional donations of sites for public buildings. Such cases are evaluated by GSA decision makers accordingly to determine if the donation is to be accepted. If a donated site becomes available to GSA, donation can be a viable method of obtaining a site to meet GSA’s needs.

H.1.iv. Exchange

An exchange is a transaction in which Government-owned property or interests therein are traded for other real property or interests therein owned by another party. Similar to a Purchase, exchanges are time-consuming and they require Congressional notice. Identifying viable exchange parcels and successfully concluding such a transaction can be a time intensive process.

H.1.v. Condemnation

Condemnation is the exercise by the Government of its inherent power to take private property for public purposes. This power is commonly known as the right of eminent domain. The Attorney General, upon the proper request of GSA, is charged by law to institute proceedings to condemn property and to prosecute such proceedings to

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completion. Wherever practicable, GSA acquires real property by means other than condemnation.

If, however, GSA were to exercise the Government’s right of eminent domain, the cost of acquisition would need to be considered first. To construct 4.5 million GSF plus parking and include required security setbacks, the Government would need to condemn approximately 25 acres of land plus any improvements thereon. Based on land sales of 5 acres or more in the northeast quadrant of Washington, DC outside the Central Employment Area but near the North of Massachusetts (NoMA) sub-market, an acre of land could possibly be purchased for $1 million or approximately $23 per square foot. Parcels smaller than 5 acres would most likely cost more. Each parcel will require a market appraisal to determine fair market value for the owner. As noted below, before any action can be initiated, the Government would need to seek authorization from Congress.

Condemnation is, however, a means of acquiring real estate that could be used in the context of satisfying DHS’ headquarters requirements. Condemnation actions involve a variety of considerations: 1) Congress must first approve of the acquisition by endorsing an acquisition prospectus, a process that typically takes between 18 and 24 months; 2) GSA must obtain an appraisal of the fair market value of the property and comply with the requirements of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, and 3) generally, the federal government prefers to negotiate property acquisitions rather than exercise its right of eminent domain.

H.1.vi. Federal Transfer

A Federal transfer occurs when another Federal agency reports real property excess to its needs, and GSA (or another agency) takes over the care, custody, and accountability for that real property. GSA is required to utilize available excess real property acquired by Federal transfer prior to expending funds for an alternative acquisition.

H.2. Time to Acquire Sites Increases Government Costs

In addition to the increased costs, site acquisitions generally add time to the development schedule because of the time required to select a suitable site and to complete the transaction. The additional time required for site selection and to consummate a transaction adds to the project schedule and increases costs due to the delay in commencing design and construction of the federal facility.

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H.3. Known Nonfederal Sites Dismissed

GSA identified several nonfederal sites in the Washington, National Capital Region (NCR) that could possibly meet the DHS Collocation requirement. The evaluation criteria used for these sites were the same criteria as were used for the Federal sites:

(1.) Is there developable land on the site with the potential to meet the DHS need for 4.5 million gross square feet plus parking? (2.) Is the site compatible with DHS’ need for Level 5 security? (3.) Is the site within proximity to the White House and Congress? (4.) Is the developable land available for use by DHS? (5.) Can the site accommodate DHS’ FY2013 initial occupancy timetable? (6.) Is the site located in proximity to major roadways? (7.) Is the site located in proximity to a Metro station? (8.) Does the site have access to neighborhood amenities within walking distance? (9.) If the site does not contain sufficient developable land to meet the DHS need for 4.5 million gross square feet plus parking, does the site have developable land adjacent to it that will accommodate approximately 750,000 GSF of new development plus parking?

None of the sites identified was in the District of Columbia and therefore none met the DC proximity requirement imposed by the Seat of Government Act. Although they typically had access to major roadways, they were generally not on major public transportation routes nor were they generally close to amenities.

GSA developed a summary analysis of sites identified in the NCR and evaluated those sites against the DHS evaluation criteria:



Yes.

Security Needs Are the sites compatible with DHS’ need for Level 5 security (a walled campus)?

Yes.


Are the sites within proximity to the White House and Congress?

No. All sites are outside the District of Columbia and not located near public transport for ready access to downtown DC.


No.

Schedule Can the sites accommodate DHS’ FY2013 initial occupancy?

Likely not. Site acquisition would need to be negotiated and consummated.

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Roadway Access Are the sites located in proximity to major roadways?

Generally, yes.

Transit Access Are the sites located in proximity to Metro station?

No.


Do the sites have access to neighborhood amenities within walking distance?

No.

Adjacent Parcel


Generally, yes.

I. Non-Federally Owned Sites – Lease

A general discussion of considerations related to leasing real property to satisfy Federal agency requirements follows, together with an analysis of sites considered.

The two primary disadvantages of leased space are that on a life cycle present value cost basis, leasing is generally more expensive than federal ownership and the Government often cannot implement the full complement of security features as required by the Interagency Security Committee (ISC).

Leasing is a higher cost of occupancy alternative to the Government because of the need to pay market rents. In January 2003, GAO designated federal real property as a high-risk-area because of long standing problems with excess and underutilized property, deteriorating facilities, unreliable real property data, and over-reliance on costly leasing. Federal agencies were also facing many challenges in protecting their facilities against the threat of terrorism. GAO found further that these problems have been exacerbated by obstacles that include competing stakeholder interests in real property decisions, various legal and budget-related limitations, the need for better agency capital planning, and the lack of a strategic, government-wide focus on real property issues.31

An April 2007 GAO report indicated that federal agencies reported challenges associated with implementing physical security measures because of issues securing leased space.32

58 31 GAO-07-349, Federal Real Property, Progress Made Toward Addressing Problems, but Underlying Obstacles Continue to Hamper Reform, p. 1

32 Ibid., p. 35.

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Even when GSA is able to locate leased facilities that provide the necessary space for an agency to operate, land required for security setbacks is often not available in leased locations in urban areas. Furthermore, GSA is prohibited by OMB Circular A-11 from incorporating security requirements in leases to the degree that the rent paid by the Government exceeds the high end of the local real estate market. Also, including required security criteria in leases often results in an operating lease becoming a capital lease. A capital lease is a lease where, among other factors, the present value cost of the rental payment approaches the value of the asset. In those instances, OMB requires an agency to account for the lease payment in one year as if the Government had purchased the property, as opposed to recognizing the payments over the term of the lease. “Scoring” the lease in this manner has very negative budgetary ramifications and is based on Financial Accounting Standards No. 13 which was first issued in 1976.

As a part of its evaluation of development alternatives to house the DHS requirement, GSA’s TAPS analysis indicates that the present value cost advantage to develop the St. Elizabeths West Campus compared to leasing the requirement in a downtown location is greater than $600 million dollars as indicated in the latest prospectus under review by Congress. (See also Overall Conclusion.) It should be further noted that GSA has been unable to locate any leased site in downtown Washington that can meet the DHS need.

I.1. Method for Leasing

Lease projects are identified through defined agency requirements that are based on a detailed Program of Requirements (POR) that, depending on the size of the requirements, can take up to 18 months to complete. Using the POR, and depending upon the estimated dollar amount of the requirements, GSA prepares a lease prospectus for approval by Congress. Once the GSA regional office concurs on the annual leasing program, the Assistant Regional Administrator signs an official transmittal of the prospectus to GSA’s Central Office (CO). This usually occurs in the fall of each year, 18 to 36 months prior to the fiscal year in which GSA proposes to execute the project. Following review by GSA’s Central Office, the CO-approved prospectus is then sent to the Office of Management and Budget (OMB). Prospectuses are considered supporting documents for GSA’s budget. After OMB approves a prospectus, it is returned to GSA for official signatures of the Administrator of GSA and the Commissioner of the Public Buildings Service (PBS). The signed prospectus is then submitted to Congress. At this point, the prospectus becomes a public document, and is no longer considered draft or administratively confidential. During the prospectus process, GSA in partnership with its customer agency develops a Solicitation

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for Offers (SFO) that outlines in greater detail than the prospectus the entire agency requirements identified in the POR.

Once the prospectus is submitted to Congress, GSA can issue the SFO to the market to begin the lease procurement process. Lease award cannot be made until Congress authorizes the prospectus.

The House Committee on Transportation and Infrastructure and the Senate Committee on Environment and Public Works, both with oversight of GSA, receive the prospectus at the same time. Each committee schedules its own hearings and mark-up of the prospectus. Either committee may authorize the prospectus first. However, the House Subcommittee on Economic Development, Public Buildings and Emergency Management must approve the prospectus before it is sent to the full committee. Each Committee sends GSA a resolution authorizing the action proposed in the prospectus. Both resolutions are necessary prior to taking action.

Once the House and Senate authorizations are executed for a lease prospectus, GSA may award the lease.

I.2. Time Needed to Lease

Up to five and a half years may be required between conception and lease execution. The initial planning, including development of the POR and agency planning and budgeting for furniture, fixtures & equipment (FF&E) plus Information Technology (IT) needs, can take 18 months. Another 18 months can be required for the lease prospectus review and approval process plus initial steps in the lease procurement. Even when the procurement process is run concurrently with the prospectus process, the time needed to procure the lease can run up to 12 months. Once the lease is procured, and depending on the size of the procurement, it can take up to two years for design and construction of the build out plus agency procurement and installation of FF&E and IT / telecommunications equipment.

I.3. Owned Buildings Perform Better Financially

Government Owned Buildings are more profitable from a GSA perspective and increase the solvency of the Federal Buildings Fund. The GSA Federal Buildings Fund (FBF) is an intra-governmental revolving fund that finances the cost of acquiring and managing United States Federal Government real estate and real property maintenance activities for those properties under the legal custody and control of the GSA. The real property maintenance activities include the operation, maintenance and repair of federally owned and leased buildings. The

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FBF was authorized and established by the Public Buildings Amendments of 1972 (Public Law 92-313; Public Law 107-217; as codified by 40 U.S.C. § 592). The basic philosophy that led Congress to establish the FBF is that federal agencies budgeting and paying for their own space requirements will establish more stringent controls over space usage and ultimately produce savings.

The FBF, although it is a revolving fund, is subject to annual enactment of new obligational authority (a limitation on the use of revenue) by the Congress, in total and for each of its budget activities; it is apportioned by OMB. New Obligational Authority (NOA) for the activities of the FBF is provided through the normal appropriations process. The FBF operates much like an appropriation, with allowances, operating budget plans, and legal limitations on the level of obligations incurred. NOA is enacted in five no-year budget activities, which permits the authorized funds to remain available until expended. The FBF is financed by revenue from rental charges assessed to federal government occupants for space, which GSA is legally responsible to maintain. The rental charges, by law (40 U.S.C. § 586), are determined by the GSA Administrator and shall approximate commercial rates for comparable office space. In addition, Congress may appropriate monies from the general funds of the Treasury to the FBF, as it deems necessary. The balance of revenues of the FBF not authorized for use by Congress in a particular year, remain in the Fund until authorized for use in future appropriation Acts.

Rental charges to occupants for federally owned space are priced by an appraisal based on comparable properties that sets a market rate rent for a five year period. Rental charges to occupants for leased space are priced as a pass through of the underlying GSA lease contract, plus a GSA fee that funds lease management costs incurred by GSA. Each space assignment in GSA managed space is the result of an agreement between GSA and the federal agency occupying the space, called an Occupancy Agreement (OA), stating the financial terms and conditions for the occupancy.

To ensure GSA is operating efficiently and effectively, PBS tracks a number of financial indicators: revenue, operating expenses, indirect expenses, return on equity (ROE), net operating income (NOI), and Funds from Operations (FFO). GSA compares these metrics to industry benchmarks and prior performance. FFO, GSA’s primary indicator of financial performance, is the amount of revenue remaining after deducting all day-to-day expenses associated with operating owned and leased buildings.33 A review of the GSA annual report 61 33 GSA Public Buildings Service, State of the Portfolio, FY 2007, p.11.

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for Fiscal Year 2007, State of the Portfolio, indicates that from fiscal years FY04 through FY07, GSA’s federal owned inventory outperformed the leased inventory on a Funds from Operations basis by a factor of 29. That is, GSA received approximately 29 times more Funds from Operations from owned versus leased facilities. The resulting benefits associated with the increase in FFO are advantageous for GSA, and, ultimately, the American taxpayer.

I.4. Owned Buildings Allow for implementation of ISC Criteria

Security is a major concern in housing Federal agencies. All new federal buildings should have a minimum standoff distance of 50 feet. Some specialized facilities may require a higher standard for security. GSA recognizes that dense urban areas and historic properties may require an exemption from the standoff distance and, possibly, from blast criteria. Exemption from the PBS Commissioner must be issued for any reduction or modification of that requirement. In the Commissioner’s words, “The achievement of this standoff distance must be based on the feasibility of the site to accommodate a pragmatic, efficient, reasonable, cost effective, and well designed facility.” As GSA is the owner of most federal facilities, there is generally more flexibility to apply ISC security criteria there, as opposed to leased space.

I.5. Known Dismissed Leased Site

GSA identified one leased site in the National Capital Region (NCR) that could meet the DHS’ HQ consolidation requirement.

The evaluation criteria used for this site were the same criteria used for the Federal sites:

(1.) Is there developable land on the site with the potential to meet the DHS need for 4.5 million gross square feet plus parking? (2.) Is the site compatible with DHS’ need for Level 5 security? (3.) Is the site within close proximity to the White House and Congress? (4.) Is the developable land available for use by DHS? (5.) Can the site accommodate DHS’ FY2013 initial occupancy timetable? (6.) Is the site located in close proximity to major roadways? (7.) Is the site located in close proximity to a Metro station? (8.) Does the site have access to neighborhood amenities within walking distance? (9.) If the site does not contain sufficient developable land to meet the DHS need for 4.5 million gross square feet plus parking, does the site have developable land adjacent to it that will accommodate approximately 750,000 GSF of new development plus parking?

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The site is not under the Government’s custody and control nor is it currently master planned. GSA would need to conduct a lease acquisition to acquire an interest in the property that would allow DHS to relocate its headquarters functions there. This could take several years to accomplish, including submission of a lease construction prospectus to Congress, master planning of the site, and construction of the real estate with subsequent fit out for tenant occupancy. The site would therefore be unable to meet DHS’ occupancy timeframe. Furthermore, taxpayer funds would need to be expended unnecessarily when GSA already has land in its inventory that can meet DHS needs. As noted previously in the document, in determining acquisition method, GSA assesses lease versus owned costs.


Space Needs

Is there developable land with the potential to meet the DHS need for 4.5 million GSF plus parking? Yes.

Security Needs Is the site compatible with DHS’ need for Level 5 security (a walled campus)? Yes.


Is this site within proximity to the White House and Congress? The site is just outside the Beltway.


Not immediately. The site needs to be master planned


Likely not. Prospectus approval, then lease acquisition would need to be negotiated and consummated.

Roadway Access Is this site located in proximity to major roadways? Yes.

Transit Access Is this site located in proximity to Metro station? No.


Does the site have access to neighborhood amenities within walking distance? Possibly.

Adjacent Parcel

Does the site have developable land adjacent to it that will accommodate 750,000 GSF of new development plus parking? Yes.

This lease location could potentially accommodate the Level 5 security requirements and it has access to major roadways and possibly planned amenities; however, it is not located in the District of Columbia in accordance with the Seat of Government Act, nor is it immediately available for use by DHS. The site was dismissed for these reasons and because

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taxpayer funds would need to be expended unnecessarily when GSA already has land in its inventory that can meet the DHS needs.

J. Summary of Analysis

The DHS requirement for 4.5 million gross square feet of space plus parking, with an initial occupancy in 2013, represents one of the most expeditious and largest agency relocation efforts ever undertaken by GSA. As documented by DHS, a consolidation of its headquarters function at a single campus is a vital element to its need to increase agency effectiveness in carrying out its critical national security functions.

GSA bases its project requirements on the customer agency’s needs, facility and parking requirements, and operational needs.34 In accordance with Executive Order 1207235, “site selection and space assignments take into account the management needs for consolidation of agencies or activities in common or adjacent space in order to improve administration and management and effect economies.” Further, GSA’s development decisions are guided by the principles laid out in Executive Order 13327: Federal Real Property Asset Management as established by the Federal Real Property Council (the Council). The Council’s ten guiding principles, applicable to Federal real property asset management, are to:

1. Support agency missions and strategic goals

2. Use public and commercial benchmarks and best practices

3. Employ life-cycle cost-benefit analysis

4. Promote full and appropriate utilization

5. Dispose of unneeded assets

6. Provide appropriate levels of investment

7. Accurately inventory and describe all assets

8. Employ balanced performance measures

9. Advance customer satisfaction

10. Provide for safe, secure, and healthy workplaces

In carrying out its duties to provide office space to Federal agencies, GSA is obligated to acquire and utilize space in suitable buildings of historical, architectural, or cultural

64 34 GSA, Public Buildings Service, Office of the Chief Architect, March 2003.


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significance unless use of the space would not prove feasible and prudent compared with available alternatives.36 An additional consideration when locating offices in the National Capital Region is the legislative requirement for certain offices of the U.S. government to be located in the District of Columbia (DC), which requirement dates to 1790. Finally, one of the federal government’s goals has always been to assure the physical safety of federal employees who work in, and the private citizens who visit government-owned or leased buildings – this goal drives security features that must be included in Federal office projects.

GSA, in its role as real estate agent for Federal agencies, has assessed a wide variety of site options to locate the DHS headquarters campus. In Section F, the assessment considered land currently owned by the federal government, land currently controlled by the GSA, and land controlled by other federal agencies. In Section H, the assessment considered acquisition of sites not owned or controlled by the United States. In Section I, the assessment considered the merits of leasing a site for development of the DHS headquarters campus.

As explained in more detail below, based upon the analysis in this location analysis, GSA has concluded that DHS’ space requirements are best met through the renovation and redevelopment of St. Elizabeths. While there are challenges inherent in the use of the St. Elizabeths site and its redevelopment involves a complex approval process, no other site offers the same combination of ability to meet the need for 4.5 million gross square feet of secure office space, plus parking, in the time frame required.

Despite GSA’s general preference to utilize federally controlled property in housing federal agencies as described elsewhere in this Location Alternatives Analysis, GSA has considered a density reduction alternative on the West Campus of St. Elizabeths that would relocate a subset of DHS’ overall headquarters requirement to a parcel on the DC-Government controlled East Campus. It is important to note that the entirety of the DHS’ headquarters requirement could be accommodated on the West Campus; however, the West/East Campus alternative was devised as a mitigation/minimization measure in response to comments received on the West Campus alternatives. The West/East Campus alternative would locate a subset of DHS’ overall headquarters requirement on the East Campus, while retaining the bulk of DHS’ core functions on the West Campus, a federally controlled site to which a number of policy, strategic, financial, and schedule advantages are applicable (as 65 36 40 USC § 3306

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described in this Location Alternatives Analysis). Further, it is only because construction of the DHS program will commence on the West Campus in the earliest phase of the project – with a portion of the DHS program identified for the East Campus in a later phase – that a lease on the East Campus is viable from a schedule perspective

Since the release of the DHS Consolidation DEIS in Sep. 2007, GSA has expanded this Location Alternatives Analysis to explore the availability of sites that could accommodate 3.8 M GSF, with adjacent sites capable of accommodating 750,000 K GSF. GSA has also considered whether there are sites adjacent to the federally owned sites assessed herein to determine whether those adjacent sites could accommodate DHS’ requirement in a manner similar to the East/West Campus alternative. When considering all nine of the site selection criteria identified in this Location Alternatives Analysis, the expanded search did not reveal any sites capable of appropriately accommodating DHS’ headquarters requirement in the 3.8/.7 formulation contemplated by the new mitigation/minimization alternative other than St. Elizabeths.

Based upon the research in this Location Alternatives Analysis, set out below is the rationale for selecting the St. Elizabeths site.

J.1. Federally-owned or Controlled Sites

GSA reviewed fifteen potentially available sites that were either controlled by GSA or otherwise owned by the United States or an agency of the United States. The ability of each site to meet the DHS requirement was evaluated using the following criteria:

1. Is there developable land on the site with the potential to meet the DHS need for 4.5 million gross square feet plus parking?

2. Is the site compatible with DHS’ need for Level 5 security?

3. Is the site within close proximity to the White House and Congress?

4. Is the developable land available for use by DHS?

5. Can the site accommodate DHS’ FY2013 initial occupancy timetable?

6. Is the site located in close proximity to major roadways?

7. Is the site located in close proximity to a Metro station?

8. Does the site have access to neighborhood amenities within walking distance?

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9. If the site does not contain sufficient developable land to meet the DHS need for 4.5 million gross square feet plus parking, does the site have developable land adjacent to it that will accommodate approximately 750,000 GSF of new development plus parking?

None of the sites evaluated met all of the criteria. Only one site, St. Elizabeths, met eight of the nine criteria. One site, the Franconia Storage Depot, met five of the criteria but is subject to legislation that may lead to the Army using the site to relocate Defense Department employees to Fort Belvoir. Also, the Franconia Storage Depot would require a waiver of the Seat of Government Act requirement. Two other sites met five of the criteria; the Cotton Annex and Walter Reed Army Medical Center. Sites that met four or fewer of the criteria are not considered viable candidates for further consideration because they are not adequately responsive to DHS’ office space needs.

St. Elizabeths: The St. Elizabeths site meets eight of the nine evaluation criteria. (1) As GSA has concluded from the 2005 Land Use Feasibility Study, the 176 acre site is capable of accommodating DHS’ requirement for 4.5 million gross square feet plus parking, acknowledging the complex approval process required for Federal projects in the District of Columbia. While the site does have some development constraints due to its designation as a National Historic Landmark (“NHL”), the site’s status as a NHL does not prevent a reuse of the site. In fact, as discussed in Section B of this Location Analysis, federal policy favors reuse of historic sites when possible. (2) The St. Elizabeths site is large enough to provide sufficient setbacks to allow for the necessary security requirements. The existing wall that surrounds part of the site can be utilized as part of the required security system needed to meet DHS’ level 5 security requirements. Also, because the historic use of the site as a psychiatric hospital required limited and controlled public access, limitations and control of public access needed to maintain a level 5 security posture is in keeping with past uses of the site. (3) The site is within proximity to the White House and the Capitol as well as Congressional offices. Given DHS’ mission, efficient and sure access to the President, his advisors and key members of Congress is required for DHS to function effectively and quickly when national security requirements or natural disaster response requirements arise. Proximity to other key government officials is crucial for successful completion of DHS’ mission. (4) The site is immediately available for use by DHS. DHS has established the year 2013 as the first year of occupancy for the U.S. Coast Guard, one of its component agencies.

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This is dictated by the need to manage DHS’ current real estate portfolio as well as the need to consolidate headquarters functions at a single site to obtain maximum effectiveness in carrying out its functions. Because the St. Elizabeths site is not currently used by other agencies, there will be no delays caused by the need to relocate an agency from the site in order to accommodate DHS’ use of the site. Relocation of an existing tenant would consume much of the time prior to 2013 thereby preventing commencement of work needed to build specialized facilities needed for DHS to carryout its mission. (5) As detailed in item 4 above, the site is capable of meeting DHS’ initial occupancy timetable. (6) The site offers adequate access to roadways and transit. (7) The site is located relatively close to a Metro station. This allows DHS employees the option to use mass transit to commute to the site. (8) Although the site does not currently have access to neighborhood amenities within walking distance, an expanded array of amenities is anticipated as the surrounding neighborhood grows. Taking all of the aforementioned factors into consideration, the St. Elizabeths West Campus is an appropriate site to fulfill the DHS Collocation requirement. (9) The site does have developable land adjacent to it that can accommodate approximately 750,000 GSF plus parking. The East Campus of St. Elizabeths, owned by the District of Columbia, consists of more than 150 acres, a portion of which could house a portion of DHS’ requirements. As noted above, GSA has initiated discussion with the District of Columbia about developing a portion of the East Campus to accommodate DHS’ needs.

Franconia Storage Depot: The Franconia Storage Depot met five of the criteria. Based on a study prepared by another Federal agency, the site (1) could potentially accommodate up to 6 M GSF of space. The site is also (2) likely to meet Level 5 security requirements. However, (3) the site is unacceptably distant from Congress and the White House (14 miles), and while (4) GSA controls the site and could potentially make it available to DHS, (5) it would be difficult to develop the site for DHS’ use to meet the DHS occupancy timetable, since: (i) existing tenants would need to be relocated; (ii) the site would require a legislative waiver of the Seat of Government Act; and (iii) Congress would need to discontinue its consideration of the Franconia Storage Depot as an available site to house certain Army personnel currently slated to be relocated to Fort

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Belvoir.37 The site is (6) located near major roadways, (7) Metro, (8) neighborhood amenities, and (9) there is not available land adjacent to the site to accommodate another 750,000 GSF of space plus parking, however, additional land would not be needed in order to meet the DHS' requirement of 4.5 million GSF. Taking all of the aforementioned factors into consideration, the Franconia Storage Depot is not an appropriate site to fulfill the DHS Collocation requirement.

Cotton Annex: The Cotton Annex met five of the criteria. However, most significantly, (1) the site does not have enough developable land to meet the DHS need for 4.5 M GSF, as it is only 1.86 acres in size. In addition, (2) the site would not be capable of meeting Level 5 security. These considerable deficiencies make the site unacceptable. The site is (3) within close proximity to the White House and Congress, but (4) is not available for use by DHS for headquarters functions because FPS is currently using the site to screen vehicles and (5) is thus not capable of accommodating DHS’ FY2013 initial occupancy timetable. The site is also (6) located near major roadways, (7) Metro, and (8) neighborhood amenities but (9) does not have an adjacency to an available site capable of delivering 750,000 GSF of space plus parking. Taking all of the aforementioned factors into consideration, the Cotton Annex is not an appropriate site to fulfill the DHS Collocation requirement.

Walter Reed: The Walter Reed site met five of the criteria. However, most significantly, (1) the site does not have enough developable land to meet the DHS need for 4.5 M GSF, as massing studies show that only 3.7 M GSF can be accommodated on site, inclusive of parking. The site is (2) capable of meeting Level 5 security and it is (3) not unacceptably distant from Congress and the White House (5 miles). However, (4) the developable land is not available for use by DHS, since the site is not available until 2012 at earliest and (5) therefore the site cannot accommodate DHS’ FY2013 initial occupancy timetable. The site is (6) located near major roadways, (7) Metro, and (8) neighborhood amenities but (9) there is not an adjacent site capable of accommodating an additional 750,000 GSF of space plus parking. Taking all of the aforementioned factors into

69 37 P.L. 110-181 dated January 28, 2008 gives GSA authority to transfer the Franconia Storage Depot site to the Department of the Army to accommodate certain Army functions and personnel that are slated for relocation under the 2005 BRAC process.

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consideration, the Walter Reed site is not an appropriate site to fulfill the DHS Collocation requirement.

J.2. Non-federally Owned Sites – Acquisition

As previously discussed in Section G herein, Federal regulations require GSA to utilize assets under its control before acquiring another site. Further, the time and cost to conduct a acquisitions for sites needs to be considered in any development schedule. Site acquisitions can be costly and time consuming. Despite the clear preference by the Federal Government to own versus lease, GSA identified some privately controlled sites in the National Capital Region that could meet the DHS Collocation requirement in terms of available square footage.

These acquisition sites met only three of the evaluation criteria. Although the sites (1) had developable land with the potential to meet the DHS need and (2) were capable of delivering Level 5 security, the sites were (3) generally unacceptably distant from the White House and the Capitol. In addition, the sites (4) were not available for use by DHS, nor were they (5) capable of meeting DHS’ FY2013 initial occupancy timetable, due to the time-consuming requirements of negotiating and consummating site acquisition. The sites were generally (6) located in proximity to major roadways, but not (7) in close proximity to Metro or (8) accessible to neighborhood amenities. Some had (9) adjacent sites that could accommodate 750,000 GSF of space plus parking if DHS were to split its 4.5 million GSF of space plus parking requirement. However, taking all of the aforementioned factors into consideration, the privately controlled acquisition sites are not appropriate to fulfill the DHS Collocation requirement.

J.3. Non-federally Owned Sites – Lease

As previously discussed in Section I herein, the two primary disadvantages of leased space are that on a life cycle present value cost basis, leasing is generally more expensive than federal ownership and the Government often cannot implement the full complement of security features as required by the Interagency Security Committee (ISC).

Even when GSA is able to locate leased facilities that provide the necessary space for an agency to operate, land required for security setbacks is often not available in leased locations in urban areas. Furthermore, GSA is prohibited by OMB Circular A-11 from

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incorporating security requirements in leases to the degree that the rent paid by the Government exceeds the high end of the local real estate market.

Between five and seven years may be required between conception and lease execution. The initial planning, including development of the POR and agency planning and budgeting for furniture, fixtures & equipment (FF&E) plus Information Technology (IT) needs, can take 18 months. Another 18 to 36 months can be required for the lease prospectus review and approval process plus initial steps in the lease procurement. Even when the procurement process is run concurrently with the prospectus process, the time needed to procure the lease can run up to 12 months. Once the lease is procured, and depending on the size of the procurement, it can take up to two years for design and construction of the build out plus agency procurement and installation of FF&E and IT / telecommunications equipment. If the move is phased, an additional six months can elapse before the final employee has been moved into the new space. Finally, as discussed in detail in Section I, owned buildings perform better financially than leased buildings, and thereby save the taxpayer money.

Despite these significant considerations, GSA identified a site available for lease in the National Capital Region that could meet the overall DHS Collocation requirement in terms of available square footage.

The lease site met four of the evaluation criteria. The site (1) had the potential to meet the DHS need, and (2) the ability to meet the Level 5 security requirements. However, (3) the site was unacceptably distant from the White House and the Capitol. In addition, the site (4) was not immediately available for use by DHS, but (5) it was apparently capable of meeting DHS’ FY2013 initial occupancy timetable, due to the time-consuming requirements of negotiating and consummating a lease acquisition. The site was (6) located in proximity to major roadways, but not (7) in proximity to Metro nor (8) readily accessible to neighborhood amenities. (9) The site was adjacent to other sites that could accommodate 750,000 GSF of space plus parking if DHS were to split its 4.5 million GSF of space plus parking requirement. However, taking all of the aforementioned factors into consideration, the lease site is not appropriate to fulfill the DHS collocation requirement.

GSA also tested the St. Elizabeths site against a potential leased site to determine if the use of St. Elizabeths was cost effective. As is more fully documented in section G.4. of this Location Analysis, the present value cost advantage to develop St. Elizabeths compared to leasing a site able to accommodate the DHS requirements is greater than $600 million..

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J.4. Conclusion

Consistent with the aforementioned evaluation factors and with this Location Analysis, GSA has concluded that the St. Elizabeths site is the only site available that is capable of meeting DHS’ requirements in the National Capital Region.

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