The American Recovery and Reinvestment Act (ARRA) provided the General Services Administration (GSA) with $5.55 billion for the Federal Buildings Fund to transform federal buildings into high-performance green buildings, as well as to construct federal buildings, courthouses, and land ports of entry. The GSA Office of Inspector General (OIG) reviewed two ARRA projects to determine if the Public Buildings Service (PBS) awarded and administered the contracts in accordance with prescribed criteria and ARRA mandates.
Goodfellow Federal Center Complex, St. Louis, Mo.
The OIG reviewed the Goodfellow Federal Center (Goodfellow) contract because energy usage on the 65-acre campus was substantially higher than any of the other buildings under review. In fact, the OIG found that Goodfellow exhibited a pattern of increased electricity usage, despite receiving more than $42 million in ARRA funding for infrastructure, building modernization, and energy-related improvements, as well as storm and sewer improvements, heating/ventilation/air conditioning, interior, electrical, and seismic work.
The OIG concluded that Goodfellow neither meets energy goals for ARRA projects nor contributes to the energy consumption goals mandated by the Energy Independence and Security Act of 2007, given that electricity use has been increasing. The OIG also noted that a complete assessment of the project could not be made due to the lack of historical information on energy use at the building level.
In its response to the OIG memorandum, GSA management outlined a variety of energy-related projects that were undertaken at Goodfellow after the OIG’s review. These initiatives included:
- An Energy Savings Performance Contract covering 14 different energy projects;
- Ongoing work to complete the installation of advanced software to provide energy data for all metered GSA buildings; and,
- Temporary installations to test energy-saving technologies through the GSA’s Green Proving Ground Program.
PBS also requested funding for a Targeted Energy Efficient Expert Evaluation project for Goodfellow Building Number 110.
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Bonneville Power Administration and Federal Buildings in Portland, OR
In 2010, GSA awarded a $5.22 million contract to Allen Bradbury Construction LLC (Allan Bradbury) for energy- efficiency upgrades and general construction services at the Bonneville Power Administration and GSA Federal Buildings located in Portland, Oregon.
The GSA OIG identified three issues related to the award and administration by PBS of construction services at the federal buildings:
- Security clearance requirements were not followed;
- Foreign-manufactured construction material was incorporated into the project; and,
- Davis-Bacon requirements were not followed.
Security clearance requirements were not followed
The OIG’s review found that three subcontractor employees were allowed to work on the project although they had been found unfit to work on a federal project by the Department of Homeland Security. Further, security officials had no personal identity verification records for 11 individuals and their names did not appear on the escorted list. The lack of adequate security clearances for prime and subcontractor employees could have put the occupants of the building, as well as the public, at risk.
Buy American Provisions
Section 1605 of ARRA required, unless an exception applied, that all iron, steel, and other manufactured goods used in construction be produced in the United States. The OIG inspected the mechanical and electrical equipment installed by Allen Bradbury and found equipment that was not in compliance with Section 1605. Specifically, the Schneider Electric Square D disconnect/breaker boxes were marked “Made in Mexico.” The OIG found no evidence that PBS had reviewed the contractor’s equipment submittals for compliance. Allowing foreign-made material to be installed violates the requirements of ARRA.
Federal Acquisition Regulations requiring the submission of payroll records in excess of $2,000 for construction projects were incorporated into Allen Bradbury’s contract. The payrolls assist the federal government in determining if prevailing wages are being paid. The OIG compared employees covered by Davis-Bacon wage determinations to the certified payrolls and found 26 employees, six whose names did not appear on the certified payrolls provided.
The OIG also found that at least three companies working under the contract had not submitted the required payrolls.
PBS officials concurred with the OIG’s findings and provided a comprehensive action plan to correct the deficiencies noted in the memorandum.