Acquisition of Leased Space

TABLE OF CONTENTS

OVERVIEW

2.1 What is the purpose of this chapter? This chapter describes the U.S. Fish and Wildlife Service’s (Service) requirements and policies for acquisition of leased space, which includes planning, requesting, and managing space leasing projects.

2.2 What is the scope of this chapter? This chapter applies to all Service employees involved in the acquisition of leased space. Although this chapter’s content refers to General Services Administration (GSA)-provided space, the space request package requirements and project management processes are generally the same for direct leases (see 370 FW 4). See Part 340, Real Property Management, for planning and requesting Service-owned administrative space.

2.3 What are the authorities for this chapter? See 370 FW 1 for a list of authorities for all the chapters in Part 370. For authorities specific to this chapter, see:

A. Cross-Reference to the Federal Management Regulation (FMR) (41 CFR 101-17.0). 

B. 425 Department of the Interior Manual (DM) 1 – 6, Space Management.

CLASSIFICATIONS OF LEASES

2.4 What are the classifications of leases? Within the Federal Government there are several classifications of leased space. Leasing Contracting Officers (LCO) assess space requests based on strategic goals, lease scope, size, period of performance, and cost to determine the best method for leasing. Table 2-1 describes Service space leasing options and limitations.

Table 2–1: Classifications of Leases

PLANNING 

2.5 Who do programs or Regions contact to plan for and acquire leased space? Contact the Joint Administrative Operations (JAO) Space Leasing Team via mySupport. 

2.6 How long does it take to lease space? This varies according to the complexity of the project. GSA requires 36 months advance notice of the expected space delivery date or current lease expiration. For new GSA-provided space requests, you should begin planning with the Space Leasing Team at least 6 months earlier. 

2.7 Who may contact potential lessors? Only Space Leasing Specialists or GSA may contact lessors about leasing space for the Service. 

2.8 Who funds leased space rent, tenant improvements, security, furnishings, and facilities management, and how are they paid?  

A. The programs fund the leased space they occupy. The programs pay rent for GSA-provided or direct leases through the Financial and Business Management System (FBMS).

(1) Annual obligations for OA and U.S. Department of Homeland Security (DHS) agreements are created in FBMS. For guidance on obligation requirements, see Department of the Interior Acquisition, Arts, and Asset Policy (DOI-AAAP)-0086, Obligation Requirements for Leases Executed Under Statutory and Delegated Authorities, GSA Occupancy Agreements, and DHS Security Charges.

     (a) GSA OAs require a customer agency to fund only current-year rent obligations. This is possible because GSA has special authorities that flow through to the customer agencies. The Service is barred by fiscal law from using current year funds to meet a future year’s obligation.

     (b) The OA is an interagency agreement between GSA and its customer agency and must not be construed as obligating future year customer agency funds until they are legally available. A multi-year OA simply means the customer agency will seek the necessary funding through budget and appropriations processes (see 41 CFR 102-85.65).

(2) Annual obligations for categorical and GSA-delegated direct leases are created in FBMS at the beginning of each fiscal year as part of the fund-year update. For guidance on obligation requirements, firm term, and option year(s), see DOI-AAAP-0086.

(3) ISA obligations are created in FBMS for the entire lease value at the initiation of the lease. For guidance on obligation requirements, firm term, and option year(s), see DOI-AAAP-0086.

B. The programs may pay for Tenant Improvements (TI), also known as space alterations, using the following methods. 

(1) For GSA OAs, the program may pay:

     (a) GSA via FBMS in advance as a lump sum, using a Reimbursable Work Authorization (RWA);

     (b) GSA via FBMS through amortized rent payments;

     (c) The Service’s contractor via FBMS after receiving GSA contracting delegation; or

     (d) The Service’s contractor via micro-purchase using the Government purchase card. The program must coordinate with a Space Leasing Specialist for GSA and lessor approval. Payment made using the Government purchase card must not exceed the $2,000 threshold for construction micro-purchases.

(2) For direct leases, the program may pay:

     (a) The direct lease landlord via FBMS as a lump sum or through rent payments;

     (b) The Service’s contractor via FBMS with direct lease landlord approval; or

     (c) The Service’s contractor via micro-purchase using the Government purchase card. The program must coordinate with a Space Leasing Specialist for landlord approval. Payment made using the Government purchase card must not exceed the $2,000 threshold for construction micro-purchases. 

C. Programs may contract for space-related personal property (e.g., audio/visual systems, electronic security, furniture, and phone and data cabling) with permission from GSA and in conjunction with the landlord. 

D. The DHS Federal Protective Service (FPS) provides physical security oversight, building security assessments, and guard services for GSA-provided space. FPS processes separate monthly bills for basic security and guard services, and the Service distributes the bills to programs based on rent payment distribution. 

E. The programs may distribute space and facilities expenses based on the program’s occupied square feet, percentage of occupancy, number of assigned desks/occupants, or other criteria they negotiate. 

2.9 How does the Service plan for space? The Department of the Interior (Department) requires the Service to submit a 5-year strategic plan called the Space Management Plan (SMP).

A. The SMP describes our long-term strategy to:   

(1) Reduce the space footprint,

(2) Control lease sizes and costs at Headquarters and Regional offices, 

(3) Seek collocation opportunities, and

(4) Execute our space management policy. 

B. The SMP is updated annually to reflect our changing needs and goals, and:

(1) Includes inventories of Service-owned assets, direct leases, and GSA OAs with planned leasing actions noted;   

(2) Reports significant changes in our space portfolio; 

(3) Assesses the space-related performance metrics we report to the Department; and   

(4) Aligns space management with Administration and Departmental goals.

STANDARDS

2.10 What space planning standards are applied to achieve space management goals?  

A. We must comply with, or be lower than, the Department’s established standard Utilization Rate (UR) when acquiring or significantly renovating office space. The standard UR is 180 Usable Square Feet (USF) or less per person and is measured using American National Standards Institute (ANSI) and Building Owners and Managers Association (BOMA) standards. If the USF measurement is not available, see DOI-AAAP-0049, Office Space Utilization Design Standard, for using rentable square feet for direct leases or gross square feet for Service-owned administrative space.

B. The standard UR includes all individual and shared space such as closed offices, workstations, circulation, general office filing, storage space, and meeting rooms. This standard UR applies to office space for: 

(1) All new or renewing GSA-provided space, 

(2) Direct leases, 

(3) Non-lease agreements that supply office space for employees, and 

(4) New office space requirements in Service-owned buildings. 

C. For prospectus-level leases, the UR is 150 USF or less per person (see GSA.gov for the current prospectus threshold). 

D. Where practical, open floor plan design should be used to take advantage of large spaces and minimize small rooms such as enclosed offices. Our space planning standards for typical sizes and layouts of workspaces and support spaces are described in the Space Management Desk Reference Guide (DRG) and incorporated into the Service's Space Calculator (calculator). 

E. Assigned workspace is limited to employees who report to a physical office at least 50 percent of the pay period.

F. Unassigned workspace (also called hoteling or hot-desking) is used by employees who have remote work or core telework agreements that do not require them to report to a physical office at least 50 percent per pay period. Temporary employees, contractors, cooperators, and volunteers use unassigned work space (see Part 633, Friends Organizations).

G. Enclosed offices are limited to, but are not required for, supervisors. We assign workstations to non-supervisory staff or supervisory employees who do not require an office. A workstation may not have: 

(1) Panels that exceed 66 inches in overall height, or 

(2) Doors. 

H. We use Universal space and kit-of-parts design concepts to ensure common accessibility, standardize space allocation and furnishings, and reduce waste and expense (see the DRG).

2.11 When can variances to the standard UR be approved? 

A. The Regional Director may allow for a variance to the standard UR when one of the following applies. The program must include a complete description of the variance in the space request package.

(1) Market research proves that only one competitively available option exists within the delineated area, and the lease cannot be further reduced or modified to meet the standard UR;

(2) The Service’s mission would be adversely affected by reduced space requirements for support or special type space (see the DRG for descriptions of support and special spaces); 

(3) A standard UR is not in the best interest of the Service financially as demonstrated by a cost-benefit analysis over the term of the lease; or

(4) Space requirements for a reasonable accommodation can’t be achieved within the standard UR.

B. Space requirements for exempt special spaces are included in the calculator when determining the UR. (See DOI-AAAP-0049 for descriptions of space excluded from the UR. GSA does not always recognize agency space-type exemptions and uses an all-inclusive methodology.)

SPACE REQUESTS

2.12 When do programs need to complete a space request? A space request is required for all new and renewing direct leases and OAs. The program must conduct a reassessment of space needs at lease renewal.

2.13 Who approves leased space requests?  

A. Regional Directors, via memorandum, approve: 

(1) Regional leased space requests under 50,000 RSF; and

(2) Exceptions to the standard UR for individual leases up to 50,000 RSF. Regions must meet the standard UR when measured on a Regionwide basis.

B. The Assistant Director − Management and Administration (AD-MA), via memorandum, approves: 

(1) Leased space requests for locations assigned to the Headquarters Region;  

(2) Regional leased space requests for prospectus-level leases, Regional Offices (RO), and other spaces that are 50,000 RSF and greater. For these leases, the Regional Director’s team submits the package to the JAO Operations Chief, whose team:

     (a) Conducts a compliance review and facilitates approval from the AD-MA;

     (b) Requests approval from the Department’s Director, Office of Acquisitions and Property Management; and

     (c) Submits final space requirements to GSA;

(3) Leased space requests that use an independent statutory authority. 

2.14 How do programs initiate a leased space request, and what is included in the request package? Refer to the DRG for additional details and consult with the assigned Space Leasing Specialist to discuss space policy and project timelines. 

A. When a program requires new leased space, ARDs (and program Assistant Directors in Headquarters) should initiate the request with a Space Leasing Specialist via mySupport. 

B. When lease renewals are due, a Space Leasing Specialist will contact the local point of contact to initiate the request in advance of the expiration date. 

C. The request must include: 

(1) A memorandum describing and justifying the space needs. The space request must also include descriptions of any applicable exclusions (see section 2.11) or requested variances to the UR; 

(2) An approved and funded organizational chart indicating employee duty station and telework status. This document is not required for requests of non-office leases; 

(3) A completed calculator showing the amount and type of space needed and that the standard UR is met. The calculator may be prepared by either the requestor or the Space Leasing Specialist but must be signed by the authorized program project representative. The Space Leasing Specialist may approve the use of another programming document format if it provides equivalent information as the calculator. This document is not required for requests of non-office leases;

(4) A certification of funding signed by the approving official (see the template in DOI-AAAP-0086), which serves to identify the rent-paying lines of accounting that the Space Leasing Specialist inputs in FBMS; and

(5) A map that delineates connected road or landmark boundaries and illustrates the area where the space will be leased. The boundaries may be adjusted by GSA or the LCO during market research to achieve the desired competition.

2.15 What additional documents does GSA require? The Space Leasing Specialist will send the package to GSA with a courtesy copy to the Department’s Office of Acquisition and Property Management (PAM), and include the following additional documents:

A. Standard Form 81 (SF-81), Request for Space, signed by an LCO;

B. Agency-Specific Requirements (ASR);

C. GSA Client Project Agreement (CPA), Initial Engagement form, signed by an LCO; and

D. A Program of Requirements document (POR) or similar supporting narrative document describing the types and sizes of required spaces.

2.16 How is the OA produced and signed? 

A. GSA will produce the OA when space is accepted. 

B. The Space Leasing Specialist:

(1) Assesses the OA,

(2) Addresses any issues with GSA, and

(3) Sends the OA financial analysis to the program point of contact for program approval.

C. The LCO signs and authorizes the OA after the steps above are completed.

PROJECT MANAGEMENT

2.17 How are space projects managed? New and renewing leased space projects should follow project management principles to achieve best results. The project scope should be well defined and determine team membership and the project’s schedule.

A. Space project stakeholders and program representatives should participate in space projects to develop requirements; acquire the lease; and oversee alterations, furnishings, and relocation. See 370 FW 1 for the roles and responsibilities of all employees involved in space management. See the DRG and the examples below for project management roles.

(1) The project sponsor is the senior-level program representative who has final authority over the project. The project sponsor must assign one or more project manager(s) according to the needs of the project to ensure completion within scope, schedule, resources, and budget. The candidates for the role of project manager may be from the Space Leasing Team, JAO Project Management Team, Regional Business Team, GSA contractors, or they can be a hired consultant.

(2) The Space Leasing Specialist is the leasing Subject Matter Expert (SME). For many projects, the Space Leasing Specialist is also the project manager.

(3) GSA may provide a contracted consultant to assist in project development.

(4) The project manager should consult with SMEs from internal programs to include acquisition, budget, emergency management, engineering, environmental compliance, finance, information technology, personal property, physical security, and safety. The following project collaboration is strongly encouraged:

     (a) Initial planning – Stakeholders should be given an opportunity to participate in early project planning to ensure proper project phasing and coordination and that funding investments are anticipated and integrated into the individual project plan.

     (b) Schematic design – Stakeholders should be given an opportunity to review the 35 percent or equivalent construction documentation.

     (c) Design development - Stakeholders should be given an opportunity to review the 65 percent construction documentation.

(5) Programs must provide personnel resources for planning committees, purging paper files, and packing in preparation for the move to the new space. 

(6) Stakeholders and program representatives should participate in Departmental priority space projects.

B. Space projects generally follow these phases:  

(1) The planning phase includes defining the scope of the project, researching space options, developing the initial space requirements, and establishing the schedule, resourcing, and budgeting.

(2) The space request phase includes further developing the space requirements, compiling documents, receiving approvals, and submitting the package. 

(3) The leasing phase includes coordinating with GSA and the Space Leasing Specialist, as they are procuring the lease, reviewing and approving the OA, funding any TIs through an RWA, and making the commitment to pay the estimated rent and DHS/FPS security fees. 

(4) The design phase includes collaborating with GSA, the Space Leasing Specialist, and contracted consultants for services such as architectural, engineering, interior design, relocation, branding, security, and information technology. An architect will produce design intent and construction drawings for review by the Space Leasing Specialists, program representatives, and other Service SMEs for coordination of information technology, physical security, safety, sustainability, and environmental compliance. 

(5) The alterations phase includes the lessor’s general contractor performing any building renovation and TIs. GSA and the Service accept possession of the space and begin paying rent when the project is at substantial completion. 

(6) The relocation phase includes procuring move services, completing the physical move, and procuring and installing new furnishings and other personal property such as information technology, audio/visual, and electronic security systems in the new space. The former space will require personal property disposal, condition assessment and repairs, and close out, after which the Service stops paying rent.