considered are presented to the GSA Administrator.

GSA then

incorporates essentially this same information in to a Prospectus which, in accordance with law, it presents to the House and Senate Public Works Committees. GSA is precluded by statute from spending money on a project for construction, alteration, acquisitions, or lease of buildings involving expenditures of over $500,000 before the Prospectus has been approved by the Committees.

I would like to discuss the differences between this

approach and the A-109 acquisition framework. GSA's acquisition process is dictated to a great extent by law and the longstanding desires and practices of the congressional committees responsible for reviewing, approving, and funding individual projects.

The Commission and A-109 call for the agency head to approve a mission need statement before the identification and exploration of alternative system solutions. This requirement would normally be communicated to Congress during the budget process so that the Congress could consider the major needs of all agencies and their relative priorities prior to decisions to initiate

new programs.

GSA's approach differs from A-109 in that Congress is presented with the requirement and a preferred solution at the

same time.

To some,

this may not seem to be a significant variation, but we do believe it shortcuts one of the key elements of A-109-

the full examination of alternatives in

a competitive environment.

Under A-109, after agency he ad approval of the mission need statement, the agency would proceed to what OF PP has labeled the key action in the acquisition process. This is a formal solicitation so that industry can respond to the mission need with alternative concepts. Alternatives which might be proposed to satisfy a Feder al office space need include (1) use of excess or surplus space, (2) joint use of existing Federal buildings, (3) purchase of a non-Federal building, (4) leasing of space, or (5) construction of a new building.

As described above, GSA uses its market survey techniques to identify alternatives and to arrive at a recommended solution without a formal solicitation.

Another difference concerns the level of competition which will be obtained. For construction projects, GSA normally selects a single architect-engineer (A-E) firm from a list of qualified firms. For leasing projects, GSA selects the lessor without formal competition and then negotiates the lease price.

The Procurement Commission and A-109, however, strongly favor open competition. Leasing, new construction, and other alternatives should compete openly, and smaller and newer businesses should be given a cnance to compete. For new construction projects, the Commission favored maintaining at least two competing conceptual designs, and felt that the proposed concept of the end product should be a factor in selecting the A-E firm for the final design effort.

We have discussed these matters with OF PP and GSA officials. OF PP officials have also expressed confidence that the A-109 framework could be applied by Public Buildings Service; GSA officials, responsible for implementing A-109, on the other hand, nave said that they believe GSA accomplishes the spirit of A-109 in its existing acquisition process. GSA objected to the A-109 concept of a formal solicitation to industry based on the approved mission need, and made the following comments: --They feel formal competition is not necessary as GSA has the in-house expertise to adequately identify and consider alternatives and to arrive at the best solutions.

--They feel the A-109 framework is tailored toward
acquisition involving research and development and
the uncertainty inherent in these activities. They
believe this high level of uncertainty does not
exist in PBS activities.

--Statutory restrictions govern Public Buildings
Service activities and require Congressional
approval and funding before money can be spent
on a lease or construction project exceeding
$500,000. Implementation of A-109 would require
changes to existing statutes.

We have found no indication that GSA and OF PP are working together or with the appropriate Congressional Committees to resolve these

issues.

You also requested that we address other specific areas.

Each area is discussed below.

LEADERSHIP ROLE PLAYED BY GSA
IN ASSISTING OTHER AGENCIES

We found that for major acquisitions of other agencies, GSA is taking the position, which by the way is consistent with OF PP direction, that other agencies are responsible for insuring compliance with A-109 for that portion of the acquisition

process occuring within the agency. If GSA becomes the executive agency for the construction or acquisition at some point in the process, GSA would be responsible only for compliance with

A-109 for actions taken by GSA.

AGENCY REORGANIZATION TO

ACCOMMODATE A-109 REQUIREMENTS

To study and direct implementation of A-109, GSA initially established a Systems Acquisition Office. This office prepared a detailed plan for A-109 implementation and a draft GSA order which, we believe, reflected the acquisition framework intended by A-109. The office was dissolved in mid-1977 after the change in administrations. The order was not approved and the implementation plan was not carried out, apparently because of the GSA objections to the A-109 concept previously described.

GSA's current organization for implementation of A-109

consists of the Acquisition Executive, who is the Deputy Adminis-
trator, a two-person staff in his office, and one person each
in the Public Buildings Service and in the Automated Data and
Telecommunications Service who have been assigned implementation
responsibilities in addition to his basic responsibilities.

Actions to date include two GSA orders (an agency wide order and an order governing Public Buildings Service activities). A third order is being prepared governing automated data and telecommunications acquisitions and implementing instructions for Public Buildings Service activities are being prepared. As I said earlier, we believe the completed actions do not call for any significant change from the way GSA has conducted its PBS activities in the past. You also requested that we examine training relative to A-109 and GSA's plans regarding ongoing programs. We believe that if GSA implements A-109 as currently planned, there would be little effect on ongoing programs and no need for new training programs. Regardless, ten GSA officials have attended A-109 training conducted by the Federal Acquisition Institute and about 37 GSA officials have heard a lecture on A-109 which was presented at a Regional Commissioner's meeting.

LEVEL OF EFFICIENCY OF

GSA'S SELF-SERVICE

STORES

On April 14, 1977, we reported that GSA self-service stores were not providing agencies with efficient service and necessary supplies.