GSA's Guidance and Oversight Concerning Areawide Utility	 
Contracts (17-DEC-01, GAO-02-56R).				 
								 
In September 2001, GAO issued a report on the District of	 
Columbia school system's use of a General Services Administration
(GSA) areawide utility contract with the Washington Gas Light	 
Company. The school system has used this contract for $43 million
worth of general facility improvements and maintenance--work that
was outside the scope of the contract. GAO raised concerns about 
GSA's guidance on the use of areawide utility contracts. GAO	 
found that the guidance does not adequately indicate that, when  
the utility is not the only available source, services ordered	 
under areawide contracts must be provided by the utility acting  
in its capacity as a public utility. In addition, GSA lacked	 
oversight of the school system's use of the contract and was	 
unaware of the scope of work ordered under it, largely because	 
neither the school system nor Washington Gas complied with GSA's 
reporting requirements. 					 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-02-56R 					        
    ACCNO:   A02592						        
    TITLE:   GSA's Guidance and Oversight Concerning Areawide Utility Contracts                                                  
     DATE:   12/17/2001 
  SUBJECT:   Public schools					 
	     Facility maintenance				 
	     Contract oversight 				 
	     Maintenance services contracts			 
	     Reporting requirements				 
	     District of Columbia				 

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GAO-02-56R
     
1

GAO- 02- 56R GSA Areawide Utility Contracts

United States General Accounting Office Washington, DC 20548

December 17, 2001 Mr. David A. Drabkin Deputy Associate Administrator U. S.
General Services Administration Office of Acquisition Policy 1800 F Street,
N. W. Washington, DC 20405

Subject: GSA?s Guidance and Oversight Concerning Areawide Utility Contracts
Dear Mr. Drabkin: In September 2001, we issued a report on the District of
Columbia school system?s use of a General Services Administration (GSA)
areawide utility contract with the Washington Gas Light Company. 1 The
school system has used this contract for $43 million worth of general
facility improvements and maintenance- work that was outside the scope of
the contract. In the report, we raised concerns about GSA?s guidance on the
use of areawide utility contracts.

The guidance does not adequately indicate that, when the utility is not the
only available source, services ordered under areawide contracts must be
provided by the utility acting in its capacity as a public utility (i. e.,
subject to regulatory authority). Otherwise, the government?s competitive
contracting requirements apply. In addition, we found that GSA lacked
oversight of the school system?s use of the contract and was unaware of the
scope of work ordered under it, largely because neither the school system
nor Washington Gas complied with GSA?s reporting requirements. This letter
discusses these findings in greater detail and recommends actions that GSA
can take to improve its oversight of areawide contracts and its guidance on
their use.

Background

GSA is authorized by statute to prescribe policies and methods governing the
acquisition and supply of utility services for federal agencies. 2
Competition to

1 See District of Columbia: D. C. Public Schools Inappropriately Used Gas
Utility Contract for Renovations (GAO- 01- 963, Sept. 28, 2001). 2 See
section 201 of the Federal Property and Administrative Services Act of 1949,
as amended (40 U. S. C. sec. 481).

GAO- 02- 56R GSA Areawide Utility Contracts 2 provide such services is often
unavailable within the market established by a utility?s

regulators. In such cases, GSA and utility service providers enter into
areawide contracts to cover the service needs of federal agencies within the
utility?s franchise territory. The franchise territory is a geographical
area that a utility has a right to serve on the basis of a franchise or
other legal means. Areawide contracts provide a preestablished contractual
vehicle for ordering utility services such as electricity and natural gas.

According to the Federal Acquisition Regulation, areawide contracts
generally provide for ordering utility services at rates approved and/ or
established by a regulatory body (such as a public utility commission) and
published in a tariff or rate schedule. 3 Any federal agency having a
requirement for utility services within an area covered by an areawide
contract is required to acquire the services under that contract unless
service is available from more than one supplier. If service is available
from more than one supplier, the Federal Acquisition Regulation requires
that the service be acquired using competitive acquisition procedures. 4

The District of Columbia government is authorized by GSA to use available
areawide contracts for utility services. The District of Columbia school
system started using the GSA areawide contract with Washington Gas in late
1997. To date, the school system has ordered about $43 million worth of
general facility improvements and maintenance from Washington Gas as ?energy
management services? under the contract?s ordering procedures. For example,
the school system used the GSA contract for a variety of renovation
services, including painting, carpeting, plumbing, and electrical work;
boiler, air conditioning, and heating repairs; playground upgrades; bathroom
renovations; and the refurbishing of flagpoles.

Guidance on Use of Areawide Contracts Is Misleading

GSA?s Energy Center of Expertise has published two sets of guidance to
familiarize agencies with the use of its areawide utility contracts: the
Utility Areawide Guide

and Procuring Energy Management Services with the Utility Areawide Contract.

However, this guidance is misleading. GSA?s guidance does not explain that,
when the utility is not the only available source, services ordered under
areawide contracts must be provided by the utility acting in its capacity as
a public utility (i. e. subject to a regulatory authority such as a public
utility commission). Instead, the guidance states only that areawide
contracts allow agencies to procure from utilities a variety of energy
management services-

3 See 48 C. F. R. sec. 41. 204. 4 Id.

GAO- 02- 56R GSA Areawide Utility Contracts 3 including energy audits,
feasibility studies, and installation of energy conservation projects- and
that agencies can define their own energy management projects
under the contract.

GSA's use of areawide contracts for energy- efficiency services is based on
the National Energy Conservation Policy Act, as amended by the Energy Policy
Act of 1992. This law encourages investment in energy efficiency by electric
and gas utilities, establishes energy management requirements for federal
agencies, and authorizes federal agencies to participate in utility
incentive programs. (Appendix II contains more detail on the authorization
for agencies to participate in utility incentive programs). Furthermore,
Executive Order 13123, Greening the Government Through Efficient Energy
Management, issued on June 3, 1999 and based on the Energy Policy Act,
requires agencies to reduce energy usage and cost through the use of
alternative financing and contracting mechanisms.

Areawide contracts may be appropriate vehicles for carrying out the federal
energy management goals of the Energy Policy Act and the Executive Order.
However, under these authorities, use of these contracts is limited to only
those services that are subject to public utility regulatory authority and
offered by a utility in its capacity as a public utility.

The Energy Policy Act authorizes agencies to participate in a utility
company's energy- efficiency programs that are generally available to the
utility's customers. Such utility services are subject to public utility
regulatory authority not only because of the regulated nature of the utility
industry in general, but also because of the Energy Policy Act's specific
requirement that investment by electric and gas utilities in energy
efficiency be subject to state regulatory authority. 5 Congress, in
requiring under the Energy Policy Act that utilities and public utility
commissions consider energy- efficiency programs to reduce energy demand,
intended that state laws and regulatory commissions would continue to
determine whether utilities actually engage in such activities. 6 Further,
Executive Order 13123 defines 'utility' as meaning public agencies and
privately- owned companies that market, generate, and/ or distribute energy
or water as commodities for public use and that provide the service under
federal, state, or local regulated authority for all authorized customers. 7

5 Sections 111 and 115 of the Energy Policy Act amended the Public Utilities
Regulatory Policies Act of 1978 (16 U. S. C. sec. 2621; 15 U. S. C. sec.
3203) to encourage investments in conservation and energy efficiency by
electric and gas utilities under state regulatory authority.

6 H. R. Conf. Rep. No. 102- 1018, at 381- 82, 383- 83, reprinted in 1992 U.
S. C. C. A. N. 2472- 73, 2474- 75. 7 The principal determinative
characteristic of a public utility is that of service to, or readiness to
serve, an indefinite public that has a legal right to demand and receive its
services or commodities. 64 Am Jur 2d Public Utilities sec. 2 (2001). A
public utility holds itself out to the public generally and may not refuse
any legitimate demand for service, while a private business independently
determines whom it will serve. Id.

GAO- 02- 56R GSA Areawide Utility Contracts 4 Accordingly, the energy-
efficiency programs available to federal agencies under the

Energy Policy Act- and generally available to the utilities' customers- are
subject to public utility regulatory authority. To the extent that the
Executive Order authorizes the use by federal agencies of GSA areawide
contracts for the procurement of energyefficiency services from utilities,
such services may be provided only in the utility's capacity as a public
utility (i. e. subject to regulatory authority). Otherwise, such services
would not be properly available to federal agencies through areawide
contracts, which are typically entered into by GSA with utilities on a sole-
source basis precisely because of utilities' status as public utilities with
exclusive franchises. GSA's guidance on the use of areawide contracts fails
to make this clear.

Finally, GSA's guidance does not list alternatives to areawide contracts for
use in situations where these contracts are inappropriate. For example, the
guidance could refer agencies to procedures for using energy savings
performance contracts (which are awarded using competitive procedures) or to
the Federal Acquisition Regulation procedures for acquiring utility services
where more than one source is available. Appendix III contains more detail
on energy savings performance contracts. Preexisting government sources,
such as GSA's federal supply schedules, may be another option for fulfilling
agencies' needs for certain energy management services.

Guidance Does Not Emphasize Competitive Contracting Requirements

In responding to our September 2001 report, GSA takes the position that the
acquisition of utilities' energy- efficiency services without competition,
through an areawide contract, is an authorized exception to the government's
competitive contracting requirements. According to GSA, the Energy Policy
Act's authorization for federal agencies' participation in utility incentive
programs provides authorization to procure the services from a specified
source (the utility), which is one of the statutory exemptions from
competition in the Competition in Contracting Act of 1984. 8 However, even
if the Energy Policy Act provides such authorization, the exemption from
competition is limited to the acquisition of utility services subject to
regulatory authority. GSA's guidance does not make clear that, when the
utility is not the only available source for the services, the acquisition
of the services is otherwise subject to the government's competitive
contracting requirements.

GSA enters into areawide contracts without competition due to the regulated
nature of utility services, which, because of the legal right granted to a
utility to service an exclusive area, typically precludes competition. A
service is authorized under a utility incentive program- and thus under an
available areawide contract- when it is

8 41 U. S. C. sec. 253( c)( 5).

GAO- 02- 56R GSA Areawide Utility Contracts 5 subject to public utility
regulatory authority. 9 Federal agencies would then be

authorized to participate in the program by the Energy Policy Act,
notwithstanding the availability of other sources for specific energy-
conservation projects. The use of an areawide contract to procure energy-
efficiency services that are not subject to regulatory authority is
inconsistent with the government's competitive procurement requirements. In
a June 20, 1974, bid protest decision, we held that in procuring utility
service, GSA is obligated to obtain competition to the extent that it is
available

(RCA Alaska Communications, Inc., B- 178442). We held that GSA's authority
to procure utility services under the Federal Property and Administrative
Services Act does not justify noncompetitive procurements where competition
is available. We recognized that where public utilities are involved, the
number of potential sources may be severely limited, or, for that matter,
only one source may be available. However, we stated that, in our opinion,
'the duty to obtain maximum competition is paramount.' We concluded that GSA
must assess the availability of competition and act accordingly before
entering into public utilities contracts.

Unless utilities provide energy- efficiency services in their capacity as
public utilities, we believe the services cannot be procured through a GSA
areawide contract without violating the Competition in Contracting Act of
1984. This Act establishes an even higher competition standard-' full and
open'- than was applicable in the 1974 GAO bid protest decision. If GSA
allows federal agencies to use areawide contracts to procure energy
efficiency services that are not subject to public utility regulatory
authority, GSA is not providing for full and open competition for potential
sources of these services, as required.

The GSA guidance lists a variety of potential energy- efficiency projects,
none of which involve work that only a utility could provide. Most of them-
general facility improvements and heating, ventilation, and air conditioning
equipment upgrades- could be performed by other sources such as a general
contractor, licensed plumber or electrician, or heating and air conditioning
equipment company. Nonetheless, the guidance states that most types of
energy and energy management services are

9 For example, a July 29, 1994, GSA Office of General Counsel memorandum
approved the use of an existing areawide contract for the acquisition of
energy management services. The utility company's proposed energy
conservation measures were a tariffed service offered under a program
authorized by the state public utilities commission, and participation in
the program was generally available to customers of the utility. The public
utility would provide GSA a subsidy offsetting the total cost of certain
energy conservation measures (including the installation of energy- saving
equipment) which would be paid for through a monthly service charge on the
agency's electric bill over 14 years. Payment for the services rendered by
the utility would be determined in accordance with an equipment services
tariff approved by the public utilities commission.

GAO- 02- 56R GSA Areawide Utility Contracts 6 available through areawide
utility contracts, and that these contracts have the

flexibility to cover 'nearly every type of energy, water, and demand- side
management project possible.' According to the guidance, 'if your local
utility services provider offers it, your Agency can procure it quickly and
easily using the GSA Areawide Contract.' However, GSA's guidance does not
inform agencies that the procurement of any of the numerous potential energy
conservation projects it lists is subject to the availability of those
services through regulatory authority over public utilities and thus may not
actually be available in each case. The guidance also fails to state that,
when the utility is not the only available source, services ordered under
areawide contracts are limited to those provided by the utility in its
capacity as a public utility.

GSA Lacked Oversight Over School System's Use of Washington Gas Contract

Neither Washington Gas nor the District of Columbia public school system
complied with requirements to inform GSA of all orders executed under the
areawide contract with Washington Gas. In fact, the GSA contracting officer
responsible for the contract was unaware that the school system had
improperly used the contract until we informed her in April 2001.

GSA's contract with Washington Gas requires a copy of each order executed
under the contract to be transmitted by the ordering agency (in this case,
the District of Columbia Public Schools) to GSA. This instruction is also
printed on the front of the contract's ordering form. In addition, the
contractor is required to provide GSA with an annual report listing all
federal customers requiring service under the contract, including the
nature, dollar value, and quantity of service. Furthermore, the Federal
Acquisition Regulation requires agencies using GSA areawide contracts to
provide GSA with a copy of each order issued to the contractor within 30
days after execution. 12

The contracting officer stated that many ordering agencies and contractors
do not comply with the requirement to report on their use of areawide
contracts. In this case, neither Washington Gas nor the school system filed
copies of any of the orders executed under the contract. The official said
GSA administers about 160 areawide contracts nationwide and lacks the
resources to adequately monitor contract usage. As a result, GSA relies on
ordering agencies to raise questions or concerns. In the case of the school
system's use of the Washington Gas contract, however, the school system's
contracting officer did not raise questions about the scope of work allowed
under the contract. Thus, GSA was unaware that the contract was being
improperly used.

12 48 C. F. R. sec. 41.204( e).

GAO- 02- 56R GSA Areawide Utility Contracts 7 Once we notified GSA that the
school system was using the Washington Gas contract
for work outside the scope of the contract, the GSA contracting officer took
prompt action. In May 2001, GSA sent a letter to the schools' contracting
officer stating that

GSA's contract with Washington Gas is not intended to provide general
facility improvements and maintenance that are not energy- related and

the continued use of the contract for services outside its scope and intent
would jeopardize the school system's ability to continue using the contract.

The schools' contracting officer responded that the school system would
adhere to the intended use of the contract when ordering future services and
would follow GSA guidance to ensure that only proper services are ordered.
However, we remain concerned that, by following the GSA guidance, the school
system may continue to procure services not covered under the areawide
contract.

As the scope of our review was limited to the school system's use of the
Washington Gas contract, we did not determine whether other GSA areawide
utility contracts are being improperly used or whether other contractors and
ordering agencies are failing to comply with the requirement to notify GSA
of orders executed under the contracts.

Conclusion

Unless GSA's guidance on areawide contracts is revised, the potential for
misuse exists. Following current guidance, ordering agencies could
inappropriately define an energy- efficiency project to be anything a
utility- or its subsidiaries- is willing and able to perform as a private
business rather than in its capacity as a public utility. The guidance could
be interpreted as permitting agencies to order such energyefficiency
projects on a sole- source basis under an areawide contract, even if the
projects are not subject to regulatory authority as required by law. We
believe the guidance fails to clearly advise agencies that unless the
ordered services are subject to regulatory authority, agencies are required
to use competitive acquisition procedures to obtain the services when more
than one source exists.

The District of Columbia public school system's misuse of the GSA areawide
utility contract with Washington Gas may be a solitary occurrence among the
many agencies that use these types of contracts. However, we believe that a
contracting agency such as GSA should be responsible for knowing how its
contracts are used and that ordering agencies and contractors are
responsible for complying with GSA's reporting requirements. Better contract
management and oversight by GSA would help ensure that contracts are not
used for more than their intended purpose and that contractors provide no
services beyond the scope of the contract.

GAO- 02- 56R GSA Areawide Utility Contracts 8

Recommendations for Executive Action

We recommend that you take the following actions:

Direct a revision of GSA's guidance on areawide utility contracts to
emphasize that ordering agencies must use competitive acquisition procedures
to procure utility services that are (1) not subject to regulatory authority
and (2) available from more than one supplier.

Conduct an assessment- or request the GSA Inspector General to conduct an
assessment- of the extent to which (1) ordering agencies and contractors are
reporting the use of the contracts as required and (2) GSA is adequately
monitoring the contracts' use. If appropriate monitoring is not taking
place, GSA should develop cost- effective controls to ensure that agencies
are complying with reporting requirements and properly using the contracts.

Please provide us with a response within 30 days of planned actions to be
taken on our recommendations.

Agency Comments

In written comments on a draft of this report, GSA concurred with our
recommendations. GSA's agreement with our first recommendation was
contingent on an understanding that our interpretation of GSA's authority
under the Energy Policy Act is consistent with GSA's. GSA's interpretation
of its authority to provide energy management services through areawide
contracts is consistent with our position. Specifically, GSA acknowledges in
its comments that its authority to negotiate utility contracts is limited to
services that are subject to state regulatory authority and to public
utilities acting in their capacity as public utilities. GSA agrees with our
position that areawide contracts are limited to those utility services
subject to public utility regulatory authority or provided under such
authority (which is what we mean by the term "regulated"). We have clarified
this language in the report.

GSA plans to implement a number of actions to address our recommendations.
As part of its efforts to revise its guidance on areawide contracts, GSA
will survey state regulatory commissions on the scope of their authorities
and request public utilities to certify that their energy management
services offered to federal agencies are in compliance with state rules and
regulations. Further, because state standards may vary, GSA plans to adopt a
revised definition of, and additional guidance on, what constitutes a
demand- side energy management service. Once an agency has determined that a
project meets the definition, GSA will require the agency to follow the
required justification and approval process for using other than full and
open competition.

To increase oversight and monitoring of areawide contracts, GSA plans to
clarify the language in areawide contracts regarding the energy management
services authorized to be ordered; conduct periodic sampling and reviews of
contract actions placed

GAO- 02- 56R GSA Areawide Utility Contracts 9 against areawide contracts;
encourage agencies to compete energy management

requirements; and provide clearer guidance to both agencies and utilities on
the use of areawide contracts for energy management services. If improper
use of the contracts is discovered, GSA will take steps to advise agencies
or, if warranted, terminate the portion of the areawide contract pertaining
to demand- side energy management services.

GSA also states that it will (1) require utility companies to provide GSA
with a copy of any future authorization for energy management services and
(2) remind ordering agencies of their responsibilities to inform GSA when
they order services under areawide contracts.

GSA's comments appear in appendix I. We conducted our review from July to
October 2001 in accordance with generally accepted government auditing
standards. In conducting our review, we met with officials at GSA, the
District of Columbia Public Schools, and Washington Gas. We analyzed GSA's
areawide contract with Washington Gas and GSA's guidance provided to
ordering agencies.

- - - - We are sending copies of this letter to the Honorable Stephen A.
Perry, Administrator, GSA; Dr. Paul Vance, Superintendent, District of
Columbia Public Schools; Subcommittee on the District of Columbia, House
Committee on Appropriations; and other interested congressional committees.
This letter will also be available on GAO's home page at http:// www. gao.
gov. Please contact me at (202) 512- 4841 or Sheila Ratzenberger at (202)
512- 8244 if you or your staff have any questions. Other major contributors
to this report were Adam Vodraska, Michele Mackin, and Charles D. Groves.

Sincerely yours, David E. Cooper, Director Acquisition and Sourcing
Management

Sheila K. Ratzenberger Associate General Counsel

GAO- 02- 56R GSA Areawide Utility Contracts 10 Appendix I

Comments From the General Services Administration

GAO- 02- 56R GSA Areawide Utility Contracts 11 Appendix I

GAO- 02- 56R GSA Areawide Utility Contracts 12 Appendix I

GAO- 02- 56R GSA Areawide Utility Contracts 13 Appendix I

GAO- 02- 56R GSA Areawide Utility Contracts 14 Appendix I

GAO- 02- 56R GSA Areawide Utility Contracts 15 Appendix I

GAO- 02- 56R GSA Areawide Utility Contracts 16 Appendix I

GAO- 02- 56R GSA Areawide Utility Contracts 17 Appendix I

GAO- 02- 56R GSA Areawide Utility Contracts 18 Appendix I

GAO- 02- 56R GSA Areawide Utility Contracts 19 Appendix I

GAO- 02- 56R GSA Areawide Utility Contracts 20 Appendix I

GAO- 02- 56R GSA Areawide Utility Contracts 21 Appendix II

Utility Incentive Programs

Section 152( f) of the Energy Policy Act of 1992 (P. L. 102- 486) amended
the National Energy Conservation Policy Act (42 U. S. C. sec. 8256( c)) to
provide that

federal agencies are authorized and encouraged to participate in programs to
increase energy efficiency and water conservation or the management of
electricity demand conducted by gas, water, or electric utilities and
generally available to the customers of such utilities;

each agency may accept any financial incentive, goods, or services generally
available from any such utility to increase energy efficiency or to conserve
water or manage electricity demand;

each agency is encouraged to enter into negotiations with electric, water,
and gas utilities to design cost- effective demand management and
conservation incentive programs to address the unique needs of facilities
utilized by such agency; and

agencies may not be denied the collection of rebates or other incentives if
an agency satisfies the criteria that generally apply to other customers of
a utility incentive program.

GAO- 02- 56R GSA Areawide Utility Contracts 22 Appendix III

Energy Savings Performance Contracts

Energy savings performance contracts are authorized by section 155 of the
Energy Policy Act of 1992 (P. L. 102- 486), 42 U. S. C. sec. 8287.
Performance contracting is a tool for implementing energy conservation
measures. Under performance contracting, a federal agency enters into a
multiyear contract with a qualified energy service company, which then
installs improvements in the agency's buildings. The company assumes all the
up- front capital costs and, in return, receives a portion of the annual
savings attributable to the improvements for the duration of the contract.
The company's portion of the energy savings is paid by the agency from funds
that the agency would otherwise have used to pay its utility costs.
Performance contracting allows the government to reduce its energy costs
without appropriating funds and without incurring capital costs for energy-
efficient improvements. Unlike areawide utility contracts, an energy savings
performance contract is awarded through competitive procedures and is not
limited to regulated public utilities. For a more detailed description of
energy savings performance contracting, see our report

Energy Conservation: Energy Savings Performance Contracting in Federal
Civilian Agencies (GAO/ RCED- 96- 215, Sept. 16, 1996).

(120096)

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