Federal Property Management & GSA

The General Services Administration (GSA) is the federal government's landlord, buyer, and logistics manager — governing the acquisition, management, and disposal of federal real and personal property under 40 U.S.C. §§ 101–611. GSA's Public Buildings Service (PBS) manages approximately 8,800 owned or leased assets encompassing 370 million square feet of workspace for 1.1 million federal civilian employees — from landmark federal courthouses to suburban office parks. When a federal agency needs office space, it typically turns to GSA rather than leasing independently; GSA negotiates the leases, manages the buildings, and bills agencies for occupancy costs through an internal charge system. GSA's Federal Acquisition Service (FAS) manages the Multiple Award Schedule (MAS) — formerly called GSA Schedules — which allows federal agencies to purchase commercial products and services from pre-vetted contractors at pre-negotiated prices, accounting for roughly $45 billion/year in government purchases. Property disposal is another core function: 40 U.S.C. § 521–541 governs how GSA transfers excess and surplus federal property to other agencies, state and local governments, nonprofits, and ultimately the public through auction. The Trump administration's 2025 initiative to dramatically reduce the federal office footprint and sell surplus properties has put GSA's property management authority at the center of federal workforce and real estate policy debates.

Current Law (2026)

Legal Authority

• 40 U.S.C. § 101-102 — Purpose and definitions (economical and efficient system for management of government property; procurement and supply of property and services)
• 40 U.S.C. § 121 — Administrative authority (Administrator of GSA prescribes policies and methods of procurement, supply, and property management for executive agencies)
• 40 U.S.C. § 501-502 — Federal supply and procurement (GSA procurement of goods and services for federal agencies; economy and efficiency in procurement)
• 40 U.S.C. § 524-529 — Disposal of excess and surplus property (agencies report excess property to GSA; GSA determines if property is surplus; disposal by sale, donation, or transfer)
• 40 U.S.C. § 541-545 — Property disposal procedures (competitive bidding; negotiated sales; surplus property for public benefit — education, health, parks, homeless assistance)
• 40 U.S.C. § 585-592 — Building management (operation, maintenance, and protection of public buildings; energy conservation; charges to tenant agencies)
• 40 U.S.C. § 3101-3105 — Public building construction authorization (prospectus process — GSA submits building prospectuses to Congress for projects exceeding threshold; Congressional authorization required)
• 40 U.S.C. § 3301-3314 — Acquisition and construction standards (sites; design standards; fire safety; accessibility; historic preservation; energy performance requirements)

How It Works

The General Services Administration is the federal government's landlord, purchasing agent, and property manager. GSA manages the buildings where federal employees work, the vehicles they drive, the supplies they use, and the technology infrastructure that supports government operations. Title 40 of the U.S. Code provides the legal framework for this massive logistical operation.

GSA's Public Buildings Service (PBS) owns or leases approximately 370 million square feet in over 8,600 properties — one of the largest real estate organizations in the world — managing federal buildings, courthouses, land ports of entry, and other facilities. When an agency needs space, GSA provides it from its owned inventory, acquires a new building, or leases from the private market; tenant agencies pay GSA rent through an internal billing system, and GSA uses those revenues to operate, maintain, and improve its portfolio through the Federal Buildings Fund, a revolving fund where rent from agencies pays for building operations, construction, and repairs. For major construction projects and leases exceeding threshold amounts (approximately $3.961 million for FY2026), GSA must submit a prospectus to the Senate Environment and Public Works Committee and the House Transportation and Infrastructure Committee, and Congress must authorize the project before GSA can proceed. When federal property is no longer needed, the disposing agency reports it to GSA as "excess"; GSA checks whether any federal agency needs it, and if not, declares it "surplus" for disposal through competitive bidding via GSA Auctions, transfer to state or local governments at reduced cost, conveyance for homeless assistance under the McKinney-Vento Act, or donation for educational or health purposes.

GSA's Federal Acquisition Service provides centralized purchasing for common goods and services — office supplies, furniture, fleet vehicles, telecommunications, and IT solutions — through GSA Multiple Award Schedule (MAS) contracts that allow agencies to purchase from pre-negotiated contracts with commercial vendors at volume-discounted prices. The MAS program, governed by the Federal Acquisition Regulation, covers over 11 million commercial products and services and streamlines purchasing for agencies that would otherwise need to conduct their own competitive procurements for routine needs. GSA also operates approximately 220,000 vehicles leased to federal agencies — one of the largest government fleets in the world — and is required by statute to reduce fleet petroleum consumption and increase the use of alternative fuel vehicles.

How It Affects You

State Variations

Implementing Regulations

• 41 CFR Part 101-1 — GSA general provisions (§§ covering GSA authority, organization, and general regulations for federal property management)
• 41 CFR Part 102 — Federal Management Regulation (real property, personal property, motor vehicles, telecommunications, federal workplace)
• 41 CFR Part 101-25 — General Supply Catalog (federal standard items, supply management)
• 41 CFR Part 101-26 — Procurement sources and programs (GSA supply operations, Federal Supply Service)

The Department of Energy regulations implementing the federal alternative fuel fleet mandate live at 10 CFR Part 490 — Alternative Fuel Transportation Program. Key provisions:

• § 490.200 — Mandatory State Fleet Program: any state government fleet that acquires new light-duty vehicles must meet annual alternative fueled vehicle (AFV) acquisition percentages under EPAct 1992 § 507(o)
• § 490.201 — Acquisition schedule: states must hit 75% AFV acquisitions for model year 2001 and thereafter (phased up from 10% in MY1997)
• § 490.202 — Qualifying acquisitions include OEM AFVs, after-market conversions within 4 months of purchase, and AFV credits from the credit program
• § 490.203 — State Light Duty AFV Plan: a state may substitute an approved voluntary plan covering state, local, and private fleets — so long as the aggregate AFV acquisitions equal or exceed the state's mandate
• § 490.204 — Exemptions available where AFV fueling infrastructure is unavailable, AFVs are not commercially available on reasonable terms, or compliance would cause unreasonable financial hardship
• § 490.205 — Annual reporting due December 31 after each model year: total acquisitions, AFV acquisitions, credits applied, vehicle ID numbers, and fuel types for every AFV purchased
• §§ 490.300–490.340 — Alternative Fuel Provider mandate (Subpart D): private companies that produce, import, or significantly distribute alternative fuels must also acquire AFVs in their fleets — separate schedule from the state mandate
• §§ 490.500–490.530 — AFV Credit Program: fleets that exceed their mandate earn credits; credits may be transferred to fleets that fall short, creating a market-based compliance pathway

In practice, GSA's 220,000-vehicle federal fleet operates under separate Executive Order directives (EO 13693 and successors) that require federal agencies to procure AFVs and zero-emission vehicles through GSA's Federal Acquisition Service fleet management program — the DOE Part 490 rules specifically cover state and alternative fuel provider fleets, while the federal fleet's vehicle acquisition rules run through GSA's fleet schedules and OMB guidance. Alternative fuels covered by Part 490 include ethanol (E85), compressed natural gas (CNG), liquefied petroleum gas (LPG), hydrogen, biodiesel (B100), and electricity — dual-fuel vehicles qualify so long as they are capable of operating on the alternative fuel.

Recent rulemakings: 79 FR 15903–15907 (2014) updated several subparts including the credit program and biodiesel provisions.

The GSA Acquisition Regulation (GSAR) provisions governing how GSA leases privately owned space for federal agencies are at 48 CFR Part 570 — Acquiring Leasehold Interests in Real Property. Key provisions:

• § 570.103 — GSA's leasing authority derives from 40 U.S.C. § 585; the Administrator of General Services is authorized to enter lease agreements on behalf of all federal agencies; agencies must generally route space needs through GSA rather than leasing independently
• § 570.104 — FAR Part 6 competition requirements apply to leases exceeding the simplified lease acquisition threshold; sole-source awards above that threshold require a justification and approval (J&A) just as in any other federal procurement
• § 570.106 — Congressional notification required before GSA acquires any space exceeding 10,000 rentable square feet; notification goes to the House Transportation and Infrastructure Committee and the Senate Environment and Public Works Committee; projects above the prospectus threshold (approximately $3.961 million for FY2026) require affirmative Congressional authorization
• §§ 570.201–570.212 — Simplified procedures: for acquisitions at or below the simplified lease acquisition threshold, GSA may use streamlined competition — fewer solicitation requirements, oral negotiations, and abbreviated documentation; this pathway covers smaller regional and field office leases
• §§ 570.301–570.306 — Competitive procedures: for larger acquisitions, GSA issues a Solicitation for Offers (SFO) — the leasing equivalent of an RFP — after conducting a market survey (§ 570.302) to identify suitable buildings; the SFO specifies required space in ABOA square feet (American National Standards Institute/BOMA Office Area — the net usable space metric, which excludes lobbies, corridors, and mechanical rooms), the proposed lease term and occupancy date, evaluation factors, and lease terms; GSA converts competing offers to a present-value rent for apples-to-apples comparison (§ 570.306)
• § 570.401 — Award to the offeror whose proposal represents best value to the government considering price and all non-price evaluation factors stated in the SFO; price evaluation uses total present value of the lease, not just the initial annual rent

The ABOA/rentable area distinction is practically significant: building owners quote rents on rentable square feet (which includes a share of common areas through a "load factor"), but GSA requirements are specified in ABOA (pure usable space). A building with a 1.15 load factor provides 15% fewer ABOA feet than its rentable area suggests — meaning a lease for "10,000 rentable square feet" might only satisfy a requirement for 8,700 ABOA. GSA price evaluators convert all offers to per-ABOA cost to normalize comparisons across buildings with different load factors. Understanding this distinction is essential for property owners bidding on GSA lease solicitations and for agency real property officers translating headcount requirements into space requirements.

Recent rulemakings: 84 FR 15929 (2019) updated several GSAR provisions including leasing procedures.

The rules governing how federal agencies manage their aircraft fleets live at 41 CFR Part 102-33 — Management of Government Aircraft (55 sections across 5 subparts; authority: 40 U.S.C. § 121, 31 U.S.C. § 101). This Part implements OMB Circular A-126 and governs every civilian federal agency operating aircraft — from DOJ helicopters used in border operations to NOAA research planes to USDA crop-survey aircraft. Military and intelligence community aircraft are exempt (§ 102-33.100):

• § 102-33.20 — Agency responsibilities: each agency must acquire, manage, and dispose of aircraft safely, efficiently, and effectively; document and report types and numbers of aircraft in the Federal Aviation Interactive Reporting System (FAIRS) database; and comply with FAA airworthiness and operational requirements for FAA-certificated aircraft
• §§ 102-33.105–102-33.115 — Flight Program Standards: agencies must publish agency-specific Flight Program Standards covering management structure, safety, pilot qualifications, duty/flight time limits, currency requirements, and mission protocols; the standards must cover both traditional aircraft and unmanned aircraft systems (UAS); military branches, intelligence agencies, and legislative/judicial entities are exempt from the Flight Program Standards requirement
• §§ 102-33.110–102-33.125 — Operations: pilot qualifications and currency requirements must be established; duty time and flight time limits required; FAA regulatory compliance for all FAA-type-certificated aircraft; aircraft maintenance programs must comply with manufacturer specifications and FAA standards; maintenance personnel training must be tracked
• § 102-33.130 — Aviation safety management: agencies must implement a Safety Management System (SMS) complying with the FAA's current Advisory Circular (AC 120-92B or successor); SMS covers hazard identification, risk assessment, and continuous safety improvement; accident and incident response procedures must be established, including compliance with NTSB reporting requirements (§ 102-33.135)
• § 102-33.140 — Accountable aircraft operations and ownership costs: agencies must track all aircraft operations and ownership costs including acquisition, maintenance, personnel, fuel, insurance, and overhead; costs reported into FAIRS using the standard U.S. Government Aircraft Cost Accounting Guide
• § 102-33.145 — Automated cost accounting system: agencies that own Federal aircraft or operate bailed aircraft must use an automated system to collect FAIRS-required cost data; GSA reviews data for accuracy and uses FAIRS data to report to Congress and OMB on the federal aircraft fleet
• § 102-33.150 — Ownership justification: after holding a Federal aircraft for 5 years, the agency must justify continued ownership by documenting that ownership is more cost-effective than chartering, renting, or using other government aircraft; this "5-year review" prevents agencies from retaining aircraft that no longer serve mission needs
• § 102-33.165 — Carrying passengers: agencies may only carry passengers on government aircraft operated in compliance with 14 CFR (FAA rules); official passengers are those whose travel is justified by their official duties; the rules restrict agencies from giving free flights to friends, contractors, or others without mission justification; records of all passenger flights must be maintained for 2 years (§ 102-33.160)
• §§ 102-33.185–102-33.200 — Disposition: before disposing of aircraft, agencies must determine if the aircraft is excess to the mission; excess aircraft are reported to GSA; Flight Safety Critical Aircraft Parts (FSCAP) — parts whose failure could cause loss of the aircraft — must be tracked with documentation throughout their lifecycle and cannot be disposed of without ensuring traceable documentation accompanies the parts

Part 102-33 was substantially revised to incorporate UAS (unmanned aircraft systems/drones) alongside traditional manned aircraft. Federal agencies operating drones for surveillance, scientific research, or law enforcement must apply the same Flight Program Standards, cost accounting, and safety management requirements as those operating manned aircraft. The FAIRS database is the mechanism through which OMB and Congress track the approximately 1,400 civilian aircraft and the growing drone fleet operated by executive agencies.

The framework governing what happens when a federal agency no longer needs its personal property is at 41 CFR Part 102-36 — Disposition of Excess Personal Property (55 sections across 5 subparts; authority: 40 U.S.C. § 521, 40 U.S.C. § 121). "Excess personal property" is any government-owned personal property (equipment, vehicles, furniture, computers, supplies) that an agency determines is no longer needed for its programs — as distinct from "surplus" property, which is excess property that GSA determines is not needed by any other federal agency either. The disposition process moves through a defined sequence:

• § 102-36.10 — Agency responsibility: agencies must check available excess personal property before authorizing new procurement; the mandatory "excess property screening" requirement exists because it is far cheaper for Agency B to acquire a surplus computer from Agency A than for Agency B to buy new. Agency procurement policies must require this check
• §§ 102-36.20–102-36.25 — GSA responsibilities and eligibility: when excess property is reported to GSA (via Standard Form 120, Report of Excess Personal Property), GSA screens it for potential transfer to other federal agencies first; if no federal agency claims it during the screening period, GSA makes it available to eligible non-federal recipients (states, local governments, and nonprofits through the Federal Surplus Personal Property Donation Program)
• § 102-36.40 — Transfer costs: acquiring agencies pay no acquisition cost for transferred excess property — the government doesn't pay itself — but are responsible for shipping and handling; reimbursement to the holding agency is required in limited circumstances (e.g., property acquired using reimbursable funds or property in special categories)
• § 102-36.50 — Screening period: GSA sets the screening period duration during which agencies may claim excess property before it moves to the next disposition option; typically 21 days for most property categories; after the period ends, property either moves to the donation program or is sold as surplus
• § 102-36.65 — Direct transfers: agencies may transfer excess personal property directly to another federal agency without going through GSA if the total acquisition cost does not exceed a specified threshold (historically $15,000); direct transfers avoid the screening process and are often used within departments when one bureau has equipment another bureau needs
• §§ 102-36.100–102-36.120 — Grantee transfers: agencies may furnish excess property to their grantees (recipients of federally sponsored project grants) if the grantee is a public agency or eligible nonprofit and the property is necessary for the grant project; a 25% fee generally applies unless waived (§ 102-36.105); total transfers to any grantee are capped at the original acquisition cost equal to the grant value
• § 102-36.165 — Abandonment/destruction: property may be abandoned or destroyed only when an authorized official makes a written determination that it has no commercial value or costs more to dispose of than it's worth; the destruction method must comply with environmental, safety, and national security requirements (§ 102-36.170)
• §§ 102-36.175–102-36.195 — Special categories: aircraft and aircraft parts, Flight Safety Critical Aircraft Parts (FSCAP), excess firearms (may only transfer to agencies authorized to acquire firearms, § 102-36.205), Munitions List Items (require demilitarization before disposal), hazardous property (must certify proper packaging/labeling), and foreign excess personal property (property located overseas has separate disposition rules, § 102-36.215) all require additional steps
• § 102-36.200 — Disaster relief: upon a presidential disaster declaration, agencies may loan excess property to state and local governments for disaster response; this expedited pathway bypasses normal screening to get equipment to affected areas quickly

The excess personal property system is one of the federal government's most practical cost-saving mechanisms — it channels billions of dollars of reusable equipment back into active use rather than incurring new procurement costs. State and local governments and nonprofits benefit from the donation program's access to surplus computers, vehicles, and equipment. The system's weakness is that agencies sometimes hold excess property too long before reporting it, diminishing its value to potential recipients.

• 41 CFR Part 102-118 — Transportation Payment and Audit (GSA, 52 sections): the rules governing how federal agencies order, pay for, and audit transportation services — freight shipping, household goods moves for federal employees, and passenger travel — implementing GSA's transportation management authority under 40 U.S.C. § 501 and coordinating with the Jones Act (46 U.S.C. § 55305 — U.S. flag vessel preference) and Fly America Act (49 U.S.C. § 40118 — U.S. air carrier preference). The Part covers the full lifecycle from requisitioning a government bill of lading through payment and post-payment audit.

  • § 102-118.10 — Applicability: covers all federal agencies (including DoD) and wholly owned government corporations; agencies must incorporate the Part's requirements into their transportation programs; transportation service providers (TSPs) — carriers, freight forwarders, and travel management companies — that serve federal agencies must also comply
  • §§ 102-118.100–102-118.130 — Ordering and paying for transportation: agencies pay for freight using a Transportation Document (TD) (the successor to the Government Bill of Lading — GBL); TSPs must submit certified bills of lading (BOLs) and SF 1113 forms for reimbursement; agencies may only pay the TSP listed on the BOL with whom they have a contract (§ 102-118.110); TSPs may not bill agencies for preparing the BOL or charge higher than the contracted rate (§ 102-118.115); Government Transportation Requests (GTRs) are the equivalent for passenger travel — government-issued travel authorizations that airlines and travel agents accept in lieu of cash payment
  • § 102-118.130 — Mandatory audit: pursuant to 31 U.S.C. § 3726, all agencies must establish a program to audit transportation bills; audits may be either prepayment (verifying the bill before payment) or post-payment (reviewing after payment and recovering overcharges); agencies may contract with the GSA Transportation Audits Division or a private audit firm to perform the audit function; the audit requirement is not optional — it is a statutory mandate reflecting that federal agencies spend billions on transportation annually and overcharges are common
  • Subpart D — Audit of Transportation Services: the audit must verify that (a) the service was actually performed; (b) the rate charged matches the applicable contract rate or tariff; (c) origin, destination, weight, and service level are accurately stated; and (d) no duplicate billing occurred; TSPs must retain supporting documentation for 3 years and make it available to auditors; agencies must establish records of transportation documents sufficient to enable complete reconstruction of each shipment
  • Subpart E — Claims and Appeals: when an audit reveals an overcharge, the agency (or its audit contractor) issues a demand for repayment; TSPs have the right to dispute the demand through an administrative appeal; the Part establishes 60-day response periods, standards of proof, and escalation procedures; unresolved disputes may be referred to the Civilian Board of Contract Appeals (CBCA); agencies must also process TSP claims (where carriers believe they were underpaid) within specified time limits
  • Jones Act and Fly America compliance: the Part incorporates the Jones Act preference for U.S. flag vessel use (overseas shipments of federal cargo must use U.S. flag vessels when available at reasonable rates under 46 U.S.C. § 55305) and the Fly America preference for U.S. air carriers (federal employees and federally funded travelers must use U.S. carriers under 49 U.S.C. § 40118 unless an Open Skies Agreement exception applies); audits must verify compliance with both preferences

  The Transportation Payment and Audit rules collectively govern billions of dollars in annual federal transportation spending. GSA's Transportation Audits Division recovered over $150 million in transportation overcharges in a recent year — demonstrating the financial significance of mandatory auditing. The shift from paper GBLs to electronic transportation documents has streamlined the billing process but has also created new audit challenges as electronic data interchange formats vary across carriers.

The GSA Federal Property Management Regulation governing the use of federal real property and buildings is at 41 CFR Part 102-71 — Real Property Management. The Part has two operative subparts:

Subpart 102-71A — General Provisions establishes the definitions and building management rules that apply to all GSA-controlled facilities:

• § 102-71.5 — GSA sets real property policies for executive agencies; agencies occupying GSA-controlled space must comply with GSA's building management directives
• § 102-71.50 — Rent: agencies pay GSA occupancy charges ("rent") for space assigned to them; GSA sets rent at market rates based on the commercial equivalent, creating a financially transparent accounting of federal office costs
• § 102-71.55 / 102-71.65 — Occupant Emergency Program: each GSA facility must have an occupant emergency plan; the highest-ranking official of the primary occupant agency serves as the "Designated Official" responsible for coordinating emergency response with GSA
• § 102-71.25 / 102-71.30 — Fire safety: the Fire Administration Authorization Act of 1992 requires automatic sprinkler systems in all federal buildings over 10 stories or where occupants are overnight; GSA may accept an equivalent level of safety analysis as an alternative to sprinkler installation
• § 102-71.90 — Tobacco policy: tobacco use is prohibited in all interior federal space and within 25 feet of doorways and air intakes; limited exceptions may be designated by agency heads for outdoor areas

Subpart 102-71B — Use of Federal Real Property to Assist the Homeless implements the McKinney-Vento Homeless Assistance Act (42 U.S.C. § 11411) mandate that suitable surplus federal property be made available to homeless service providers before going to auction or other disposal:

• § 102-71.200 — Scope: applies to all real property under the custody or control of executive agencies that has been determined excess to agency needs; before an agency declares property surplus for general disposal, HUD must review the property for suitability for homeless assistance use
• § 102-71.205 / 102-71.210 — Utilization and enforcement: approved homeless assistance providers receive properties at no cost or nominal cost (often $1/year) for the duration of an approved program; providers must use the property for the approved homeless services purpose; other approved uses may be permitted with GSA consent
• § 102-71.215 — Abrogation: if a provider fails to use the property for the approved purpose, GSA may abrogate (terminate) the use agreement and reclaim the property; providers must maintain the property at their expense and return it to federal control at the end of the agreement term
• § 102-71.220 — Compliance inspections: GSA and the cognizant agency may conduct periodic inspections to verify that the property is being used for the approved homeless assistance purpose; GSA has the right of entry at all reasonable times
• § 102-71.230 — Waivers: GSA may waive specific requirements in this subpart in individual cases where compliance is impracticable or where the public interest would be better served

The McKinney-Vento process runs through HUD's coordination role: when an agency reports excess real property, HUD reviews it and publishes a notice in the Federal Register giving eligible homeless service providers 60 days to express interest. If an approved nonprofit or government entity submits a viable use plan, GSA processes the transfer for homeless use rather than routing the property to general surplus disposal. This process has transferred hundreds of federal properties — former office buildings, warehouses, military installations, and clinics — to homeless shelter operators, transitional housing providers, and supportive service organizations.

Pending Legislation

• HR 6926 — Federal Property Integrity Act: would prohibit naming federal buildings after a sitting president. Status: Introduced.
• HR 6481 — Federal Building Threat Notification Act: would require GSA and the Federal Protective Service to notify building tenants and the public of credible security threats to federal buildings. Status: Passed House.
• S 1094 — Mass Timber Federal Buildings Act: would encourage the use of mass timber construction in new federal buildings, promoting sustainable building materials. Status: Introduced.
• HR 3431 — Green Energy for Federal Buildings Act: would require all federal buildings to use 100% renewable energy by 2050. Status: Introduced.
• HR 2046 — Would require Congressional approval before GSA can sell historic federal properties, adding a preservation safeguard to the surplus disposal process. Status: Introduced.

Recent Developments

• Federal real property portfolio reviews have identified billions of dollars in potential savings from disposing of underutilized buildings and consolidating office space
• Increased telework since the pandemic has reduced federal office space utilization, raising questions about the appropriate size of the federal real estate portfolio
• GSA has pursued sustainability and energy efficiency improvements across its building portfolio, including net-zero energy buildings
• The shift to cloud computing and remote work has reduced demand for traditional office space while increasing demand for data center and technology infrastructure
• GSA Auctions (formerly GovPlanet/GSA Surplus) continue to sell surplus vehicles, equipment, and supplies to the public