Number: 

DAO 217-21

SECTION 1. PURPOSE.

.01 This Order prescribes the policy of the Department of Commerce (the Department) for office space allocation in GSA-assigned space and Department-leased and owned facilities. It covers all leased and owned office space acquired to house the Department's missions. The goal of this policy is to bring the Department's space per person allocation in line with that of the Federal government average through a variety of methods including new/renovated construction design, consolidation, new leases, and other workplace innovations.

.02 This revision updates the name of the Office of Primary Interest (Office of Facilities and Environmental Quality) and provides space standards for workstation type. It also incorporates the Department's policy on workstations from DAO 217-22, Workstation Space Design Standard, because DAO 217-22 is planned to be revoked.

SECTION 2. AUTHORITIES.

.01 Executive Order 13327, Federal Real Property Asset Management, dated February 4, 2004, states that it is the policy of the United States to promote the efficient and economical use of America's real property assets and to assure management accountability for implementing Federal real property management reforms. Executive branch departments shall recognize the importance of real property resources through increased management attention, the establishment of clear goals and objectives, improved policies and levels of accountability, and other appropriate action.

.02 Presidential Memorandum, Disposing of Unneeded Federal Real Estate”Increasing Sales Proceeds, Cutting Operating Costs, and Improving Energy Efficiency, dated June 10, 2010, requires that agencies take immediate steps to make better use of remaining real property assets as measured by utilization and occupancy rates, annual operating cost, energy efficiency, and sustainability. Further, it requires increasing occupancy rates in current facilities through innovative approaches to space management.

.03 Section 3 of Office of Management and Budget (OMB) Memorandum M-12-12, Promoting Efficient Spending to Support Agency Operations, dated May 11, 2012, requires that the acquisition of new Federal building space that increases an agency's total square footage of civilian property be offset through consolidations, co-locations, or disposals of property. See also OMB Memorandum M-17-08, Amending OMB Memorandum M-12-12, Promoting Efficient Spending to Support Agency Operations, dated November 25, 2016.

.04 OMB Management Procedures Memorandum No. 2015-01, Implementation of OMB Memorandum M-12-12 Section 3: Reduce the Footprint, dated March 25, 2015, clarifies the policy to dispose of excess properties and promote more efficient use of real property assets. It also requires that agencies report on actions taken to maximize and increase efficiency in its utilization of space, including cost effective alternatives to acquisition, such as space consolidation, co-location, teleworking, and hoteling.

SECTION 3. POLICY.

.01 The standard utilization rate, requirements, and guidelines set forth in this Directive provide a goal and guidance to Operating Units to facilitate development of their implementing procedures. These procedures will then be incorporated into individual facility project space requirements when and where feasible in existing space, in all lease renewals, and renovations. The use of these procedures is intended to be flexible while ensuring that office space will be designed to support the re-engineering of work tasks and functions required by innovations such as flexible workplace, telework, and other initiatives. The Department expects that each Operating Unit will incorporate, to the greatest extent possible, the standard utilization rate and innovations in new construction and build-to-suit leases and limit exceptions through an active governance structure. This policy outlines general Departmental direction in order to:

a. Support maximum utility and efficiency of office space;

b. Align office space equitably across Operating Units;

c. Promote the use of open office/open workstation space allowing for cost effectiveness and flexibility in organizational structure;

d. Reduce the number of enclosed offices;

e. Create enclosed spaces only as needed for communications of a sensitive nature, such as conference, interview, and negotiation rooms;

f. Encourage the development of office environments that promote flexibility, collaboration and communication, such as open office environments; and

g. Promote sustainable workplaces that can adapt to changes in work processes and staffing and incorporate telework with minimal costs. It is the Department's goal to have effective and efficient use of office space. This policy establishes office space standards and provides guidance to achieve that goal.

.02 The Department is committed to the open office environment for facilities that are leased or owned for its missions. The open office concept is to be used wherever practical and possible, as it generally provides the highest degree of sustainability, adaptability, efficiency, and functionality available in the contemporary workplace, as well as may provide aesthetic appeal.

.03 The Department's goal is to right size its portfolio footprint in order to efficiently and effectively support its missions. To meet this goal, the Department's standard utilization rate for office space is set at 170 usable square feet (USF) per person. The 170 USF standard utilization rate includes primary office space, reception area, circulation space, associated storage space and auxiliary space (such as conference rooms, server closets, processing area, file room, break room, etc.). For example, if office space is planned for 100 people, the maximum total utilized area would be 17,000 USF. Allocations of office space, such as workstations and support space, are made by the Operating Unit.

.04 To implement this policy and meet the Department's standard utilization rate, all Operating Units are required to develop implementing procedures, internal controls, an Operating Unit general standard utilization rate, building-specific standard utilization rate when mission/facility constraints preclude application of the Operating Unit standard utilization rate, and a governance structure.

.05 Operating Units will use the Department's standard utilization rate to develop an Operating Unit general standard utilization rate, and, as needed, a building-specific standard utilization rate, and implementing policies and processes for approval of standards. Hereinafter, use of the term the "Operating Unit Standard" will cover both the Operating Unit standard utilization rate and the Operating Unit building-specific standard utilization rate. Application of the Operating Unit Standard is required for office space acquisition, regardless of whether the office space is in an office building, laboratory, or warehouse.

.06 Operating Units' implementing procedures shall, at a minimum, address application of the appropriate Operating Unit Standard to the following scenarios:

a. space being renovated or reconfigured;

b. succeeding leases;

c. consolidation; and

d. space reduction.

.07 In existing office facilities, or "as-is" space acquisitions, the Operating Unit Standard is expected to make a best effort to achieve the 170 USF per person standard utilization rate as established by this policy.

.08 In build-to-suit office space, the Operating Unit Standard is expected to comply with or be lower than the 170 USF per person standard utilization rate.

.09 Operating Units implementing procedures shall specifically address the following: telework goals, hoteling workstations for telework, restacking of existing system furniture, reconfiguration due to work process change, video conferencing, and changes in staff levels into the development of facility requirements.

.10 When investments are needed to improve the utilization rate, Operating Unit implementing procedures must require that an economic analysis be performed to determine the payback period for investing in restacking or floor plan changes and system furniture acquisitions that will further the intent of this policy. A return-on-investment analysis will be performed using OMB Circular A-94, Appendix C rates. Payback periods of less than five years are to be pursued in succeeding leases and GSA assignments (owned and leased) or in renovation projects for owned facilities. These analyses shall also address Operating Unit telework plan goals.

.11 Operating Units implementing procedures shall include a process for granting an interim variance from the Operating Unit Standard for existing space. Such variances must be justified and include a plan to achieve the Operating Unit Standard (e.g., consolidation, termination of lease, sale of property strategy, renovation, etc.).

.12 Office space in excess of the applicable standard utilization rate will be considered an unsupported space requirement for portfolio management purposes. Therefore, the Operating Unit Standard must incorporate any unique mission-driven requirements.

SECTION 4. DEFINITIONS.

.01 Building-specific standard utilization rate is a utilization rate that in addition to the requirements for the General Standard, addresses limitations on space standards caused by column spacing or suite sizes in small or historic buildings. A building-specific standard may be increased to address structural limitations of buildings and layout inefficiencies. Other factors that may affect the space requirements include, but are not limited to, space availability, irregular building shape, and a non-economical cost to correct.

.02 Build-to-suit office space is space that is provided by new construction of a building or its internal partition walls. It is space in a building that was recently constructed or vacant space in an existing building that had non-demising walls removed prior to offer or will be included as part of the offer.

.03 Hoteling is the optimization of unused space in a building by utilizing temporarily vacant cubicles or offices of people teleworking or on leave or travel, and conference rooms, for short periods of time or specific cubicles or areas designated as hotels for teleworkers. Under hoteling, unassigned or temporarily vacant cubicles or office space are "bookable" and other employees are allowed to use it. To increase effectiveness and efficiency, it is helpful if the information technology (IT) and telephone networks allow for employees to reserve workstations in advance, and then when present, employees can simply plug in their laptop, log into their network, and forward calls from their assigned number to the desk phone, laptop, or a cell phone.

.04 Net Square Feet (NSF)is a subset of USF that does not include support space or circulation space within an office.

.05 Operating Unit general standard utilization rate is a utilization rate that incorporates the business processes, bargaining unit agreement, equipment, and security unique to an Operating Unit that increase or decrease the need for space. Basis for space in excess of the 170 USF per person goal has to be justified within the standard.

.06 Unsupported space requirement is a classification intended to indicate that a facility's utilization rate for office space is above the Operating Unit Standard or that a building-specific standard utilization rate is not in place. A facility with the unsupported space requirement classification should be analyzed to determine if its density can be improved, if a building-specific standard utilization rate is appropriate (e.g., architectural layout, historic features, or that additional support space is required for mission), or if a planned improvement opportunity is pending.

.07 Usable Square Feet (USF) is the actual area the agency occupies in an office suite. It is the office area, workstation area, conference rooms, kitchenettes, server closet, storage rooms, and circulation within the office suite area. It is calculated by measuring from the dominant portion of the exterior wall to the outside face of major vertical penetrations. It includes all structural elements (columns), openings for vertical cables, and vertical penetrations built for the private use of the occupant.

.08 Workstation is any office, cubicle, or open workspace where employees or contractors work, counted by individual seat.

SECTION 5. ‚ RESPONSIBILITIES.

.01 The Office of Facilities and Environmental Quality, in accordance with Department Organization Order 20-1, is responsible for the development, implementation and oversight of this policy.

.02 Heads of Operating Units are responsible for designating an office of primary responsibility for developing the Operating Unit Standard.

.03 Heads of Operating Units are responsible for the development of their implementing procedures and governance structure for the incorporation and implementation of their Operating Unit Standard that addresses specific individual buildings for new, owned or leased space. This includes processes for approval of the standards, periodic reviews, and granting of variances from the standards.

SECTION 6. REPORTS.

The Director of the Office of Facilities and Environmental Quality shall be provided with a copy of all Operating Unit Standards and implementing policies within 6 months of the date of issuance of this policy and within 60 days of all subsequent changes.

SECTION 7. IMPLEMENTATION GUIDANCE.

Operating Unit Standards and their implementing policies and governance structure will at a minimum address the types of space present in their office facilities. General guidelines are included in Appendix 1 to assist in the development of Operating Unit Standards. Another source for guidance is in the GSA publication. "Workplace Utilization and Allocation Benchmark." These guidelines identify topics to be addressed in the general and building-specific standards. Space requirements based on pay grade for maximum area per person are no longer mandated by Federal regulations, stipulated by GSA, or recommended by the GSA's Office of Government-wide Policy (OGP). The OGP recommends that space requirements be based on job title and function, defining tasks required for a particular job and on the organization needed to accomplish its mission. How space is allotted among different uses is determined by the organization, working in conjunction with their staff, managers, and designers.

SECTION 8. EFFECT ON OTHER ORDERS.

This Order supersedes Department Administrative Order 217-21, dated September 4, 2016.

Signed: Director, Office of Facilities and Environmental Quality

Approved: Chief Financial Officer and Assistant Secretary for Administration

Office of Primary Interest: Office of Facilities and Environmental Quality

APPENDIX 1 (General Guidelines)