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This document is a memorandum from the Chief Architect of the U.S. General Services Administration (GSA) Public Buildings Service (PBS) granting a waiver to allow the use of imperial units instead of metric units for the FY2024 PBS Design and Construction Program. The waiver is based on several factors, including the increased costs and complexity associated with converting to the metric system, challenges with the local construction industry's lack of experience with metric construction, and the resulting impact on competition and the ability to deliver projects on budget and schedule for federal agencies. The memorandum outlines the reasoning behind the waiver, citing factors such as material and service costs, procurement lead times, labor productivity, and coordination issues. The waiver is granted in accordance with relevant federal policies and standards.

The related federal contract opportunity is for a design-build contract to address approximately 515,000 square feet of concrete pavement repair and replacement at the Kika De La Garza Land Port of Entry in Pharr, Texas. The project, funded in part by the Inflation Reduction Act of 2022, requires the use of low-embodied carbon construction materials and will take approximately 460 calendar days to complete. The solicitation is set aside for small businesses with the NAICS code 237310 (Concrete and Asphalt Paving), and the construction cost magnitude is between $20,000,000 and $30,000,000.

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U.S. General Services Administration Public Buildings Service

16 April 2024

MEMORANDUM FOR: REGIONAL CHIEF ARCHITECTS

REGIONAL DESIGN AND CONSTRUCTION DIRECTORS

FROM: CHARLES HARDY

CHIEF ARCHITECT

ASSISTANT COMMISSIONER OFFICE OF ARCHITECTURE & ENGINEERING

SUBJECT: Waiver – Metric Units FY24 PBS Design And Construction Program

This memorandum issues a metric waiver for the FY24 PBS Design and Construction Program, in accordance with the GSA PBS Policy for Granting Waivers and Exceptions. Relevant policy and standards include:

● FAR 11002(b)

● GSAM 511.002 GSA Metric Program

● GSA Order 8000.1D ADM GSA Metric Program

● P-100 Facilities Standards for the Public Buildings Service

The FY24 PBS Design and Construction Program supports successful delivery of projects to federal agencies, on budget and schedule. The GSA works to develop and execute construction programs that best utilize funding.

Currently, use of hard metric does not provide a cost-effective way to best satisfy the long-term requirements of federal agencies.

This waiver allows all project documentation and construction materials to be in imperial units. The approval of this waiver is based on both traditional and project specific reasons for waiving hard metric requirements, including:

● Cost of materials and services

● Procurement lead times

● Labor productivity and increased complexity of construction projects

● Impact to client agencies, operational and maintenance issues

● Personnel are not fluent in the metric system.

● Ongoing operational and maintenance costs as a result of industries not stocking metric products and only providing them as a result of special order which increases cost and delay in receiving products

● Increased risk for coordination errors in BIM, fabrication, and installation.

● Local industry having disproportionate or lack of local experience with metric construction, which may increase the cost and/or time to deliver the project.

The use of metric increases risk of design and coordination errors for the repairs and alterations (modernization) of the existing historic buildings and existing facilities originally constructed using imperial units. The use of both “soft metric” and the mixture of metric and imperial units increases the complexity of construction of projects as well as risks coordination errors between equipment and building systems, coordination with third party contractors, and coordination with tenant agencies. Further, given local market’s lack of experience in using metric for construction projects, waiving the use of metric supports GSA’s obligation to maximizing competition to the fullest extent practicable.

U.S. General Services Administration 1800 F Street NW

Washington, DC 20405-0002

DocuSign Envelope ID: 5C534F1D-0FE2-4875-B65F-D25D96B4AEBF

U.S. General Services Administration Public Buildings Service

The three main issues with implementing hard metric in the current market conditions are:

● The trade work in the USA is trained using Imperial units, which means trade workers will need additional training to adapt to metric, and will impact productivity by 10-20%.

● The material supplier market might lose interest in our projects, because the pivot to metric system would not be cost effective in the long term, for the immediate investment needed on changing all of their systems (Manufacturing and Design). We would expect to see a 20-30% premium when applying hard metric to a construction project in the current US market place. The commercial sector has enough work in the current state, therefore pivoting to metric is not enticing them.

● Additional investments for contractors to create fail safe procedures to reduce human error on sites, specially on the Geotech, Civil and Structural fields, where the trade workers are all working on

Imperial. The additional surveying costs to make sure the systems and batter boards are coordinated in metric. In a foundation project. This can increase project costs between 2-5%.

Hard metric currently is not the accepted industry system for design and construction, commissioning, and facility management, thus, the FY24 Capital Investment Program requests a waiver be granted. In addition, use of the metric system creates inefficiencies and causes hardship to the program and mission of impacted agencies. Furthermore, waiving the hard metric requirement supports the GSA obligation to maximize competition to the fullest extent practicable.

This waiver is allowable per Executive Order 12770, 1991; Metric usage shall not be required to the extent that such use is impractical or is likely to cause significant inefficiencies or loss of markets to United States firms.

Thank you for your attention to this matter and consideration of this request. If you have any questions or concerns, please do not hesitate to contact Natalie Huber at 202-716-4969.

Cc: Central Office OAE Division Directors Office of Design & Construction Directors

CIPMO

U.S. General Services Administration 1800 F Street NW

Washington, DC 20405-0002

DocuSign Envelope ID: 5C534F1D-0FE2-4875-B65F-D25D96B4AEBF

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