DISPOSAL Act Mandates Sale of Six Major DC Federal Buildings, Waives Environmental and Historic Reviews

The new DISPOSAL Act (Disposing of Inactive Structures and Properties by Offering for Sale And Lease Act) is a major federal real estate bill that requires the General Services Administration (GSA) to sell or enter into long-term leases (up to 99 years) for six massive federal buildings in Washington, D.C.

These aren't small offices; they include the Frances Perkins Federal Building, the James V. Forrestal Building, and the Robert C. Weaver Federal Building. The GSA Administrator gets “full discretion” to approve the sale or lease terms deemed to be in the “best interests of the United States,” provided they aren't sold to foreign entities. The goal is to raise money: after covering the costs of relocating the agencies currently housed there, any remaining net proceeds must go straight to the general Treasury to reduce the deficit.

The Fine Print: Cutting the Red Tape

If you're wondering how the government plans to move these properties quickly, the answer is by cutting a lot of regulatory corners. Section 2 of the bill exempts the disposal of these six specific buildings from several major federal laws. This is the part that policy wonks are going to be talking about.

First, the sales are exempt from the National Environmental Policy Act (NEPA). NEPA is the law that requires the government to study and disclose the environmental impacts of major federal actions. Waiving NEPA means a potential private developer could convert or demolish a massive structure like the Forrestal Building without a public environmental review. Second, the bill waives key historic preservation laws (Division A of subtitle III of title 54), meaning these buildings—some of which are historically significant—can be sold and potentially altered or destroyed without the usual protections. Finally, the bill exempts the sales from Section 501 of the McKinney-Vento Homeless Assistance Act, which typically requires federal agencies to identify and offer surplus property for use as housing for the homeless.

What About the Agencies and the Relocation Shuffle?

Since these buildings are currently occupied, the agencies must move. The GSA Administrator has “sole and absolute authority” to choose the new location for any relocated agency, though they must consult with the agency head. For people working in these departments, this means their work location is entirely in the hands of the GSA, and they could be moved anywhere within D.C., or even outside of it.

To manage this, the bill explicitly prohibits the GSA from entering into “build-to-suit” leases, where a developer constructs a brand-new building specifically tailored for the agency. This is likely intended to save money and speed up the process, but it means relocated agencies will have to fit into existing, potentially older or less suitable space. The GSA must give Congress 30 days' notice before moving any agency outside of the District of Columbia.

The Power of the Administrator and the Lack of Review

Beyond the initial six buildings, the Administrator is granted the authority to add up to 20 more federally owned buildings per year to the disposal list until 2028, provided the building’s utilization rate was below 60% over the previous year. This creates a fast track for selling off underutilized federal real estate nationwide.

Perhaps the most sweeping provision is that any action taken by the Administrator to carry out this section is not subject to judicial review. In plain English, this means if a citizen group, an environmental organization, or even a local government believes the GSA violated its own rules or acted inappropriately in selling one of these properties, they cannot sue to stop the action or challenge the decision in court. For busy people, this is a major red flag: the decisions involving potentially billions of dollars in public assets are being shielded from legal challenge, concentrating immense, unchecked power in the hands of one appointed official.