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Report to Congressional Requesters:



September 2002:



Building Security:



Interagency Security Committee Has Had Limited Success in Fulfilling 

Its Responsibilities:



Building Security:



GAO-02-1004:



Contents:



Letter:



Results in Brief:



Background:



ISC Has Made Limited Progress Implementing Its Responsibilities:



Implications of the Creation of DHS on ISC:



Conclusions:



Recommendations for Executive Action:



Matter for Congressional Consideration:



Scope and Methodology:



Agency Comments:



Appendix I: Executive Order 12977 of October 19, 1995:



Appendix II: Federal Executive Branch Entities with Some 

Level of Independent Authority to Acquire Real Property:



Appendix III: Definition of Security Levels I through V, from 

DOJ’s Vulnerability Assessment of Federal 

Facilities:



Appendix IV: ISC Participant-Identified Strengths and 

Weaknesses:



Appendix V: Comments from the Social Security Administration29:



Appendix VI: Major Contributors:



Tables:



Table 1: ISC Products and Working Groups, in Relation to Its 

Responsibilities:



Table 2: ISC Strengths Identified by Participating Agencies or by ISC 

Agency Representatives:



Table 3: ISC Weaknesses Identified by Participating Agencies or by ISC 

Agency Representatives:



Abbreviations:



AOUSC: Administrative Office of the United States Courts



CIA: Central Intelligence Agency



DHS: Department of Homeland Security



DOC: Department of Commerce



DOD: Department of Defense



DOE: Department of Energy



DOJ: Department of Justice



DOL: Department of Labor



DOS: Department of State



DOT: Department of Transportation



Education: Department of Education



EPA: Environmental Protection Agency



FPS: Federal Protective Service



GSA: General Services Administration



HHS: Department of Health and Human Services



HUD: Department of Housing and Urban Development



Interior: Department of the Interior



ISC: Interagency Security Committee



OHS: Office of Homeland Security



OMB: Office of Management and Budget



PBS: Public Buildings Service



SSA: Social Security Administration



Treasury: Department of the Treasury



USDA: Department of Agriculture



USMS: U.S. Marshals Service



USPS: U.S. Postal Service



VA: Department of Veterans Affairs:



Letter: 



September 17, 2002:



The Honorable Joseph I. Lieberman, Chairman

Committee on Governmental Affairs

United States Senate:



The Honorable Robert F. Bennett

United States Senate:



In the wake of the events of September 11, 2001, you requested 

information regarding critical infrastructure protection within the 

federal government. In response to your October 4, 2001, letter and 

discussions with your offices, we are preparing two products on federal 

facility infrastructure protection. For this first report, we reviewed 

the activities performed by the Interagency Security Committee (ISC) 

since it was created by Executive Order 12977 in October 1995 (see app. 

I). The ISC is chaired by the General Services Administration (GSA) and 

comprises 14 department-level agencies and other executive agencies and 

officials. It has three primary security responsibilities for 

nonmilitary activities: (a) establish policies for security in and 

protection of federal facilities; (b) develop and evaluate security 

standards for federal facilities, develop a strategy for ensuring 

compliance with such standards, and oversee the implementation of 

appropriate security measures in federal facilities; and (c) take such 

actions as may be necessary to enhance the quality and effectiveness of 

security and protection of federal facilities. With the various recent 

proposals to create a Department of Homeland Security (DHS), we have 

expanded our work to include the implications of the proposed 

department on ISC.[Footnote 1] The second report will discuss the 

responsibilities of federal agencies to protect federal buildings they 

control and/or occupy.



The objectives of this first review were (1) to determine the extent to 

which the ISC had fulfilled the responsibilities established for it by 

the executive order and (2) to identify the potential implications of 

the proposed DHS on ISC and its responsibilities. To meet our review 

objectives, we reviewed ISC documents, relevant executive orders, and 

proposed DHS legislation; and we interviewed past and present GSA 

officials, 17 of 21 ISC participants, and Office of Management and 

Budget (OMB) representatives. We requested comments on a draft of this 

report from the OMB Director, the Administrator of GSA, the Office of 

Homeland Security’s (OHS) General Counsel, and from ISC agencies 

participating in the review. We received comments from 17 agencies. The 

Departments of Commerce (DOC), and the Interior (Interior); the 

Environmental Protection Agency (EPA); and OHS did not provide comments 

on the report.



Results in Brief:



ISC has carried out some elements of its responsibilities, but it has 

made little progress on several other assigned responsibilities. Over 

its 7-year existence, ISC has developed and issued security design 

criteria and minimum standards for building access procedures; 

disseminated information to member agencies, for their consideration 

and implementation, on entry security technology for buildings needing 

the highest security levels; and, through its meetings and 13 working 

groups, provided a forum for federal agencies to discuss security-

related issues and share information and ideas. On the other hand, ISC 

has made little or no progress in other elements of its 

responsibilities, such as developing and establishing policies for 

security in and protection of federal facilities, developing a strategy 

for ensuring compliance with security standards, overseeing the 

implementation of appropriate security in federal facilities, and 

developing a centralized security database of all federal facilities.



Representatives from agencies that participate on ISC had several 

positive comments about the committee, such as that it provides a 

vehicle for coordination and cooperation among federal agencies and a 

forum for agencies to discuss security topics of common interest. 

However, agency representatives also raised significant concerns about 

ISC’s overall effectiveness, the way it is operated, and the lack of 

progress in certain areas. Agency representatives identified several 

factors that they believe have contributed to ISC’s limited progress. 

These factors include (1) the lack of consistent and aggressive 

leadership by GSA, (2) inadequate staff support and funding for ISC, 

and (3) ISC’s difficulty in making decisions. GSA, which chairs ISC, 

has acknowledged these factors, promised full support, and initiated 

efforts to address them, such as establishing a charter and voting 

process and initiating the process to provide a full-time staff person 

to support ISC.



If DHS is created, it would have significant implications for ISC and 

its responsibilities.[Footnote 2] While the need for ISC, or an 

organization like ISC, would likely continue with the creation of a 

DHS, leadership responsibility for ISC could shift from GSA to DHS, and 

ISC’s responsibilities, role, membership, and operation could change. 

Under DHS proposals, responsibility for federal building security would 

be transferred from GSA and possibly other federal agencies to DHS, and 

DHS’s responsibilities could vary depending on the legislation enacted 

to create DHS. GSA’s and other federal entities’ responsibilities for 

other facilities management functions would not be affected. The 

transfer of security responsibilities would separate security from 

other facility management functions, such as the siting, design, and 

construction of federal buildings, which play an important role in the 

provision of appropriate and effective security. DHS would need to work 

through ISC or some other vehicle to see that security is appropriately 

integrated with other facility management functions. DHS and ISC could 

also have a role in overseeing security protection for executive branch 

officials for whom no single government agency or official is 

responsible.



We are making recommendations to the Administrator of GSA, as chair of 

the ISC, and to the Director of OMB, because of his responsibility 

under Executive Order 13267 for establishing a transition planning 

office for DHS. Our recommendations are aimed at addressing the 

concerns that agency officials identified in the management of ISC, as 

well as ensuring that coordination exists between building security and 

other facility management functions, contingent upon a new DHS assuming 

responsibility for federal building security. Also, ISC’s future 

depends largely on how Congress defines DHS’s role for federal facility 

security. The pending bills to create DHS would establish different 

roles for DHS. Therefore, we are including as a matter for 

congressional consideration that Congress clarify the scope of DHS’s 

authority and responsibilities for federal facility security in any 

legislation enacted to create a DHS. Then, ISC’s role in federal 

facility security can be determined based on the legislation enacted to 

create DHS. GSA and OMB concurred with our recommendations.



Background:



The federal government owns or leases more than 3.2 billion square feet 

of space in 12 categories, such as office, housing, and storage space. 

Office space is the largest of the 12 categories, representing about 23 

percent of the total, or about 758 million square feet. The three 

largest holders of owned and leased office space are GSA, with about 

292 million square feet; defense agencies, with about 191 million 

square feet; and the U.S. Postal Service (USPS), with about 190 million 

square feet.[Footnote 3] In addition to these three agencies, over 30 

other executive branch organizations have some level of authority to 

purchase, own, or lease office space or buildings. (See app. II for a 

listing of these organizations.) In general, agencies are responsible 

for the security of the buildings they own or acquire. GSA assigns 

space to many federal agencies in GSA-owned 

or -leased space; for example, postal facilities are sometimes located 

in GSA space. GSA sometimes delegates the security responsibility for 

assigned space to the agency occupying that space.



Federal agencies provide security with their own police force or 

security personnel; by contracting with the private sector for 

security; or by using another agency to provide security, which in turn 

may provide security with federal employees or contract guards. Within 

GSA, the Federal Protective Service (FPS), which is currently a 

component of the Public Buildings Service (PBS), is responsible for 

primary security for GSA-owned or -leased properties. FPS may delegate 

this responsibility to agencies assigned space in a GSA building. The 

bills currently being considered by Congress to create DHS would 

transfer FPS and its functions from GSA to DHS. It is unclear whether 

FPS’s responsibilities would remain the same under DHS or would be 

expanded to include more than just GSA-owned or -leased properties, 

although H.R. 5005, as passed by the House of Representatives, would 

specifically give DHS the responsibility to protect buildings and 

grounds and property that are owned, occupied, or secured by the 

federal government, including any agency, instrumentality, or wholly 

owned or mixed-ownership government corporation. In addition, the U. S. 

Secret Service provides security for the White House complex and 

certain other executive branch buildings. The Marshal of the Supreme 

Court and the Supreme Court Police provide security for the Supreme 

Court; however, the Department of Justice’s (DOJ) U. S. Marshals 

Service (USMS) and GSA provide security for other federal courts, which 

may be located in federal office buildings that house several federal 

agencies. The U.S. Capitol Police are responsible for the security of 

the Capitol complex, including the Capitol and House and Senate office 

buildings; but GSA is responsible for the security of office space it 

provides to Members in their home states or districts.



According to an FPS official, FPS had a staff on board of approximately 

1,135, consisting of approximately 574 uniformed officers, 108 physical 

security specialists, and 453 administrative and other personnel. FPS’s 

fiscal year 2002 budget is $362.1 million, of which about $207 million 

is spent on contract guard services. Additionally, GSA is slated to 

spend over $300 million more from its reimbursable program for contract 

guard services, according to the official.[Footnote 4] This total of 

over $500 million for contract guard services will fund approximately 

7,300 contract guards according to the FPS official.



The day after the April 19, 1995, bombing of the Alfred P. Murrah 

federal building, the president directed DOJ to assess the 

vulnerability of federal office buildings in the United States, 

particularly to acts of terrorism and other forms of violence. On June 

28, 1995, DOJ issued a report entitled Vulnerability Assessment of 

Federal Facilities. In this report, DOJ included security levels 

designated I through V for office buildings (see app. III for the 

definitions of these security levels), minimum security standards for 

office buildings, and, as one of its recommendations, the creation of 

ISC to provide a permanent body to address continuing governmentwide 

security concerns.



Prior to 1995 there were no governmentwide standards for security at 

federal buildings. On October 19, 1995, Executive Order 12977 

established ISC to develop, among other things, such standards for 

buildings and facilities occupied by federal employees for nonmilitary 

activities. The committee was to be made up of the Administrator, GSA; 

representatives from the 14 department-level agencies; EPA; the Central 

Intelligence Agency (CIA); OMB; the Director, USMS; the Assistant 

Commissioner, FPS, GSA; the Assistant to the President for National 

Security Affairs; the Director, Security Policy Board.[Footnote 5] The 

executive order specified that the GSA Administrator or his designee 

was to chair the committee. The President reserved the right to appoint 

other federal employees to the committee. FPS was designated to provide 

administrative services, funds, facilities, staff, and other support 

services for ISC to the extent permitted by law and subject to the 

availability of appropriations. Also subject to these provisions, other 

executive departments and agencies were charged with helping to support 

ISC.



ISC was established to enhance the quality and effectiveness of 

security in and protection of buildings and facilities in the United 

States that are occupied by federal employees for nonmilitary 

activities, and to provide a permanent body to address continuing 

governmentwide security for federal facilities. ISC’s responsibilities 

are to:



* establish policies for security in and protection of federal 

facilities;



* develop and evaluate security standards for federal facilities, 

develop a strategy for ensuring compliance with such standards, and 

oversee the implementation of appropriate security measures in federal 

facilities; and:



* take such actions as may be necessary to enhance the quality and 

effectiveness of security and protection of federal facilities, 

including but not limited to:



* encouraging agencies with security responsibilities to share 

security-related intelligence in a timely and cooperative manner;



* assessing technology and information systems as a means of providing 

cost-effective improvements to security in federal facilities;



* developing long-term construction standards for those locations with 

threat levels or missions that require blast-resistant structures or 

other specialized security requirements;



* evaluating standards for the location of, and special security 

related to, day care centers in federal facilities; and:



* assisting the GSA Administrator in developing and maintaining a 

centralized security database of all federal facilities.



The order also directs the GSA Administrator, through FPS, to be 

responsible for monitoring federal agencies’ compliance with ISC’s 

policies and recommendations.



ISC Has Made Limited Progress Implementing Its Responsibilities:



ISC has carried out some elements of its responsibilities, but it has 

made little progress on several other responsibilities given to it by 

the executive order. ISC has issued two formal products. The first, ISC 

Security Design Criteria for New Federal Office Buildings and Major 

Modernization Projects (ISC Security Design Criteria), was issued in 

May 2001. This document contains physical security-design and 

construction criteria and standards for federal buildings. The second 

product, issued in July 2001, is Minimum Standards for Federal Building 

Access Procedures. In 1997 ISC disseminated information on entry 

security technology for buildings with high security designations to 

member agencies for their consideration and implementation, if 

applicable; and it developed a draft report on preparedness for 

nuclear, biological, and chemical events. ISC also has been a forum for 

federal agencies to discuss security-related issues and share 

information and ideas. However, for a number of reasons, it has not 

accomplished several elements of its responsibilities. ISC has no 

governmentwide data on the extent to which it has enhanced the quality 

and effectiveness of federal facility security since its inception, 

although this was one of its major objectives. Consequently, several 

ISC participants believe it has not been very effective or has not 

lived up to its potential.



ISC records show that ISC established 13 working groups between 

December 1995 and April 2002, but 11 of 13 working groups were inactive 

in July 2002. At its initial meeting in December 1995, 9 working groups 

were established within ISC. Eight of these working groups addressed 

the various responsibilities identified in Executive Order 12977; the 

ninth group was to focus on funding issues.[Footnote 6] In 1996, an 

existing working group was split into 2 groups; the new working group 

was called “information systems and centralized database,” and it 

became the tenth working group. A new working group, the eleventh, was 

also formed to focus on protective forces at federal facilities. 

Further, as the result of congressional testimony we delivered on 

security breaches,[Footnote 7] the twelfth working group was 

established in 2000 to develop guidelines to improve building access 

procedures.[Footnote 8] Finally, in April 2002, ISC established its 

thirteenth working group to focus on the security of leased space.



Table 1 shows the areas of responsibility, the working groups 

established, and products drafted or issued in each area. As the table 

indicates, two products were issued by ISC and two draft products, one 

addressing entry security technology and the other preparedness for 

nuclear, biological, and chemical events, were not officially issued by 

ISC. However, ISC disseminated the product on entry security to 

participating agencies for implementation, if appropriate. GSA’s ISC 

records do not indicate what happened to the other product.



Table 1: ISC Products and Working Groups, in Relation to Its 

Responsibilities:



Responsibility: Establish policies for security in and protection of 

federal facilities.; Name of working group, status, and products 

drafted or Issued: No information in ISC records.



Responsibility: Develop and evaluate security standards for federal 

facilities, develop a strategy for ensuring compliance with such 

standards, and oversee the implementation of appropriate security 

measures in federal facilities.; Name of working group, status, and 

products drafted or Issued: Five working groups established: (1) 

Security Standards for Federal Facilities, established in 1995. No 

records of products issued; working group inactive in July 2002. (2) 

Oversee Implementation of Security Measures, established in 1995; no 

record of products issued by ISC; working group inactive in July 2002. 

(3) Protective Forces at Federal Facilities, established 1996; no 

record of products issued by ISC; working group inactive in July 2002. 

(4) Working group formed in June 2000 to address improving building 

access procedures. Issued Minimum Standards for Federal Building Access 

Procedures in 2001; working group inactive in July 2002. (5) Working 

group formed April 2002 to address security of leased space; working 

group active.



Responsibility: Take such actions as may be necessary to enhance the 

quality and effectiveness of security and protection of federal 

facilities, including but not limited to:; Name of working group, 

status, and products drafted or Issued: [Empty].



Responsibility: encouraging agencies with security responsibilities to 

share security-related intelligence in a timely and cooperative manner; 

Name of working group, status, and products drafted or Issued: Working 

group established 1995: Responsibility of Sharing Security Related 

Intelligence; no record of products issued by ISC; working group 

inactive in July 2002.



Responsibility: assessing technology and information systems as a means 

of providing cost-effective improvements to security in federal 

facilities; Name of working group, status, and products drafted or 

Issued: Working group established 1995: Technology and Information 

Systems for Security Improvements and Centralized Data Base; made 

recommendations on entry security technology and on preparedness for 

nuclear, biological, and chemical events in 1997; working group 

inactive in July 2002.



Responsibility: developing long-term construction standards for those 

locations with threat levels or missions that require blast-resistant 

structures or other specialized security requirements; Name of working 

group, status, and products drafted or Issued: Three working groups 

established in 1995: (1) Long-Term Construction Standards, issued ISC 

Security Design Criteria for New Federal Office Buildings and Major 

Modernization Projects in May 2001; working group still active. (2) 

Court Security Issues: no record of products issued by ISC; working 

group inactive in July 2002. (3) Specialty/ Unique Facilities: no 

record of products issued by ISC; working group inactive in July 2002.



Responsibility: evaluating standards for the location of, and special 

security related to, day care centers in federal facilities; Name of 

working group, status, and products drafted or Issued: Working group 

established 1995: People Issues (child care, agency collocation); no 

record of products issued by ISC; working group inactive in July 2002.



Responsibility: assisting the Administrator in developing and 

maintaining a centralized security database of all federal facilities; 

Name of working group, status, and products drafted or Issued: Working 

group established 1996: Information Systems and Centralized Data Base 

(separated from Technology and Information Systems for Security 

Improvements); no record of products issued by ISC; working group 

inactive in July 2002.



Responsibility: funding.; Name of working group, status, and products 

drafted or Issued: Working group established 1995: Funding Issues; no 

record of products issued by ISC; working group inactive in July 2002.



Note: We have assigned the working groups to responsibilities based on 

descriptions given about the working group in ISC records and the name 

of the working group or its product. ISC records do not identify which 

working group was formed to meet which responsibility.



Source: ISC documents and minutes of meetings and discussions with 

agency personnel involved with ISC.



[End of table]



ISC members and participating agencies have identified various 

strengths and weaknesses with the way in which ISC is structured and 

has operated. As examples of ISC’s strengths, several representatives 

from agencies that attend ISC meetings identified the coordination, 

communication, and sharing of information among agencies on security 

issues; the ability to bring together diverse security and related 

expertise to address problems; and the ability to interface with the 

private sector.



The reported weaknesses could help explain why ISC has made limited 

progress toward meeting some of the responsibilities given to it by the 

executive order. Agency representatives identified several weaknesses, 

including a lack of consistent and aggressive leadership by GSA and 

inadequate staff support and funding, that they said have limited ISC’s 

effectiveness. GSA’s lack of aggressive leadership and support were 

illustrated by the following:



* No charter or operating procedures been issued. The ISC perceived the 

need for a charter and operating procedures, and ISC meeting minutes in 

1997 indicated that a charter was ready for the GSA Administrator’s 

signature and that GSA would draft standard operating procedures to 

implement the charter. Nevertheless, we found no record of an approved 

charter or any operating procedures. Several ISC participants expressed 

concerns about ISC’s decisionmaking. These concerns included their 

perception of ISC’s difficulty in making decisions, the lack of agreed-

upon policies and procedures on voting and decisionmaking, and the 

limited amount of influence given to smaller agencies as compared with 

the larger ones.



* Although ISC has met 14 times since its inception in 1995, no 

meetings were held for an approximately 18 month period, from November 

1998 to June 2000.[Footnote 9]



* GSA assigned one FPS staff member to support ISC for the past several 

years, and this individual supported ISC only on a part-time basis, in 

addition to his other duties. According to this individual, ISC had no 

independent funding. According to a former GSA official involved with 

ISC, the lack of sufficient staff support and budget have adversely 

affected ISC’s success.



* Some ISC representatives point to the long time it took GSA to issue 

security design criteria as an example of GSA’s lack of leadership and 

support. Although the design criteria were unanimously approved by ISC 

(including GSA) in 1998, they were not officially released until May 

2001. The former GSA official who delayed issuance of the security 

design criteria said that although he did not know whether he had the 

authority to delay issuance, he did so because he believed that the 

criteria were too prescriptive and would adversely affect GSA’s ability 

to obtain properties. According to this official, GSA also did not 

establish clear lines of authority within GSA concerning ISC, and did 

not try hard enough to make ISC work.



* In 1997, ISC agreed to seek full membership for the USPS and the 

Social Security Administration (SSA). The ISC Chairman agreed to 

initiate the process of formally accepting these two as new members. 

Although representatives from the USPS and SSA served on working 

groups, they could not vote on ISC issues because the executive order 

creating ISC did not specify these agencies as members. Although a GSA 

official told us that this issue was discussed with OMB, he said that 

GSA did not follow through on having the executive order changed to add 

new members because GSA perceived it as a long, drawn-out process.



* Although ISC issued annual reports for 1996 and 1997 discussing such 

matters as security enhancements at federal buildings and the status of 

various ISC working groups, it has not issued annual reports for the 

years after 1997--limiting information about ISC efforts. Furthermore, 

we found no evidence that ISC has established performance goals or 

measures that would enable it to determine the extent to which one of 

its major objectives--enhancing the quality and effectiveness of 

federal facility security--has been achieved.



* We found no records, and, when asked, GSA was unable to provide any 

documents indicating that either GSA or ISC monitored federal agency 

compliance with ISC’s policies and recommendations, even though both 

had been charged with this responsibility.



More recently, under GSA’s leadership, ISC has recognized that its 

success had been constrained by a number of factors; it has been 

working to revitalize the committee to meet its responsibilities in 

light of the September 11, 2001, terrorist attacks. At a December 2001 

conference and in a December 2001 follow-up letter, a GSA official 

stated that GSA is committed to reinvigorating ISC. On April 26 and 

June 27, 2002, ISC had the first two business meetings in its 

revitalization effort. At these meetings, ISC identified the need to 

address general ISC issues, such as a charter, voting protocol, and a 

new membership process. It also discussed ISC operating procedures and 

agreed to meet quarterly unless an emergency meeting were needed. GSA 

announced that it was seeking a full-time staff person to plan and 

coordinate ISC’s efforts.



On the programmatic side, in December 2001, GSA, ISC and the American 

Institute of Architects participated in a conference entitled Better 

Security-Better Design. At its April and June 2002 business meetings, 

ISC established a working group to develop security standards for 

leased space, and GSA and the State Department agreed to share their 

alert systems with the other agencies; ISC representatives also 

discussed a number of topics, such as creating one document that would 

provide security criteria for new buildings, existing buildings, child 

care centers, and leased space, and reducing duplication of effort 

between ISC and other groups in the government looking at security 

issues.



Implications of the Creation of DHS on ISC:



The creation of a DHS would have significant implications for ISC and 

its responsibilities. While the need for ISC, or an organization like 

ISC, would likely continue with the creation of a DHS, leadership 

responsibility for ISC could shift from GSA to DHS, and ISC’s 

responsibilities, role, membership and operation could change.



Concerning ISC’s continued existence, the need for an organization like 

ISC would likely continue for several reasons. The proposed legislation 

by the President and both houses of Congress calls for DHS’s mission to 

include security for and protection of the nation’s critical 

infrastructure. Over 30 federal agencies have authority to own or 

acquire real property for which they have security-related 

responsibilities. Various agencies, such as the Departments of the 

Treasury (Treasury) and Veterans Affairs (VA), have independent police 

forces. It would be difficult for DHS to develop and implement policies 

and standards for the security of federal facilities without the 

participation and assistance of the federal organizations that own and 

occupy the facilities, given their large number, their variety, and 

their dispersion.



The President’s DHS proposal as well as the DHS bills being considered 

in Congress would move FPS from GSA to DHS. With respect to the ISC’s 

leadership, such a move would likely mean that the ISC chairmanship 

would shift from GSA to DHS if FPS were moved, since GSA would no 

longer have the security role of FPS. Should this occur, DHS could 

decide to seek a change in ISC’s role, or the law creating DHS could 

necessitate changes in ISC’s role. The President’s proposal and S. 2452 

did not specifically address whether DHS’s security responsibilities 

for facilities would include more than just buildings that are GSA-

owned or -occupied. However, H.R. 5005, as passed by the House of 

Representatives, provides that the DHS Secretary “shall protect the 

buildings, grounds and property that are owned, occupied, or secured by 

the Federal Government (including any agency, instrumentality, or 

wholly owned or mixed-ownership corporation thereof) and the persons on 

the property.”[Footnote 10] This could include facilities controlled by 

the Department of Defense (DOD), Congress, and the Judiciary. Thus, if 

such a provision were included in the legislation that is enacted, DHS 

would have significantly greater authority and responsibility than GSA 

currently has for federal property security, and the nature of the 

relationship between the ISC Chair and ISC member agencies would 

change. This is because the GSA Administrator currently does not have 

direct authority or responsibility for security for federal property 

that GSA does not own or acquire by lease; under H.R. 5005, the DHS 

secretary would have direct authority and responsibility for security 

governmentwide. Moreover, the DHS Secretary, in consultation with the 

GSA Administrator, could issue and enforce policies and standards 

governmentwide; the GSA Administrator needs the auspices of ISC to do 

this for buildings not under GSA’s control.



It appears that ISC’s role after DHS is established would depend 

largely on the role that DHS’s authorizing legislation assigns to DHS 

for federal facility security, which differs in pending legislation, as 

well as how DHS would decide to use the ISC or groups similar to ISC. 

For example, if DHS were given direct overall responsibility for the 

full range of federal security functions, it would appear that ISC or a 

similar group would play more of an advisory/information-sharing role. 

On the other hand, if DHS were directly responsible for security only 

for GSA-owned and -leased space, then the ISC or a similar group might 

continue to make decisions for other owned or leased space. In 

addition, the specific nature of the responsibilities given to DHS 

would affect the ISC. For example, DHS’s responsibilities for federal 

facility security could include one or more of the following: 

policymaking, standard setting, decisionmaking, training, planning, 

information/intelligence sharing, providing day-to-day security 

protection, and oversight. The challenge of having DHS be directly 

responsible for all of these functions for all federal facilities would 

have to be considered. For those functions given to DHS, it would have 

to decide which functions it would perform, which ones it might 

delegate to the organization previously responsible, and which ones 

would be appropriate for an organization like the ISC. The specific 

language of the final legislation creating DHS and how it addresses 

this issue would obviously affect ISC’s future role.



Another possible responsibility ISC could have under a newly 

established DHS would be to assist DHS in carrying out the initiatives 

contained in the July 2002 Office of Homeland Security’s National 

Strategy for Homeland Security as they relate to critical 

infrastructure. For example, ISC could assist in performing and 

maintaining a complete and accurate assessment of the nation’s critical 

federal facilities and related infrastructure and in developing a 

national infrastructure protection plan for federal facilities. 

According to the strategy, this would include establishing standards 

and benchmarks for infrastructure protection and providing a means for 

measuring performance as related to federal facilities. In addition, 

the ISC could have a role in assisting DHS to carry out its 

intelligence-related responsibilities, including the sharing of threat 

and risk information, as they relate to federal facilities.



Still another responsibility that could be considered for ISC is the 

security protection that is provided to executive branch officials. In 

July 2000, we reported that responsibility for this was divided among 

many agencies, and no single agency or official was responsible for 

handling issues related to the routine protection of these 

officials.[Footnote 11] We said that from fiscal years 1997 through 

1999, agencies reported that personnel from 27 different agencies 

protected officials holding 42 executive branch positions in 31 

executive branch agencies. The problems we found included lack of 

specific statutory authority to provide protection, lack of 

standardized threat assessments and training, and lack of a federal 

organization responsible for overseeing this function on a 

governmentwide basis. We recommended that the OMB Director, in 

consultation with the President, designate an official or group to 

assess issues related to security protection for executive branch 

officials. In early 2002, an OMB representative told us that OMB had 

not yet acted on our recommendation and that the Office of Homeland 

Security (OHS) might be the appropriate organization to handle this 

issue. Thus, this could also be an appropriate responsibility for DHS 

and ISC.



After ISC’s future role and responsibilities are determined, such 

issues as membership, operating procedures, and funding and support 

needs would have to be assessed. These could entail looking at the 

factors and issues that we and the agency representatives had 

identified as contributing to limited progress by ISC as it has existed 

prior to DHS, to see whether the actions initiated by GSA addressed 

them sufficiently or needed to be modified or enhanced. These include 

ISC’s charter, operating procedures, decisionmaking process, 

membership, meeting schedule, funding and support, and performance 

goals and measures. For example, if DHS becomes responsible for all the 

facilities provided in H.R. 5005, it may be appropriate to add other 

organizations besides the USPS and SSA to ISC, including government 

corporations. For another example, GSA has said that it was seeking a 

full-time staff member to support ISC. DHS would have to determine 

whether one person would be sufficient to meet DHS’s objectives and 

schedule for ISC.



Another important responsibility that would have to be considered is 

integration between security and the facility management functions. 

Under DHS proposals, DHS would be responsible for property security, 

but GSA and other agencies with authority to own or acquire space would 

retain their responsibilities for such functions as choosing facility 

locations and building design and operation. In addition, agencies will 

still have to ensure that each property adequately and effectively 

supports the mission of the occupying agency or other government entity 

and that any security systems, procedures, or devices implemented at a 

facility do not materially hamper the ability of the entity to carry 

out its mission effectively.



We and a GSA official have both testified that security is a key 

facilities management function: security needs to be integrated into 

decisions about location, design and operation of federal 

facilities.[Footnote 12] Further, in testifying on a proposal to make 

FPS a separate service within GSA, GSA stated that such an action would 

divorce security from other federal facility functions. According to 

GSA, separating FPS from PBS would create an organizational barrier 

between protection experts and the PBS asset managers, planners, and 

other staff who set PBS budgets and policies for GSA’s building 

inventory. GSA said that FPS’s budget, personnel actions, and 

operational focus have been centralized to yield results that are 

better than if FPS were separate. Additional concerns were raised about 

security and the facilities management function in a November 1999 

Symposium on Security and the Design of Public Buildings, which was 

jointly sponsored by GSA and the Department of State (DOS) in 

cooperation with the American Institute of Architects. Presenters 

concluded that public building design processes must find innovative 

ways to improve security and protect American values without creating a 

fortress image. Thus, if DHS becomes responsible for the security of 

federal facilities, DHS would likely not only need a mechanism like ISC 

to work with GSA and other federal entities on security-related 

matters; it would also need a way to ensure that building security and 

other facility management functions are integrated. An organization 

like ISC that comprises the affected entities could serve to promote 

such integration.



Finally, in commenting on a draft of this report, DOS’s Senior Advisor 

in DOS’s Office of Diplomatic Security raised another issue he believed 

would be relevant for DHS’s creation. This issue related to the 

existing delegations of authority from GSA to various agencies that 

enable them to provide their own facility protection. He believes that 

these delegations are important elements of the government’s efforts to 

protect its facilities that ISC and DHS need to consider.



Conclusions:



Although ISC has carried out some of its responsibilities, it has made 

little progress on others, and several participants believe that its 

progress has been limited. Agency officials and ISC participants 

identified factors and issues in areas such as membership, leadership, 

charter, operating procedures, decisionmaking processes, meeting 

frequency, and staffing and funding support that they believe have 

limited ISC’s progress. We also noted that ISC lacks performance goals 

and measures. GSA has acknowledged the lack of consistent and 

aggressive leadership by GSA, inadequate staff support and funding for 

the ISC, and ISC’s difficulty in making decisions and has initiated 

efforts to address them. However, it is too early to tell whether these 

efforts will be sufficient.



With the potential creation of a DHS, the need for ISC, or an 

organization like ISC, would likely continue. The creation of DHS would 

have significant implications for ISC and its responsibilities. ISC’s 

leadership, responsibilities, role, membership, and operation could 

change. To deal with these possible changes, the factors and issues 

that affected ISC’s progress prior to the creation of DHS should be 

considered, including the extent to which GSA has addressed these 

issues. DHS’s creation and assignment of responsibility for federal 

facility security would also necessitate the need to consider how best 

to integrate facility security and the other facility management 

functions. Further, DHS’s creation would raise the issue whether DHS 

and ISC should be given responsibility for security protection for 

executive branch officials. Finally, how Congress ultimately decides 

upon DHS’s role for federal facility security in any legislation to 

create DHS would have significant implications for ISC, DHS, and other 

federal agencies.



Recommendations for Executive Action:



In the short term, we recommend that the Administrator of GSA work with 

ISC to ensure that actions are effectively implemented to correct the 

problems identified with ISC in this report. Furthermore, given that 

OMB is a current member of ISC and has been given responsibility for 

heading the government’s efforts to help establish DHS,[Footnote 13] we 

recommend that the Director of OMB work with DHS, GSA, and other 

appropriate entities to ensure that the issues our review has 

identified are addressed by the appropriate agency or agencies that 

will have the responsibility of overseeing the protection of federal 

facilities and executive branch officials.



Matter for Congressional Consideration:



As Congress continues its deliberations on proposed legislation 

creating DHS, it may want to clarify DHS’s jurisdiction with respect to 

the federal organizations under its purview and the specific security-

related functions for which it is responsible. Federal organizations 

under DHS’s jurisdiction could range from, exclusively, the federal 

buildings now under GSA’s control to all facilities owned, occupied, or 

secured by the federal government. Limiting DHS’s jurisdiction to 

exclusively GSA-controlled properties would leave out many nonmilitary 

facilities, while extending it to all property owned or occupied by the 

federal government would be an enormous undertaking. The functions for 

which DHS could assume responsibility could include policy and standard 

setting, training, information and intelligence sharing, planning and 

oversight, and the actual provision of security services. In deciding 

which security-related functions DHS should be responsible for 

providing, two factors for Congress to consider are the need for 

integrating the security function with the day-to-day management of the 

facility and the challenge that would be associated with providing day-

to-day security for all federally owned, occupied, or secured 

facilities.



Scope and Methodology:



To achieve our objective of determining whether ISC had fulfilled the 

duties and responsibilities established by the executive order, we 

reviewed Executive Order 12977, the minutes of ISC meetings, and 

available products developed by ISC. We also interviewed 17 of 21 

members and participating nonmembers of ISC; FPS officials; and both 

current and former GSA officials. Further, we attended the December 

2001 and the April and June 2002 ISC meetings. We did not interview the 

Central Intelligence Agency’s officials, because the agency declined to 

participate in our assignment. Also, we did not interview the Assistant 

to the President for National Security Affairs because, being new to 

the position, this person had limited knowledge of ISC and its past 

efforts. Further, our report does not reflect any comments from OMB 

about ISC’s current or past operations, because an OMB official said 

that OMB had not attended meetings in the past several years and did 

not have time-relevant information to provide us on these matters. We 

did not interview the Director of the Security Policy Board because it 

has been abolished. Further, responses from several agencies were 

limited by the fact that ISC representatives were new or had not 

attended meetings in several years. Our review of ISC accomplishments 

was constrained by the lack of detailed ISC records after 1997 and by 

the turnover of agency personnel who participated in ISC activities. 

Thus, our reporting of accomplishments was based on available ISC 

records and the recollections of those persons whom we interviewed who 

had varying lengths of experience with ISC.



To determine the implications of the creation of DHS on ISC, we 

reviewed the President’s proposal to create DHS, proposed legislation 

that would create DHS, the OHS’s July 2002 National Strategy, Executive 

Order 13267, and our July 2001 report on security protection for 

executive branch officials. We also discussed this issue with 

representatives from OMB, GSA, and OHS.



We conducted our review of ISC between December 2001 and July 2002 in 

accordance with generally accepted government auditing standards. We 

received written responses from 3 agencies; oral or E-mail comments 

from 14 agencies; and 4 agencies did not respond. The comments are 

discussed in the following section.



Agency Comments:



We requested comments on a draft of this report from the OMB Director, 

the Administrator of GSA, OHS’s General Counsel, and ISC agencies 

participating in our review. We received written responses on our draft 

report from the Departments of Health and Human Services (HHS) and 

Housing and Urban Development (HUD), and from SSA. HHS had no comments. 

HUD and SSA generally agreed with the report’s conclusions and 

recommendations. We received oral or E-mail responses on our draft 

report from GSA; the Administrative Office of the United States Courts 

(AOUSC); DOD; DOJ; DOS; Treasury; VA; the Departments of Education 

(Education), Energy (DOE), Labor (DOL), Transportation (DOT), and 

Agriculture (USDA); OMB; and USPS. GSA, DOE, DOL, USDA, USPS, and VA 

concurred with the information in our report. AOUSC, Education, DOD, 

DOJ, DOT, and Treasury had no comments. OMB agreed with our 

recommendation and suggested technical changes that we have made. DOS 

raised several issues, which we discuss below. The DOC, Interior, EPA, 

and OHS did not provide comments on the report.



GSA’s Commissioner of the Public Buildings Service said that he 

concurred with our recommendation and our view that a full resolution 

of the ISC issues we identified depended on the mission and authorities 

given to DHS. He also said that GSA would seek ISC member comments on 

our report at its next meeting and would consult with OMB officials and 

the DHS transition planning office to address the future role of the 

ISC within the context of DHS.



SSA’s Commissioner raised two issues that SSA believes the ISC needs to 

consider. These are the role of the federal facilities building 

security committees and the need to integrate the term “force 

protection” into the ISC charter and operating procedures. While these 

issues may be reasonable for ISC to consider, we did not address them 

in our review and are not in a position to discuss them definitively. 

(See app. V.):



DOS’s Senior Advisor in the Office of Diplomatic Security raised a 

question about our discussion that the ISC assume some role in security 

protection of executive branch officials, considering the ISC’s 

responsibility for facility security. Our discussion on this issue 

related to both DHS and ISC. If DHS is created, a role in the 

protection of executive branch officials may be appropriate. He also 

suggested that we provide the basis for this discussion in this report. 

The basis is discussed in our report and relates to work we have 

previously reported on in a separate review. He also expressed concern 

about the lack of reference in our report to GSA’s delegation of 

authority to various agencies, to enable them to provide their own 

facility protection. Although our report pointed out these delegations, 

we have modified it to reflect his concern. He also recommended a 

technical change, which we have made.



DOS’s Director of the Office of Domestic Operations said that offices 

responsible for safety and security often have opposing views and that, 

in his opinion, any mechanism established to integrate security into 

federal facilities should include safety offices. We did not address 

this issue in our review and are therefore not in a position to comment 

on it. He also pointed out the there are other entities currently 

working on federal facility security issues, such as the Physical 

Security Working Group and the Protective Forces Working Group, which 

should be included under the DHS or ISC umbrella or should have a 

specific separate mandate. While we did not address the roles of these 

two groups, this appears to be a reasonable issue for DHS or ISC to 

address.



As agreed with your office, unless you publicly announce the contents 

of this report, we plan no further distribution until 7 days from the 

report date. At that time, we will send copies of this letter to the 

Ranking Minority Member of the Senate Committee on Governmental 

Affairs, other appropriate congressional committees, the Director of 

OMB, the Administrator of GSA, OHS, and other interested organizations. 

We will also make copies available to others upon request. In addition, 

the report will be available at no charge on the GAO Web site at http:/

/www.gao.gov.



Please contact Ron King or me at (202) 512-2834. Major contributors to 

this report are acknowledged in appendix VI.



Bernard L. Ungar

Director, Physical Infrastructure Issues:



Signed by Bernard L. Ungar:



[End of section]



Appendix I: Executive Order 12977 of October 19, 1995:



The President:



Interagency Security Committee:



By the authority vested in me as President by the Constitution and the

laws of the United States of America, and in order to enhance the 

quality and effectiveness of security in and protection of buildings 
and 

facilities in the United States occupied by Federal employees for 
nonmilitary 

activities (‘’Federal facilities’’), and to provide a permanent body to 

address continuing government-wide security for Federal facilities, it 

is hereby ordered as follows: 



Section 1. Establishment. There is hereby established within the 

executive branch the Interagency Security Committee (‘’Committee’’). 

The Committee shall consist of: (a) the Administrator of General 

Services (‘’Administrator’’);

(b) representatives from the following agencies, appointed by the 

agency

heads:



(1) Department of State;

(2) Department of the Treasury;

(3) Department of Defense;

(4) Department of Justice;

(5) Department of the Interior;

(6) Department of Agriculture;

(7) Department of Commerce;

(8) Department of Labor;

(9) Department of Health and Human Services;

(10) Department of Housing and Urban Development;

(11) Department of Transportation;

(12) Department of Energy;

(13) Department of Education;

(14) Department of Veterans Affairs;

(15) Environmental Protection Agency;

(16) Central Intelligence Agency; and

(17) Office of Management and Budget;

(c) the following individuals or their designees:

(1) the Director, United States Marshals Service;

(2) the Assistant Commissioner of the Federal Protective Service of the

Public Buildings Service, General Services Administration (‘’Assistant 

Commissioner’’);

(3) the Assistant to the President for National Security Affairs; and

(4) the Director, Security Policy Board; and

(d) such other Federal employees as the President shall appoint.



Sec. 2. Chair. The Committee shall be chaired by the Administrator, or

the designee of the Administrator.



Sec. 3. Working Groups. The Committee is authorized to establish 

interagency working groups to perform such tasks as may be directed by 

the Committee.



Sec. 4. Consultation. The Committee may consult with other parties, 

including the Administrative Office of the United States Courts, to 

perform its responsibilities under this order, and, at the discretion 

of the Committee, such other parties may participate in the working 

groups.



Sec. 5. Duties and Responsibilities. (a) The Committee shall: 



(1) establish policies for security in and protection of Federal 

facilities;

(2) develop and evaluate security standards for Federal facilities, 

developa strategy for ensuring compliance with such standards, and 

oversee theimplementation of appropriate security measures in Federal 

facilities; and

(3) take such actions as may be necessary to enhance the quality and

effectiveness of security and protection of Federal facilities, 

including butnot limited to:



(A) encouraging agencies with security responsibilities to share 

security-related intelligence in a timely and cooperative manner;

(B) assessing technology and information systems as a means of 

providing cost-effective improvements to security in Federal 
facilities;

(C) developing long-term construction standards for those locations 

with threat levels or missions that require blast resistant structures 
or 

other specialized security requirements;

(D) evaluating standards for the location of, and special security 

related to, day care centers in Federal facilities; and

(E) assisting the Administrator in developing and maintaining a 

centralized security database of all Federal facilities.



Sec. 6. Agency Support and Cooperation. (a) Administrative Support. To

the extent permitted by law and subject to the availability of 

appropriations, the Administrator, acting by and through the Assistant 

Commissioner, shall provide the Committee such administrative services, 

funds, facilities, staff and other support services as may be necessary 

for the performance of its functions under this order.

(b) Cooperation. Each executive agency and department shall cooperate 

and comply with the policies and recommendations of the Committee 

issued pursuant to this order, except where the Director of Central 

Intelligence determines that compliance would jeopardize intelligence 

sources and methods. To the extent permitted by law and subject to the 

availability of appropriations, executive agencies and departments 

shall provide such support as may be necessary to enable the Committee 

to perform its duties and responsibilities under this order.

(c) Compliance. The Administrator, acting by and through the Assistant

Commissioner, shall be responsible for monitoring Federal agency 

compliance with the policies and recommendations of the Committee.

Sec. 7. Judicial Review. This order is intended only to improve the 

internal management of the Federal Government, and is not intended, and 

should not be construed, to create any right or benefit, substantive or 

procedural, enforceable at law by a party against the United States, 

its agencies, its officers, or its employees.



ÏÐ:



THE WHITE HOUSE,

October 19, 1995.

[FR Doc. 95-26497

Filed 10-20-95; 2:55 pm]

Billing code 3195-01-P:



[End of section]



Appendix II: Federal Executive Branch Entities with Some Level of 

Independent Authority to Acquire Real Property:



This information is from Facilities Location: Agencies Should Pay More 

Attention to Cost and Rural Development Act, GAO-01-805, July 31, 2001.



Agency for International Development

American Battle Monuments Commission

Appalachian Regional Commission

Bonneville Power Administration

Broadcasting Board of Governors

Central Intelligence Agency

Department of Agriculture

Department of Commerce

Department of Defense

Department of Education

Department of Energy

Department of Health and Human Services

Department of Housing and Urban Development

Department of the Interior

Department of Justice

Department of Labor

Department of State

Department of Transportation

Department of the Treasury

Department of Veterans Affairs

Environmental Protection Agency

Federal Emergency Management Agency

General Services Administration

National Aeronautics and Space Administration

National Archives and Record Administration

National Science Foundation

National Transportation Safety Board

Panama Canal Commission

Pennsylvania Avenue Development Corporation

Securities and Exchange Commission

Smithsonian Institution

Tennessee Valley Authority

U.S. Parole Commission

U.S. Postal Service

U.S. Sentencing Commission

U.S. Trade Representative:



[End of section]



Appendix III: Definition of Security Levels I through V, from DOJ’s 

Vulnerability Assessment of Federal Facilities:



Level I:



A level I facility has 10 or fewer federal employees. In addition, the 

facility likely has 2,500 or less square feet of office space and a low 

volume of public contact or contact with only a small segment of the 

population. A typical level I facility is a small storefront-type 

operation, such as a military recruiting office.



Level II:



A level II facility has between 11 and 150 federal employees. In 

addition, the facility likely has from 2,500 to 80,000 square feet; a 

moderate volume of public contact; and federal activities that are 

routine in nature, similar to commercial activities. A typical level II 

building is the Social Security Administration Office in El Dorado, 

Colorado.



Level III:



A level III facility has between 151 and 450 federal employees. In 

addition, the facility likely has from 80,000 to 150,000 square feet 

and a moderate to high volume of public contact. Tenant agencies may 

include law enforcement agencies, courts and related agencies and 

functions, and government records and archives. A typical level III 

building is the Pension building, a multitenant, historical building 

between 4th and 5th Streets on F Street, N.W., Washington, D.C.



Level IV:



A level IV facility has over 450 federal employees. In addition, the 

facility likely has more that 150,000 square feet; a high volume of 

public contact; and tenant agencies that may include high-risk law 

enforcement and intelligence agencies, courts, judicial offices, and 

highly sensitive government records. A typical level IV building is the 

Department of Justice Building on Constitution Avenue in Washington, 

D.C.



Level V:



A level V facility is a building such as the Pentagon or CIA 

Headquarters that contains mission functions critical to national 

security. A level V facility will be similar to a level IV facility in 

terms of number of employees and square footage.



[End of section]



Appendix IV: ISC Participant-Identified Strengths and Weaknesses:



Table 2 shows the strengths identified by the participating agencies or 

by their representatives to ISC. Table 3 shows the weaknesses 

identified by the agencies or by their ISC representatives.



Table 2: ISC Strengths Identified by Participating Agencies or by ISC 

Agency Representatives:



ISC participants’ comments: Coordination and cooperation among federal 

departments, when utilized appropriately.



ISC participants’ comments: Provides a forum for discussing issues, 

networking, and assistance in making agency security determinations.



ISC participants’ comments: Provided a forum for exchanging ideas and 

practices.



ISC participants’ comments: Continued support of the Administration and 

coordination efforts with the new Office of Homeland Security.



ISC participants’ comments: A forum for interagency coordination of 

security requirements.



ISC participants’ comments: The broad composition of membership allows 

meaningful communication among high levels of federal agencies on 

topics of shared and mutual concern. ISC’s activities should result in 

effective coordination of policy and operational protocol for security 

in and protection of federal facilities.



ISC participants’ comments: Ability to bring a very wide and diverse 

range of professional expertise together to address security issues 

that affect the federal government. Ability as a group to interface 

with and positively affect state and local agencies.



ISC participants’ comments: Brings agencies together to work on 

consensus on security issues.



ISC participants’ comments: The group is widely diverse and there is 

expertise in almost all security arenas. Also, participants are up-to-

date on the newest technology. They also interface with the private 

sector, so there is coordination on security issues. This is 

particularly important in the area of leased buildings.



ISC participants’ comments: Something like ISC is needed as a forum to 

bring up and discuss problems, make recommendations, gather 

information, and so forth. ISC can reach a lot of people quickly.



ISC participants’ comments: ISC has brought governmentwide security 

community together and provides a forum where security “best practices” 

can be exchanged, security innovations are presented, and policies are 

developed. These efforts promote a consistent and uniform approach to 

how the federal government ensures a secure environment for its 

employees.



ISC participants’ comments: There is potential for this committee to 

provide a permanent body to address continuing governmentwide security 

for federal facilities.; * Lessons learned are exchanged by committee 

members on security experiences within their government agencies.; * 

Potential exists to improve communications and intelligence-sharing 

with other federal agencies.; * Committee brings high-level government 

professionals together to focus on the security needs of all federal 

agencies.; * This committee attempts to address and meet the 

requirements of the Executive Order 12977.



ISC participants’ comments: Served as a forum for discussing and 

resolving security issues common to all federal agencies.



ISC participants’ comments: Brings all federal agencies together.



ISC participants’ comments: Executive Order 12977 provides ISC with the 

authority and responsibility to develop and issue uniform security 

policies for implementation by federal agencies.



ISC participants’ comments: ISC has representation from throughout the 

Executive Branch and offers a venue for GSA to offer new security 

guidelines and recommendations for interagency review and comment. It 

also initially provided a means for information dissemination 

immediately following the Oklahoma City bombing of the federal 

building--a role since taken over by the Federal Bureau of 

Investigation, to share threat data information.



ISC participants’ comments: ISC’s strength lies in that it provides an 

opportunity to harness federal ideas and find reasonable solutions to 

problems. This has been especially important since Oklahoma City.



Note: Each block represents comments from an ISC participant. However, 

not all ISC participating agencies are represented in the tables, 

because one agency did not respond to our questions, one agency said it 

had no time-relevant data with which to answer our questions, one 

agency had a new ISC representative who did not comment on strengths 

and weaknesses, one agency had no positive comments, and two agencies 

did not comment on the weaknesses.



Source: Oral and written comments received from agencies and their ISC 

representatives.ISC Weaknesses Identified by Participating Agencies or 

by ISC Agency Representatives:



Note: Each block represents comments from an ISC participant. However, 

not all ISC participating agencies are represented in the tables, 

because one agency did not respond to our questions, one agency said it 

had no time-relevant data with which to answer our questions, one 

agency had a new ISC representative who did not comment on strengths 

and weaknesses, one agency had no positive comments, and two agencies 

did not comment on the weaknesses.



Source: Oral and written comments received from agencies and their ISC 

representatives.



[End of table]



[End of section]



Appendix V: Comments from the Social Security Administration:



SOCIAL SECURITY:



The Commissioner:



August 29, 2002:



Mr. Bernard L. Ungar:



Director, Physical Infrastructure Issues U.S. General Accounting Office 

Washington, D.C. 20548:



Dear Mr. Ungar:



Thank you for the opportunity to review and comment on the draft 

report, “Building Security: Interagency Security Committee Has Had 

Limited Success in Fulfilling Its Responsibilities” (GAO-02-1004). Our 

comments on the report are enclosed. If you have any questions, please 

have your staff contact Trudy Williams at (410) 965-0380.



Sincerely,



Jo Anne B. Barnhart:



Signed by Jo Anne B. Barnhart:



Enclosure:



SOCIAL SECURITY ADMINISTRATIONBALTIMORE MD 21235-0001:



COMMENTS OF THE SOCIAL SECURITY ADMINISTRATION (SSA) ON THE GENERAL 

ACCOUNTING OFFICE (GAO) DRAFT REPORT, “BUILDING SECURITY: INTERAGENCY 

SECURITY COMMITTEE HAS HAD LIMITED SUCCESS IN FULFILLING ITS 

RESPONSIBILITIES” (GAO-02-1004):



Recommendation 1:



GAO recommends that the Administrator of the General Services 

Administration (GSA) work with the Interagency Security Committee (ISC) 

to ensure that actions are effectively implemented to correct the 

problems identified with ISC in the report. Furthermore, given that 

Office of Management and Budget (OMB) is a current member of ISC and 

has been given responsibility for heading the Government’s efforts to 

help establish the Department of Homeland Security (DHS), OMB appears 

to be the appropriate agency to work with DHS, GSA, and other 

appropriate entities to address the issues GAO’s review has identified. 

As part of its transition efforts to help establish the proposed DHS, 

GAO recommends that the Director of OMB work with the Administrator of 

GSA and other relevant Federal officials: to determine the appropriate 

leadership, responsibilities, and the role for ISC, or its successor; 

to take the steps necessary to see that ISC, or its successor, has an 

appropriate charter, operating procedures, membership, and decision-

making process, meeting schedule, staffing and funding support, and 

performance goals and measures; and to provide for the integration of 

security with other facility management functions. GAO also recommends 

that the Director of OMB, consistent with relevant legislation, 

determine whether DHS and ISC, or its successor, are the appropriate 

entities to oversee the security protection of executive branch 

officials and, if so, see that this responsibility is clearly assigned 

and effectively implemented.



Comment:



We agree with GAO’s recommendations. The ISC should support the 

initiatives on the starting points of contact with foreign nationals, 

with the goal of protecting the nation’s borders by assisting the DHS 

in addressing physical security and critical infrastructure 

requirements to prevent the entry of terrorists. This must be done 

while not obstructing the legal, efficient and reliable flow of 

persons, goods and services on which the economy depends.



Other Comments:



We want to highlight the comment on page 11, the second bullet, 

sentences 1 and 2, that states, “In 1997, ISC agreed to seek full 

membership for the U.S. Postal Service and the Social Security 

Administration (SSA)-two large federal organizations. The ISC Chairman 

agreed to initiate the process of formally accepting these two as new 

members.” To date, we are still pursuing full membership in the ISC.



There is no reference in this report concerning the role the Federal 

Facilities Building Security Committees should play in the process as 

stated in the Department of Justice Vulnerability Assessment of Federal 

Facilities, June 28, 1995: Page 4-3, (4.2.2).



This report has not addressed the need to integrate the term “Force 

Protection” into the ISC charter and operating procedures. The DHS and 

the ISC must network, coordinate and train. Furthermore, they must 

understand the Department of Defense initiatives and the roles of 

Emergency and First Responder Teams and local authorities in supporting 

the Homeland Security objectives, Congressional Bills and the 

Presidential agendas.



[End of section]



Appendix VI: Major Contributors:



Major contributors to this report include Ron King, Tom Keightley, Lisa 

Wright-Solomon, John Vocino, Shirley Bates, and Michael Yacura.



[End of section]



FOOTNOTES



[1] The President’s proposal to Congress, June 18, 2002, to create a 

Department of Homeland Security; H.R. 5005, 107th Cong. (2002); S. 

2452, 107th Cong. (2002).



[2] All current bills on the proposed creation of DHS would move the 

Federal Protective Service from GSA to DHS. In addition to providing 

security for GSA-owned and -occupied facilities, the Service also 

provides the secretariat for ISC.



[3] The data on owned and leased space are taken from the GSA reports 

Summary Report of Real Property Owned, June 2001, and Summary Report on 

Real Property Leased, June 2001. We issued a report, U.S. General 

Accounting Office, Federal Real Property: Better Governmentwide Data 

Needed for Strategic Decisionmaking, GAO-02-342 (Washington, D.C.: Apr. 

16 2002), concerning the accuracy of the data in GSA’s report, Summary 

Report of Real Property Owned. However, although we reported that some 

of the data are outdated or incomplete, the GSA reports are the only 

sources available that provide estimates of governmentwide ownership 

and leasing.



[4] The reimbursable program provides security funding through payments 

made by agencies assigned space in GSA-owned or -leased buildings. 



[5] Appendix I contains a list of all ISC members. The Security Policy 

Board no longer exists.



[6] Although funding was not listed specifically as a responsibility, 

the executive order did not limit ISC to just those responsibilities 

identified in the executive order.



[7] U.S. General Accounting Office, Security: Breaches at Federal 

Agencies and Airports, GAO/T-OSI-00-10 (Washington, D.C.: May 25, 

2000).



[8] There may have been other working groups formed. However, ISC’s 

records do not show evidence of any.



[9] Thirteen of these were regular ISC meetings. The other meeting was 

a conference among ISC, GSA, and the members of the American Institute 

of Architects in December 2001. There are no minutes of the June 2000 

meeting, but a June meeting (no year stated) is mentioned in the 

December 2000 ISC minutes. We included a June 2000 meeting in our 

count.



[10] Section 2(a) of Section 906



[11] U.S. General Accounting Office, Security Protection: 

Standardization Issues Regarding Protection of Executive Branch 

Officials, GAO/GGD/OSI-00-139 (Washington, D.C.: July 11, 2000).



[12] U.S. General Accounting Office, Homeland Security: Proposal for 

Cabinet Agency Has Merit, but Implementation Will be Pivotal to 

Success, GAO-02-886T (Washington, D.C.: June 25, 2002). Statement of F. 

Joseph Moravec, Commissioner of the Public Buildings Service, U.S. 

General Services Administration before the Subcommittee on Technology 

and Procurement Policy, Committee on Government Reform, U.S. House of 

Representatives (November 1, 2001).



[13] Executive Order 13267 assigns OMB the responsibility of 

establishing a Transition Planning Office for the Department of 

Homeland Security.



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