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Implementation Of The Interagency Security Committee Standard

July 27, 2005

Chairman Davis and members of the Committee, my name is F. Joseph Moravec and I am the Commissioner of the Public Buildings Service at the General Services Administration.  I am here today to discuss security standards in Government leased space and, specifically, the implementation of the Interagency Security Committee’s (ISC’s) standards. 

GSA Security Philosophy

GSA manages a diverse portfolio of real estate for the Federal Government - over 340 million square feet of space in office buildings, courthouses, border stations, and warehouses.  We serve nearly 60 agencies (consisting of more than 400 bureaus), the U.S. Courts, and Congress.  Providing secure facilities for our client agencies, their customers, and the visiting public is of paramount concern for us. 

GSA strives to manage the delicate balance between security and openness in Federal buildings.  Federal buildings need to be inviting to the citizens of this country, but very secure at the same time.  GSA is forward-looking in its federally owned and leased architecture—showing that modern public architecture can be made safer yet still reflect the democratic qualities of openness and transparency.

Security considerations are an integral part of our lease procurement process.  In developing security requirements, a multi-disciplinary team determines the appropriate criteria for each leased project, based on a security assessment of the client and an analysis of all available information on threats and vulnerabilities as well as constraints imposed by budget and location.

Our goal is to develop a meaningful program of security requirements that considers clients’ needs and the availability of those requirements in the marketplace. 

Overview of FPS - GSA Relationship

GSA’s primary partner in providing secure facilities for our clients is the Department of Homeland Security.  GSA coordinates with various DHS entities to accomplish different security related goals for the facilities we own and lease. The DHS components include the Federal Protective Service, the Interagency Security Committee and DHS' Office of Security.  DHS’s Federal Protective Service (FPS) provides law enforcement and physical security services, including security assessments at Federal buildings that are in GSA’s portfolio, and is instrumental in developing and implementing the security program for all of our clients’ space needs.

On March 1, 2003, FPS was transferred from GSA to DHS.  We have focused significant effort toward assisting FPS’s transition, specifically on their contracting capacity for guard service and their ability to appropriately acquire and maintain necessary security equipment on behalf of client agencies.  A Memorandum of Agreement (MOA) between FPS and GSA that outlines our roles and responsibilities has governed our relationship.  FPS and GSA are currently working together on a revised MOA that will further outline our relationship and responsibilities.  This will enhance security provided to our clients and the properties they occupy.

History of ISC and GSA

The horrific bombing of the Alfred P. Murrah Building in 1995 focused attention on the vulnerability of our public institutions to terrorist threats and forever altered the way the Government views security in its buildings. In addition to the development of the Justice Department’s Vulnerability Assessment that same year, Executive Order (EO) 12977 was issued.  This EO created the Interagency Security Committee (ISC), composed of 21 Federal agencies, including GSA, “to establish policies for security in and protection of federal facilities.” 

The ISC produced the Security Design Criteria in 2001, which addressed security standards in new construction.  At that time, GSA also concluded that security standards were needed for our leased facilities- standards that were informed by a client agency’s risk, the vulnerability profile, and product availability in the marketplace.  To that end, GSA initiated a subcommittee within the ISC composed of representatives from FPS, Department of Defense (DOD), Internal Revenue Service (IRS), Social Security Administration, Health and Human Services, Department of Transportation, the Department of Justice and the Federal Courts.  We pursued a collaborative approach, working with the subcommittee members, vetting our progress with our regional offices and client agencies, and obtaining the perspective and contribution of private sector commercial building owners and managers.  ISC issued a draft report in June 2003, and formally issued the end product, Security Standards in Leased Space, in February 2005.

Description of Leased Space Standards

The ISC standards provide a consistent and considered level of security to Federal tenants in leased space.  This level of security is commensurate with the tenant agency’s mission-specific risk and vulnerability, including the necessity and degree of public access to the facility, as well as conditions in the market. 

The ISC standards are categorized into four levels based on inputs such as client mission, size of the space requirement, number of employees, and use of space.  The stringency of security measures increases incrementally by level, ranging from secured utility areas and window glazing, at the low end, to full building control that includes the right to inspect, deny access, and remove persons and vehicles.  For example, a Level II occupancy may need no more than adequate lighting, locks, emergency power, shatter-resistant windows, and controlled access to utility areas and the roof.  By comparison, a Level IV occupancy will include those requirements plus additional requirements for guard service, magnetometers, control over public areas and parking, surveillance and intrusion detection systems, inaccessible air intakes, and dedicated HVAC.

The ISC requirements at each level are minimums, but any agency may select certain elements from a higher level for incorporation into its program.  For example, a Level II occupancy, such as a field office, may decide that guard service and magnetometers are appropriate because of the type of business they conduct and/or the location of the facility.

When a Federal agency launches a search for new or replacement leased space, a collaborative effort between the agency, FPS, and GSA begins.  FPS conducts a security evaluation for the client, and an appropriate level of security is determined that will guide the procurement from the market survey through to occupancy.  GSA also provides current market and real estate information for consideration the client agency.  The goal is to develop a meaningful validated program of security requirements for clients through this process. 

The ISC recognizes that not all standards are achievable in all markets, and they allow for alternative risk mitigation strategies in the event that no market solution is available.  Where standards are unobtainable, the standard becomes to achieve the best security solution available. 

The standards recognize that the Government procures space in a commercial marketplace.  The standards are not intended to force location decisions contrary to the client agency’s mission requirements, and they do not preclude leasing in central business areas (CBA’s).

Although we anticipate that ISC’s process for setting an informed and appropriate level of security will accommodate the needs of Federal agencies and departments, I will note that, if there is substantial demand for the most stringent security elements and countermeasures, it may pose particular procurement challenges.  As the Government Accountability Office (GAO) pointed out in their June report, certain standards at Level IV "may put the government at odds with private lessors and other nonfederal occupants.”  In particular, the Level IV standard that requires Government control of entrances, common areas, and parking areas—with the right to inspect, deny access, and remove persons and vehicles—may receive less interest from the market and, thus, be less competitive.  One solution to such a scenario may be to consolidate agencies with similar security profiles to achieve efficient and cost effective full-building occupancies.

As you know, DOD has also promulgated its own security standards, known as the Unified Facilities Criteria.  Where called to act on behalf of DOD, GSA will treat these standards like any other program requirement and will seek to obtain leased space meeting those standards.  As with all our procurements, we will advise the client on the likelihood of success, potential location outcomes, and likely costs before issuing solicitations to procure space.


In conclusion, I will reiterate the importance of recognizing that securing leased space for Federal agencies must be driven by several key factors, including mission-specific inputs, and the constraints imposed by location and budget.  We believe the ISC standards for leased space provide a practical approach that will allow Federal agencies to fulfill their mission in secure facilities. 

Mr.  Chairman, that concludes my prepared statement.  I will be pleased to answer any questions that you or Members of the Committee may have.