U.S. General Services Administration
Security Standards
STATEMENT OF
SAMUEL MORRIS
ASSISTANT COMMISSIONER
OFFICE OF REAL ESTATE ACQUISITION
PUBLIC BUILDINGS SERVICE
U.S. GENERAL SERVICES ADMINISTRATION
BEFORE THE
COMMITTEE ON TRANSPORTATION AND INFRASTRUCTURE
SUBCOMMITTEE ON ECONOMIC DEVELOPMENT,
PUBLIC BUILDINGS, AND EMERGENCY MANAGEMENT
U.S. HOUSE OF REPRESENTATIVES
MAY 20, 2010
Good morning Chairwoman Norton, Ranking Member Diaz-Balart, and members of this Subcommittee. My name is Chip Morris and I am the Assistant Commissioner for Real Estate Acquisition of GSA’s Public Buildings Service (PBS). Thank you for inviting me to appear before you today to discuss the risk balance for protecting federal employees in leased facilities and the implementation of DoD’s Antiterrorism Standards for Buildings in GSA lease procurements.
GSA is responsible for safeguarding approximately one million federal tenants housed in our facilities, along with their visitors. Our buildings must be secure and at the same time, inviting, as we act as a good neighbor in the community. After the Oklahoma City bombing, our country recognized the need for increased security and protection, particularly in buildings housing federal employees. As a result, increased security standards were developed to protect federal employees in all federally occupied space, regardless if the space was owned or leased. Recognizing that there is a trade-off to protect our federal employees from every conceivable act of violence and terrorism while keeping buildings open and welcoming to the public, GSA has been an active participant in the development and analysis of the security standards promulgated by the Interagency Security Committee.
Security Standards
Prior to the Oklahoma City tragedy, the government’s building security standards focused on preventing theft and unauthorized entry into federally owned or leased buildings. DOJ subsequently completed a study that led to security standards for all federally occupied facilities.
Interagency Security Committee - In October 1995, Executive Order 12977, established the Interagency Security Committee (ISC) comprising of multiple agencies, was issued "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." In order to maintain consistency between our federally owned and leased space, the ISC later developed the Lease Security Subcommittee. In 2003, the ISC Lease Security Subcommittee, chaired by GSA with representatives from other executive agencies, was established to develop a distinct set of standards for leased facilities. In 2005, the Subcommittee issued the ISC Security Standards for Leased Space. In following these standards, GSA issued leasing guidance and instructions for competitive lease procurements.
Last month, the ISC issued a new interim ISC standard, Physical Security Criteria for Federal Facilities, which applies to all U.S. facilities occupied by federal employees for nonmilitary activities. These facilities include:
existing buildings, new construction, or major modernizations;
facilities owned, to be purchased, or leased; and
special-use facilities.
The new ISC interim standard provides a formalized process for non-DoD federal facilities to determine the risk of the facility. This interim standard recognizes that not all conceivable modes of attack are a threat to each facility; this recognition allows the security posture for the facility to be customized to address the most likely threat. As a result, agencies can customize security measures to address the unique risks and threats at each facility. The new interim standard provides an integrated, single source of physical security standards for all federal facilities, including those occupied by law-enforcement and intelligence agencies. Guidance which provides for flexibility and customization of these interim standards as well as the integration of new concepts are contained in two other key ISC documents issued April 12, 2010: Design-Basis Threat: An ISC Report; and Facility Security Committees: An Interagency Security Guideline. This interim standard supersedes the physical security standards in the 2005 ISC Security Standards for Leased Space, ISC Design Criteria for New Federal Office Buildings and Major Modernization Projects, and the 1995 DOJ Report.
GSA will develop leasing guidance to adhere to the new interim ISC standard, as well as update our Solicitation for Offers for lease procurements. The guidance will become final once the interim ISC standard is finalized.
Unified Facilities Criteria - The Department of Defense’s Unified Facilities Criteria: DoD Minimum Antiterrorism Standards for Buildings was issued in October 2003. These standards are more rigorous than the ISC standards and apply to DoD for new construction and "all new leases executed on or after October 1, 2005 and to the renewal or extension of any existing lease on or after October 1, 2009." The standards are required and applied consistently for all DoD facilities, regardless if the facility is owned or leased or the aspect of the DoD mission that is performed within the facility. DoD’s security standards have historically been independent and separate from the standards set for other executive agencies. GSA currently adheres to these standards for DoD leases, as required by the customer agency and will continue to work with DoD to refine their customer requirements as they apply these criteria to GSA’s lease procurements.
Implementing Security Standards
GSA is a service provider for many different agencies. We work with each agency on a case by case basis to define their space and security requirements. For those agencies subject to the ISC, the security measures implemented can vary greatly depending on factors such as tenant agency mission, location of the property, and size of the project. Setback requirements, for example, typically result in additional land acquisition costs, especially in urban areas. As the Facility Security Level increases, additional security measures, such as increased setbacks, site planning, façade hardening, and structural measures, may be necessary to prevent progressive collapse.
For DoD lease procurements, GSA applies the UFC standards to select the most appropriate lease facility, taking their customer requirements, which include security standards and cost, into consideration. As DoD secures leased facilities in the same manner as owned facilities, GSA implements the Unified Facilities Criteria for DoD leases, except in cases where DoD would occupy less than 25% of the facility.
Our understanding in working with DoD is that the UFC standards cannot be customized or waived. Every facility is regarded as a military installation, needing the same level of security and protection and must be compliant with DoD Antiterrorism standards. These unique customer requirements make the level of protection difficult to achieve in many leased facilities. As a result, competition of leased facilities is often reduced, which can increase costs. Additionally, these standards can impact the location of DoD’s facilities, contributing to locations outside of urban areas and without close proximity to public transportation.
That concludes my testimony. Thank you for inviting me to appear before you today, and I would be happy to answer any questions that you may have.