a

GAO

United States Government Accountability Office

Report to the Chairman, Committee on 

Government Reform, House of 

Representatives

June 2005 HOMELAND 

SECURITY

Actions Needed to 

Better Protect 

National Icons and 

Federal Office 

Buildings from 

Terrorism

GAO-05-790
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

www.gao.gov/cgi-bin/getrpt?GAO-05-790.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Mark Goldstein 

at (202) 512-2834 or GoldsteinM@gao.gov. 

Highlights of GAO-05-790, a report to the 

Chairman, Committee on Government 

Reform, House of Representatives 

June 2005

HOMELAND SECURITY

Actions Needed to Better Protect National 

Icons and Federal Office Buildings from 

Terrorism 

Interior faces a range of major challenges in protecting national icons and 

monuments from terrorism—these include balancing security and public 

access; addressing jurisdictional and competing stakeholder issues; and 

securing assets in rugged, remote areas. In addition, there was concern 

among Interior officials about the department’s ability to leverage limited 

resources for security. Since September 11, 2001, Interior has improved 

security at high-profile sites, created a central security office to oversee its 

security efforts, developed physical security plans required by Homeland 

Security Presidential Directive 7, and developed a uniform risk management 

and ranking methodology. As Interior moves forward, linking the results of 

its risk rankings to security funding priorities at national icons and 

monuments is an important next step. Also, given Interior’s complex and 

often contentious environment, setting forth the guiding principles by which 

the department balances its core mission with security could have benefits. 

Other organizations have used guiding principles to foster greater 

transparency in complex environments. 

GSA also faces a range of major challenges, some similar to Interior’s, that 

include balancing security and public access, addressing jurisdictional and 

competing stakeholder issues, securing federally leased space, and adjusting 

to the transfer of the Federal Protective Service (FPS) from GSA to the 

Department of Homeland Security (DHS). Actions GSA has taken to address 

the challenges include working to develop security standards for securing 

leased space and establishing a memorandum of agreement with DHS on 

security at GSA’s facilities. However, despite these actions, GSA lacks a 

mechanism—such as a chief security officer position or formal point of 

contact—that could serve in a liaison role with FPS and tenant agencies, 

work to address the challenges GSA faces related to security at its buildings, 

and enable GSA to better define its overall role in security given the transfer 

of FPS to DHS. 

Examples of Security Measures at National Icons and Federal Buildings 

The threat of terrorism has made 

physical security for federal real 

property assets a major concern. 

Protecting these assets can be 

particularly complex and 

contentious for agencies whose 

missions include ensuring public 

access such as the Department of 

the Interior (Interior) and the 

General Services Administration 

(GSA). GAO’s objectives were to 

(1) identify any challenges that 

Interior faces in protecting national 

icons and monuments from 

terrorism, as well as related actions 

intended to address these 

challenges; and similarly, (2) 

determine any challenges GSA 

faces related to the protection of 

federal office buildings it owns or 

leases and actions that have been 

taken. 

What GAO Recommends

GAO recommends that the 

Secretary of the Interior (1) link the 

results of its risk assessments and 

related risk rankings to its funding 

priorities and (2) develop guiding 

principles for balancing security 

initiatives with Interior’s core 

mission. Interior did not comment 

on our recommendations. GAO 

also recommends that the 

Administrator of GSA establish a 

mechanism—such as a chief 

security officer position or formal 

point of contact—so it is better 

equipped to address securityrelated matters related to its 

federal building portfolio. GSA 

concurred with the 

recommendation. 
Page i GAO-05-790 Homeland Security

Contents

Letter 1

Results in Brief 2

Background 5

Terrorist Threat Poses a Range of Challenges for Interior in 

Protecting National Icons and Monuments 7

The Threat Against Federal Office Buildings is Significant, and GSA 

Faces Various Challenges as the Owner and Landlord of These 

Assets 34

Conclusions 45

Recommendations for Executive Action 47

Agency Comments and Our Evaluation 47

Appendixes

Appendix I: Objectives, Scope, and Methodology 49

Appendix II: Comments from the General Services Administration 51

Appendix III: GAO Contact and Acknowledgments 52

Figures Figure 1: The Statue of Liberty in New York Harbor 9

Figure 2: Security Checkpoint for Liberty Island 10

Figure 3: Hoover Dam and Linked Boom Line Used to Enhance 

Perimeter Security 12

Figure 4: Security Checkpoint on the Arizona Side of Hoover 

Dam 13

Figure 5: Independence Hall in Philadelphia 15

Figure 6: Vehicle Traffic in Front of Independence Hall and Park 

Service Staff Allowing Visitors to Cross Chestnut Street 

17

Figure 7: Jersey Barriers and Fencing on the East Side of the 

Lincoln Memorial 19

Figure 8: Jersey Barriers and Snow Fencing at the Jefferson 

Memorial 21

Figure 9: Security Camera near the Amphitheatre at Mt. 

Rushmore 26

Figure 10: Rugged Terrain Surrounding Mt. Rushmore 27

Figure 11: Bollards in Front of a Federal Building in New York 38
Contents

Page ii GAO-05-790 Homeland Security

Abbreviations

BOR Bureau of Reclamation 

CFA U.S. Commission on Fine Arts

DHS Department of Homeland Security

EIS Environmental Impact Statement

FBI Federal Bureau of Investigation

FPS Federal Protective Service

FSRM Federal Security Risk Management

GSA General Services Administration

HSPD-7 Homeland Security Presidential Directive Number 7

ICE Immigrations and Customs Enforcement

IG Inspector General

IMBARC Independence Mall Business and Residents Coalition

Interior Department of the Interior

INHP Independence National Historical Park

ISC Interagency Security Committee

MOU Memorandum of Understanding

NCPC National Capital Planning Commission

NHPA National Historic Preservation Act

NPS National Park Service

NPCA National Parks Conservation Association

NYPD New York Police Department

OLES Office of Law Enforcement and Security

OMB Office of Management and Budget

Park Service National Park Service

Park Police U.S. Park Police

SEPTA Southeastern Pennsylvania Transportation Authority

SHPO State Historic Preservation Officer

SSA sector-specific agency

USMS U.S. Marshals Service

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately.
Page 1 GAO-05-790 Homeland Security

United States Government Accountability Office

Washington, D.C. 20548

A

June 24, 2005 Letr

The Honorable Tom Davis

Chairman, Committee on Government Reform

House of Representatives

Dear Mr. Chairman:

Since the 1995 bombing of the Alfred P. Murrah Federal Building in 

Oklahoma City and the September 11, 2001, attacks, federal agencies have 

devoted significant resources and attention to the physical security of their 

real property assets. Protecting federal real property assets can be 

particularly complex and contentious for agencies whose missions include 

ensuring public access to their assets, including the Department of the 

Interior (Interior) and the General Services Administration (GSA). Interior 

and its eight bureaus are charged with protecting the nation’s natural, 

historic, and cultural treasures, including thousands of facilities. GSA 

houses agencies in over 8,000 owned and leased facilities that contain 

roughly 338 million square feet. These facilities are used by over a million 

federal employees and contractors and are visited by citizens receiving 

services from, and conducting business with, the federal government. 

In November 2002, the Department of Homeland Security (DHS) was 

created to bring a central focus to the government’s efforts to prevent and 

respond to terrorist threats, including threats to its physical infrastructure. 

DHS, through its Federal Protective Service (FPS), is directly responsible 

for law enforcement and related security functions at GSA facilities and 

also provides policy leadership on facility protection issues to other 

agencies, including Interior. Although law enforcement and related security 

functions were transferred from GSA to DHS when FPS transferred to 

DHS, GSA officials said that it still assists FPS and tenant agencies with 

facility security, implements various security measures that FPS 

recommends, and incorporates enhanced security measures into new 

space it constructs or leases.

Our objectives were to (1) identify any challenges that Interior faces in 

protecting national icons and monuments from terrorism, as well as related 

actions intended to address these challenges; and similarly, (2) determine 

any challenges GSA faces related to the protection of office buildings it 

owns or leases and the actions that have been taken. To do this work, we 

interviewed officials from Interior, including officials at the department 

level, the National Park Service (Park Service), U.S. Park Police (Park 
Page 2 GAO-05-790 Homeland Security

Police), and the Bureau of Reclamation (BOR); GSA; and DHS, including 

FPS. We also interviewed other agencies and organizations that have an 

interest in security issues, including the National Capital Planning 

Commission and the National Parks Conservation Association. We also 

reviewed pertinent documents and policies that we obtained from these 

agencies and related laws and directives. Our work included visiting sites 

that Interior and GSA identified as particularly illustrative of the challenges 

they face and how they are trying to address them. Additional information 

about our methodology and the sites we visited, along with a complete 

description of the organizations we interviewed, appears at the end of this 

report. We conducted our work between January 2004 and March 2005 in 

accordance with generally accepted government auditing standards. 

Separately, we issued a “For Official Use Only” report detailing the results 

of our review. This version of the report, for public release, provides a 

general summary of the challenges identified and our recommendations to 

help Interior and GSA enhance their protection of national icons and 

federal office buildings from terrorism. (The “For Official Use Only” report 

provided technical details to assist Interior and GSA in their efforts.)

Results in Brief Interior faces a range of major challenges in protecting national icons and 

monuments from terrorism. First, there is an inherent conflict between 

physical security initiatives and Interior’s mission to provide access to, and 

education about, the nation’s natural and cultural heritage. Striking a 

balance between protecting its assets from terrorism and maintaining 

public access is a new role for Interior, which has historically focused 

mainly on its preservation and education mission. Second, jurisdictional 

issues and competing stakeholder interests are another challenge. Pursuing 

security improvements that Interior believes are needed often puts the 

department at odds with other entities—such as planning commissions, 

private foundations, and local governments—that have jurisdiction over, or 

input regarding, physical enhancements. Third, some icons and 

monuments are in rugged, remote locations and, therefore, pose additional 

challenges related to securing perimeters and ensuring an adequate 

response in the event of an attack. Lastly, leveraging limited resources is an 

ongoing challenge. Interior officials responsible for security at the 

individual icons and monuments were concerned about whether the 

department will have a sustained level of staff and funding resources for 

security initiatives. Effectively addressing these challenges is vital for 

Interior because highly visible assets such as the Washington Monument 

and Mt. Rushmore National Memorial (Mt. Rushmore) could be targeted for 
Page 3 GAO-05-790 Homeland Security

symbolic reasons and for the purpose of harming people. Information from 

Interior shows that these and other assets are vulnerable to attack in a 

variety of ways. 

In addition to security improvements Interior has made at individual 

locations, several broader actions have been taken that are intended to 

address the department’s challenges and improve its security program 

overall. These security improvements are as follows: 

• The administration has identified goals for overcoming challenges and 

vulnerabilities unique to national icons and monuments as part of its 

national strategy for homeland security.

• Interior has developed physical security plans in response to Homeland 

Security Presidential Directive 7 (HSPD-7). This directive establishes a 

national policy for prioritizing the protection of critical infrastructure 

and requires all departments and agencies to develop physical and cyber 

security plans for the assets they own. In addition, the directive 

designates Interior as a sector-specific agency (SSA) for the national 

icons and monuments sector—SSAs are responsible for coordinating 

protection in their respective sectors across all levels of government 

and the private sector.

• To centrally manage Interior’s security initiatives and address its 

challenges, the department established a central coordination and 

oversight office for homeland security-related activities. This office—

the Office of Law Enforcement and Security (OLES)—has worked 

within Interior to identify assets that are likely targets, conduct risk 

assessments using a number of external experts, and coordinate efforts 

by Interior’s bureaus to enhance security at individual locations. 

• Interior has developed a uniform risk assessment methodology that it 

has used to generate risk rankings for high-profile national icons and 

monuments.

Overall, these efforts have been positive steps. As Interior moves forward, 

linking the results of its risk assessments and related risk rankings to 

security funding priorities at national icons and monuments is an important 

next step that we are recommending. This should allow for well-informed 

decisions by stakeholders—such as Interior, OMB, and Congress—about 

where to direct resources so that they have an optimal return on 

investment in terms of better protection. Furthermore, given Interior’s 
Page 4 GAO-05-790 Homeland Security

complex and often contentious environment, setting forth the guiding 

principles by which the department balances its core mission with 

security—which we are also recommending—could have benefits. Guiding 

principles have been used by other organizations to foster greater 

transparency and thus allow stakeholders to better understand the basis 

for decisions. By identifying and conveying the principles it follows for 

making security-related decisions, Interior could be better positioned to 

achieve additional transparency and more mutually acceptable outcomes 

with its stakeholders. Interior did not comment on our recommendations.

GSA also faces a range of major challenges—some similar to those facing 

Interior—related to security at buildings it owns or leases. First, federal 

buildings are where the government and the public transact business, and 

striking a balance between security and public access is an ongoing 

challenge. This challenge is of particular concern with federally leased 

space, where the government does not have complete control over building 

access. Second, GSA faces challenges in addressing jurisdictional and 

competing stakeholder interests, particularly in urban areas where local 

governments and others have a role in the type of security that is employed. 

Finally, the transfer of FPS to DHS has presented a major challenge for 

GSA. In addition to no longer having direct control over security services in 

its buildings, GSA officials were concerned about their ability to track 

security expenditures and stay informed about FPS protection activities in 

GSA buildings. In general, GSA officials said that GSA is still trying to 

define its overall role in security given the transfer of FPS. Addressing 

these challenges is critical because the terrorist threat against federal 

office buildings is significant. The Oklahoma City bombing and September 

11 attacks demonstrated that terrorists possess the capabilities to destroy 

these types of assets. In the post-September 11 era, warnings from DHS 

have shown that there is still a concern regarding the threat that terrorists 

will use methods such as truck bombs to destroy office buildings. GSA 

owns many federal office buildings, on which an attack could seriously 

disrupt the business of government and harm federal employees and the 

public. 

To address the challenges associated with protecting federal office 

buildings, a number of actions have been taken. GSA has continued with 

the implementation of security enhancements to buildings in its inventory 

that it began after the Oklahoma City bombing—these enhancements are 

designed, in part, to achieve a balance between security and access. GSA 

has worked with the Interagency Security Committee (ISC) to develop 

security design criteria for newly constructed office buildings and security 
Page 5 GAO-05-790 Homeland Security

standards for addressing challenges associated with federally leased space. 

Established after the Oklahoma City bombing, ISC has a range of 

governmentwide responsibilities related to protecting nonmilitary facilities 

and has representation from all the major property-holding agencies. The 

administration has also identified the challenge of protecting federal office 

buildings as a top priority in the critical infrastructure area. In addition, ISC 

is responsible for coordinating agencies’ building security efforts. The 

transfer of FPS to DHS—though a challenge for GSA—was intended to 

improve law enforcement and related functions by centralizing building 

security activities with other homeland security functions. A March 2003 

operational memorandum of agreement between GSA and DHS made FPS 

responsible for the same types of security services that FPS provided for 

GSA properties prior to the transfer to DHS. These include performing risk 

assessments, managing the installation of some security equipment, 

conducting criminal investigations, and managing the contract guard 

program. These actions are all steps in the right direction. However, despite 

the range of challenges GSA faces, it lacks a mechanism—such as a chief 

security officer position or formal point of contact—to coordinate 

homeland security efforts at its buildings with FPS and tenant agencies. 

The officer/official in such a position, which we are recommending, could 

serve in a liaison role with FPS and tenant agencies, work to address the 

challenges GSA faces related to security in buildings it owns and leases, 

and enable GSA to better define its overall role in security given the 

transfer of FPS to DHS. Having such a position is recognized in the security 

community as essential in organizations that own and operate large 

numbers of mission-critical facilities. GSA concurred with this 

recommendation.

Background Interior is responsible for the safety of 70,000 employees and 200,000 

volunteers, 1.3 million daily visitors, and over 507 million acres of public 

lands that include a number of sites of historical or national significance 

(national monuments and icons), and the security of dams and reservoirs. 

The Park Service’s mission is the unimpaired preservation of the natural 

and cultural resources and values of the national park system for the 

enjoyment, education, and inspiration of current and future generations. 

According to Interior officials, the Park Service cooperates with various 

partners to extend the benefits of natural and cultural resource 

conservation and outdoor recreation throughout this country and the 

world. Within Interior, the Park Service is responsible for managing and 

protecting some of the nation’s most treasured icons, including the 

Washington Monument, the Lincoln and Jefferson Memorials, the Statue of 
Page 6 GAO-05-790 Homeland Security

Liberty, Independence Hall and the Liberty Bell in Philadelphia, and Mt. 

Rushmore in South Dakota. The Park Service welcomes 428 million visitors 

to its 388 national park units each year throughout the United States, 

American Samoa, Guam, Puerto Rico, and the Virgin Islands. 

The Park Police provides security and law enforcement services to Park 

Service monuments and memorials in the District of Columbia, New York 

City, and in conjunction with Park Service rangers in San Francisco. Park 

superintendents and rangers manage and provide security and law 

enforcement services at the other parks throughout the United States in 

conjunction with their other duties. These other duties include 

management of public use, dissemination of scientific and historical 

information, and protection and management of natural and cultural 

resources. 

Among Interior’s other bureaus, BOR has an important role in protecting 

critical infrastructure because of its responsibilities related to dams. BOR’s 

core mission is to manage, develop, and protect water and related 

resources in an environmentally and economically sound manner. It is the 

largest wholesale water supplier in the nation, delivering 10 trillion gallons 

of water to over 30 million people each year. According to information from 

BOR, it manages 471 dams, making it the nation’s second largest producer 

of hydropower; the dams generate approximately 42 billion kilowatt hours 

each year. BOR, among other things, is responsible for managing and 

protecting well-known assets, such as Hoover Dam in Arizona and Nevada.

While Interior is responsible for protecting icons, monuments, and dams, 

GSA serves as the federal government’s landlord and designs, builds, and 

manages facilities to support the needs of other federal agencies 

throughout all three branches of government. GSA is responsible for 

managing over 8,000 owned and leased buildings that comprise roughly 3 

billion square feet of building floor area. FPS was created in 1971 to 

provide security services and law enforcement to GSA-owned facilities 

across the United States. FPS has the authority to, among other things; 

enforce laws and regulations that protect federal property, and persons on 

such property, and conduct investigations. As a result of the Homeland 

Security Act, 22 agencies—including FPS—were centralized under DHS, 

and FPS retained its role related to law enforcement and security at GSA 

buildings. In accordance with the act, the transfer of FPS from GSA to DHS 

became effective on March 1, 2003. GSA officials said that GSA still assists 

FPS and tenant agencies with facility security, implements various security 

measures that FPS recommends, and incorporates enhanced security 
Page 7 GAO-05-790 Homeland Security

measures into new space it constructs or leases. Within DHS, FPS fell 

under the authority of the Immigration and Customs Enforcement (ICE), 

which, according to DHS, is its largest investigative arm. DHS also chairs 

ISC, which has representation from all the major property-holding agencies 

and was established after the Oklahoma City bombing. ISC has a range of 

governmentwide responsibilities related to protecting nonmilitary 

facilities. In July 2004, we reported on issues related to the transfer of FPS 

from GSA to DHS; and in November 2004, we reported on progress ISC has 

made and key practices in facility protection.1

Terrorist Threat Poses 

a Range of Challenges 

for Interior in 

Protecting National 

Icons and Monuments 

The September 11 attacks demonstrated the nation’s vulnerability to the 

threat posed by formidable, well-organized terrorists. As evidenced by the 

attacks, the terrorists are sophisticated, relentless, and patient in their 

planning and execution. This new type of threat represents a shift from 

historical assumptions about national security, where the military, foreign 

policy establishment, and intelligence community are responsible for 

protecting the nation, to a new paradigm where others—such as Interior, 

state and local governments, and the private sector—also have a role in 

homeland security. National icons and monuments represent the nation’s 

heritage, tradition, values, and political power. Among Interior assets that 

could logically be categorized as potential symbolic targets are national 

icons and monuments such as Mt. Rushmore and the Washington 

Monument. Destroying these icons would likely have a profound effect on 

the nation’s morale. In addition, Interior’s portfolio includes assets that are 

part of the nation’s critical infrastructure, such as the 471 dams it operates 

that provide hydropower to Western states. Information from Interior 

shows that these assets are vulnerable to attack in a variety of ways and 

that Interior faces a range of challenges to improving protection. These 

challenges include the inherent conflict between security and public 

access, jurisdictional issues and competing stakeholder issues regarding 

such matters as access and oversight of enhancements, the effect that the 

rugged and remote location of some assets has on perimeter security, and 

the ability to leverage available resources to address vulnerabilities by 

implementing security enhancements. 

1

GAO, Homeland Security: Transformation Strategy Needed to Address Challenges Facing 

the Federal Protective Service, GAO-04-537 (Washington, D.C.: July 14, 2004); GAO, 

Homeland Security: Further Actions Needed to Coordinate Federal Agencies’ Facility 

Protection Efforts and Promote Key Practices, GAO-05-49 (Washington, D.C.: Nov. 30, 

2004).
Page 8 GAO-05-790 Homeland Security

Balancing Security with 

Public Access at Icons and 

Monuments Is a Major 

Challenge

Interior officials and staff at the icons and monuments we visited 

acknowledged, and the Interior Inspector General (IG) has reported, that 

balancing security with access is a major challenge facing the department. 

Implementing appropriate physical protection measures can be a challenge 

because such measures often run counter to societal values that associate 

access to icons and monuments with living in a free society. And, the core 

missions of some of the Interior’s agencies—including the Park Service—

reflect a high level of public accessibility and interaction. As reported by 

the Interior IG and discussed by Interior officials we interviewed, the 

organizational challenge of shifting to a homeland security focus in a 

culture rooted in preservation and education is also significant.2

 Overall, 

the challenge of balancing protection against terrorism with public access 

is formidable and transcends other challenges Interior faces, including 

jurisdictional issues and competing stakeholder interests.

Security versus Access: The 

Statue of Liberty

The Park Service’s efforts to balance security with access at the Statue of 

Liberty demonstrate this challenge. The Statue of Liberty is one of the 

nation’s most treasured sites and is an international symbol of American 

values. Located on 12-acre Liberty Island in New York Harbor, the Statue of 

Liberty was a gift of international friendship from the people of France to 

the people of the United States and is one of the most universal symbols of 

political freedom and democracy. It is a popular tourist attraction for 

visitors from around the world. In fiscal year 2003, over 3.2 million people 

visited the Statue. Park Service management of the Statue of Liberty and 

Liberty Island also includes Ellis Island and its facilities. The Statue 

consists of three sections: the Statue, the pedestal, and a base known as 

Fort Wood. The Park Service and Park Police oversee the monument’s 

security program, including operation of screening facilities housed at 

Battery Park in Lower Manhattan in New York and Liberty State Park in 

New Jersey. Park Service and Park Police officials consider these locations, 

plus Governor’s Island, part of a 5-point security perimeter that they 

monitor within New York Harbor. Figure 1 shows the Statue of Liberty, 

which is surrounded by New York Harbor.

2

U.S. Department of the Interior, Office of the Inspector General, Review of National Icon 

Park Security, Report 2003-I-0063 (Washington, D.C.: August 2003).
Page 9 GAO-05-790 Homeland Security

Figure 1: The Statue of Liberty in New York Harbor

Due to concerns about additional terrorist attacks, the Park Service closed 

Liberty Island and the Statue of Liberty immediately following September 

11. The Park Service reopened Liberty Island in December 2001 but 

refrained from allowing access to the Statue until additional security and 

fire safety assessments could be done. These assessments identified a 

number of steps that needed to be taken before visitors could be allowed 

back into the Statue. In addition, the primary threats included aerial attacks 

and explosives detonated inside the structure. 

In August 2004, the Park Service reopened the Statue to visitors with 

access restricted to the top of the pedestal and the exterior observation 

deck. The security improvements were primarily aimed at preventing 

would-be terrorists from gaining access to the interior of the Statue and its 

grounds. Under this revised plan, visitors are able to tour the Statue of 

Liberty Museum, see close-up views of the statue from the promenade, 

view the inside structural elements of the statue, and experience a 360-

Source: GAO.
Page 10 GAO-05-790 Homeland Security

degree panoramic view of New York Harbor from the observation deck. In 

addition, the Park Service and Park Police implemented other 

improvements, including more rigorous visitor screening, better explosive 

detection capabilities, improved fire safety, and enhanced communications. 

Park Service officials also noted that new barriers were installed at the 

Ellis Island service bridge and that Park Service and Park Police staffing 

has been increased since September 11 to implement the improved security 

plan. The Park Service reported in mid-2004 that, to make these 

improvements, it had invested $19.6 million and was anticipating an 

additional $9 million in future spending. In addition, the Park Service 

reported that the Statue of Liberty-Ellis Island Foundation, which is a 

consortium of private donors, had partnered with the Park Service to assist 

with funding a number of the safety improvements. Figure 2 shows the 

security checkpoint for Liberty Island.

Figure 2: Security Checkpoint for Liberty Island 

Source: GAO.
Page 11 GAO-05-790 Homeland Security

According to Park Service officials, the issue of public access to the Statue 

received high visibility and publicity while a new security plan was being 

developed. Some of the editorial press from this time expressed a concern 

that by closing the Statue, it had “ceded to al Qaeda.” The Mayor of New 

York was quoted in a newspaper saying that as long as the Statue is closed, 

“in some sense, the terrorists have won.” Interior and Park Service officials 

said that it was difficult to communicate the rationale for initially 

prohibiting, then later limiting, public access to the Statue without 

revealing the specific vulnerabilities that led to their decisions. A major 

reason for limiting access to the Statue was the need to adhere to building 

codes related to fire safety. For example, the Statue did not meet standards 

for exits and fire suppression capability. However, Interior and Park 

Service officials were also concerned with the security vulnerabilities of 

the Statue and the fact that knowledge of these vulnerabilities could make 

the Statue an even more attractive target. Although many security 

improvements have been implemented at the Statue of Liberty National 

Monument and Ellis Island, Park Service officials noted that several key 

security challenges remain. 

Security versus Access: Hoover 

Dam 

Hoover Dam in Nevada and Arizona is another icon that presents Interior 

with challenges related to public access. Located approximately 38 miles 

southeast of Las Vegas, Hoover Dam is a national, historical, hydrological, 

and structural icon that is part of the nation’s critical infrastructure. 

Managed by BOR, it receives approximately 1 million paid visitors every 

year and provides water and electricity for millions of people throughout 

the Southwest. Its 4.4 million cubic yards of concrete is recognized as a 

marvel of civil engineering. In addition, nearly 9 million people visit 

adjacent Lake Mead every year, which is the nation’s largest man-made lake 

and is a national recreational area managed by the Park Service. Hoover 

generates electricity for southwestern states through its 17 turbines using 

water from Lake Mead. Also, Interstate 93 sits on top of the dam, serving as 

the region’s main vehicular route across the Colorado River. 

According to BOR officials, following the terrorist attacks of September 11, 

BOR implemented a range of security enhancements, such as hiring 

additional security officers and guards and revising and canceling some 

public tours. In addition, BOR is taking steps to provide a long-term 

solution for its biggest security concern to visitors—the proximity of 

Interstate 93 to large crowds of visitors who also have access to the top of 

the dam. Related to security staffing, BOR nearly doubled the number of 

federal police officers and added new contract security guards. To help 

control the flow of tourists and provide additional security, BOR added 
Page 12 GAO-05-790 Homeland Security

access doors, and contract guards to certain areas of the visitor center. 

BOR also improved security at the visitor center by adding blast-resistant 

films to the windows. In addition, BOR improved gates and fencing in some 

areas surrounding the dam to improve perimeter security. BOR also 

installed a series of buoys and linked “boom lines” to serve as a security 

perimeter at water access points. Figure 3 shows the dam and a linked 

boom line in the water.

Figure 3: Hoover Dam and Linked Boom Line Used to Enhance Perimeter Security

To further secure the dam’s perimeter, BOR created two traffic security 

checkpoints, one in Arizona and one in Nevada, to screen and inspect 

passenger vehicles crossing the dam. Figure 4 shows a security checkpoint 

on the Arizona side of the dam.

Source: GAO.
Page 13 GAO-05-790 Homeland Security

Figure 4: Security Checkpoint on the Arizona Side of Hoover Dam

Since September 11, BOR also made other changes to its security 

operations, including performing additional background checks on 

contractor personnel, obtaining security clearances for office directors and 

key personnel, conducting various site security inspections, initiating boat 

patrols on Lake Mead, contracting for the design of a new integrated 

security system, and installing additional surveillance cameras to monitor 

traffic checkpoints and other parts of the dam and visitor areas. To address 

one security concern as far as visitors are concerned—public access to the 

top of the dam due to the proximity to Interstate 93—BOR is currently 

working with Arizona, Nevada, the Federal Highway Administration, and 

others to construct a new four-lane bridge across the Colorado River 

approximately 1,500 feet from the dam. This bridge and additional 

roadways would re-route Interstate 93 off of the dam and improve traffic 

flow for the thousands of trucks and vehicles that use this road daily and 

reduce security vulnerabilities for the dam and its visitors. The cost of the 

project is currently estimated at $234 million, with funding coming through 

Source: GAO.
Page 14 GAO-05-790 Homeland Security

a combination of federal and state sources. Construction has already begun 

on new highways that approach the bridge, and the project is currently 

scheduled to be completed in 2008. Nonetheless, although it appears that 

BOR has taken the necessary steps to address the security concern with the 

highway, ensuring adequate security while allowing vehicle access will 

remain a unique and significant challenge for the next few years.

Addressing Jurisdictional 

Issues and Competing 

Stakeholder Interests Is 

Another Challenge for 

Interior

Complicating its efforts to balance security and access, balancing 

jurisdictional issues and competing stakeholder interests represents 

another challenge facing Interior. Pursuing security improvements that 

Interior believes are needed often puts the department at odds with other 

entities—such as planning commissions, private foundations, and local 

governments—that have jurisdiction over, or input regarding, physical 

security enhancements. For example, efforts to secure the perimeter of a 

national monument or icon in an urban setting by closing streets and/or 

alleyways can be prevented by local governments. Similarly, local planning 

commissions and other oversight groups can prevent the placement of 

various protective measures because of aesthetic concerns and other 

considerations, such as perceived loss of revenue. According to 

information from Interior, limiting the types of measures it can employ can 

lead to delays in enhancing security and the use of potentially more costly 

and/or less effective alternatives.

Jurisdictional and Competing 

Stakeholder Issues: 

Independence National 

Historical Park in Philadelphia

One location that illustrates the major challenges Interior faces related to 

jurisdictional issues and competing stakeholder interests is Independence 

National Historical Park (INHP) in Philadelphia, Pennsylvania. INHP is an 

open, national park space in the center of a densely populated urban area. 

Spanning approximately 45 acres, the park has about 20 buildings open to 

the public, including Independence Hall (site of the signing of the 

Declaration of Independence) and the Liberty Bell Center. Additionally, 

INHP houses multiple historically irreplaceable buildings and documents, 

including Carpenter’s Hall (site of the first Continental Congress), Congress 

Hall, and an original copy of the Declaration of Independence. Figure 5 

shows a security sign near Independence Hall, where the Declaration of 

Independence and U.S. Constitution were created.
Page 15 GAO-05-790 Homeland Security

Figure 5: Independence Hall in Philadelphia

Due to its urban location, oversight responsibility at INHP involves several 

stakeholders. The Park Service and the city of Philadelphia have a 

memorandum of understanding (MOU) regarding emergency response 

responsibilities and other jurisdictional issues. Public city streets that carry 

both pedestrian and vehicular traffic surround the park and its buildings. 

Source: GAO.
Page 16 GAO-05-790 Homeland Security

According to Interior officials, the park is surrounded by local businesses 

that, along with city officials, are consulted regarding any change in park 

operations. Complicating oversight, the Park Service owns the land that 

covers the three blocks known as Independence Mall, and the city of 

Philadelphia owns the Independence Hall building and the Liberty Bell. The 

city and the Park Service operate under a cooperative agreement for the 

management and operation of Independence Mall. Also, the focus on 

security in this area of Philadelphia is further heightened because of the 

presence of other federal assets. Within a few block radius of INHP are 

multiple federal buildings, including the U.S. Mint, the Federal Reserve 

Bank of Philadelphia, and a federal courthouse that houses the U.S. District 

Court for the Eastern District of Pennsylvania. 

Park Service officials reported that prior to September 11, INHP managed 

its law enforcement and security operation consistently with the majority 

of urban parks across the nation. After the Oklahoma City bombing, a blast 

assessment focused primarily on Independence Hall was conducted and 

influenced the design of the new Liberty Bell Center. Aside from this 

assessment, no comprehensive risk assessment had been completed that 

addressed overall threat potential. Following September 11, the Park 

Service decided to keep the park open but added staff patrols from parks 

around the country to support INHP staff for approximately 6 to 9 months. 

A perimeter consisting of temporary fencing and concrete jersey barriers 

was also placed around the two city blocks containing the Liberty Bell and 

Independence Hall and, with the approval of city officials, Chestnut Street 

was closed on December 12, 2001. With these security improvements, staff 

coverage was roughly doubled, but the Park Service had to have rangers 

work overtime to allow for 24-hour coverage. The Park Service also 

implemented security measures that included the use of magnetometers 

and individual hand searches conducted at Liberty Bell Center and 

Independence Hall. 

After September 11, the Park Service also contracted with a private firm to 

conduct a threat assessment, which used a pre-existing blast assessment. 

Park Service officials added that the blast assessment, however, was too 

narrowly focused, and the lack of a comprehensive assessment of threats 

and vulnerabilities limited their ability to identify the full range of security 

measures that were needed to fully protect the park. In early 2005, an 

Interior security official told us that a comprehensive assessment 

conducted in compliance with HSPD-7 had been completed, and Interior 

officials are evaluating this assessment to determine additional security 

enhancements.
Page 17 GAO-05-790 Homeland Security

Interior officials told us that jurisdictional issues at INHP and the political 

sensitivity of related disagreements have been the greatest challenges in 

terms of implementing security enhancements since September 11. These 

officials said that although there is a standing operational agreement 

between the Park Service and the city of Philadelphia, there is no current 

MOU regarding law enforcement and security. INHP security officials 

stated that their ability to effectively secure the park is limited by a lack of 

authority over Chestnut Street and consensus among stakeholders as to 

how to provide the best protection. This challenge is evidenced most 

clearly by the ongoing disagreement between INHP and the city of 

Philadelphia over the closure of Chestnut Street, the street that carries 

both pedestrian and vehicular traffic between Independence Hall and the 

Liberty Bell Center. INHP officials said that the city reopened Chestnut 

Street on April 1, 2003, after local residents and business owners made the 

case to the city that the closure would have an adverse impact on business. 

Chestnut Street currently remains open to pedestrians and traffic with the 

use of a controlled pedestrian intersection at Sixth and Chestnut Streets 

managed by Park Service security staff and contract guards to monitor 

park visitors transiting from the Liberty Bell Center to Independence Hall. 

Figure 6 shows traffic in front of Independence Hall and park rangers 

allowing screened visitors to cross Chestnut Street. 

Figure 6: Vehicle Traffic in Front of Independence Hall and Park Service Staff 

Allowing Visitors to Cross Chestnut Street 

In addition to addressing jurisdictional issues related to differences with 

the city, Park Service officials at INHP said that their views on what 

security measures are needed often put them directly at odds with local 

Source: GAO.
Page 18 GAO-05-790 Homeland Security

stakeholder groups and business owners, specifically the Independence 

Mall Business and Residents Coalition (IMBARC). IMBARC was created for 

the purpose of challenging the closure of Chestnut Street. IMBARC’s 

chairman told us that IMBARC members are united in their belief that the 

security measures implemented at INHP since September 11 are excessive 

and aesthetically unappealing. In addition, potential street closures 

surrounding Independence Mall also affect the Southeastern Pennsylvania 

Transportation Authority (SEPTA), the regional transit provider. Chestnut 

and Sixth Street are considered thoroughfares through the city’s 

downtown, and Park Service officials said that major changes to the traffic 

patterns would likely meet additional resistance. We did not evaluate the 

competing views of the Park Service, the city of Philadelphia, or IMBARC 

regarding the Park Service’s security efforts at INHP. Nonetheless, the 

situation the Park Service faces at this park illustrates the complex and 

often differing jurisdictional and competing stakeholder views that Interior 

faces related to security in the post-September 11 era.

Jurisdictional and Competing 

Stakeholder Issues: Monuments 

on the National Mall in 

Washington, D.C.

Other national icons where Interior faces jurisdictional and competing 

stakeholder challenges are the monuments on the National Mall (the Mall) 

in Washington, D.C. In particular, Interior has responsibility for several 

major monuments on or near the Mall—including the Washington 

Monument; the Lincoln, Jefferson, and Roosevelt Memorials; and the World 

War II, Korean War, and Vietnam War Memorials. The Park Police provides 

protection for these monuments and icons. 

Prior to September 11, there was a concern that monuments and icons on 

or near the Mall could be the focus of a terrorist attack. According to 

Interior officials, after September 11, Interior worked with a private 

security firm to assess the risk of terrorist attacks at Mall monuments. This 

assessment examined potential threats and alternate methods of both 

prevention and protection. Additionally, the Park Service identified specific 

protection criteria and designated key areas with the highest vulnerability 

as priority status for increased security. According to Interior and Park 

Service officials, they have used the report’s findings to determine where to 

allocate appropriated funds and implement security upgrades for high-risk 

structures.

The Park Service has pursued a number of security enhancements to the 

Washington Monument and Lincoln and Jefferson Memorials, which were 

the focus of our review. Construction is currently under way on a 

landscape security solution for the grounds of the Washington Monument. 

When construction is complete, a 30-inch-high granite retaining wall along 
Page 19 GAO-05-790 Homeland Security

newly constructed pedestrian pathways will surround the monument. The 

wall will serve as a vehicle barrier while also providing visitor seating. In 

addition, the monument grounds will receive nearly 800 new shade and 

flowering trees, upgraded lighting, and granite paving on the plaza. The 

Park Service closed the monument to the public in September 2004 to 

complete the final phase of the security enhancement project and reopened 

it on April 1, 2005. At the Lincoln Memorial, the Park Service plans to 

construct a 35-inch-high granite retaining wall at the edge of the roadway 

around the north, west, and south sides of Lincoln Memorial Circle, and 

install retractable bollards for a portion of the circle that does not handle 

everyday traffic. The Park Service is also developing an alternative to a 715-

foot line of jersey barriers on the memorial’s east side, facing the Mall. 

Figure 7 shows the temporary jersey barriers and fencing on the east side 

of the memorial.

Figure 7: Jersey Barriers and Fencing on the East Side of the Lincoln Memorial

Source: GAO.
Page 20 GAO-05-790 Homeland Security

For the Jefferson Memorial, the Park Service has proposed the 

construction of a security barrier, closure of a U-shaped driveway next to 

the monument to create a pedestrian plaza, and creation of additional 

parking away from the monument to improve security by limiting vehicular 

access. The Park Service’s proposal includes the elimination of parking 

adjacent to the monument. According to the Park Service’s environmental 

assessment of various options, the options under consideration would have 

adverse impacts on historic structures and the cultural landscape because 

the proposed security barrier would introduce a new element within the 

historic scene. However, the Park Service also said that the historic 

structures, cultural landscape, and aesthetic and visual quality would 

benefit due to the removal of the existing security measures that currently 

compromise the views, vistas, and historic scene. According to the Park 

Service, safety and security would be improved because the barrier would 

provide a first line of defense from the potential threat of a vehicle bomb 

and would serve as a deterrent to terrorists. Figure 8 shows a jersey barrier 

and temporary snow fencing at the memorial. According to Park Service 

officials, the snow fencing is used to control pedestrian flow to and from 

the memorial.
Page 21 GAO-05-790 Homeland Security

Figure 8: Jersey Barriers and Snow Fencing at the Jefferson Memorial

In addition to these improvements at the monuments, the Park Service has 

upgraded its security camera capabilities in and around the Mall. The 

camera system began its initial test run in July 2002 and was fully 

operational by the fall of 2002. Park Service officials reported that the 

system consists of cameras mounted in and around the Mall that digitally 

record footage. It is designed for redundancy; if one camera fails, another 

camera could quickly cover the same area. Park Service officials stated that 

in the near future, they would like to expand coverage and progressively 

Source: GAO.
Page 22 GAO-05-790 Homeland Security

upgrade the camera system. Since September 11, Interior has also 

established internal security protocols directly tied to the Homeland 

Security Advisory System.3

In implementing security enhancements, several entities have an oversight, 

advisory, or advocacy role for the monuments on the National Mall and 

have an interest in security enhancements at the monuments. These 

entities include the National Capital Planning Commission (NCPC), 

Advisory Council on Historic Preservation (Advisory Council), the U.S. 

Commission on Fine Arts (CFA), and the District of Columbia’s State 

Historic Preservation Officer (SHPO). In addition, advocacy groups, 

including the National Coalition to Save Our Mall and the National Parks 

Conservation Association (NPCA), are involved in, and offer their views on, 

security enhancements to the monuments. The roles of the major entities 

and organizations are as follows:

• NCPC (www.ncpc.gov) is the central planning agency for the federal 

and District of Columbia governments in the national capital. 

Established in 1924 as the National Capital Park Commission and later 

renamed, NCPC’s responsibilities include conducting comprehensive 

planning to direct federal activities and protect federal interests, 

reviewing and approving all federal development projects in the city and 

outlying region, leading specific initiatives to enhance the region, and 

preparing an annual Federal Capital Improvements Program. NCPC is 

composed of three presidential appointees, two D.C. mayoral 

appointees, the Secretaries of Defense and the Interior, the Chairmen of 

the Senate Committee on Homeland Security and Governmental Affairs 

and House Committee on Government Reform, the Administrator of 

GSA, the Mayor of the District of Columbia, and the Chairman of the 

D.C. City Council.

• The Advisory Council (www.achp.gov) is an independent federal agency 

that promotes the preservation, enhancement, and productive use of the 

nation’s historic resources and advises the president and Congress on 

national historic preservation policy. The National Historic Preservation 

Act (NHPA) established the Advisory Council in 1966. According to the 

3

As we reported in GAO, Homeland Security: Communication Protocols and Risk 

Communication Principles Can Assist in Refining the Advisory System, GAO-04-682

(Washington, D.C.: June 2004), the Homeland Security Advisory System is composed of five 

color-coded threat conditions, which represent levels of risk related to potential terror 

attack. Red is severe, orange high, yellow elevated, blue guarded, and green low.
Page 23 GAO-05-790 Homeland Security

Advisory Council, it seeks to have federal agencies act as responsible 

stewards of our nation's resources when their actions affect historic 

properties. The Advisory Council recommends administrative and 

legislative improvements for protecting the nation’s heritage; advocates 

full consideration of historic values in federal decision making; and 

reviews federal programs and policies to promote effectiveness, 

coordination, and consistency with national preservation policies.

• CFA (www.cfa.gov) was established by Congress in 1910 as an 

independent agency to advise the federal and District of Columbia 

governments on matters of art and architecture that affect the 

appearance of the nation's capital. CFA’s primary role is to advise on 

proposed public building projects, but it also reviews private buildings 

adjacent to important public buildings and grounds.

• NHPA provides for the designation of a SHPO in each state. SHPOs have 

duties that include locating and recording historic resources; 

nominating significant historic resources to the National Register of 

Historic Places; fostering historic preservation programs at the local 

government level; reviewing all federal projects for their impact on 

historic properties in accordance with Section 106 of NHPA; and 

providing technical assistance on rehabilitation projects and other 

preservation activities to federal agencies, state and local governments, 

and the private sector.

• The National Coalition to Save Our Mall (www.savethemall.org) was 

founded in 2000 as a coalition of professional and civic organizations 

and other concerned artists, historians, and citizens to provide a 

national constituency dedicated to the protection and preservation of 

the National Mall in Washington, D.C. According to the Coalition’s Web 

site, its mission is to 

“defend our national gathering place and symbol of Constitutional principles against threats 

posed by recent and ongoing proposals—for new memorials, security barriers, service 

buildings and roads—that would encroach on the Mall's historical and cultural integrity, its 

open spaces and sweeping vistas, and its significance in American public life.”

• NCPA (www.ncpa.org) is an advocacy organization whose mission is to 

protect and enhance the National Park System for present and future 

generations. According to its Web site, NCPA has been in existence for 

85 years and has 300,000 members. NCPA’s objectives are to advocate 

for the national parks and the Park Service, educate decision makers 

and the public about the importance of preserving the parks, help to 
Page 24 GAO-05-790 Homeland Security

convince Members of Congress to uphold the laws that protect the 

parks and support of new legislation to address threats to the parks, 

fight attempts to weaken these laws in the courts, and assess the health 

of the parks and park management to better inform its advocacy work. 

Interior and Park Service officials said that implementing security 

measures can be particularly challenging at monuments on the Mall in 

Washington, D.C., because of the number of entities and organizations that 

have jurisdictional, advisory, or advocacy roles regarding changes. These 

officials said that in gaining the approval for projects from NCPC and 

incorporating the views of the other organizations, the Park Service tries to 

strike a balance among the various stakeholders and build consensus. For 

example, in an effort to streamline the process for gaining approval and 

input for enhancements at the Washington Monument, the Park Service, 

NCPC, ACHP, and the D.C. SHPO established a streamlined review process 

in 2002 that allows for public participation. However, Interior and Park 

Service officials acknowledged that there is often disagreement over how 

to balance security with public access and aesthetic beauty. For example, 

as part of its plans for security enhancements at the Washington 

Monument, the Park Service gained approval from the NCPC in April 2003 

to build an underground visitor screening area and tunnel that would lead 

to the basement of the monument. However, after meeting significant 

resistance from NCPA, the Save Our Mall Coalition, and other interested 

stakeholders, a senior Park Service official told us that the Park Service 

abandoned this concept in the interest of maintaining support for security 

enhancements. Due to the high visibility that security enhancements at 

Mall monuments receive, Interior officials said that addressing 

jurisdictional issues and competing stakeholder interests on the Mall will 

remain their biggest challenge.

Remote Location of Some 

Interior Assets Poses a 

Security Challenge

Due to the remote and rugged location of some assets, Interior officials 

reported that some icons and monuments pose additional issues related to 

securing perimeters and ensuring an adequate response in the event of an 

attack. According to information from Interior, although the remoteness of 

the locations may reduce the threat exposure associated with more “target 

rich” environments, it can present a significant disadvantage when Interior 

attempts to implement security measures. 

Remote Locations: Mt. 

Rushmore

Mt. Rushmore, which is located in the Black Hills of southwestern South 

Dakota, typifies how difficult it can be for Interior to protect icons and 

monuments that are located in remote and often rugged environments. Mt. 
Page 25 GAO-05-790 Homeland Security

Rushmore is the world’s largest sculpture and is one of the most widely 

recognized symbols of the United States. In addition to its cultural and 

symbolic significance, size, and location, Mt. Rushmore hosts a large 

number of visitors each year, including numerous dignitaries. The 

monument has a visitor center, restaurant, gift shop, and amphitheatre that 

are used for various events. Each Fourth of July, the park hosts a holiday 

celebration with fireworks and other activities that attracts tens of 

thousands of visitors. The monument is also about 50 miles south of 

Sturgis, the site of an annual motorcycle rally that can bring over 500,000 

tourists to the area—many of whom visit Mt. Rushmore. Approximately 2.9 

million tourists visit the monument annually, with up to 40,000 visiting on 

some days during the summer months. 

Mt. Rushmore has a history prior to September 11 of security incidents 

involving domestic terrorists, political demonstrators, and bomb threats, 

according to Park Service officials. The threats and related incidents have 

included the following:

• Between 1970 and 1973 there were multiple efforts by the American 

Indian Movement to occupy the mountain and deface the monument. 

• In 1975, a bomb was detonated in front of the visitor center—there were 

no injuries because the detonation occurred early in the morning.

• In 1987, the environmental group Greenpeace illegally climbed the 

mountain and attempted to unfurl a protest banner.

• In 1991, the Park Service received multiple, credible threats to 

assassinate then-President George H.W. Bush during the 50th 

anniversary celebration of the monument.

• In 1999, a Colorado man was arrested for making a threat to blow up Mt. 

Rushmore.

According to Park Service officials, because of these incidents, the Park 

Service took actions, including a security assessment in 1997 that 

recommended a range of countermeasures costing approximately $2.9 

million, most of which were subsequently implemented. However, Park 

Service officials told us that prior to September 11, the focus of their 

security efforts was directed at protecting the monument. In light of the 

September 11 attacks, Park Service officials are now including visitors and 

employees in their protection at Mt. Rushmore. With increases in funding 
Page 26 GAO-05-790 Homeland Security

for security after September 11, Park Service officials told us in mid-2004 

that they were in the process of adding protection park rangers and other 

employees. In addition, the Park Service made other security 

enhancements, including the installation of security fencing, lighting, and 

gates at multiple locations; improvements to existing mechanical systems 

for dispatch and incident management; and the purchase of all-terrain 

vehicles for use in patrols and at special events. Figure 9 shows a security 

camera mounted near the amphitheatre at the base of the monument.

Figure 9: Security Camera near the Amphitheatre at Mt. Rushmore

Despite these improvements, security at Mt. Rushmore is a major Park 

Service concern, due to the large area to patrol and large number of 

visitors. The park has 1,278 acres, 40 acres of which are part of the visitor 

service area that offers hiking and educational opportunities at the 

sculptor’s studio and visitor center’s amphitheater, museum, and 

bookstores. In addition, the area immediately surrounding the sculpture 

Source: GAO.
Page 27 GAO-05-790 Homeland Security

has steep rock faces and a series of canyons. While terrain serves as a 

natural barrier for most visitors and casual hikers, preventing individuals 

seeking to climb to the top of the monument for nefarious purposes is 

difficult. Park rangers at the monument told us that in order to fully secure 

the monument’s perimeter, rangers must regularly hike and patrol the 

mountain—a time-consuming and physically challenging task. Figure 10 

shows the rugged terrain at the front of the sculpture and a canyon in the 

area behind the sculpture. 

Figure 10: Rugged Terrain Surrounding Mt. Rushmore 

In addition, the park relies on backup from state and county law 

enforcement agencies, as well as the Federal Bureau of Investigation. 

According to Park Service officials, these agencies also provide support 

during major events at the park. 

Leveraging Limited 

Resources for Security 

Improvements Is Viewed by 

Interior Officials as a 

Challenge 

In addition to the range of challenges with protecting icons and 

monuments, Interior officials were also concerned about the department’s 

ability to leverage limited resources for its protection initiatives in terms of 

security staffing and funding. These officials said that the increased 

emphasis on visitor protection and homeland security demands that 

Source: GAO.
Page 28 GAO-05-790 Homeland Security

Interior maintain a well coordinated and highly professional law 

enforcement capability. However, the department’s law enforcement staff 

is already spread thin, according to these officials, averaging one law 

enforcement officer for about every 110,000 visitors and 118,000 acres of 

land. Funding challenges for Interior homeland security programs have 

been well documented. According to the August 2003 Interior IG report 

mentioned earlier, September 11 and the resulting increase in icon park 

security have had an impact on other parks and law enforcement officers 

across the Park Service.4

 According to the report, rangers have been 

detailed from their permanent parks to supplement the icon park forces, 

leaving many other parks with a diminished protection staff. The Interior 

IG also reported that law enforcement staff were strained right after 

September 11 because officers were working 12-hour shifts 7 days a week 

for several months and with no days off. The Interior IG reported that there 

is a concern about the long-term effectiveness of the protection staff and 

the officers who operate under these conditions. 

At the icons and monuments we visited, concerns about having adequate 

resources for security were evident. In Philadelphia at INHP, Park Service 

officials said that law enforcement represents the largest portion of the 

INHP budget at approximately $8 million per year and accounts for more 

than one-third of the park’s budget. By comparison, prior to September 11, 

law enforcement accounted for about $2.4 million per year. At the Jefferson 

Memorial, Park Service officials told us that they sometimes leave the snow 

fencing (shown in fig. 8) in place because they lack the staff resources to 

remove and reinstall the fencing before and after each major event on the 

Mall. At Mt. Rushmore, the need for additional staff was, as mentioned 

before, an ongoing concern. 

Although we did not do a detailed assessment of security funding issues, 

officials at the sites we visited told us that they were concerned about their 

ability to implement further security enhancements that they believe are 

needed. They viewed lack of additional funding as a major challenge. 

Interior officials with OLES, including the Deputy Assistant Secretary for 

Law Enforcement and Security, expressed concern about the department’s 

inability to obtain homeland security funding through DHS. These officials 

said that state and local governments receive significant funding through 

DHS. These officials said that there have been discussions within the 

administration about allowing other federal agencies to receive funding 

4

2003-I-0063.
Page 29 GAO-05-790 Homeland Security

through DHS but such actions have not been taken. Nonetheless, with the 

establishment of a central office to manage security matters and Interior’s 

efforts to respond to various governmentwide initiatives, the department 

has taken some important steps to better position itself to compete for 

homeland security-related funds. At the individual icons and monuments 

we visited, steps clearly had been taken to improve security since 

September 11, such as the Washington Monument perimeter landscaping 

project, the Lincoln and Jefferson Memorial security projects, the visitor 

screening system at the Statue of Liberty, increased staffing at Mt. 

Rushmore, and the rerouting of Interstate 93 at Hoover Dam. 

Initiatives to Protect 

National Icons and 

Monuments Are Part of the 

National Homeland Security 

Strategy

Initiatives by Congress and the administration since September 11 to 

improve homeland security have been intended to, among many objectives, 

address the range of challenges associated with protecting national icons, 

monuments, and other key assets held by Interior. The September 11 

terrorist attacks prompted Congress to pass the Homeland Security Act, 

which created DHS. DHS’s mission includes preventing terrorist attacks 

within the United States, reducing the vulnerability of the United States to 

terrorism, and minimizing the damage and assisting in the recovery from 

attacks that do occur. The creation of DHS centralized the government’s 

homeland security efforts, including policy setting with regard to 

protecting national icons and monuments. As discussed earlier, several of 

Interior’s assets are highly visible and symbolic icons, monuments, and 

critical infrastructure such as dams. Due to the prominence of Interior’s 

assets, protecting them has figured heavily into the broad strategic goals 

set forth by the administration after September 11. 

More specifically, the President’s July 2002 National Strategy for 

Homeland Security recognized the potential for attacks on national icons 

and monuments, which could be targets for symbolic reasons and whose 

destruction could profoundly damage national morale.5

 The President’s 

February 2003 National Strategy for the Physical Protection of Critical 

Infrastructures and Key Assets provides a statement of national policy to 

remain committed to protecting critical infrastructures and key assets—

including national monuments, icons, and dams that Interior is responsible 

for—from terrorist attacks and is based on eight guiding principles. These 

principles include establishing responsibility and accountability and 

5

The President of the United States, National Strategy for Homeland Security (Washington, 

D.C.: July 2002).
Page 30 GAO-05-790 Homeland Security

encouraging and facilitating partnering among all levels of government and 

between government and industry. The strategy also establishes three 

strategic objectives, which are to (1) identify and ensure the protection of 

the most critical assets, in terms of national level public health and safety, 

governance, and economic and national security and public confidence; (2) 

ensure protection of infrastructures and assets facing specific, imminent 

threats; and (3) pursue collaborative measures and initiatives to ensure the 

protection of other potential targets that may become attractive over time.6

The critical infrastructure strategy identifies Interior as the lead federal 

entity for taking actions in a number of areas, in conjunction with DHS, 

related to protecting icons, monuments, and other key assets. These 

actions include developing guidance and standards for determining 

criticalities and protection priorities, conducting threat and vulnerability 

assessments, exploring opportunities for using technology to protect 

visitors at monuments, and collaborating with state and local governments 

and private foundations to ensure the protection of symbols and icons 

outside the federal domain. In our prior work, we assessed these plans and 

in February 2004 testified that the national strategy related to critical 

infrastructure contained the most desirable characteristics among the 

strategic plans for homeland security that the administration has produced 

since September 11.7

 These characteristics included addressing such areas 

as purpose, scope, and methodology; problem definition and risk 

assessment; and organizational roles, responsibilities, and coordination.

While the 2002 and 2003 national strategies identified a broad framework 

for homeland security as it relates to critical infrastructure, HSPD-7, which 

the administration issued in December 2003, establishes a national policy 

for federal agencies to identify and prioritize critical U.S. infrastructure and 

key resources and to protect them from terrorism.8

 The directive identified 

several critical infrastructure sectors, such as agriculture, water systems, 

public health, and national monuments and icons. For several of the 

sectors, the directive identifies lead agencies that have sector-specific 

6

The President of the United States, National Strategy for the Physical Protection of 

Critical Infrastructures and Key Assets (Washington, D.C.: February 2003).

7

GAO, Combating Terrorism: Evaluation of Selected Characteristics in National 

Strategies Related to Terrorism, GAO-04-408T (Washington, D.C.: Feb. 3, 2004).

8

Homeland Security Presidential Directive Number 7, Critical Infrastructure 

Identification, Prioritization, and Protection (Washington, D.C.: Dec. 17, 2003).
Page 31 GAO-05-790 Homeland Security

knowledge, including Interior for national icons and monuments. SSA 

responsibilities include collaborating with all relevant federal entities, state 

and local governments, and the private sector; conducting or facilitating 

vulnerability assessments of the specific sector; and encouraging risk 

management strategies to protect against and mitigate the effects of 

attacks. Section 35 of the directive also requires, on an annual basis, that 

sector-specific agencies report on their efforts to identify, prioritize, and 

coordinate the protection initiatives in their respective sectors. In addition, 

section 34 of the directive requires that all federal departments and 

agencies develop physical and cyber security plans for the assets they own 

or operate. 

Interior’s Actions Have Been 

Positive, and Further Steps 

Could Strengthen Its Efforts in 

the Security Area 

After September 11, the Secretary of the Interior took steps to address 

serious organizational and management problems in the law enforcement 

and security components of the department. Of particular concern, 

according to Interior’s IG, was the lack of coordination among these 

components and the absence of a meaningful single point of contact that 

the Secretary and senior managers could depend upon for reliable 

information and advice.9

 The Secretary approved a Deputy Assistant 

Secretary for Law Enforcement and Security in July 2002, established the 

security office named OLES, and approved the implementation of the 

additional 24 recommendations from a January 2002 Inspector General 

report.10 OLES oversees the department’s security efforts and seeks to 

ensure consistent application across bureaus and offices. OLES has 

responsibilities related to (1) coordinating the development of policies and 

standards, (2) coordinating and overseeing implementation of policies and 

standards, (3) representing the department externally, (4) conducting 

compliance reviews, and (5) providing leadership during incidents. 

Because Interior was designated as an SSA, OLES prepared a sectorspecific security plan for icons and monuments, as required by section 35 

of HSPD-7. Interior also developed a physical security plan for the assets it 

owns and operates in response to section 34 of HSPD-7. These plans 

recognize many of the major challenges facing Interior, including security 

versus access, jurisdictional considerations, security in remote locations, 

and security staffing issues. 

9

U.S. Department of the Interior, Office of Inspector General, Disquieting State of Disorder: 

An Assessment of Department of the Interior Law Enforcement, Report 2002-I-0014 

(Washington, D.C.: January 2002).

102002-I-0014.
Page 32 GAO-05-790 Homeland Security

In response to HSPD-7’s requirement that Interior formulate a plan for 

identifying, assessing, prioritizing, and developing protective programs for 

critical assets within the national icons and monuments sector, Interior 

developed a uniform risk assessment and ranking methodology called the 

National Monuments and Icons Assessment Methodology (NM&I 

methodology). According to information from Interior, the NM&I 

methodology is specifically designed to quantify risk, identify needed 

security enhancements, and measure risk-reduction benefits at icon and 

monument assets. The NM&I methodology has a consequence assessment 

phase and a risk assessment phase. During the consequence assessment 

phase, there is an asset tier ranking process, in which each asset’s iconic 

significance is subjectively determined. Specific attack scenarios—such as 

chemical/biological, aircraft, or improvised explosive device—are used to 

evaluate security at each asset and score attack consequences. 

Consequence categories include casualties, economic impact, and length of 

disruption. During the risk assessment phase, Interior uses the 

methodology to determine the effectiveness of existing security systems 

for preventing or mitigating the specified attack scenarios. Using risk 

values calculated from this comparison, Interior assigns asset risk ratings 

of high, medium, or low, and specific mitigation recommendations are 

formulated. To date, Interior has applied this methodology to assets that 

fall under the purview of the Park Service. Interior officials said that BOR 

has used a risk assessment methodology for dams for several years. These 

officials said that BOR’s methodology is similar, but also takes into account 

several factors that are unique to dams, such as downstream population at 

risk, structural vulnerability, and the economic impact if the asset were to 

be destroyed.

Interior has made significant progress in the risk assessment area, 

particularly regarding the new methodology for national icons and 

monuments. Before the development of this approach, Interior did not have 

a uniform, comprehensive risk management approach for icons and 

monuments. It relied instead on the judgment of senior officials in 

determining where resources should be directed, and the risk assessments 

completed at individual sites were done by a number of external experts 

using different methodologies. Given the range of challenges Interior faces, 

particularly with regard to limited resources, it is especially important that 

Interior’s funding priorities are linked with its risk rankings so that decision 

makers—including Interior, Office of Management and Budget (OMB), and 

Congress—can direct resources where they will have an optimal return on 

investment in terms of better protection. Setting funding priorities for 

protecting assets using a uniform approach is the foundation of the 
Page 33 GAO-05-790 Homeland Security

National Strategy for Homeland Security and the National Strategy for 

the Physical Protection of Critical Infrastructure and Key Assets. For 

example, the section of the National Strategy related to critical 

infrastructure calls for DHS and stakeholders like Interior to develop a 

uniform methodology for identifying facilities, systems, and functions with 

national level criticality to help establish priorities. 

Government agencies often face a variety of interests whose competing 

demands force policymakers and managers to balance stakeholders’ 

concerns and other factors such as quality, cost, and customer satisfaction. 

For Interior, the trade-offs that have to be made between security and its 

cultural mission are often difficult, which was apparent at the sites we 

visited. Full transparency regarding the basis for its decisions on security 

matters could, in our view, improve Interior’s ability to achieve mutually 

acceptable and consistent outcomes with stakeholders. As Interior 

continues with the implementation of security measures, a clearly defined 

set of guiding principles for balancing security with its core cultural 

mission could also be beneficial due to the complex and often contentious 

environment in which Interior operates. Such principles could be used in 

conjunction with the broader guiding principles the administration set 

forth in the national strategy for critical infrastructure and efforts by the 

department to define its guiding principles in other areas that are already in 

place. For example, the Park Service’s strategic plan for fiscal years 2001 to 

2005 identifies a set of guiding principles for achieving its mission that 

include excellent service, productive partnerships, and citizen 

involvement. 

Guiding principles have been used by other organizations to improve 

transparency and thus allow stakeholders to better understand the basis 

for decisions. For example, the administration has outlined guiding 

principles for postal reform given the U.S. Postal Service’s financial 

difficulties and a complex operating environment that involves multiple 

competing interests and stakeholders.11 These principles relate to best 

practices, transparency, flexibility, accountability, and financial selfsufficiency. In another example that relates directly to security, the 

government of Canada has identified guiding principles that are part of its 

11President’s Commission on the United States Postal Service, Embracing the Future: 

Making the Tough Choices to Preserve Universal Mail Service (Washington, D.C.: July 31, 

2003).
Page 34 GAO-05-790 Homeland Security

long-term plan for the Parliament Precinct area in Ottawa.12 These 

principles address the issue of balancing openness, accessibility, and 

security; which, like in the United States, is a concern in Canada.

The Threat Against 

Federal Office 

Buildings is Significant, 

and GSA Faces Various 

Challenges as the 

Owner and Landlord of 

These Assets

Terrorism is a major threat to federally owned and leased buildings, the 

civil servants and military personnel who work in them, and the public who 

visits them. This threat was evidenced by the Oklahoma City bombing in 

1995; the 1998 embassy bombings in Africa; the September 11, 2001, attacks 

on the World Trade Center and Pentagon; and the anthrax attacks in the fall 

of 2001. Since the attacks on the World Trade Center and the Pentagon, the 

focus on security in federal buildings has been heightened considerably. 

More recently, DHS raised the national threat level to Code Orange in some 

areas in August 2004 because of specific threat information for office 

buildings with critical missions. According to information from DHS, 

intelligence reports indicated that al Qaeda was targeting several specific 

buildings, including the International Monetary Fund and World Bank in 

the District of Columbia, Prudential Financial in northern New Jersey, and 

Citigroup buildings and the New York Stock Exchange in New York. GSA 

owns several federal office buildings on which an attack could seriously 

disrupt the business of government and harm federal employees and the 

public. Overall, GSA controls more than 8,000 buildings that it owns and 

leases nationwide, encompassing about 338 million square feet of space. 

These properties include office buildings, courthouses, border stations, 

and other types of facilities, representing about 6 percent of all federally 

owned space worldwide and 39 percent of all federally leased space 

worldwide. In addition to most of the major departmental headquarters in 

Washington, D.C., including the Departments of State, Justice, and Interior, 

GSA owns most of the key multiagency federal office buildings in major 

cities, including New York, and Chicago, as well as every federal 

courthouse in the country. 

Various potential threats—including large-scale attacks using truck bombs 

to other breaches and attempts to bring weapons, explosives, or 

chemical/biological agents into the buildings—pose several challenges for 

GSA as the owner and landlord of these buildings. These include 

maintaining a proper level of security without limiting the public’s access to 

federal offices for services that the government provides and for other 

12Public Works and Government Services Canada, A Legacy for Future Generations: The 

Long-Term Vision and Plan for the Parliamentary Precinct.
Page 35 GAO-05-790 Homeland Security

business; working with stakeholders and other jurisdictions that have an 

interest in the type of security that is employed; securing access to 

privately owned buildings and space where GSA leases space for federal 

agencies, but where GSA and FPS do not have control over security for the 

building; and the challenge GSA faces as a result of the transfer of FPS, 

which has responsibility for providing law enforcement and security 

related functions, to DHS. 

Balancing Security with 

Public Access at Federal 

Facilities Is a Major 

Challenge 

A major challenge in protecting federal buildings is balancing increased 

security with the public’s access to government offices for services and to 

transact other business. According to GSA, its intent is to create an 

environment that reflects an open, welcome atmosphere, but one that 

challenges those with intent to do harm. In addition, GSA also considers 

federal workers’ convenience and privacy an important part of these 

considerations. Nonetheless, striking a balance among these competing 

factors is an ongoing challenge. It is particularly challenging for federal 

agencies in GSA-owned buildings that require regular public access such as 

courthouses, and federal office buildings that have agencies that interact 

often with the public, such as the Social Security Administration. A GSAowned and managed federal courthouse in Nevada demonstrates the 

challenge of balancing public access with security needs and how GSA has 

fostered this balance. This large courthouse houses multiple tenants 

requiring heightened security, including the federal courts, the U.S. 

Attorney’s Office, and the U.S. Marshals Service (USMS).

According to GSA officials, the courthouse is unique because it hosts 

cultural events such as concerts and contains many displays of sculpture, 

painting, and photographic art that are open to the public. Located in what 

GSA officials said is a neglected downtown area, the courthouse is also a 

key part of a business and community revitalization effort that offers free 

public events and encourages public participation. Balancing the need for 

securing the facility and public accessibility is especially important given 

the dual roles of the courthouse.

The courthouse has many security features incorporated into its design. It 

is the first courthouse to be designed with federal architectural blastresistance guidelines adopted after the Oklahoma City bombing. According 

to GSA officials, the design of the courthouse incorporated many of the 

lessons learned from Oklahoma City. Some of these many security features 

incorporated into the building design include the following:
Page 36 GAO-05-790 Homeland Security

• setback from the streets;

• window glazing and hardened exterior building;

• advanced structure design;

• bollards around building perimeter;

• controlled parking for building staff;

• security barriers entrance to mitigate the danger of high-speed vehicle 

attempting to enter the parking garage;

• separate sally port for prisoner transfer and elevators for transfers of 

prisoners to courtrooms;

• unique, unobtrusive design for magnetometer checkpoints at main 

public entrance;

• access card operated doors and nonpublic elevators; and

• surveillance cameras both within and outside the structure.

USMS and FPS provide law enforcement and security functions for federal 

buildings that house court functions. Given the events of September 11, 

FPS and USMS made a number of enhancements to their operations and 

physical security features at the courthouse. For example, FPS and USMS 

officials told us that they now hold weekly meetings with the buildings’ 

principal stakeholders to review security issues. In addition, USMS officials 

told us that they have instituted new gun and hazardous materials training 

for their officers and have stepped up evacuation drills and training for 

building employees. FPS and USMS officials said that since September 11 

there has been a great deal of cooperation amongst local law enforcement 

agencies. For example, one local law enforcement agency allowed FPS to 

link to its radio systems to enhance communication between the entities. 

The local law enforcement agency also involved USMS in their regionwide 

security efforts on New Year’s eve 2003, when the national threat alert level 

was raised to orange. Finally, USMS and FPS have made physical security 

enhancements, including, among other things, hardening the exterior wall 

of the courthouse that did not have a setback with a reinforced retaining 

wall and a rock garden with large boulders, replacing the gates to the 

vehicle sally port—which is a secure entryway for the loading and 
Page 37 GAO-05-790 Homeland Security

unloading of prisoners and protected witnesses—with stronger iron gates, 

adding surveillance cameras, adding alarms, and constructing a secure gun 

locker for use by armed officers.

The fact that office buildings traditionally have been constructed with an 

emphasis on ease of access makes security measures difficult to 

implement. However, as mentioned above, the design of the courthouse 

incorporated many of the lessons learned from the Oklahoma City bombing 

with respect to building security and safety, as well as a design that 

emphasizes openness and accessibility. Nonetheless, according to GSA 

officials, balancing security design and enhancement with access is an 

ongoing challenge.

Addressing Jurisdictional 

Issues and Competing 

Stakeholder Interests Is 

Another Challenge for GSA

In addition to the challenges related to balancing security with public 

accessibility at GSA buildings, addressing the competing needs of federal 

agencies, local governments, and private sector entities in securing its 

buildings is a challenge. For example, local governments get involved when 

GSA requests permits to implement additional security enhancements that 

require such actions as closing streets, removing public parking spaces, 

and installing bollards around the perimeter of the facility. One location 

that typifies the jurisdictional and stakeholder issues GSA faces is a federal 

building in New York City. It is a GSA-owned and managed building that 

houses multiple federal agencies and is visited by thousands of individuals 

each year conducting business with the government. 

GSA was focused on security at the federal building before the September 

11 terrorist attacks. In coordination with the FBI and the city, GSA had 

developed a preliminary security upgrade plan, which included 

improvements such as maintaining street control around the building, 

increasing the use of building access controls, and hardening the building 

to protect it from blasts. After September 11, GSA and FPS implemented 

several additional security enhancements, including further strengthening 

perimeter security, access control, surveillance, and blast resistance. GSA 

and FPS took steps to improve the perimeter security of the federal 

building by accelerating plans to install bollards and barriers around the 

perimeter and working with city and fire department officials to close some 

nearby streets to vehicular traffic. In addition, GSA instituted a new 

building access system employing smart card technology. Smart cards 

contain the name, title, and picture of the employee; electronic data that 

can prove the authenticity of the card; and biometric data about the 
Page 38 GAO-05-790 Homeland Security

employee. Figure 11 shows the bollards that were installed in front of the 

federal building.

Figure 11: Bollards in Front of a Federal Building in New York

GSA officials said that to implement these and other security 

enhancements, their greatest challenge has been dealing with competing 

stakeholder interests and jurisdictional issues. GSA officials indicated that 

the decision-making process involves multiple stakeholders, steps, and 

requirements, most of which involve the city of New York. GSA officials 

noted that in addition to new steps and requirements that arose during the 

permit process, some requirements changed after permit issuance. In these 

cases, city officials have retracted some permits for security 

enhancements, and GSA has had to restart the permitting process. 

Specifically, GSA officials noted that they encountered delays when trying 

to install bollards along the building perimeter. Initially, the city 

Department of Transportation was supportive of the idea; but as the 

Source: GAO.
Page 39 GAO-05-790 Homeland Security

process continued, GSA officials said that issues related to historic 

preservation arose that needed to be addressed. Moreover, GSA officials 

also noted that the city has prevented GSA from making some security 

enhancements that they believed were needed. 

GSA has also experienced opposition from various groups in trying to close 

a nearby street due to security concerns. According to GSA officials, the 

city has asked GSA to prepare an environmental impact statement (EIS), 

hold public hearings, and consider traffic and economic impacts on the 

street closure. In contrast with the challenges they have encountered with 

the city, GSA officials said that the New York Police Department (NYPD) 

has been supportive of their security efforts. At a recent demonstration 

near the federal building, GSA officials said that NYPD provided police 

officers to assist with crowd control. Although GSA has been faced with 

various jurisdictional issues and the process has been challenging, the city 

ultimately has also allowed GSA to close streets and make several of the 

previously mentioned security upgrades. Nonetheless, GSA’s experience at 

the federal building demonstrates the complexities it faces when 

attempting to implement security enhancements for large, multitenant 

buildings in urban settings. 

The Challenge of Security 

for Leased Space 

Securing access to privately owned buildings and space that houses federal 

tenants is a unique challenge that may put the government at odds with 

private lessors and other nonfederal building occupants. GSA has reported 

that its goal and biggest challenge in this area is to provide the same level of 

security for occupants of leased facilities as it provides for those that GSA 

owns. However, this is often difficult because GSA has to work with lessors 

to implement changes and in some instances coordinate with other 

nonfederal tenants. As a result, GSA may have difficulty getting the lessor 

to allow security countermeasures in buildings that are not fully occupied 

by federal employees. This challenge arises because many private owners 

resisted heightened levels of security because of the adverse impact or 

inconvenience potentially caused to private tenants. GSA officials also 

identified negotiating the need and costs of increased security standards in 

leased properties as a significant challenge in the post-September 11 

environment. GSA officials said that negotiating with private owners 

presents a challenge of determining how to effectively secure mixed-tenant 

buildings without security being overly burdensome. A GSA official, 

knowledgeable of leasing issues told us, however, that September 11 

changed the perspective of private owners as they realized vulnerabilities 
Page 40 GAO-05-790 Homeland Security

and recognized that federal tenants would begin requiring increased levels 

of security in order to continue to lease space. 

The D.C. metro area, managed by GSA’s National Capital Region, has a high 

concentration of federal leases. One such leased building is a 10-story, 

privately owned facility located in Washington, D.C. The property is a 

mixed-tenant space with both private sector and federal tenants. The 

building posts guards and operates screening checkpoints at each entrance 

and restricts access to elevator banks and stairwells to only those 

authorized or with escort. In addition, a GSA official said that at the request 

of the building’s largest federal tenant, every individual entering the 

building must be screened. Additionally, the building also operates a mail 

facility to screen all mail, packages, and deliveries. 

Due to security concerns following the September 11 attacks, FPS, along 

with GSA and the building’s largest federal tenant, assessed the building’s 

risk and began to develop and implement a comprehensive security 

program. FPS conducted a threat assessment of the building and 

determined the building to be classified as a Level IV13 property. Once the 

building had been assessed and classified, agency officials from the 

building’s largest federal tenant, GSA, and FPS began developing a plan for 

security program development and implementation. The program plan 

included armed contract guards manning magnetometers and X-ray 

machines, random spot checks of vehicles entering the parking garage, and 

close monitoring of visitor badges.

Additionally, a GSA official said that technology advancement has changed 

since September 11. The leased building’s security program incorporates its 

newest technology, the E-Pop system. The E-Pop system can be controlled 

by security officials; in the event of an emergency, it is able to connect to 

computers in the building and deliver emergency messages communicating 

evacuation instructions. Furthermore, E-Pop allows tenants to be 

immediately informed of an incident, thereby increasing their chances of 

exiting the building safely. The leased building is also considering 

implementing smart card technology, a building access system that uses 

plastic identification cards containing an individual’s personal and 

13According to Department of Justice standards, a Level IV facility has over 450 federal 

employees. In addition, the facility likely has more than 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.
Page 41 GAO-05-790 Homeland Security

biometric data. This is the same system used at the federal building in New 

York City.

A GSA leasing official stated that ISC’s development of leased space 

security standards, which will be discussed later, has been useful in 

effectively communicating increased physical security needs to private 

owners and involving them directly in the process of security program 

development for their buildings. This official said that the standards have 

established the credibility and validity of increased security measures, 

where no or few guidelines existed before. A GSA official said that even 

though the commercial real estate community in the capital area has 

become attuned to the needs of the federal government in the postSeptember 11 security environment, challenges still exist. According to 

GSA and security officials, one challenge in leasing space in property 

mixed with federal agency and private sector tenants is incorporating 

increased security standards while balancing occupants’ varying interests 

and needs. Some private owners and their private sector tenants may not 

want random car checks conducted or magnetometers placed at the 

entrances to their buildings because this may, in some way, adversely affect 

their business. GSA officials also noted that negotiating the need and costs 

of increased security standards in leased properties is still a significant 

challenge, as security demands for privately owned buildings are still 

relatively new. 

FPS Transfer to DHS Poses 

a Challenge for GSA

The Homeland Security Act transferred FPS to DHS, effective March 1, 

2003.14 FPS’s transfer to DHS was intended to improve law enforcement 

and related security functions by centralizing building security activities 

with other homeland security functions. Under the act, DHS became 

responsible for protecting buildings, grounds, and property owned, 

occupied, or secured by the federal government that are under GSA’s 

jurisdiction, as well as other DHS facilities. A March 2003 operational 

memorandum of agreement between GSA and DHS made FPS responsible 

for the same types of security services that FPS provided for GSA 

properties prior to the transfer to DHS. These include, among other things, 

performing risk assessments, managing the installation of some security 

14Executive Order 13286 dated February 28, 2003, amended numerous executive orders to 

reflect the transfer of certain functions and responsibilities to the Secretary of Homeland 

Security. Section 23 of the Executive Order transferred the ISC chairmanship responsibility 

from GSA to DHS.
Page 42 GAO-05-790 Homeland Security

equipment, conducting criminal investigations, and managing the contract 

guard program.15 Although law enforcement and security related functions 

were transferred to DHS from GSA, GSA officials said that it still assists 

FPS and tenant agencies in implementing various security measures that 

FPS recommends, and incorporating enhanced security measures into new 

space it constructs or leases. In October 2003, GSA and DHS agreed on a 

number of interim support services GSA would provide to FPS during the 

transition in a separate memorandum of agreement. In July 2004, we 

reported on the challenges FPS was facing related to the transfer, including 

its expanding homeland security mission and related increase in 

responsibility; unresolved issues related to how it would be funded, 

because its funds at that time were tied to the rent GSA charges tenant 

agencies; and, difficulties with transferring mission-support functions for 

FPS from GSA to DHS.16 DHS concurred with our findings and related 

recommendations and agreed to take action.

In addition to the challenges facing FPS, our work for this review showed 

that GSA is facing its own management challenges because it no longer has 

control over the law enforcement and related security functions of its 

properties. GSA officials expressed concern about their ability to track 

security expenditures and stay informed about FPS protection activities in 

GSA buildings. These officials also expressed concern about not having a 

formal mechanism for communicating with FPS and for ensuring that FPS 

is meeting its responsibilities with regard to security enhancements and 

services. The Deputy Commissioner of GSA’s Public Buildings Service said 

that since the departure of FPS, GSA has had difficulty adjusting to not 

having responsibility for protecting its own buildings and is still trying to 

define its overall role in security. This official said that GSA’s new role 

should be that of a coordinator between FPS and the tenant agencies and 

that GSA was examining the MOU between GSA and DHS to determine if 

GSA’s role and visibility in facility protection could be enhanced. Concerns 

about the departure of FPS were identified by GSA’s Office of the Inspector 

General (IG) in its August 2004 updated assessment of GSA’s major 

management challenges. The GSA IG identified protection of federal 

facilities and personnel as one of seven major management challenges 

15As of September 30, 2003, FPS had approximately 1,100 uniformed officer full-time 

equivalents and 13,000 contract guards to protect GSA-owned or–occupied facilities.

16GAO-04-537.
Page 43 GAO-05-790 Homeland Security

facing the agency.17 The GSA IG said that although FPS was transferred to 

DHS, GSA will have a continual need to closely interact with security 

personnel due to GSA’s mission of housing federal agencies. The GSA IG 

concluded that ensuring federal employees have a secure working 

environment and that building assets are adequately safeguarded must 

remain a primary concern of GSA. 

Prior to the creation of DHS, we expressed concern about separating 

security from other real property portfolio functions, such as site location, 

design, and construction for new federal buildings. Decisions on these 

factors have implications for what type of security will be necessary and 

effective.18 We concluded that if DHS was given the responsibility for 

securing facilities, the role of integrating security with other real property 

functions would be an important consideration. Given the transfer of FPS 

to DHS, the range of challenges FPS faces, and the concerns about GSA’s 

new role expressed by GSA officials and the GSA IG, it is critical that GSA 

be well-equipped to engage in security-related matters given that it is still 

the owner and landlord of these buildings. However, GSA does not have an 

organizational unit or mechanism that is directly accountable for security 

matters, such as a chief security officer position or formal point of contact. 

Such an officer/official could coordinate GSA’s responsibilities related to 

the safety and security of its facilities, similar to the role fulfilled by 

Interior’s Deputy Assistant Secretary for Law Enforcement and Security 

and OLES. GSA’s Deputy Commissioner for public buildings and other GSA 

officials who are knowledgeable of security matters said that it would be 

beneficial for GSA to have a designated position for coordination purposes. 

Having a chief security officer position for physical assets is recognized in 

the security industry as essential in organizations with large numbers of 

mission-critical facilities. According to chief security officer guidelines 

developed by ASIS International:19

17General Services Administration, Office of the Inspector General, Updated Assessment of 

GSA’s Major Management Challenges (Washington, D.C.: August 2004). The other major 

management challenges the IG identified were procurement activities, contract 

management, information technology, management controls, aging federal buildings, and 

human capital.

18GAO, Building Security: Security Responsibilities for Federally Owned and Leased 

Facilities, GAO-03-8 (Washington, D.C.: Oct. 31, 2002).

19ASIS International has over 33,000 security industry members and according to its Web site 

is the preeminent international organization for professionals responsible for security, 

including managers and directors of security.
Page 44 GAO-05-790 Homeland Security

“Traditionally, what has previously been lacking is a single position at the senior governance 

level having the responsibility for crafting, influencing, and directing an organization-wide 

protection strategy. In many organizations, accountability is dispersed, possibly among 

several managers in different departments; with potentially conflicting objectives....the 

diversity of today’s risks comes in a complex matrix of interrelated threats, vulnerabilities, 

and impacts, the safeguards for which must, therefore, be interdependent. The ability to 

influence business strategy and address matters of internal risk exposure requires a chief 

security officer at the appropriate level in the organization.” 

Protecting Government 

Facilities Is Part of the 

National Homeland Security 

Strategy

The National Strategy for the Physical Protection of Critical 

Infrastructures and Key Assets mentioned earlier has clear implications 

for GSA and its role as the owner and landlord of federal facilities. The 

strategy identifies a number of actions intended to improve federal facility 

protection. These included developing a process to screen nonfederal 

tenants and visitors entering private sector facilities that house federal 

organizations, determining the criticality and vulnerability of government 

facilities, developing long-term construction standards for facilities 

requiring specialized security measures, and implementing new security 

technology at federally occupied facilities. 

GSA Actions in Response to the 

National Homeland Security 

Strategy and Other Related 

Initiatives

 GSA has taken a number of positive actions, as follows:

• A senior GSA official chaired ISC’s working group on security in leasing; 

after receiving input from ISC member agencies, ISC issued its policy on 

security standards for leased space in July 2003.

• GSA is working with DHS to utilize a risk management process called 

Federal Security Risk Management (FSRM) for assessing federally 

owned and leased facilities.

• GSA worked with ISC to develop security design criteria and is involved 

with ISC’s ongoing efforts to update the criteria annually.

• GSA is working with ISC on several technology-related initiatives, 

including smart card and biometrics access control technology, 

nonjersey barrier perimeter protection, and indoor air monitoring 

systems to prevent uncontrolled movement of toxic air substances.

In the area of risk assessment, FPS uses a computer-based methodology 

that allows FPS to evaluate risk and identify countermeasures on an 

ongoing basis. FPS is able to use a series of input screens and queries to 

maintain pertinent data that can be adjusted as threats and vulnerabilities 
Page 45 GAO-05-790 Homeland Security

change. The tool allows the user to enter information on each asset, 

identify existing countermeasures, assign an impact of loss and a 

vulnerability rating to each threat, and input countermeasure upgrade 

alternatives and their associated costs. 

As mentioned earlier, HSPD-7 requires, on an annual basis, that sectorspecific agencies report on their efforts to identify, prioritize, and 

coordinate the protection initiatives in various critical infrastructure 

sectors. Although GSA was not given responsibility for any of the sectors 

identified in the directive, all federal departments and agencies are 

required, under the directive, to develop physical and cyber security plans 

for the assets they own or operate. However, in a July 2004 letter to the 

Director of OMB, GSA stated that “no GSA owned or leased space meets 

the definitions for critical infrastructure and/or key resources.” The letter 

went on to say that “GSA owns and leases many buildings where important 

activities take place, but GSA is unable to make a determination as to 

whether these tenant activities are critical infrastructure.” 

GSA officials said that OMB has not commented on GSA’s response to 

HSPD-7 regarding a physical security plan. The Executive Director of ISC—

which has responsibility for reviewing agencies’ HSPD-7 plans for the 

administration—said that ISC has not completed its review of agencies’ 

plans, including GSA’s response to HSPD-7. We are deferring to ISC on 

whether GSA’s decision not to prepare a physical security plan is 

reasonable. In the future, a chief security officer position or formal point of 

contact could aid in determining GSA’s involvement in governmentwide 

critical infrastructure efforts such as HSPD-7. 

Conclusions There is a heightened concern that terrorists may again try to exploit the 

nation’s vulnerabilities. In this environment, Interior has a critical role in 

protecting our national icons and monuments and ensuring the safety of 

the millions of people who visit them. National icons such as the Statue of 

Liberty and Mt. Rushmore could be attacked for symbolic reasons. Since 

September 11, Interior has made significant progress in improving security 

by doing vulnerability assessments of high-profile sites that are likely 

targets and implementing various security measures. For example, at the 

individual icons and monuments we visited, steps clearly had been taken to 

improve security since September 11, such as the Washington Monument 

perimeter landscaping project, the Lincoln and Jefferson Memorial security 

projects, the visitor screening system at the Statue of Liberty, increased 

staffing at Mt. Rushmore, and the rerouting of Interstate 93 at Hoover Dam. 
Page 46 GAO-05-790 Homeland Security

In addition, Interior has made management changes, including creating a 

central security office, intended to enhance its homeland security 

initiatives, and has recently developed a uniform risk management 

methodology for national icons and monuments. These actions should help 

Interior address the major challenges it faces—which include balancing 

security and Interior’s mission related to access and education; addressing 

jurisdictional and competing stakeholder issues; securing icons and 

monuments in rugged, remote areas; and leveraging limited staff and 

funding resources. 

As Interior moves forward, it could link the results of its risk assessments 

and related risk rankings to its security funding priorities. This could allow 

for well-informed decisions by stakeholders—such as Interior, OMB, and 

Congress—about where to direct resources so that they have an optimal 

return on investment in terms of better protection. Also, a set of guiding 

principles for balancing security with its core cultural and educational 

mission—which Interior lacks but other organizations with complex 

environments have developed—could help in addressing the challenges. A 

set of guiding principles could provide decision makers and Interior’s other 

stakeholders with greater transparency regarding the rationale for security 

decisions. An approach with these components should yield results that 

would allow decision makers both within and external to the department to 

better gauge and consider competing priorities.

Since September 11, security at office buildings has remained a concern, as 

evidenced by threats revealed by DHS in August 2004 that al Qaeda was 

targeting several office buildings in New York, northern New Jersey, and 

Washington, D.C. GSA has taken action to address the challenges it faces as 

the owner and landlord of federal office buildings. These challenges 

include balancing security and public access, addressing jurisdictional and 

competing stakeholder issues, securing federally leased space, and 

adjusting to the transfer of FPS to DHS. These actions have included 

working with ISC to develop security standards, continuing with upgrades 

that GSA began implementing after the Oklahoma City bombing, and 

establishing a memorandum of agreement with DHS related to FPS. 

Despite these actions, GSA lacks a mechanism such as a chief security 

officer position or formal point of contact to coordinate security efforts for 

its federal office building portfolio. As a result, GSA is less equipped to 

effectively share information with FPS and tenant agencies, ensure that 

FPS is fulfilling its responsibilities, track security expenditures, and define 

its overall role in security—capabilities that GSA officials were concerned 

the agency was lacking. 
Page 47 GAO-05-790 Homeland Security

Recommendations for 

Executive Action

We are making two recommendations to the Secretary of the Interior and 

one recommendation to the Administrator of GSA. First, to ensure that 

useful information is available for decisions on resources for the protection 

of national icons and monuments, we recommend that the Secretary of the 

Interior link the results of the agency’s risk assessments and related risk 

rankings to its funding priorities. Second, given the complex nature of the 

challenges Interior faces in protecting national icons and monuments, the 

Secretary should also develop guiding principles for balancing security 

initiatives with Interior’s core mission so that decision makers and 

stakeholders will have a clearer, more transparent understanding of 

Interior’s rationale for security enhancements at individual assets. 

Regarding GSA, we recommend that the Administrator establish a 

mechanism—such as a chief security officer position or formal point of 

contact—that could serve in a liaison role with FPS and tenant agencies, 

work to address the challenges GSA faces related to security in buildings it 

owns and leases, and enable GSA to define its overall role in security given 

the transfer of FPS to DHS.

Agency Comments and 

Our Evaluation 

We provided a draft of this report to Interior, GSA, and DHS for their review 

and comment. Interior did not comment on our conclusions and 

recommendations. However, Interior provided technical comments, which 

we incorporated, where appropriate. GSA concurred with the report’s 

overall findings and stated that it concurs with the recommendation and 

will address it. GSA comments are contained in appendix II. DHS provided 

technical comments, which we incorporated where appropriate. 

We are sending copies of this report to the Secretaries of the Interior, 

Homeland Security, and the Administrator of GSA. Additional copies will 

be sent to other interested Congressional Committees. 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.
Page 48 GAO-05-790 Homeland Security

If you have any questions regarding this report, please contact me on (202) 

512-2834 or at goldsteinm@gao.gov. Contact points for our Offices of 

Congressional Relations and Public Affairs may be found on the last page 

of this report. GAO staff who made major contributions to this report are 

listed in appendix III. 

Sincerely yours,

Mark L. Goldstein

Director, Physical Infrastructure Issues
Page 49 GAO-05-790 Homeland Security

Appendix I

Objectives, Scope, and Methodology ApApenednxidexiIs

Our objectives were to (1) identify any challenges that the Department of 

the Interior (Interior) faces in protecting national icons and monuments 

from terrorism, as well as related actions intended to address these 

challenges, and similarly, (2) determine any challenges the General 

Services Administration (GSA) faces related to the protection of federal 

office buildings it owns or leases and the actions that have been taken. To 

determine what challenges Interior and GSA have faced in their efforts, we 

interviewed Interior and GSA officials to identify the major challenges, and 

reviewed available reports and other documents. In addition, in 

consultation with these officials, we identified sites that are illustrative of 

these challenges. 

From the sites identified, we selected five Interior sites and three GSA 

buildings for further analysis of the challenges. These eight sites were 

geographically dispersed and represented a range of asset types, including 

office buildings and national icons in both densely populated and remote 

areas. The sites included, the Statue of Liberty, New York, NY; 

Independence National Historical Park, Philadelphia, PA; Mt. Rushmore 

National Memorial, Keystone, SD; Hoover Dam, Boulder City, NV; the 

Washington Monument and Lincoln and Jefferson Memorials on the 

National Mall in Washington, D.C.; and three major facilities in the GSA 

inventory. Collectively, the sites we selected provided examples of the 

range of challenges Interior and GSA reported facing. We included the 

Hoover Dam because, in addition to being a source of hydropower, the dam 

has iconic status and attracts large numbers of tourists. At each site, we 

interviewed agency officials with primary responsibility for security 

implementation, operation, and management. We toured each site and 

observed the physical environment, the facilities, and the principal security 

elements to gain firsthand insights on the challenges. Furthermore, we 

interviewed stakeholders with significant interest in the security program, 

including the National Parks Conservation Association, the Commission on 

Fine Arts, the National Capital Planning Commission, Independence Mall 

Business and Residents Coalition, the National Coalition to Save our Mall, 

the U.S. Marshals Service, a charitable organization, and local government 

and law enforcement officials. We collected documents, when available, 

that contained site-specific information on security plans, policies, 

procedures, budgets and staffing. Finally, we considered prior GAO work 

on challenges in facility protection and security.

To determine what actions have been taken by Interior and GSA to address 

its challenges, we collected and analyzed documents from, and conducted 

interviews with Interior and GSA officials. The documents collected 
Appendix I

Objectives, Scope, and Methodology

Page 50 GAO-05-790 Homeland Security

provided information on these agencies’ past and present security plans, 

policies and procedures, organizational structures, funding and staffing. 

The interviews included officials from GSA’s Public Building Services and 

Interior’s Office of Law Enforcement and Security, National Park Service, 

and Bureau of Reclamation. We also interviewed officials from the Federal 

Protective Service, which is part of DHS and protects leased and owned 

GSA facilities. We reviewed relevant laws and guidance including the 

Homeland Security Act of 2002, the Federal Property and Administrative 

Services Act of 1949, and the Interagency Security Committee Security 

Standards for Leased Space. Additionally, we reviewed other pertinent 

reports, including the National Strategy for Homeland Security1

 and the 

National Strategy for the Physical Protection of Critical Infrastructures 

and Key Assets.

2

 We also considered past GAO work related to facility 

protection and security issues at Interior and GSA, as well as broader GAO 

work on homeland security issues. 

Agency officials and the representatives of stakeholder organizations 

provided much of the data and other information used in this report. In 

cases where officials provided their views and opinions within the context 

that they were speaking for their organization, we corroborated the 

information with other officials. We requested official comments on this 

report from Interior, GSA, and DHS. 

1

The President of the United States, National Strategy for Homeland Security (Washington, 

D.C.: July 2002).

2

The President of the United States, National Strategy for the Physical Protection of 

Critical Infrastructures and Key Assets, (Washington, D.C.: February 2003). 
Page 51 GAO-05-790 Homeland Security

Appendix II

Comments from the General Services 

Administration ApendxiI

GAO-05-790 is the public 

version of GAO-05-367SU.
Page 52 GAO-05-790 Homeland Security

Appendix III

GAO Contact and Acknowledgments ApendxiI

GAO Contact Mark Goldstein (202) 512-2834

Staff 

Acknowledgments

In addition to those individuals named above, David Sausville, Casey 

Brown, Matt Cail, Erika Carter, Roshni Davé, Daniel Hoy, Anne Izod, Donna 

Leiss, and Susan Michal-Smith were key contributors to this report. 

(543134)
The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help 

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost 

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To 

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Paul Anderson, Managing Director, AndersonP1@gao.gov (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

GAO’s Mission 

Obtaining Copies of 

GAO Reports and 

Testimony 

Order by Mail or Phone 

To Report Fraud, 

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER