Federal Protective Service: Better Data on Facility Jurisdictions Needed to Enhance Collaboration with State and Local Law Enforcement
Released: 2012-04-26T00:00:00

Letter

Background

FPS—located within the National Protection and Programs Directorate of DHS—protects the over 9,000 federal facilities that are under the control and custody of GSA, as well as the persons on those properties. FPS headquarters is located in Washington, D.C.; regional offices are located in New York, Boston, Philadelphia, Atlanta, Denver, Chicago, San Francisco, Seattle, Fort Worth, Kansas City, and the District of Columbia. FPS is authorized to enforce federal laws and regulations aimed at protecting GSA buildings and persons on the property and to investigate offenses against these buildings and persons.include buildings of exclusive, concurrent, and proprietary jurisdictions.

Exclusive: Under exclusive federal jurisdiction, the federal government—and federal law enforcement entities—have all of the legislative authority within the land area in question, while the state— and its state and local law enforcement entities—have no residual police powers.

Concurrent: In concurrent jurisdiction facilities, both federal and state governments—and law enforcement entities—have jurisdiction over the property.

Proprietary: Under proprietary jurisdiction, the federal government has rights—similar to a private landowner—but also maintains its authorities and responsibilities as the federal government. Under proprietary jurisdiction, the local government is the principal municipal police authority.

To enable FPS to track changes in the inventory of federal buildings that it protects, GSA, through its Public Buildings Service, provides building data in electronic files to FPS weekly from GSA’s building property system. These data include each building number with address; type of jurisdiction; and square footage and number of personnel to assist FPS to bill for its services, among other things. FPS personnel then input this information into its systems electronically. MegaCenters—the four regional dispatch centers within FPS that are the primary focal points for incident notification (see figure 1)—use the data to direct calls concerning building incidents and emergencies to FPS personnel as well as state and local law enforcement agencies.

As a general practice, MegaCenters make direct radio calls for incident response to FPS personnel and telephone calls to state and local law enforcement agencies. FPS instructs tenants to contact the MegaCenter by calling 1-877-4FPS-411 and, in areas where FPS responders cannot provide an immediate response; tenants are often directed to also dial 911. (See fig. 2.)

In this report, we assess GSA and FPS’s processes against GAO’s collaboration key practices and internal control standards. Our previous work has broadly defined collaboration as any joint activity that is intended to produce more public value than could be produced when organizations act alone. We have found that key practices for collaboration include: identifying and addressing needs by leveraging resources to support the common outcome and, where necessary, identifying opportunities to leverage resources; agreeing upon agency roles and responsibilities; and establishing compatible policies, procedures, and other means to operate across agency boundaries.

Additionally, agencies can strengthen their commitment to work collaboratively by articulating their agreements in formal documents, such as an MOU. We have also reported that organizations may face a range of barriers when they attempt to collaborate with other organizations. One such barrier stems from agencies’ concerns about protecting jurisdiction over missions. In addition, interagency collaboration is often hindered by incompatible procedures, processes, data, and computer systems. GAO has identified standards in facility protection that provide a framework for guiding agencies’ efforts in this area, such as establishing a means of coordinating and sharing information with other government entities and the private sector. Finally, standards for controls over information processing come from GAO’s Standards for Internal Control in the Federal Government. According to these standards, internal control is a major part of managing an organization and comprises the plans, methods, and procedures used to meet missions, goals, and objectives.

Internal control standards specific for information systems help ensure the completeness and accuracy of data.

Some other federal agencies provide their own law enforcement at their facilities. These include the Department of Veterans Affairs (VA) Police, National Park Service (NPS) law enforcement within the Department of the Interior, and Smithsonian Institution (SI) Police. VA Police provide law enforcement duties to the 152 VA Medical Centers (VAMC). U.S. Park Police is a unit of the National Park Service, with jurisdiction in all National Park Service areas and certain other federal and state lands. U.S. Park Police provides law enforcement services to designated areas within the National Park Service (primarily in the District of Columbia, New York City, and San Francisco, California metropolitan areas). Additionally, Law Enforcement Park Rangers, belonging to the “Visitor and Resource Protection Division” within the National Park Service, are authorized to carry firearms, conduct investigations, make arrests, and serve warrants pursuant to law and policy. Protection and security services at Smithsonian Institution facilities are provided by the Smithsonian Police.

FPS Uses Various Approaches to Collaborate with State and Local Law Enforcement, but Jurisdictional Data on Federal Facilities Are Incomplete

FPS’s Approach Involves a Variety of MOUs, Reliance on Long-standing Relationships, Guidance, and Other Initiatives

FPS uses a variety of methods to collaborate with state and local law enforcement, ranging from establishing MOUs to document agreement on roles and responsibilities with some, to relying on long-standing working relationships with others. FPS also has guidance and various other efforts under way related to coordination with state and local law enforcement. More specifically, FPS reported that it had 21 signed MOUs with state and local law enforcement agencies across the United States as of September 2011.usage in Alabama; MOUs for arrest authority on properties adjacent to federal property in California and Florida; and MOUs for mutual aid in the District of Columbia and Georgia, such as FPS’s reciprocal support agreement with Metropolitan Atlanta Rapid Transit Authority. MOUs are mechanisms that can be used to formalize key practices in agency collaboration such as agreeing on roles and responsibilities, including For example, there is an MOU for radio frequency leadership, and to establish compatible policies, procedures, and other means to operate across agency boundaries.

While FPS has often found MOUs helpful, the general consensus among FPS officials was that effective coordination did not depend on having MOUs. FPS prefers a flexible approach of pursuing MOUs only when it determines they are needed, as opposed to seeking them in all cases. FPS’s Director stated that FPS has generally not found it necessary to create written documents, requirements, or MOUs because FPS has always received good cooperation from state and local law enforcement agencies when their assistance was needed. For example, in some jurisdictions such as the suburbs surrounding the District of Columbia, FPS has no MOUs with state and local law enforcement agencies but has regular contact and longstanding mutual aid relationships. In addition, several FPS Regional Directors highlighted the importance of local response to incidents in and around federal facilities in rural areas because of the lack of FPS staff at these locations and noted that their informal relationships have worked successfully because state and local law enforcement agencies were consistently reliable in their response to these locations. FPS officials stated that mandating the pursuance of MOUs with all law enforcement entities would not be in the best interest of effectiveness and efficiency and would increase the burden on already task-saturated FPS staff. In addition, it is generally up to state and local law enforcement agencies as to whether they would be willing to enter into an MOU with a federal agency.

With regard to long-standing working relationships and regular contact with state and local law enforcement, FPS Inspectors and Regional Directors have developed relationships with state and local law enforcement agencies and collaborate on different levels. Regional Directors in all 11 FPS regions stated that their offices routinely had direct contact with state and local law enforcement agencies at multiple types of security meetings such as the Federal Executive Boards, joint terrorism task forces, and regional fusion center meetings.state and local law enforcement agencies and FPS at these meetings establishes mutually reinforcing or joint strategies designed to help align activities, core processes, and resources to achieve a common outcome. For example, FPS participates in monthly meetings of the Law Enforcement Working Group of the Atlanta Downtown Improvement District. State and local law enforcement chiefs or deputy chiefs from the surrounding area, officials from 15 local colleges, and officials from other federal agencies participate. According to an FPS regional official, the group acts as a “force multiplier” to fight crime within the district, which includes GSA-controlled facilities. FPS officials also have discussions with state and local law enforcement agencies as needed during operational planning associated with special events such as the Olympics, protests, and parades.

FPS also has guidance for FPS staff and other efforts under way to collaborate with state and local law enforcement. Regional Directors are responsible for carrying out FPS policy and guidance, and state that many of these written policies contain directives for collaboration with state and local law enforcement. One such directive is FPS Directive 15.1.2.1, Law Enforcement Authority and Powers, which outlines the scope of law enforcement authority on federal property. Other policies that reference state and local law enforcement agencies’ coordination include FPS’s Regional Information Sharing Program, Detention and Arrest, and Joint Terrorism Task Force Policy, among others. Best practices and lessons learned are also communicated throughout FPS regions with weekly regional director conference calls, a regional director’s council that meets monthly, and yearly Regional Director conferences.

In addition to guidance, FPS added three new positions in fiscal year 2011 intended to improve communication and standardization across FPS by coordinating with federal, state, and local law enforcement officials to reduce crime at, and potential threats to, federal facilities. These positions are titled Assistant Director for Field Operations (ADFO) for west, central, and east operations. The ADFO will be a spokesman for FPS, representing the Director in his or her designated area.

Other initiatives employed by FPS include collaborative operations to avert or obstruct potential threats inside the facility, such as the presence of unauthorized persons, or potentially disruptive or dangerous activities, such as potential terrorist operations and criminal activity in and around federal buildings. Using a combination of law enforcement agencies is consistent with facility protection key practices to establish a means of coordinating and sharing information with other government entities. These operations begin with planning meetings involving FPS and any other federal, state, and local law enforcement agencies that may be called upon to assist. The operations combine physical security expertise and law enforcement authority into an enhanced security team to provide a visual deterrent at FPS-protected facilities. The combined team then selects a federal building for which FPS has security oversight and provides a highly visible presence for a select period of time with patrol operations, explosive detection dog sweeps, and an enhanced security posture. As a means to leverage resources, FPS has collaborated with state and local law enforcement to assist in conducting these operations by enlisting their support in Chicago, Illinois; New York, New York; Newark, New Jersey; and the District of Columbia.

Like FPS, Other Federal Agencies Use a Variety of Methods to Collaborate with State and Local Law Enforcement

Other federal organizations with law enforcement responsibilities similar to FPS also used a variety of methods to collaborate with state and local law enforcement. For example, VA has a policy requiring all locations of VA-controlled property to have formally documented MOUs with state and local law enforcement agencies to ensure timely backup support for VA VA headquarters officials stated that MOUs are useful Police officers.because VA Police typically transport detainees to state and local law enforcement agencies for arrest and processing, while state and local law enforcement agencies typically provide first response to leased property under VA control. However, VA Police reported they cannot provide mutual aid to state and local law enforcement agencies on non-VA controlled property because existing law limits the authority of Department police officers to VA property.

According to U.S. Park Police headquarters officials, the Park Police has MOUs with federal, state, and local law enforcement including a longstanding formal relationship with the District of Columbia Metropolitan Police Department (MPD). Some of the MOUs are for events and are short-term, such as the last presidential inauguration in the District of Columbia. The U.S. Park Police also stated they have MOUs that are formal incident response plans, which outline the roles and responsibilities of the various entities. In the District of Columbia, the U.S. Park Police responded to the U.S. Holocaust Museum shooting incident in 2009 and have provided service to the Kennedy Center for the Performing Arts for a fee.

State and Local Law Enforcement Generally Willing to Assist with Protecting Federal Facilities

Our questionnaire of state and local law enforcement agencies and follow-up discussions showed a general willingness of those that replied to respond to incidents at federal facilities. For example, 48 of 52 agencies that answered the question replied that they would respond to calls that dispatch to a federally occupied (owned and/or leased) building, and 27 of 44 had actually responded to a federally occupied building since 2007. As for MOUs, 11 of 43 agencies that answered the question reported having formal MOUs with FPS and 4 of 40 reported having informal agreements. (See table 1.) Four state and local law enforcement agencies stated that they would decline to respond to an incident at a federal building in their jurisdiction. Three of these four law enforcement agencies were sheriff or highway patrol entities that stated that they are not the first responders to incidents at the facilities in question and that there were local police available for response. A fourth questionnaire responder did not clarify why it answered negatively; however, additional inquiry with the federal property owner in this law enforcement’s jurisdiction stated the particular law enforcement agency did coordinate and respond to calls at the property. Only one state and local law enforcement agency replied that it was denied access to a federal building when responding to an incident within its jurisdiction; however, it declined to clarify the specific instance in which it was denied access. The only law enforcement agency that answered it had declined to respond to a call dispatched at a federally occupied (owned and/or leased) building, later clarified that the answer applied to non-GSA-controlled facilities such as buildings of Department of Defense and other federal agencies. Table 1 shows the specific questions and responses provided by state and local law enforcement.

Overall, the variety of efforts FPS has under way reflects a reasonable approach to collaboration, especially when combined with results we found from our questionnaire of state and local law enforcement agencies. The practice of maintaining working relationships and having regular contact with state and local law enforcement officials establishes mutually reinforcing or joint strategies designed to help align activities, core processes, and resources to achieve a common outcome. The MOUs that FPS has in place are mechanisms consistent with facilitating key practices in agency collaboration, such as defining and agreeing to roles and responsibilities. Establishing compatible policies, procedures, and other means to operate across agency boundaries are key practices that can help enhance and sustain collaboration. Pursuing MOUs on an as-needed basis is also consistent with how other federal law enforcement agencies approach collaboration. Performing operations such as extra patrol activities using a combination of law enforcement agencies is consistent with facility protection key practices to establish a means of coordinating and sharing information with other government entities.

Missing Jurisdictional Data Are of Concern, and Data Inconsistencies with GSA Are Being Addressed

Although FPS’s approach to collaboration is reasonable, issues related to data quality arose during our review. Specifically, we found that FPS lacked complete data from GSA on the type of jurisdiction (e.g., concurrent or exclusive) for about one-third of the buildings FPS protects, making it difficult to ensure that it is addressing the full scope of issues related to jurisdictional roles and responsibilities. At the end of our review, GSA officials informed us that they had made significant progress addressing this issue. More specifically, when we reviewed the property list that GSA provided to FPS in December 2011—which is provided on a weekly basis—about thirty-four percent of the properties lacked recorded jurisdictions, including blank and pending jurisdiction categories. (See table 2.)

GSA officials stated that they were aware of the numerous blank data fields pertaining to jurisdictions and that they were trying to individually assess these fields building by building. They further stated that it was a time-consuming process that included reviewing individual property historical records. GSA officials stated they had made progress and the jurisdictions that have not been identified were down to 2 percent. However, these data had not yet been added to GSA’s building property system or contained in the electronic files GSA sends to FPS weekly. GSA officials also stated the jurisdictional field on the GSA property list was not in the top fifty fields that the agency typically monitors because of the large number of data fields, although the officials recognized the importance of this field to FPS.

During our review, we found no instances in which state or local law enforcement exceeded their jurisdictional authority. In some instances, state and local law enforcement responded to the perimeter of buildings with exclusive jurisdiction for matters such as traffic accidents and suspicious packages. FPS officials said that state and local law enforcement may also be granted access if officers are in pursuit of a suspect. Furthermore, FPS officials said that inspectors and GSA staff at the building level generally know the jurisdiction of the individual buildings for which they are responsible.

Nonetheless, given that facilities of exclusive jurisdiction are unique because state and local law enforcement agencies generally have no law enforcement authority on these properties, incomplete data leaves FPS less equipped to define and agree to respective roles and responsibilities with regard to state and local law enforcement collaboration. An additional effect of not having these data is that FPS lacks assurance that, in relying on state and local law enforcement to respond to incidents at federal facilities, it is not creating a situation where these entities may be exercising police authority where they lack such authority as in the case of exclusive jurisdiction properties. In addition, having incomplete data is inconsistent with established standards for internal control over data systems, including those standards that relate to accuracy and completeness. While only 4 percent of GSA’s inventory was known to be of exclusive jurisdiction, 34 percent of GSA’s inventory had incomplete data on the type of jurisdiction in GSA’s building property system.

In our review, we also found inconsistencies between FPS and GSA data on buildings and their locations—6 of the 11 FPS regions reported that the GSA list does not match the current property inventory. One FPS regional official stated that GSA does not keep the property list as current as FPS needs; changes occur but are not captured by GSA. For example, the official stated that in his region, agencies sign leases about a dozen times a year without FPS’s knowledge or timely notice. FPS officials noted that the overall number could be greater across all FPS regions. The current MOU between GSA and FPS calls for a pre-lease assessment of the building by FPS, but these assessments cannot be completed if FPS is unaware of the new lease. Another FPS regional official stated that the region uses its own building list, which is updated by FPS regularly as information becomes available. A third FPS official stated that the GSA list does not capture changes to buildings with a security risk level of 1 or 2 as quickly as FPS needs. A fourth regional official stated that the region relies on a combination of building lists from GSA, FPS provided lists, and its own regional list. This official stated these lists often do not reconcile because of changes that are not updated in a timely manner. In addition, a majority of state and local law enforcement agencies we sent questions to replied that they did not identify the jurisdiction of the individual federal buildings in their geographic areas, while three entities replied that they only identified some building jurisdictions.

GSA officials recognize that the exchange of building data with FPS is an issue. GSA stated that only recently did it have the ability to cross- reference and address these differences, and is working with FPS to correct them. For example, in 2011, GSA and FPS held working groups to begin to improve the building property list, and established a permanent GSA liaison in FPS’s headquarters to improve data coordination. Although this effort is still in progress and data inconsistencies remain, GSA and FPS are addressing concerns about data inconsistencies. Further, GSA and FPS are currently negotiating a new MOU that is expected to be finalized in early 2012. GSA officials told us that the new MOU will include an agreement on sharing information, such as the building data, and specifically sharing information at the regional level. FPS and GSA did not indicate whether the revised MOU would address the aforementioned issue related to incomplete jurisdictional data. However, it would seem that addressing this issue in conjunction with revising the MOU would ensure that data shared were not only consistent, but more complete as well.

Conclusions

FPS’s approach to collaborating with state and local law enforcement is reasonable and consistent with key practices in that the approach uses mechanisms such as MOUs to document agreements on roles and responsibilities in some cases, long-standing working relationships, written guidance to FPS staff, joint operations, and other initiatives to promote mutual collaboration. Other federal organizations with law enforcement responsibilities similar to FPS—such as VA, U.S. Park Police, and Smithsonian—also use a variety of methods for collaboration with state and local law enforcement. State and local law enforcement agencies we contacted were generally willing to assist FPS with incidents at federal facilities. Related to the quality of data exchanged between FPS and GSA on buildings and their locations, FPS and GSA had taken action to address data inconsistency issues. However, as of the end of our review, FPS still lacked complete data from GSA on whether the jurisdictions of about one-third of the buildings FPS protects are exclusive, concurrent, or proprietary. Having these data is important because state and local law enforcement generally have no authority to enforce state and local law on properties of exclusive jurisdiction. At the end of our review, GSA informed us that it had made progress with addressing this issue. GSA and FPS are negotiating a revised MOU that will include agreement on sharing information such as the building data. As such, addressing the issue related to incomplete data on jurisdictions, in conjunction with revising the MOU, would ensure that data were not only consistent, but more complete as well. Otherwise, FPS would remain less equipped to define and agree to respective roles and responsibilities as it proceeds with its efforts to rely on state and local law enforcement for assistance in responding to incidents at federal facilities.

Recommendations for Executive Action

In conjunction with the revised MOU that is being developed between GSA and FPS, we recommend the Administrator of GSA ensure that efforts to identify the jurisdictions of all GSA buildings are completed and that these data are provided to FPS so that FPS is better equipped to manage jurisdictional roles and responsibilities at GSA buildings.

Agency Comments and Our Evaluation

We provided a draft of this report to GSA, DHS, DOI, VA, and Smithsonian Institution for their review and comment. GSA provided written comments, which are reprinted in appendix II. GSA concurred with our recommendation that the Administrator of GSA ensure that efforts to identify the jurisdictions of all GSA buildings are completed, and that these data are provided to FPS so that FPS is better equipped to manage jurisdictional roles and responsibilities at GSA buildings. DHS provided a letter, reprinted in appendix III, describing its efforts to collaborate with state and local law enforcement. DHS also provided technical comments, which we incorporated, as appropriate. DOI, VA, and the Smithsonian Institution provided minor technical comments, via email, which we incorporated, as appropriate.

As agreed with your office, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date. At that time, we will send copies to the Secretary of Homeland Security, the Director of FPS, the Administrator of GSA, the Secretary of the Interior, the Secretary of Veterans Affairs, and Secretary of the Smithsonian Institution. In addition, the report will be available at no charge on the GAO’s Web site at http://www.gao.gov.

If you, or your staff, have any questions about this report, please contact me at (202) 512-2834 or 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 key contributions to this report are listed in appendix IV.

Appendix I: Objective, Scope and Methodology

To assess the Federal Protective Service’s (FPS) efforts to collaborate with state and local law enforcement for assistance in responding to incidents at federal facilities, we reviewed FPS data on buildings protected, staffing, procedures, and memorandums of understanding (MOUs). We also reviewed relevant federal facility building data from the General Services Administration (GSA) including for example, each building number with address; type of jurisdiction; and square footage and number of personnel, among other things. We interviewed FPS officials throughout the regions, and FPS and GSA officials at their respective agency’s headquarters in Washington, D.C., regarding the processes and procedures for exchanging these data. We reviewed the building data for completeness, but did not verify the accuracy of the information contained for each building. To ensure we were assessing the exact data that FPS uses, we requested data samples for fiscal year 2011 from both GSA and FPS and replicated the jurisdiction category results. We assessed the extent to which there were missing jurisdiction assignments by reviewing pending and blank jurisdiction categories. We then assessed GSA and FPS’s processes for managing these data against GAO’s Standards for Internal Control in the Federal Government, Homeland Security: Further Actions Needed to Coordinate Federal Agencies’ Facility Protection Efforts and Promote Key Practices, and Results-Oriented Government: Practices That Can Help Enhance and Sustain Collaboration among Federal Agencies. According to GAO’s standards for internal control in the federal government, internal control is a major part of managing an organization and comprises the plans, methods, and procedures used to meet missions, goals, and objectives. Internal control, which is synonymous with management control, helps government program managers achieve desired results through effective stewardship of public resources. Control activities—such as reconciliations performed to verify data completeness; an agency’s data entry design features contribute to data accuracy; data validation and editing performed to identify erroneous data; and erroneous data that is captured, reported, investigated, and promptly corrected—contribute to data accuracy and completeness. We determined that the data were sufficiently reliable for the purposes of this report.

For comparison with FPS’s coordination efforts, we contacted three federal agencies that provide law enforcement at their facilities—the Department of Veterans Affairs (VA), the National Park Service (NPS) within the Department of the Interior, and the Smithsonian Institution (SI). To gain insight into FPS, VA, SI, and NPS coordination with state and local law enforcement agencies, we emailed a self-administered set of 22 structured questions to the heads of 73 state and local law enforcement agencies. Our non-random selection of locations included varying population sizes located in a mixture of metro, urban, and rural areas as defined by the United States Department of Agriculture using the most recent Rural-Urban Continuum Codes for jurisdictions that we determined had FPS, and/or VA, NPS, and SI buildings throughout the United States. The state and local law enforcement agencies we chose included a mix of police, sheriff, highway patrol agencies in each of the 11 FPS regions. We also followed up our email with phone calls to these state and local law enforcement agencies. Not every respondent answered every question related to coordination with FPS, VA Police, U.S. Park Police, and SI police. Additionally, the responses had varying levels of staff within the state and local law enforcement organization reply for the organization. Furthermore, the structured questions were related to coordination with the Federal Protective Service, Veterans Affairs Police, Smithsonian police, and the U.S. Park Police. Although the results of our questions cannot be generalized to the universe of jurisdictions that have interaction with FPS, the results provide key insights on how state and local law enforcement collaborates with FPS to assist with federal facility protection. These results illustrate how FPS relies on these organizations to respond to incidents and collectively, how this multi-faceted approach enabled us to make conclusions whether FPS’s approach is reasonable.

Further, we interviewed officials at two FPS MegaCenters—the four regional dispatch centers within FPS that are the primary focal points for initial incident notification—and toured the Suitland, Md., MegaCenter facility. We attended an FPS operational exercise in the District of Columbia. We also interviewed each of the 11 FPS Regional Directors to determine how their region coordinates with state and local law enforcement entities for the properties in their jurisdiction. We interviewed GSA officials at GSA headquarters in the District of Columbia. We obtained relevant documents pertaining to VA, NPS, and SI collaboration with state and local law enforcement and interviewed agency officials. Lastly, we reviewed prior GAO work, including reports on key practices in interagency collaboration and facility protection.

We conducted this performance audit from February 2011 to March 2012 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

Appendix II: Comments from the General Services Administration

Appendix III: Comments from Department of Homeland Security

Appendix IV: GAO Contact and Staff Acknowledgments

GAO Contact

Staff Acknowledgments

In addition to the contact named above, David Sausville (Assistant Director), Maren McAvoy, and George Depaoli made key contributions to this report. Additionally, Colin Fallon, Kathleen Gilhooly, Hannah Laufe, and Andrew Stavisky aided in this assignment.