Federal Land Management Agencies: Additional Actions Needed to Address Facility Security Assessment Requirements
Released: 2019-10-21T00:00:00

Letter

Background

Land Management Agency Law Enforcement Divisions

Federal land management agencies have law enforcement divisions that protect their employees and secure their facilities across nearly 700 million acres of federal lands (see fig. 1). To do so, the four agencies’ law enforcement divisions employ uniformed law enforcement officers who patrol federal lands, respond to illegal activities, conduct routine investigations, and, depending on the agency, may also provide expertise in assessing facilities’ security. Each agency also maintains a law enforcement data system in which law enforcement officers record and track incidents of suspected illegal activity on federal lands. These systems can be used in conducting investigations, identifying trends in crime data, and assisting with decision making regarding staffing, resource allocations, and budgetary needs.

BLM. BLM’s Office of Law Enforcement and Security is charged with promoting the safety and security of employees and visitors, as well as environmental protection, across approximately 245 million acres of BLM lands in 12 states. At the end of fiscal year 2018, BLM had 194 field law enforcement officers engaged in such duties. According to agency documentation, these law enforcement officers also coordinate with state agencies and county law enforcement officers on large-scale recreational events, such as Burning Man. These field law enforcement officers may also be tasked with conducting facility security assessments.

FWS. FWS’s division of Refuge Law Enforcement helps ensure the safety and security of visitors, employees, government property, and wildlife and their habitats on approximately 150 million acres of land. At the end of fiscal year 2018, FWS had 231 field law enforcement officers on the agency’s 567 wildlife refuges. According to agency documents, FWS law enforcement officers serve as ambassadors by providing important services to the public beyond law enforcement, such as providing visitors with information and guidance regarding fishing, hunting, hiking, and wildlife viewing opportunities. These field law enforcement officers may also be tasked with conducting facility security assessments.

Forest Service. The Forest Service’s Law Enforcement and Investigations division is charged with protecting natural resources, employees, and visitors on approximately 193 million acres of National Forest System lands in 44 states. At the end of fiscal year 2018, the Forest Service had 417 field law enforcement officers. Additionally, law enforcement officers may be tasked with conducting facility security assessments.

Park Service. The Park Service’s division of Law Enforcement, Security, and Emergency Services is charged with protecting resources, managing public use, and promoting public safety and visitor enjoyment across the agency’s 85 million acres, 418 park units, 23 national scenic and national historic trails, and 60 wild and scenic rivers. At the end of fiscal year 2018, the Park Service had 1,329 field law enforcement officers stationed at 240 of the Park Service’s units. Field law enforcement officers may also be tasked with conducting facility security assessments.

ISC’s Facility Security Assessment Requirements

The ISC Standard applies to all facilities in the United States occupied by federal employees for nonmilitary purposes, including federal land management agencies’ facilities. This includes existing facilities, new construction, or major modernizations; facilities owned, to be purchased, or leased; stand-alone facilities; special-use facilities; and facilities on federal campuses. Among other things, the ISC Standard requires agencies to assess the risks faced by each of their facilities. According to Department of Homeland Security officials, since 2010, executive departments and agencies responsible for protecting their own facilities have been required to conduct facility security risk assessments as part of the ISC Standard’s risk management process. The ISC Standard states that risk is a measure of potential harm from an undesirable event that encompasses threat, vulnerability, and consequence. The ISC Standard then defines these terms as follows:

Undesirable event: An incident, such as vandalism, active shooters, and explosive devices that has an adverse impact on the facility occupants or visitors, operation of the facility, or mission of the agency.

Threat: The intention and capability of an adversary to initiate an undesirable event.

Vulnerability: A weakness in the design or operation of a facility that an adversary can exploit.

Consequence: The level, duration, and nature of the loss resulting from an undesirable event.

Based on the assessed level of risk, the ISC Standard provides a method for agencies to identify which countermeasures, such as security cameras or security gates, should be implemented to protect the facility against each of the undesirable events. According to the ISC Standard, once an initial assessment is completed, facility security reassessments should be conducted at least once every 3 to 5 years, depending on the facility’s security level, to reassess whether existing countermeasures remain adequate for mitigating risks. Beginning in fiscal year 2020, the ISC will require departments and agencies to report their compliance with the requirement to conduct facility security assessments on occupied facilities. Figure 2 shows the steps of the ISC Risk Management Process, and figure 3 shows some examples of facility countermeasures.

Because facility security assessments are a key component of the ISC’s risk management framework, the ISC Standard includes requirements for agencies’ risk assessment methodologies. Specifically, among other things, the ISC Standard requires that agencies use facility security assessment methodologies that (1) consider all 33 of the undesirable events identified in the ISC Standard, and (2) evaluate the three factors of risk (threat, vulnerability, and consequence) to each undesirable event. During facility security assessments, ratings are assigned to the threat, vulnerability, and consequence of an undesirable event, and the combined ratings produce an overall measurement of risk. In our hypothetical facility security assessment example shown in figure 4, each component of risk is assigned a rating of between 1 (very low) and 5 (very high) based on the facility’s conditions. These ratings are then multiplied to produce an overall estimate of risk for each undesirable event. Agencies can use this and other information resulting from a facility security assessment to make security-related decisions and direct resources to implement countermeasures to address unmitigated risk.

Available Data Show a Range of Threats and Assaults against Land Management Agency Employees, but Not All Incidents are Captured in the Data

Available federal law enforcement data show a range of threats and assaults against the four federal land management agencies’ employees in fiscal years 2013 through 2017. For example, incidents ranged from threats conveyed by telephone to attempted murder against federal land management agency employees. Additionally, FBI data on its investigations into potential domestic terror threats to land management agencies show a wide variety of statutes and regulations that may have been violated. However, not all incidents are captured in the federal land management agencies’ data because not all incidents are reported to the agencies’ law enforcement officials. Additionally, some incidents are investigated by state or local law enforcement and recorded in their data systems rather than in land management agencies’ systems. As a result, the number of actual threats and assaults is unclear and may be higher than what is represented in available data.

Our analysis of data from each of the four land management agencies and the FBI showed the following:

BLM. BLM data for fiscal years 2013 through 2017 included 88 incidents of threats and assaults against BLM employees and cited eight different statutes or regulations. A federal law prohibiting people from assaulting, resisting, or impeding certain federal officers or employees, 18 U.S.C. § 111, was the statute most frequently cited in BLM’s data. Examples of incidents that identified this statute include an individual harassing a BLM law enforcement officer by repeatedly swerving and cutting off the officer on the highway, an individual making threats against a BLM employee on Facebook and YouTube, and an incident during which an employee was stabbed outside a federal building. Twenty-one of the 88 incidents occurred in fiscal year 2013, when BLM categorized incidents using uniform crime reporting codes rather than federal statutes, regulations, or state laws. These incidents include, for example, an incident in which an individual attempted to murder a law enforcement officer with a firearm. Table 1 provides additional information on threats and assaults against BLM employees for fiscal years 2013 through 2017.

FWS. FWS data for fiscal years 2013 through 2017 included 66 incidents of threats and assaults against FWS employees and cited nine different statutes and regulations. A federal law prohibiting people from assaulting, resisting, or impeding certain federal officers or employees, 18 U.S.C. § 111, was the statute most frequently cited in FWS’s data and included a variety of incidents, such as a law enforcement officer who was assaulted with a tree branch during a suspected drug trafficking incident at the border. According to FWS officials, when law enforcement officers cite violations of state statutes, they enter the violation into the law enforcement data system under a generic description such as “Assault: simple, on officer,” and then manually enter the relevant state statute. Of the total FWS incidents, 26 were recorded under unspecified state statutes. These incidents included, for example, an officer who was assaulted while arresting an individual driving under the influence and an officer who received a death threat during an arrest. Table 2 provides additional information on threats and assaults against FWS employees for fiscal years 2013 through 2017.

Forest Service. Forest Service data for fiscal years 2013 through 2017 included 177 incidents of threats and assaults against Forest Service employees and cited seven different statutes or regulations. Officials said that the data provided to us generally included only the most serious offense that occurred during an incident, due to limitations on linking records in Forest Service’s data system. For example, if both a verbal threat and physical assault occurred during an incident, only the physical assault would be included in the data. Therefore, potential violations of some statutes or regulations that occurred during incidents of threats and assaults may not be recorded in the data. About half of the Forest Service incidents involved potential violations of 36 C.F.R. § 261.3(a), which includes interfering with a forest officer, among other things. Such incidents included: an individual telling a Forest Service employee that his dog would “rip her head off” if she approached his camp; threatening graffiti written on a law enforcement officer’s personal residence; and a death threat to a law enforcement officer. Table 3 provides additional information on threats and assaults against Forest Service employees for fiscal years 2013 through 2017.

Park Service. Park Service data for fiscal years 2013 through 2017 included 29 incidents of threats and assaults against Park Service employees and cited six different offense descriptions. According to a Park Service official, some incident records cite a statute or regulation. However, all agency incident records include offense codes that are unique to the Park Service and are associated with the type of violation, such as assault or disorderly conduct. Unlike with statutes and regulations, a perpetrator does not need to be identified for the law enforcement officer to cite an offense code. Three of the six Park Service offense codes relate to assault. Incidents that cited these codes included an individual ramming an employee’s patrol vehicle and a death threat left on an employee’s personal cell phone. Table 4 provides additional information on threats and assaults against Park Service employees for fiscal years 2013 through 2017.

FBI. FBI data for fiscal years 2013 through 2017 show that the FBI initiated under 100 domestic terrorism investigations into potential threats to federal land management agencies, and that these investigations most frequently cited eight specific statutes. Investigations can either be initiated by the FBI or referred to the FBI by land management agencies. Land management agency officials said they refer only the most serious incidents to the FBI—such as the armed occupation of Malheur National Wildlife Refuge. The FBI receives information from a variety of sources, including from confidential human sources; public tips; and state, local, tribal, and federal partners. According to FBI officials, an investigation into a domestic terrorism threat may only be initiated if there is information indicating potential violent criminal activity committed in furtherance of ideology. Our analysis of FBI data showed that the majority of the domestic terrorism investigations involved BLM, and the majority involved individuals motivated by anti-government ideologies. Most of the domestic terrorism investigations cited more than one statute or regulation as having been potentially violated, and the severity of the threat varied. For example, some investigations involved written threats and threats conveyed by telephone to government officials. In one example, the investigation involved a subject posting a BLM law enforcement officer’s personal information on Twitter, which resulted in over 500 harassing phone calls and several death threats. Table 5 provides information on the percentage of FBI investigations citing various statutes and regulations related to threats to federal land management agencies for fiscal years 2013 through 2017. incidents of threats. According to officials at all four agencies, employees do not always report threats to agency law enforcement. For example, some field unit employees said that in certain circumstances, they consider receiving threats a normal part of their job. Specifically, field unit employees we interviewed at three land management agencies cited incidents in which they were yelled at, for example, by hunters, permittees, or attendees of public planning meetings. While this behavior may be threatening, some employees told us it was “a part of the job,” and they did not report such incidents. In addition, some officials described being threatened while off-duty, such as by being harassed in local stores or being monitored at their home, which officials said in some cases they did not report because it was a common occurrence. Additionally, according to agency officials, threats are subject to interpretation, so employees may be reluctant to report an incident unless it involves an explicit threat of physical harm or death.

During an incident, some threats and assaults may not be recorded in agency data systems by agency law enforcement officers. BLM and Forest Service officials told us that when a single incident involves multiple offenses, the less serious offenses are unlikely to be recorded in the data system. Therefore, the entirety of what occurred during the incident may not be captured in the data system. For example, according to one BLM official we interviewed, if an incident involved a verbal threat and a physical assault, it would likely be recorded into the data system as an assault. there were trucks regularly parked outside their homes, with individuals holding anti- government beliefs, who appeared to be monitoring them and their families. One official stated that “They were holding us hostage in our own homes.”

Some incidents are investigated by state or local law enforcement and recorded in their data systems, rather than in land management agencies’ systems. Some incidents of threats and assaults to federal employees may be investigated by state or local law enforcement entities. Specifically, during our site visits, officials from all four land management agencies stated that their employees are instructed to call 911 in the case of an emergency, such as a threat or assault, and that, generally, a local law enforcement officer—such as a county sheriff’s deputy—will respond to the call. Land management agency officials said that when state or local law enforcement respond to an incident, even those that occur on federal lands, the incident would be recorded in those entities’ data systems and may not be entered into the land management agency’s law enforcement data system. Additionally, according to agency officials at all four land management agencies, due to resource constraints, many of their field units do not have any law enforcement officers or have a limited law enforcement presence, which limits the agencies’ ability to respond to and therefore record incidents of threats and assaults. For example, according to agency officials, as of October 2018, 178 of 418 Park Service units had no law enforcement presence. Furthermore, even when field units had dedicated law enforcement officers, the officers might not have been available to immediately respond to incidents, so employees might instead have contacted local law enforcement.

Given these reasons, the actual number of incidents of threats and assaults is unclear and may be greater than the number reported and entered in the land management agencies’ law enforcement data systems, according to federal land management agency officials.

Land Management Agencies Use Various Approaches to Protect Employees, but Several Factors May Affect Their Ability to Do So Agencies Use Various Approaches to Protect Employees, Including Building Relationships with External Law Enforcement Entities and the Public

Federal land management agencies use various approaches to protect their employees from threat and assaults, including building relationships with external law enforcement entities and the public; receiving, collecting, and disseminating intelligence; and offering training to agency employees. Agency officials we interviewed cited four factors that can affect their ability to protect employees, including that employees often work in remote locations.

Federal land management agencies use various approaches to protect their employees from threats and assaults. Specifically:

Agencies deploy their law enforcement officers to protect employees and resources. All four federal land management agencies have their own law enforcement divisions with law enforcement officers who are tasked with protecting employees and resources in the field. According to agency officials we interviewed, where available, agency law enforcement officers respond to incidents, including threats and assaults against employees. When necessary, agencies also deploy additional law enforcement officers to assist local officers. For example, during the armed occupation of the Malheur National Wildlife Refuge, FWS officials said the agency deployed FWS law enforcement officers from around the country to field units in western states to provide additional security for FWS employees. Similarly, according to BLM documents, BLM officers are sometimes deployed from their home field units for various reasons, such as assisting with large-scale recreational events and supporting fire investigations and natural disaster recovery.

Agencies build relationships with local, state, and other federal agency law enforcement entities, as well as the public. Federal land management agencies build relationships with local, state, and other federal agency law enforcement entities to help protect employees and resources in the field and to assist with coordinating law enforcement responses, according to agency officials. These officials said such relationships are important because not all field units have a law enforcement officer, and those that do often rely on local law enforcement for assistance with incidents of threats or assaults against agency employees. For example, officials at one field unit in Nevada stated that during a high-profile court case involving the agency, the Las Vegas Metropolitan Police Department kept a patrol car outside the field unit for several days to help ensure the safety of the field unit’s employees. Agency field officials said that building relationships with the public—both visitors and local citizens—can help keep their employees safe by cultivating trust and reducing potential tension over federal land management practices. For example, officials at one field unit drafted talking points for employees in the event that visitors asked them about a high-profile incident of anti-government behavior directed at a federal land management agency. The talking points outlined the agency’s responsibilities and authorities and, according to agency officials, were aimed at dispelling misunderstandings about federal land management policies. Additionally, officials at several field units we visited stated that their law enforcement officers are focused on educating, rather than policing, visitors.

Agencies receive, collect, and disseminate intelligence information. To varying degrees, federal land management agencies receive, collect, and disseminate intelligence information, which helps them anticipate, prepare for, and react to threats against employees and facilities. For example, officials we interviewed from all four agencies said that they receive intelligence information from various sources, including Interior’s Office of Law Enforcement and Security, the Department of Homeland Security, FBI, Federal Protective Service, and Joint Terrorism Task Forces. Additionally, after the armed occupation of Malheur National Wildlife Refuge, FWS created a new risk and threat assessment coordination unit to collect intelligence, inform decision-making, and improve coordination with other Interior bureaus. Agency officials said they disseminate intelligence information about potential threats to their field units so that field personnel can respond appropriately to the threat—including encouraging employees to telework, directing employees to temporarily stop field work, or temporarily closing their field unit.

Agencies have developed plans and guidance to promote employee safety. Agency officials have developed a variety of written plans and guidance to promote employee safety. For example, agencies are required to develop occupant emergency plans for most occupied facilities. Occupant emergency plans we obtained covered employee safety, including what to do in the event of a bomb threat or active shooter event. Additionally, some field units developed other documents that outlined actions employees are to take to remain safe, such as plans to address critical incidents or protests at their field unit.

Agencies offer various types of safety training. All four federal land management agencies offer a variety of training to help protect employees and promote their safety, according to agency documents and officials. Examples of topics addressed in agencies’ training include understanding anti-government ideologies, communicating techniques for de-escalating conflicts, and responding to an active shooter event.

Several Factors Can Affect Land Management Agencies’ Efforts to Protect Their Employees from Threats and Assaults

Agency officials cited four factors that can affect agencies’ efforts to protect their employees:

Agency employees work with the public and are often easily recognizable. Agency officials said their employees are required to interact with the public as part of their official duties, which can put them at risk of being threatened or assaulted. FWS officials said they temporarily closed field units in an adjacent state during the beginning of the armed occupation of the Malheur National Wildlife Refuge to reduce the likelihood that their employees would interact with members of the public who were traveling to Malheur to participate in the occupation. FWS and Park Service officials stated that their employees are easily recognizable because they typically wear uniforms, which may put them at greater risk of being harassed or threatened by individuals who hold anti-government beliefs. (See figure 5 for examples of uniforms.) In response, on certain occasions, some agency officials direct their employees to wear street clothes instead of their uniforms. Officials we interviewed indicated that whenever they are concerned about a potential safety issue at their field unit, such as a protest, they may encourage eligible employees to telework from home instead of reporting to their work station.

Employees often work in remote locations to fulfill agency missions. Agency officials stated that it can be difficult to protect employees because, as part of their field work, employees may be dispersed across hundreds of miles of federal lands and may be located hours or days away from the nearest agency law enforcement officer. (See figure 6 for an example of a remote location.) As a result, some agency officials said they sometimes direct employees to postpone fieldwork if there is a known or anticipated risk of threats or assaults. In addition, according to officials, various field units have developed check-in and check-out procedures to keep track of employees when they are in the field and to help verify that they report back to the office after concluding their fieldwork. Additionally, some field units have purchased satellite communication devices that operate when cell or radio signals are not available, so that employees conducting remote field work can call for help if needed.

The number of agency field law enforcement officers has declined. As of the end of fiscal year 2018, the overall number of field law enforcement officers at each of the four land management agencies had declined from fiscal year 2013, which agency officials noted as a factor straining their efforts to protect employees. For example, the Park Service had the lowest decrease of 7 percent, whereas the Forest Service had the greatest decrease of 22 percent. (See table 6.) Figure 7 shows the total number of acres for which federal land management agencies are responsible, the number of field law enforcement officers they had as of the end of fiscal year 2018, and the ratio of officers to acres of federal land. In addition, field officials from the three Interior agencies stated that as a result of various requirements to send law enforcement officers to support border protection efforts, their law enforcement officers are occasionally absent from their field units when deployed 14 days or more to the border. To help address the effects of border deployments, some agency officials told us that they seek opportunities to share law enforcement resources among field units and with other land management agencies and that they typically deploy law enforcement officers from field offices across the agency to minimize the effects on any one unit.

Anti-government sentiment can be unpredictable, difficult to respond to, and disruptive. Agency officials we interviewed said that the risk to employee safety posed by individuals holding anti- government sentiments can be unpredictable and that incidents of threats and assaults against employees by such individuals are generally sporadic. For example, BLM, FWS, and Forest Service officials said it would have been difficult to predict that armed individuals would occupy FWS’s Malheur National Wildlife Refuge, since they were protesting BLM actions. BLM and FWS agency officials said they believed that the occupiers chose Malheur National Wildlife Refuge because it was an easier target. In addition, some agency field unit officials told us that incidents of threats and assault from individuals holding anti-government beliefs generally occur when agency personnel are conducting normal operating activities, such as during routine traffic stops or when they are collecting park entrance fees, making them difficult to predict. Officials from one field unit also noted that while their agency wants to ensure employee safety, it is contrary to their mission to close a field unit every time there is a potential anti-government threat—such as threats made on social media. However, during the armed occupation of the Malheur National Wildlife Refuge, refuges in an adjacent state were closed out of caution, and FWS employees turned away visitors who had driven hundreds of miles to view wildlife, according to FWS officials. To help address the potential disruption posed by unpredictable anti- government threats, some agencies and field units developed plans and guidance that prescribed various actions field units and their employees could take to help ensure employees’ safety while also counteracting the disruptive effects of threats and attacks on a facility’s operations.

Land Management Agencies Have Not Met Certain Facility Security Assessment Requirements

The four federal land management agencies have completed some but not all of the facility security assessments on their occupied federal facilities as required by the ISC Standard and three do not have a plan for doing so. Furthermore, the Forest Service has a facility security assessment methodology that complies with key requirements described in the ISC Standard, but BLM, FWS, and the Park Service do not.

The Four Land Management Agencies Have Not Completed All Facility Security Assessments, and Three of the Four Agencies Do Not Have Plans for Doing So

The ISC Standard requires that agencies complete facility security assessments on all occupied facilities and suggests that agencies establish annual objectives for conducting assessments. As suggested in the ISC Standard, to do so, agencies may need to consider several things, such as: the number and locations of needed facility security assessments, by establishing which facilities in the agency’s inventory are occupied and grouping them into campuses, if desired; the agency’s organizational structure, to determine entities responsible for conducting the assessments; training needs of entities responsible for conducting the assessments; which facilities or campuses should be prioritized for assessments, if a schedule for completing the assessments, given the agency’s available resources and priorities.

The four land management agencies have not completed facility security assessments on all occupied facilities, and agency officials cited various reasons for not doing so. FWS has a plan to complete its assessments, but BLM, the Forest Service, and the Park Service do not. Specifically:

FWS. FWS has conducted five facility security assessments on its approximately 465 occupied facilities and has a plan for completing the remaining assessments. According to FWS headquarters officials, FWS employees have limited physical security expertise to conduct facility security assessments; therefore, the agency has developed a plan to meet the ISC Standard’s requirement using contractors. Specifically, in May 2019, FWS hired a project manager to implement a new facility security assessment program and, according to agency documentation, the new program will, among other things, employ contracted assessors to conduct facility security assessments agency-wide. Agency officials said FWS will hire the assessors after the project manager and other agency officials complete preliminary tasks such as developing ISC-compliant policies and procedures, establishing the number and locations of facility security assessments needed, and developing an electronic tracking system for the assessors to use while conducting assessments. Once these tasks are completed—which could take up to 1 year, according to officials—FWS is to develop a schedule for assessors to complete the remaining assessments.

BLM. BLM has conducted 21 facility security assessments on its approximately 280 occupied facilities, but officials do not know when they will complete the remaining assessments and do not have a plan to do so. BLM headquarters officials we interviewed said that the agency is decentralized and its state offices are responsible for the security of facilities in their states, including scheduling and conducting facility security assessments. However, some BLM state and field officials we interviewed said they do not have the resources or expertise to conduct the assessments, and BLM does not offer relevant training. In June 2019, the agency issued a hiring announcement for a headquarters-level security manager. According to officials, once hired, the security manager is to establish training for field employees to conduct facility security assessments and monitor state offices’ compliance with the requirement to conduct assessments. Headquarters officials noted that state offices will remain responsible for scheduling and conducting their own assessments. However, as of June 2019, the agency had not developed a plan for how the security manager would implement agency-wide training given available resources, or ensure state offices’ compliance with the requirement to conduct assessments.

Forest Service. The Forest Service has conducted at least 135 facility security assessments on its approximately 1,135 occupied facilities, but officials do not know when they will complete the remaining assessments and do not have a plan for doing so. Forest Service headquarters officials we interviewed said that the agency is decentralized and its regional offices are responsible for the security of facilities in their regions, including scheduling and conducting facility security assessments. However, some regional officials we interviewed said they do not have resources or sufficient staff expertise to conduct the assessments. Forest Service headquarters officials stated that they have partnered with the U.S. Department of Agriculture’s Office of Homeland Security to offer facility security assessment training to Forest Service regional employees. Additionally, Forest Service headquarters officials stated that with the assistance of the U.S. Department of Agriculture’s Office of Homeland Security, they were restructuring their physical security program. Under the new structure, headquarters will oversee compliance at a national level and each region will have a team responsible for facility security assessments in their region, which agency officials said will establish lines of authority to account for the agency’s decentralized structure. However, the Forest Service headquarters official responsible for leading this effort said that, due in part to staff turnover, restructuring the physical security program has been difficult. As of June 2019, the Forest Service does not have a documented plan for how the restructured program will operate, how to ensure sufficient staff are trained to complete the assessments given available resources, or how and when regions will complete all of their assessments.

Park Service. The Park Service has conducted at least 148 facility security assessments on its approximately 1,505 occupied facilities, but officials do not know when they will complete the remaining assessments and do not have a plan to do so. Park Service headquarters officials we interviewed said that the agency is decentralized and the superintendents of its 418 park units are responsible for the security of facilities within their parks, including scheduling and conducting facility security assessments. However, some park unit officials we interviewed said they do not have the resources or sufficient staff with expertise to conduct the assessments. Park Service headquarters officials stated that they have developed a program to offer facility security assessment training to park employees. In February 2019, according to agency officials, the Park Service hired a security manager who will standardize the agency’s facility security assessment practices, expand facility security assessment training opportunities, and monitor parks’ compliance with the requirement to conduct assessments. Headquarters officials noted that park units will remain responsible for scheduling and conducting their own assessments. However, as of June 2019, the agency had not developed a documented plan for how to ensure sufficient staff are trained to complete the assessments given available resources, or how the security manager would ensure park units’ compliance with the requirement to conduct assessments.

Not complying with the ISC Standard’s requirement to complete facility security assessments on all occupied facilities could leave federal agencies exposed to risks in protecting their employees and facilities. Specifically, without conducting all of the required assessments, agencies may not identify the degree to which undesirable events can impact their facilities or identify the countermeasures they could implement to mitigate the risks of those events. Officials from BLM, the Forest Service, and the Park Service acknowledged that completing the remaining facility security assessments is important and that developing an agency-wide plan to do so may help them as they work towards compliance with this ISC Standard requirement. In the process of developing their plans, the agencies could take into consideration their organizational structure, available resources, and training needs, all of which may affect how quickly they can complete their assessments. Furthermore, developing a plan for completing facility security assessments will require agencies to identify the number and locations of their required assessments, which may help them fulfill the fiscal year 2020 ISC compliance reporting requirement.

BLM, FWS, and the Park Service Do Not Have Facility Security Assessment Methodologies that Fully Comply with Two Key Requirements in the ISC Standard

Three of the four federal land management agencies have not developed a facility security assessment methodology that complies with two key requirements in the ISC Standard. Specifically, according to the ISC Standard, methodologies must, among other things, (1) consider all 33 of the undesirable events identified in the Standard, such as active shooters, vandalism, and explosive devices; and (2) evaluate the three factors of risk—threat, vulnerability, and consequence—for each undesirable event.

According to our analysis of agency documentation and interviews with agency officials, the extent to which each agency’s facility security assessment methodology complied with the two key ISC Standard requirements we evaluated varied. As of June 2019, the Forest Service’s facility security assessment methodology met the two key ISC Standard requirements we evaluated, and the Park Service’s methodology partially met the requirements. BLM and FWS did not have established facility security assessment methodologies as of June 2019. Specifically:

Forest Service. The Forest Service utilizes an ISC-compliant facility security assessment methodology developed by the U.S. Department of Agriculture. The methodology adheres to the two key ISC Standard requirements that we evaluated.

Park Service. The Park Service developed a risk assessment methodology, but it only partially adheres to the two key ISC Standard requirements we evaluated. Specifically, the Park Service’s risk assessment methodology does not include a step to assess the consequences of specific undesirable events, as required by the ISC Standard. Park Service officials indicated the agency’s commitment to conducting facility security assessments using an ISC-compliant methodology and said that they plan to submit the Park Service’s risk assessment methodology to the ISC to be certified as compliant with requirements in the ISC Standard. A Park Service official acknowledged, however, that the agency needs to update its methodology to include a step to assess the consequences of specific undesirable events, and the official stated that the agency does not plan to submit the methodology to the ISC until those changes have been made. As of June 2019, officials did not have a timeframe for doing so.

BLM. BLM officials said that, as of June 2019, the agency did not have an established methodology for conducting facility security assessments. Officials told us that, once hired, the new BLM security manager will develop an assessment methodology and that the agency intends to employ a methodology that complies with the ISC Standard. However, BLM officials do not know when the security manager will be hired, and the agency has not documented requirements for the security manager to adhere to the ISC Standard’s requirements.

FWS. FWS officials said that, as of June 2019, the agency did not have an established methodology for conducting facility security assessments., Officials told us that the agency intends to employ a methodology that complies with the ISC Standard and provided a high-level description of what they expect the methodology to include. However, this description did not indicate that the agency would evaluate consequences of specific undesirable events, as required by the ISC Standard.

According to FWS officials, because staff do not have the expertise to conduct facility security assessments, in 2011, the agency developed physical security survey checklists as an interim solution for assessing facilities. These checklists allowed staff to document the presence or absence of countermeasures identified in the ISC Standard. However, FWS headquarters officials acknowledged that these checklists were not an ISC- compliant risk assessment methodology since they do not consider undesirable events or measure risk, as required by the ISC Standard.

By not using a methodology that fully complies with the ISC Standard, agencies could face adverse effects, such as an inability to make informed resource allocation decisions for their physical security needs and providing facilities—and the facilities’ occupants—with an inappropriate or insufficient level of protection. Specifically, according to the ISC Standard, when agencies do not use methodologies that comply with risk assessment requirements in the ISC Standard, facilities may have either less protection than needed, resulting in unmitigated risks, or more protection than needed, resulting in wasted resources.

Conclusions

To carry out their critical missions to manage the resources on over 700 million acres of federal lands, BLM, FWS, Forest Service, and Park Service officials and facilities are often the most visible and vulnerable representatives of the federal government in remote areas and have been subject to a range of threats and assaults. One way for these agencies to address the safety risks posed by unpredictable anti-government sentiment or other threats is to follow the ISC Standard requirements for conducting facility security assessments. However, BLM, FWS, the Forest Service, and the Park Service have not conducted all required facility security assessments, and BLM, the Forest Service, and the Park Service do not have a plan for doing so. Agency officials stated that this is due, in part, to decentralized organizational structures, limited available resources, and insufficient training. Without a plan for conducting all of the remaining assessments, agencies may not identify the degree to which undesirable events can impact their facilities or identify countermeasures they could implement to mitigate the risks of those events.

In addition, as of June 2019, BLM, FWS, and the Park Service do not have facility security assessment methodologies that fully comply with two key requirements in the ISC Standard—namely, to consider the 33 undesirable events identified in the Standard and to evaluate risk factors for each of these events. Without using a methodology that complies with the ISC Standard, the agencies could face adverse effects, including an inability to make informed resource allocation decisions for their physical security needs and providing facilities—and the facilities’ occupants—with an inappropriate or insufficient level of protection.

Recommendations for Executive Action

We are making a total of six recommendations, including two to BLM, one to FWS, one to the Forest Service, and two to the Park Service. Specifically:

The Director of BLM should develop a plan to conduct all required facility security assessments agency-wide, taking into consideration the agency’s organizational structure, available resources, and training needs. (Recommendation 1)

The Chief of the Forest Service should develop a plan to conduct all required facility security assessments agency-wide, taking into consideration the agency’s organizational structure, available resources, and training needs. (Recommendation 2)

The Director of the Park Service should develop a plan to conduct all required facility security assessments agency-wide, taking into consideration the agency’s organizational structure, available resources, and training needs. (Recommendation 3)

The Director of the Park Service should update the agency’s facility security assessment methodology to comply with requirements in the ISC Standard, including a step to consider the consequence of each undesirable event. (Recommendation 4)

The Director of BLM should develop a facility security assessment methodology that complies with requirements in the ISC Standard to assess all undesirable events and consider all three factors of risk for each undesirable event. (Recommendation 5)

The Director of FWS should develop a facility security assessment methodology that complies with requirements in the ISC Standard to assess all undesirable events and consider all three factors of risk for each undesirable event. (Recommendation 6)

Agency Comments and Our Evaluation

We provided a draft of this report to the Departments of Agriculture, Homeland Security, Interior, and Justice for their review and comment. The Forest Service, responding on behalf of the U.S. Department of Agriculture, generally agreed with the report and our recommendation and cited its efforts to develop a plan to complete required facility security assessments. The Forest Service’s written comments are reproduced in appendix III. Interior, responding on behalf of BLM, FWS, and the Park Service, concurred with our recommendations and provided examples of actions the three agencies planned to take. Specifically, regarding our recommendation that BLM and the Park Service develop a plan to conduct facility security requirements agency-wide, BLM intends to revise its policy and develop such a plan, and the Park Service intends to develop a plan that includes training and tools so that park unit staff can conduct the required assessments. Regarding our recommendation that BLM, FWS, and the Park Service develop methodologies that comply with requirements in the ISC Standard, the agencies cited various efforts to do so, including revising policies and developing new tools, training, and data system modules. Interior’s written comments are reproduced in appendix IV. The Department of Homeland Security provided a technical comment that we incorporated. The Department of Justice told us that they had no comments.

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If you or your staff members have any questions about this report, please contact me at (202) 512-3841 or fennella@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 members who made key contributions to this report are listed in appendix V.

Appendix I: Objectives, Scope, and Methodology

Our objectives were to examine for the four federal land management agencies, (1) what is known about the number of threats and assaults against their employees, (2) the approaches the agencies used to protect their employees from threats and assaults and any factors affecting their ability to do so, and (3) the extent to which agencies met facility security assessment requirements.

For the first objective, we obtained and analyzed data on threats and assaults against land management agency employees from the law enforcement databases of the Forest Service within the U.S. Department of Agriculture and the Bureau of Land Management (BLM), Fish and Wildlife (FWS), and National Park Service (Park Service) within the Department of the Interior for fiscal years 2013 through 2017. These data were the most recent available at the time we began our review. We also obtained and analyzed data from the Federal Bureau of Investigation (FBI) regarding its investigations into potential domestic terror threats to land management agencies.

Each land management agency’s law enforcement division records data on threats and assaults to employees, as part of its broader mission to enforce laws that safeguard employees and protect resources. The data systems, however, were not specifically designed for reporting threats and assaults against employees, and they do not include the suspect’s motivation for a crime, such as anti-government extremist ideologies. Since each agency collects and maintains data in a different data system and has agency-specific reporting requirements for incidents, the data differ in how they were originally recorded by field law enforcement officers and how they were queried and reported by headquarters officials responding to our request for data. As such, if data were not entered, or not entered correctly, they would not have been captured in agency queries. According to agency officials at the four land management agencies, they queried their data systems to identify records of incidents that pertained to threats and assaults against employees. BLM, Forest Service, and Park Service officials then conducted record-level reviews and removed records that they determined were not threats or assaults, contained errors, were duplicative, or did not contain sufficient information to make a conclusive determination. We did not systematically review the records they removed. Information about each agency’s data system and limitations related to the agency’s data are as follows:

BLM. BLM maintains its data in the Incident Management, Analysis, and Reporting System (IMARS). IMARS is used by most Interior bureaus for incident management and reporting and to prevent, detect, and investigate known and suspected criminal activity. Each bureau uses a different, customized version of IMARS. BLM officials said that beginning in fiscal year 2014, BLM began collecting data on violations of federal statutes, regulations, and state laws during incidents. Prior to that, BLM used a generic description of each offense. Officials also said that when multiple offenses occur during an incident, the less serious offenses are unlikely to be entered into the system. Therefore, some offenses that occurred during incidents of threats and assaults may be excluded from these data.

FWS. FWS maintains its data the agency’s Law Enforcement Management Information System (LEMIS). According to FWS documents, LEMIS is used to process and store investigations, intelligence, and other records. FWS officials said the agency changed data systems during our reporting time frame. Specifically, FWS originally stored fiscal year 2013 and 2014 data in the Law Enforcement-Information Management and Gathering System and imported the data into LEMIS in July 2014. We assessed the data across the two systems by comparing incidents per year and types of violations that occurred, and we found that the data were comparable. According to agency officials, they did not review the incidents before providing them to us; therefore, some incidents may not have been actual threats or assaults.

Forest Service. The Forest Service maintains its data in the Law Enforcement and Investigations Management Attainment Reporting System (LEIMARS). Forest Service officials said LEIMARS is used to record criminal and claims activity in the national forests, which include verified violations of criminal statutes and agency policy, as well as incidents that may result in civil claims for or against the government. Incidents are recorded in LEIMARS in one of three types of law enforcement report categories: (1) an incident report, which records when an offense occurred but the perpetrator was unknown; (2) a warning notice, which is issued when an offense occurred but the law enforcement officer determined that the offense was inadvertent or committed due to lack of understanding or misinformation; and (3) a violation notice, which is issued for an offense that violates the U.S. Code or Forest Service regulations and the perpetrator was known. We present these three types of reports as incidents. A Forest Service official identified 125 incidents for which the agency could not determine whether a threat or assault to an employee occurred. We excluded these 125 incidents from our analysis. Officials told us that they only provided data on the most serious offense occurring during an incident due to limitations on linking records in the Forest Service’s data system; they also told us that there may be a minor amount of overlap between violation notices and incident reports.

Park Service. As with BLM, Park Service data is maintained in the IMARS data system. According to a Park Service official, some but not all Park Service incident records cite a federal statute or regulation. However, all Park Service incident records include offense codes—which are unique to the Park Service—that are associated with the type of violation, such as assault or disorderly conduct. Unlike with the statutes and regulations, a perpetrator does not need to be identified for the law enforcement officer to cite an offense code. Therefore, the Park Service provided data to us by offense code, and we were not able to present the data by the statute or regulation that was potentially violated.

We also obtained data from the FBI on investigations into potential domestic terror threats to land management agencies. FBI investigation data is maintained in the Sentinel data system, which is FBI’s case management system. FBI officials provided data from the FBI’s domestic terrorism program on three types of investigations: assessments, preliminary investigations, and full investigations. We reported data on the full investigations because of the limited information available on assessments and preliminary investigations. Before providing the data to us, an FBI official reviewed the record of each domestic terrorism investigation initiated in fiscal years 2013 through 2017 to determine whether the investigation was relevant to threats to BLM, FWS, the Forest Service or the Park Service. These data represent all potential violations known at the time the FBI agent first opened the case and therefore include various potential violations beyond threats and assaults against federal employees. According to agency officials, in some cases, the FBI agent opening the case may not have been able to fully identify all relevant subsections of the statute or regulation that was potentially violated. To account for this, we report FBI’s data at the statute or regulation level.

Since we relied on the professional judgement of agency officials to review and interpret incident data, we may be unable to replicate the final data selection drawn from each agency’s database, even if we retrieved the data using the same method and search criteria. We independently assessed the reliability of each agency’s data by (1) reviewing related documentation about the data system; (2) conducting manual reviews of the data for missing data, outliers, and obvious errors; (3) reviewing related internal controls; and (4) interviewing agency officials knowledgeable about the data, among other things. In our interviews, we asked agency officials about data entry practices, data system capabilities and limitations, and circumstances whereby incidents of threats and assaults might not appear in the database. Based on our review, we determined that the data were sufficiently reliable for the purposes of reporting descriptive summary information on the number of threats and assaults against federal land management employees during fiscal years 2013 through 2017.

To address our second objective, we examined policies and requirements regarding federal land management agencies’ responsibilities for protecting employees against threats and assaults. We also interviewed headquarters and selected field unit officials about the agencies’ approaches to protecting their employees from threats and assaults and factors that may affect their ability to do so, and we obtained supporting documentation where available. We conducted site visits from March through July 2018 to a nongeneralizable sample of 11 of the 35 regional or state offices and 14 field units across the federal land management agencies. We selected sites in Colorado, Nevada, Oregon, and Utah, since the majority of federal lands are located in the West and some field units in these states had been affected by actions of individuals motivated by anti-government ideologies. Specifically, we conducted site visits to five BLM field units, nine FWS field units, seven Forest Service field units, and four Park Service field units. The number of field units we interviewed varied on several factors, including how many field units regional and state offices invited to the meeting. Findings from the interviews we conducted at our site visits provide useful insights but cannot be generalized to those units we did not include in our review. Based on our site visit interviews, we identified four primary factors affecting agencies’ abilities to protect their employees from threats and assaults. We also collected information from each agency on the number of field law enforcement officers they had at the end of fiscal years 2013 and 2018, the most recent year for which data were available—to analyze any changes in resources. We took steps to assess the reliability of these data, including comparing the data to agency budget justifications and interviewing agency officials, and found them to be sufficiently reliable for the purpose of reporting the number of field law enforcement officers agencies had in fiscal years 2013 and 2018.

For the third objective, we examined government-wide requirements promulgated by the Interagency Security Committee (ISC) and documented in ISC’s Risk Management Process for Federal Facilities, which we refer to in this report as the ISC Standard, and its related appendixes. We interviewed ISC officials to learn more about the development of the requirements in the ISC Standard and variations, if any, in how agencies are expected to implement them. To determine whether agencies met the requirement to conduct facility security assessments on all of their occupied facilities, we obtained documents on the agencies’ inventories of occupied facilities and assessed whether the agencies had conducted security assessments on those facilities. We interviewed headquarters and field officials about their inventories and their plans, if any, for completing the remaining assessments. We also examined the extent to which agencies’ facility security risk assessment methodologies complied with two key requirements in the ISC Standard. These included that methodologies must: (1) consider all 33 of the undesirable events identified in the Standard and (2) evaluate the three factors of risk—threat, vulnerability, and consequence—for each undesirable event. We analyzed the agencies’ methodologies and compared them against requirements in the ISC Standard. We also interviewed agency officials about the methodologies.

We conducted this performance audit from November 2017 to September 2019 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: The Interagency Security Committee’s 33 Undesirable Events, as of June 2019

Appendix III: Comments from the U.S. Department of Agriculture

Appendix IV: Comments from the Department of the Interior

Appendix V: GAO Contact and Staff Acknowledgments

GAO Contact

Anne-Marie Fennell, (202) 512-3841 or fennella@gao.gov.

Staff Acknowledgments

In addition to the individual named above, Casey L. Brown (Assistant Director), Tanya Doriss (Analyst in Charge), Charles W. Bausell, Charles A. Culverwell, John W. Delicath, Emily E. Eischen, Cindy K. Gilbert, Richard P. Johnson, Vanessa E. Obetz, Dan C. Royer, and Breanna M. Trexler made key contributions to this report.